Privacy Policy

Last update: 1st July 2021

Privacy policy according to the GDPR

Controller, Art. 4 No. 7 GDPR:

Brilliant-Skills GmbH
The data protection officer
Glockenblumenweg 30, D-51061 Cologne, Germany
E-mail:

The protection of your personal data is of particular concern to us. This privacy policy describes how Brilliant-Skills GmbH processes your personal data on this website and with the help of our online services. In addition, you will receive data protection notices (Art. 13 and 14 GDPR) in advance of processing operations and contractual relationships in a simple, precise, transparent, understandable and easily accessible form (Art. 12 (1) GDPR). In order to protect your personal data, Brilliant-Skills has concluded appropriate agreements (in particular Art. 26 and 28 GDPR) with the commissioned service providers and cooperation partners and has adopted technical and organizational measures to ensure the protection of your personal data. For security reasons and to protect the transmission of confidential content that you send us as the operator of the website via online forms, this site uses state-of-the-art SSL or TLS encryption. Our employees are regularly trained on the handling of personal data and are committed to the confidentiality of personal data (Art. 5 para. 1 lit. f), Art. 32 para. 4 GDPR). You can also make data protection-friendly default settings using the settings of your web browser, e.g. by using the do-not-track function, regular security updates or blocking cookies. You can make further settings using appropriate browser extensions and/or these are described separately in this data protection declaration. We would like to point out that complete protection of transmissions on the Internet is not possible and that the protection of your data can depend heavily on your individual surfing behavior. Therefore, never pass on your data to third parties who may misuse it. In the event of changes to this privacy statement, we will post the amended statement and the effective date of the amended statement on this website. We therefore recommend that you check our website regularly. We will only make changes that affect consent you have given us by obtaining your consent again.

1. Scope and definitions

This data protection information applies to online offers and services such as Internet pages and services and offers of Brilliant-Skills GmbH contained therein. In the context of this privacy policy, we use the following terms. For your better understanding, you will find here a brief explanation of the terms used within the meaning of Art. 4 (1) GDPR.

1.1 Personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1.2. Processing

“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1.3 Restriction of processing

“Restriction of processing” means the marking of stored personal data with the aim of limiting their future processing.

1.4 Profiling

“Profiling” means any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

1.5 Pseudonymization

“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

1.6 Person responsible for the processing

“Controller“ means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for by Union or Member State law.

1.7 Processor

“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the Controller.

1.8. Receiver

“Recipient” means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients; the processing of such data by the aforementioned authorities shall be carried out in accordance with the applicable data protection rules in accordance with the purposes of the processing.

1.9. Third party

“Third party” means a natural or legal person, public authority, agency or other body, other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.

1.10. Consent

“Consent” of the data subject means any freely given specific, informed and unambiguous indication of his or her wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

2. Name and address of the responsible person

The responsible party within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations is the company named in the imprint as the operator of the respective online platform.

Brilliant-Skills GmbH
Glockenblumenweg 30, D-51061 Cologne, Germany
E-mail: privacy@brilliant-skills. com

3. Name and address of the data protection officer

You can reach the data protection officer as follows:

Brilliant-Skills GmbH
The data protection officer
Glockenblumenweg 30, D-51061 Cologne, Germany
E-mail:

4. Data collection when visiting our website

During the mere informational use of our website, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (so-called “server log files”). When you call up our website, we collect the following data, which is technically necessary for us to display the website to you:

  1. IP address of the requesting computer,
  2. Date and time of access,
  3. Name and URL of the expired file,
  4. Website from which the access is made (referrer URL),
  5. Browser used and, if applicable, the operating system of your computer as well as the name of your access provider.

The processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data is not passed on or used in any other way. However, we reserve the right to check the server log files retrospectively if there are concrete indications of illegal use.

5. Cookies

In order to make visiting our website more attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your terminal device. Some of the cookies we use are deleted after the end of the browser session, i.e. after you close your browser (so-called session cookies). Other cookies remain on your terminal device and enable us or our partner companies (third-party cookies, cf. Section 6.2) to recognize your browser on your next visit (persistent cookies). If cookies are set, they collect and process certain user information such as browser and location data as well as IP address values to an individual extent. Persistent cookies are automatically deleted after a specified period of time, which may vary depending on the cookie.

In part, the cookies serve to simplify the search request by storing settings (e.g. remembering zip code for a later visit to the website). If personal data is also processed by individual cookies implemented by us, the processing is carried out in accordance with Art. 6 para. 1 lit. b GDPR either for the execution of the contract or in accordance with Art. 6 para. 1 lit. f GDPR to protect our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.

We may work with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies, see section 6.2). If we cooperate with aforementioned advertising partners, you will be informed individually and separately about the use of such cookies and the scope of the information collected in each case within the paragraphs below.

5.1 Technically necessary cookies

These cookies are always enabled, as they are necessary for basic functions of our website. These include cookies that can be used to store where on the page you move.

5.2 Functional cookies

These cookies from our analytics tools allow us to count visits and determine their origin in order to continuously improve our service. They help us answer which pages or products are most popular and where problems may arise when using our website. Disabling these cookies may result in poorly selected recommendations and a worse website experience.

5.3 Marketing and advertising consent

These cookies may be set through our website by our advertising partners. They may be used by these companies to profile your interests in order to show you relevant advertising on other websites. In some cases, this may require the processing of your personal data. Disabling these cookies may result in the display of advertising that is of less interest to you.

You can manage your personal settings by clicking at the bottom of the website.

Please note that you can set your browser so that you are informed about the setting of cookies and can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general. Each browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You can find these for the respective browsers under the following links:

Internet Explorer
Firefox
Chrome
Safari
Opera

Please note that if you do not accept cookies, the functionality of our website may be limited. If the browser you have listed is not listed, please feel free to contact us.

6. Collection and use of data

In the course of your visit to our website, we process personal data that you enter in particular through the online forms provided by Brilliant-Skills. The following is a list of the possible data processing by us as well as the online forms integrated on partner sites. This data will be deleted as soon as the purpose for keeping it no longer exists and there are no legal and/or legitimate retention periods to the contrary. In addition to the purposes and legal bases mentioned below, the data may also be used for purposes of contract execution and performance, Art. 6 para. 1 sentence 1 lit. b) GDPR as well as for marketing purposes based on your consent, Art. 6 para. 1 sentence lit. a) GDPR or on the basis of legitimate interests pursuant to Art. 6 para. 1 sentence lit. f) GDPR, if applicable in conjunction with ErwG 47 GDPR accordingly, provided that a statutory authority (e.g. § 7 para. 3 UWG) is not relevant.

6.1 Brilliant Skills forms and data collected through them

To enable you to use our services, we provide you with the appropriate form for your respective needs. When you complete and submit one or more of these forms, we receive the data you enter and process it on our systems. The following description of the forms used by Brilliant-Skills may not be exhaustive. We reserve the right to change the content of individual online forms, rename them or process similar information.

6.1.1 Form: Register for training as a coachee

Through this form, we include requests from interested parties in our search file and provide our services. For this purpose, it may be necessary for us to contact you by means of the telephone number and/or e-mail address you have provided in order to fully complete your order, in doing so we ask for specific data and preferences regarding our mediation services.

Legal basis are pre-contractual measures, which are carried out on your request, Art. 6 para. 1 sentence 1 lit. b) GDPR (interest in selling and/or buying).

If data is required for the fulfillment of the contract (so-called mandatory data), we will inform you about it. If you provide us with information that is not mandatory, the processing of this data is based on your consent, Art. 6 para. 1 lit. a GDPR. In this respect, according to Art. 7 (3) GDPR, you have the right to revoke this consent at any time with effect for the future. Alternatively, send us an email to that we should no longer use the information in the future.

In addition, we process the personal data collected in connection with your registration in order to fulfill our legal obligations, in particular from tax and commercial law as well as ancillary criminal law and the regulations for the protection of public safety and order. The legal basis for this is Art. 6 para. 1 lit. c GDPR. The details can be found in detail on the form.

Additional Processor No.1:

Name:
First Colo Ltd.

Address including country:
Hanauer Landstraße 291b, 60314 Frankfurt am Main, Germany

Scope, nature and purpose of the activity:
Data center (Frankfurt site), theoretically has access to the hardware / data, but in practice is not used!

Additional Processor No.2:

Name:
CenturyLink Communications Germany GmbH

Address including country:
Rüsselsheimer Straße 22, 60326 Frankfurt am Main, Germany

Scope, nature and purpose of the activity:
Data center (Hamburg location), theoretically has access to the hardware / data, but in practice is not used.

webgo GmbH – Heidenkampsweg 81 – 20097 Hamburg // Commercial register – HRB 132905 // Tax – St. Nr.: 46/767/03743 – Ust-ID: DE296224196 //

Bank details – Deutsche Bank – IBAN DE61 2007 0024 0186 5880 00 – BIC DEUTDEDBHAM // Managing Director – Sebastian Angermeyer //

Contact – – webgo.com

Additional Processor No.3:

Name:
Mesos, owner Ralf Dreibrodt

Address including country:
Olpener Str. 143, 51103 Cologne, Germany

Scope, nature and purpose of the activity:
External Linux system administrator, maintains the webgo web space admin

6.1.2 Form: Register own training(s) as a coach

Through this form, we include requests from interested parties in our offer file and provide our services. For this purpose, it may be necessary for us to contact you by means of the telephone number and/or e-mail address you have provided in order to be able to complete your order; in doing so, we request specific data and preferences in relation to our mediation services. The legal basis for this are pre-contractual measures that take place in response to your request, Art. 6 para. 1 sentence 1 lit. b) GDPR (sales interest).

The details can be found on the form.

Additional Processor No.1:

Name:
First Colo Ltd.

Address including country:
Hanauer Landstraße 291b, 60314 Frankfurt am Main, Germany

Scope, nature and purpose of the activity:
Data center (Frankfurt site), theoretically has access to the hardware / data, but in practice is not used!

Additional Processor No.2:

Name:
CenturyLink Communications Germany GmbH

Address including country:
Rüsselsheimer Straße 22, 60326 Frankfurt am Main, Germany

Scope, nature and purpose of the activity:
Data center (Hamburg location), theoretically has access to the hardware / data, but in practice is not used.

webgo GmbH – Heidenkampsweg 81 – 20097 Hamburg // Commercial register – HRB 132905 // Tax – St. Nr.: 46/767/03743 – Ust-ID: DE296224196 //

Bank details – Deutsche Bank – IBAN DE61 2007 0024 0186 5880 00 – BIC DEUTDEDBHAM // Managing Director – Sebastian Angermeyer //

Contact – – webgo.com

Additional Processor No.3:

Name:
Mesos, owner Ralf Dreibrodt

Address including country:
Olpener Str. 143, 51103 Cologne, Germany

Scope, nature and purpose of the activity:
External Linux system administrator, maintains the webgo web space admin

6.1.3 Duration of data processing

Personal data in connection with one of the above-mentioned forms will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. This is the case for data collected during the registration process when the registration on our website is cancelled or modified. This is also the case for the data collected during the registration process for the fulfillment of a contract or for the implementation of pre-contractual measures, if the data is no longer required for the implementation of the contract.

For evidence purposes, we must retain contractual data for three years from the end of the year in which the business relationship with you ends. Any claims shall become statute-barred at the earliest at this point in time in accordance with the standard statutory limitation period.

Even after this, we still have to store some of your data for accounting reasons. We are obliged to do so because of legal documentation obligations that may arise from the German Commercial Code, the German Fiscal Code and the German Money Laundering Act. The periods specified there for the retention of documents are two to ten years.

6.2 Data collection by third-party providers

If you visit our website, data may also be collected and processed by third-party providers. The processing is carried out for the purpose of operating and optimizing our website, for marketing purposes and for the purpose of providing and performing our mediation services (see 6.2.1. and following). Our online forms and marketing tools are also integrated on partner sites through which you can access our website and/or use our services.

Additional Processor No.1:

Name:
First Colo Ltd.

Address including country:
Hanauer Landstraße 291b, 60314 Frankfurt am Main, Germany

Scope, nature and purpose of the activity:
Data center (Frankfurt location), theoretically has access to the hardware / data, but is not used in practice!

Additional Processor No.2:

Name:
CenturyLink Communications Germany GmbH

Address including country:
Rüsselsheimer Straße 22, 60326 Frankfurt am Main, Germany

Scope, nature and purpose of the activity:
Data center (Hamburg location), theoretically has access to the hardware / data, but is not used in practice.

webgo GmbH – Heidenkampsweg 81 – 20097 Hamburg // Commercial register – HRB 132905 // Tax – St. Nr.: 46/767/03743 – Ust-ID: DE296224196 //

Bank details – Deutsche Bank – IBAN DE61 2007 0024 0186 5880 00 – BIC DEUTDEDBHAM // Managing Director – Sebastian Angermeyer //

Contact – – webgo.com

Additional Processor No.3:

Name:
Mesos, owner Ralf Dreibrodt

Address including country:
Olpener Str. 143, 51103 Cologne, Germany

Scope, nature and purpose of the activity:
External Linux system administrator, maintains the webgo web space admin

6.2.1. Web analytics services

The tracking measures listed below and used by us are processed within the meaning of Art. 6 (1) sentence 1 lit. f) GDPR to protect our legitimate interests and in individual cases on the basis of your consent, Art. 6 (1) sentence 1 lit. a). Basically, we want to continuously optimize our website through this and collect and evaluate the data statistically. In general, we use these services according to type, scope and technical-organizational prerequisite without the requirement of an explicit consent (“opt-in”) on your part. We expressly reserve the right to make adjustments and/or changes in relation to the applicable legal situation. Many of these services are active on partner and/or other third-party sites, so that the likelihood is high that your browser is already aware of these services and executes corresponding cookies.

6.2.1.1 Google Analytics

This website uses Google Analytics, a tracking tool of the US company Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, which is used to analyze the traffic of websites (web analysis).

Google Analytics uses so-called cookies and similar technologies to analyze and improve our website based on your user behavior. If you allow these cookies, they will be stored by Google in your browser for 14 months since your last visit to the site, which allows you to be recognized on your next visit. For information on how you can prevent cookies and/or third-party cookies from being replaced, see point 4. “Cookies”. The information generated by the cookie such as:

  • Browser type/version,
  • Operating system used,
  • Referrer URL (the previously visited page),
  • Host name of the accessing computer (IP address),
  • Time of the server request

are usually transferred to a Google server in the USA and stored there. In the event that personal data is transferred to the USA, we obtain your express consent for this data transfer via the cookie banner in accordance with Art. 49 (1) lit. a GDPR. Please refer to section 10 (“Data transfer to third countries”) for the associated risks. However, your IP address will be shortened before the usage statistics are analyzed so that no conclusions can be drawn about your identity. For this purpose, Google Analytics on our website has been extended by the code “anonymizeIP” to ensure anonymized collection of IP addresses. You may refuse the use of cookies by selecting the appropriate settings on your browser, see above. However, please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available here.

If you delete your cookies, you must click this link again. Read here for more information on Google Analytics privacy. You can find more information and settings here: Google Privacy Policy & Terms of Use.

6.2.1.2 Google Tag Manager

We use the Google Tag Manager. Through this service of Google LLC. (see 6.2.1.1.). website tags can be managed via an interface. The Google Tag Manager only implements tags. This means that no cookies are used and no personal data is collected. The Google Tag Manager triggers other tags, which in turn may collect data. However, the Google Tag Manager does not access this data. If a deactivation has been made at domain or cookie level, it remains in place for all tracking tags, insofar as these are implemented with the Google Tag Manager. Further information on data protection at Google can be found in Google’s terms and conditions, see 6.2.1.1.

6.2.1.3 Google Optimize

Our website also uses Google Optimize. Google Optimize analyzes the use of different variants of our website and helps us improve the user experience according to the behavior of our users on the website. Google Optimize is a tool integrated into Google Analytics. For further information on data protection at Google, please refer to Google’s terms and conditions, see 6.2.1.1.

6.2.2 Marketing services

We use the following marketing services for marketing purposes, i.e. for the purposes of advertising, providing and optimizing our brokerage services and websites. The processing of data through the use of various marketing services is thus based on our legitimate interest pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR and in individual cases on the basis of your consent, Art. 6 para. 1 sentence 1 lit. a) GDPR. In general, we use these services according to type, scope and technical-organizational prerequisite without the requirement of an explicit consent on your part. We expressly reserve the right to make adjustments and/or changes in relation to the applicable legal situation. Many of these services are active on partner and/or other third-party sites, so that the likelihood is high that your browser is already aware of these services and executes corresponding cookies.

6.2.2.1 Google Ads services (formerly Google Adwords)

Google Ads is an Internet advertising service that allows advertisers to display ads both in Google’s search engine results and in the Google advertising network. The purpose of Google Ads is to promote our website by displaying interest-relevant advertisements on partner pages as well as in search engine results. The operating company of the Google Ads services is Google LLC. (see 6.2.1.1.). Google Ads uses tracking cookies to target advertising based on information about user behavior and device-related information. Google Ads thus enables us to analyze and evaluate advertising measures in a targeted manner. These ad server cookies are used to measure certain parameters for measuring success (usually “clicks”). It becomes measurable, for example, which search terms and/or ads you used to reach our website. We pursue the legitimate interest of displaying interest-based advertising, making our online offering more attractive and optimizing advertising costs. The ads cookies usually lose their validity after 30 days. During this period, Google has the possibility to recognize you.

In the event that personal data is transferred to the USA, we obtain your express consent for this data transfer via the cookie banner in accordance with Art. 49 Para. 1 lit. a GDPR. Please refer to section 10 (“Data transfer to third countries”) for the associated risks. For information on how you can prevent cookies from being set, please refer to section 5 “Cookies”. Furthermore, you have the option to object to interest-based advertising by Google. To do so, visit www.google.de/settings/ads and make the desired settings there. The data processed by Brilliant-Skills is based on information provided by Google, which does not allow us to identify users. We have no influence on information processed by Google. An identifiability by Google could be possible if the data can be assigned to your Google account or you are logged into a Google account.

Furthermore, we use the Google Ads remarketing function of the Google Ads service, which allows us to present interest-based advertising to users of our website on other pages within the Google advertising network. For this purpose, interactions with our website are analyzed and a cookie is set by Google, through which visits within the Google display network are recorded. This information identifies a specific web browser on a specific device, but not the individual. You can prevent the setting of cookies as described above. Google also provides a special browser plug-in: https://support.google.com/ads/answer/7395996.

You can also object to the display of personalized advertising through Google’s advertising settings here or via the Network Advertising Initiative’s deactivation page.

6.2.2.2 Display & Video 360 by Google (formerly DoubleClick Bid Manager by Google)

Our website uses Display & Video 360 (DV360) – a tool of Google’s Google Marketing Platform (see 6.2.1.1.). DV360 sets cookies to serve relevant ads to users and optimize campaign results. In addition, cookie ID information can be used to record conversions related to requests for specific ads. Via the cookie ID, connections can be drawn between the ad placed and a subsequent purchase action. According to Google, the DV360 cookies do not contain any personal information. We have no influence on any processing and use of the data by Google and the identifiability through any (personal) aggregation of data on the part of Google. The DV360 cookies set help us to analyze and understand how you communicate with our website and/or perform certain actions when you click on our content on Google or other platforms (conversion tracking). In the event that personal data is transferred to the USA, we obtain your express consent via the cookie banner for this data transfer in accordance with Art. 49 (1) lit. a GDPR. Please refer to section 10 (“Data transfer to third countries”) for the associated risks. You can block the setting of these cookies by selecting the appropriate cookie settings, see section 5.

You can also object to the display of personalized advertising through Google’s advertising settings here, or through the “About Ads” self-regulatory campaign at: http://www.aboutads.info/choices .

6.2.2.3 Facebook

This website uses technology from Facebook Ireland Limited (“Facebook”, 4 Grand Canal Square, Dublin 2, Ireland). Facebook is an Internet advertising service that allows advertisers to target users with advertisements on Facebook directly and on the Facebook ad network. By using the remarketing function “Custom Audiences”, users of the website are shown so-called “Facebook ads” when visiting Facebook or other sites using the procedure, which contain interest-based advertising. The purpose is to increase the attractiveness of our website through targeted marketing as well as the placement of advertisements. If you are the owner of a Facebook account, this is recognizable by the set Facebook pixel, via which the collected usage data is transmitted to Facebook. The Facebook Pixel is a Javascript code. Facebook uses tracking cookies to target Facebook ads based on information about user behavior and device-related information. This data is stored for a maximum of 180 days. For more information about the purpose and scope of data collection and the further processing and use of data by Facebook, as well as your settings options for protecting your privacy, please refer to Facebook’s privacy policy. If you do not wish to be shown interest-based advertising, you can deactivate this function in your browser. You can see how you can prevent cookies from being set in section 5. “Cookies”.

We have no influence on information that is processed and/or merged by Facebook. An identifiability by Facebook could be possible, for example, if the data can be assigned to your Facebook account or you are logged into a Facebook account.

You can find out about corresponding Facebook advertising settings at https://www.facebook.com/about/basics/advertising and make settings accordingly. Instructions on how to do this can be found here https://www.facebook.com/about/basics/advertising/ad-preferences. Logged-in users can deactivate and adjust the functions here https://www.facebook.com/settings/?tab=ads#_.

The data generated in this context may be transferred by Facebook to a server in the USA for evaluation and stored there. In the event that personal data is transferred to the USA, we obtain your express consent for this data transfer via the cookie banner in accordance with Art. 49 (1) lit. a GDPR. Please refer to section 10 (“Data transfer to third countries”) for the associated risks.

6.2.2.4 Microsoft Bing Ads

This website uses the conversion tracking of Microsoft Corporation (“Microsoft”, One Microsoft Way, Redmond, WA 98052-6399, USA). Microsoft Bing Ads sets a cookie for this purpose when you access our website via a Microsoft Bing ad. In this way, we can recognize that our ad has been clicked on and that you have been redirected to our website and have previously reached a certain target page (“conversion page”). We receive statistical evaluations of the users who clicked on a Bing ad and were redirected to the conversion page. Your identity is not disclosed in the process. The storage period is a maximum of 60 days. You can prevent cookies from being set, see section 5 “Cookies”. You can use the opt-out function of Microsoft via this link to declare your objection and prevent the cookie from being set. In the event that personal data is transferred to the USA, we will obtain your express consent for this data transfer via the cookie banner in accordance with Art. 49 (1) lit. a GDPR. Please refer to section 10 (“Data transfer to third countries”) for the associated risks. For more information about Microsoft cookies and Bing Ads, please visit the Microsoft website.

6.2.3 Social networks / social media plugins

We use social networks on our website, insofar as these are activated accordingly at the time of using our site. You can see which company processes data in this context here. The data processing is based on our legitimate interest according to Art. 6 para. 1 lit. f) GDPR.

6.2.3.1 Facebook

Our website contains plugins from Facebook, 1601 South California Avenue, Palo Alto, CA 94304, USA. The respective plugin is recognizable by the Facebook logo or the “Like” button. As soon as you visit our website, the Facebook plugin establishes an immediate connection between your internet browser and the Facebook servers. In this way, Facebook is informed that our website has been visited with your IP address. In the event that you should be logged into Facebook, you can use the “Like me button” to link the corresponding content that is on our website in your profile on Facebook. Facebook is then able to associate your visit to our website with your Facebook account. We, as the provider of our website, are not informed by Facebook about the content of the transmitted data or data use. You can obtain further information here. In the event that you are a member of Facebook, but do not want Facebook to receive data about you through our website and connect it with your membership data, you must log out of Facebook before accessing our website.

6.2.3.2 Instagram

Functions of the Instagram service are integrated on our website. These functions are offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged into your Instagram account, you can link the content of our website to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate the visit to our website with your user account. We would like to point out that we, as the provider of the website, have no knowledge of the content of the transmitted data or its use by Instagram. For more information, please refer to Instagram’s privacy policy at https://help.instagram.com/519522125107875.

6.2.3.3 LinkedIn

On our website you will find plugins of the social network LinkedIn or LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA (hereinafter referred to as “LinkedIn”). You can recognize the LinkedIn plugins by the corresponding logo or the “Recommend” button. Please note that the plugin establishes a connection between your respective internet browser and LinkedIn’s server when you visit our website. LinkedIn is thus informed that our website has been visited with your IP address. If you click on the “Recommend Button” of LinkedIn and are logged into your account at LinkedIn at the same time, you have the option to link content from our website on your profile page at LinkedIn profile. In doing so, you enable LinkedIn to associate your visit to our website with you or your user account. You must know that we do not gain any knowledge of the content of the transmitted data and its use by LinkedIn. Further details on the collection of data and your legal options as well as setting options can be found at LinkedIn. These will be made available to you here.

6.2.3.4 Twitter

Our website contains functions of Twitter Inc, 795 Folsom Street, Suite 600, San Francisco, CA 94107, USA. When you use Twitter and in particular the “Re-Tweet” function, Twitter links your Twitter account to the websites you frequently visit. This is made known to other users on Twitter, in particular your followers. In this way, a data transmission to Twitter also takes place. We, as the provider of our website, are not informed by Twitter about the content of the transmitted data or data usage. You can obtain further information here. Please note, however, that you have the option to change your privacy settings on Twitter in your account settings there.

6.2.3.5 Rating on Trustpilot

On our website we offer the possibility to rate us via the portal Trustpilot of Trustpilot A/S, Pilestræde 58, 5, 1112 Copenhagen, Denmark. The purpose is to improve as well as give feedback on the services of Brilliant-Skills GmbH. After the conclusion of a contract you will receive an e-mail from us for evaluation on https://www.trustpilot.de, where you can evaluate our services. This requires the processing of your e-mail address and your first and last name. These ratings are potentially visible to third parties via our website as well as on partner sites. You can find more information about data protection on Trustpilot at https://legal.trustpilot.com/for-reviewers/end-user-privacy-terms.

6.2.3.6. Rating on Excellent.org

On our website we offer the possibility to rate us via the portal Ausgezeichnet.org of AUBII GMbH, Alsterufer 34, 20354 Hamburg, Germany. The purpose is the improvement as well as the feedback on the services of Brilliant-Skills GmbH. After the conclusion of a contract you will receive an e-mail from us for evaluation on https://www.ausgezeichnet.org, where you can evaluate our services. This requires the processing of your e-mail address and your first and last name. These ratings are potentially visible to third parties via our website as well as on partner sites. Further information on data protection at Ausgezeichnet.org can be found at https://www.ausgezeichnet.org/datenschutz/.

7. Marketing emails

If you have given us consent for communication by e-mail in the course of our service, we will send you relevant e-mails. The data we process in this course, we have collected through previous services used by you with us. After consent has been obtained, the sending of marketing emails is generally lawful pursuant to Art. 6 (1) a) GDPR. If you are already an existing customer of ours, the sending of marketing e-mails is permitted in accordance with Section 7 III UWG after the service has been provided. If you nevertheless no longer wish to receive these marketing e-mails, please send us a written declaration of revocation to . You can also unsubscribe from the marketing emails at any time by following the unsubscribe link in the respective marketing email. The email marketing is carried out with the help of an email cloud solution. We have concluded an order processing contract with the service provider, which includes standard contractual clauses as well as binding internal data protection regulations.

8. E-mail contact

You can contact us via the following e-mail addresses:
Data protection-relevant topics:
General customer service:
In this case, we process and store the personal data transmitted by e-mail. This will basically be your email address and any other information disclosed by you. Such data processing is necessary for the processing of the conversation. The data processing is based on our legitimate interest within the meaning of Art. 6 (1) f) GDPR and is therefore lawful, provided that you are not thereby unreasonably restricted in your rights. If the contact serves the conclusion of a contract, the processing is lawful according to Art. 6 (1) (b) GDPR. If you provide further data without being asked, the processing is based on your consent within the meaning of Art. 6 (1) a) GDPR. We delete this data as soon as the conversation has ended and there is no longer a purpose for storing it/no legal and/or legitimate retention periods conflict with this. The conversation is ended when it can be inferred from the circumstances that the process concerned has been conclusively clarified. All other data transmitted by the sending process will be deleted after a period of 7 days at the latest.

9. Disclosure of your data by us

We disclose personal data to comply with legal obligations, to investigate complaints about offers or content that violate the rights of third parties, and to protect the rights, property or safety of third parties. The disclosure of this data is done solely in accordance with applicable laws/data protection regulations. In particular, we may disclose your personal data to law enforcement or regulatory authorities or authorized third parties based on an obligation or authorization in connection with an investigation or suspicion of a criminal offense, an unlawful act or other acts from which we, you or a third party may have a justification to disclose. In such cases, we will disclose the data required for this purpose, such as name, city, postal code, telephone number, e-mail address, previous user names, IP address, fraud complaints, as well as other information, if any, to the extent permitted.

10. Data transfer to third countries

As already explained in this privacy policy, we use services whose providers are partly located in so-called third countries (such as the USA), i.e. countries whose level of data protection does not correspond to that of the European Union. Where this is the case and the European Commission has not issued an adequacy decision (Art. 45 GDPR) for these countries, we have taken appropriate precautions to ensure an adequate level of data protection for any data transfers. These include, among others, the standard contractual clauses of the European Union or binding internal data protection regulations.

Where this is not possible, we base the data transfer on exceptions of Art. 49 GDPR, in particular your explicit consent or the necessity of the transfer for the performance of the contract.

If a third country transfer is provided for and no adequacy decision or appropriate safeguards are in place, it is possible and there is a risk that authorities in the respective third country (e.g. intelligence services) may gain access to the transferred data in order to collect and analyze it, and that enforceability of your data subject rights cannot be guaranteed. When obtaining your consent via the cookie banner, you will also be informed of this.

11. Rights of the data subject

The applicable data protection law grants you, as the data subject, comprehensive data subject rights (rights of access and intervention) vis-à-vis the controller (Brilliant-Skills GmbH) with regard to the processing of your personal data, which we inform you about in the following:

11.1 Right to confirmation, Art. 15 (1) sentence 1 GDPR

The data subject has the right to obtain confirmation from the controller as to whether personal data concerning him or her are being processed.

11.2 Right to information, Art. 15 (1) sentence 2 GDPR

If personal data of the data subject are processed, the data subject shall have the right to obtain access to such personal data and the following information:

  1. the purposes of processing;
  2. the categories of personal data that are processed;
  3. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations;
  4. if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration;
  5. the existence of a right to rectification or erasure of personal data concerning them or to restriction of processing by the controller or a right to object to such processing;
  6. the existence of a right of appeal to a supervisory authority;
  7. if the personal data are not collected from the data subject, any available information on the origin of the data;
  8. the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

11.3 Right to rectification and completion, Art. 16 GDPR

The data subject shall have the right to obtain from the controller the rectification without undue delay of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to request that incomplete personal data be completed, including by means of a supplementary declaration.

11.4 Right to erasure (right to be forgotten), Art. 17 GDPR

The data subject shall have the right to obtain from the controller the erasure without delay of personal data concerning him or her, and the controller shall be obliged to erase personal data without delay where one of the following reasons applies:

  1. the personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
  2. the data subject revokes the consent on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) and there is no other legal basis for the processing.
  3. the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) d. Objection to the processing.
  4. the personal data have been processed unlawfully.
  5. the erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
  6. the personal data have been collected in relation to information society services offered in accordance with Article 8(1).

However, the above does not apply if the processing is carried out for legal purposes (see 8.). Furthermore, deletion is excluded if there are legal storage obligations or overriding interests of the data controller in the storage.

11.5 Right to restriction of processing, Art. 18 GDPR

The data subject shall have the right to obtain from the controller the restriction of processing where one of the following conditions is met:

  1. the accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data,
  2. the processing is unlawful and the data subject refuses the erasure of the personal data and instead requests the restriction of the use of the personal data;
  3. the controller no longer needs the personal data for the purposes of processing, but the data subject needs them for the assertion, exercise or defense of legal claims; or
  4. the data subject has objected to the processing pursuant to Article 21(1) as long as it is not yet established whether the legitimate grounds of the controller override those of the data subject.

Accordingly, where processing has been restricted, such personal data may be processed, except for storage, only with the consent of the data subject or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or of a Member State.

A data subject who has obtained a restriction on processing shall be informed by the controller before the restriction is lifted.

11.6 Right to information, Art. 19 GDPR

If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right to be informed about these recipients by the data controller.

11.7 Right to data portability, Art. 20 GDPR

The data subject shall have the right to receive the personal data concerning him or her that he or she has provided to a controller in a structured, commonly used and machine-readable format and shall have the right to transmit such data to another controller without hindrance from the controller to whom the personal data have been provided, provided that:

  1. the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b); and
  2. the processing is carried out with the help of automated procedures.

When exercising his or her right to data portability, the data subject shall have the right to obtain that the personal data be transferred directly from one controller to another controller, where technically feasible.

11.8 Right to object, Art. 21 GDPR

The data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to processing of personal data concerning him or her which is carried out on the basis of Article 6(1)(e) and (f); this shall also apply to any profiling based on these provisions. The controller shall no longer process the personal data unless he can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

11.9 Right to withdraw consent given, Art. 7 (3) GDPR

The data subject has the right to revoke his or her consent at any time with effect for the future. The revocation of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. The data subject will be informed of this before giving consent. You can send a revocation to us in text form at any time (e-mail will suffice) at . Please understand that in the event of a revocation, it may take up to 4 weeks for the revocation to be processed. In the meantime, there may be overlaps in the processing of your request with marketing measures.

11.10. Right to complain to a supervisory authority (Art. 77 GDPR in conjunction with § 19 BDSG)

Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or the place of the alleged infringement, if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

12. Additional data protection notices for data subjects

12.1 Jointly responsible for data processing (cooperations)

Pursuant to Art. 26 (2) sentence of the General Data Protection Regulation (GDPR), we inform you about the processing of personal data in joint responsibility with cooperation partners. The purpose of this processing is the acquisition of new customers through advertising media of various online formats and cooperations (e.g. through online forms). The parties have jointly determined the sequence of processing of this data in the individual process stages and concluded a corresponding data protection agreement. In this context, it is agreed between the parties which of the parties fulfills which obligations under the GDPR. This relates in particular to the exercise of the rights of the data subjects and the fulfillment of the information obligations pursuant to Articles 13 and 14 of the GDPR. You can exercise your rights under the GDPR directly against both parties. In particular, both parties shall make the information required under Articles 13 and 14 GDPR available free of charge in a precise, transparent, comprehensible and easily accessible form in a clear and simple language. In particular, Brilliant-Skills’ responsibility for compliance with the GDPR applies to the data processed on Brilliant-Skills’ systems. This is usually the case if the data has been transferred to us by a partner. In individual cases, the parties shall inform each other without delay about legal positions asserted by data subjects. They shall provide each other with all information necessary to respond to requests for information. Our services will be appropriately identified on third-party sites. Through banner advertising on third party sites, generally no personal data is processed by Brilliant-Skills, regardless of the fact that you reach our website through corresponding advertising media. Your contact person for services communicated by us is Brilliant-Skills GmbH, An der Schanz 2, D-50735 Cologne, Germany. A joint responsibility within the meaning of Art. 26 GDPR may also exist in the context of the processing of credit agencies and in cooperation with web analytics, marketing and social media services (see 6.2.1. to 6.2.3.). If this is the case, corresponding data protection agreements have been concluded with the respective company. These data protection provisions shall apply in the respective current version.

12.2 Additional information for customers and interested parties

We process your personal data in accordance with our data protection provisions and the applicable data protection regulations. In general, this only concerns data that you have entered via our online forms or data that you have provided to us in another way (e.g. by telephone, e-mail or other placement-relevant information that you have communicated to us in person). This may also be information relevant to recruitment that we collect from or pass on to third parties with your consent, on the basis of legitimate interest or on the basis of contractual agreements.

12.2.1 Purposes and legal bases of processing

We process your personal data to carry out pre-contractual measures (initiation of contractual relationships such as contact inquiries and viewing appointments). The legal basis for the processing in this case is Art. 6 para. 1 sentence 1 no. 1 letter b) GDPR. In some cases, processing takes place on the basis of consent within the meaning of Art. 6 (1) sentence 1 letter a), for example for purposes of further offers and marketing in connection with our mediation services, possibly on the basis of Art. 6 (1) sentence 1 letter f) in conjunction with ErwG 47 GDPR (direct advertising). Consent given can be revoked in accordance with your data subject rights at any time with effect for the future, see point 11.8. In addition, processing is carried out for the fulfillment of contracts (e.g. execution of brokerage contracts and other agreements such as commission agreements). In this case, the legal basis for the processing is Art. 6 para. 1 sentence 1 no. 1 letter b) GDPR. In some cases, processing is carried out to fulfill legal obligations (e.g. commercial, tax and credit law regulations (KWG, GWG), statutory disclosure and notification obligations). The legal basis for processing in this case is Art. 6 (1) sentence 1 no. 1 letter c) GDPR. In the context of a balancing of interests pursuant to Art. 6 (1) sentence 1 no. 1 letter f) GDPR, processing is carried out, for example, to protect our own interests as well as the legitimate interests of third parties (creditworthiness and default risks; internal evaluations and analyses for marketing measures; to assert, exercise and defend legal claims; to ensure IT security and the IT operation of our company; for purposes of preserving evidence). In addition, we process personal data in accordance with our privacy policy. Further details can be found in this privacy policy. To safeguard your data subject rights, see point 9 “Data subject rights”.

12.2.2 Categories of recipients of personal data:

  • Credit institutions: Settlement of payment transactions
  • Law firms and competent jurisdiction: Enforcement of claims, advice, legal cases
  • External auditors: Initiation and execution of legal and/or authorized testing and consulting services
  • Authorities and other government agencies: Statutory duties of disclosure, cooperation and notification (e.g. prevention of money laundering)
  • Business and cooperation partners: Contract execution, partner programs, affiliates
  • Tipster: Distribution purposes, contract execution
  • Credit bureaus: Credit assessment, checking of credit-related default risks
  • Affiliates: Placement of advertising materials, sales purposes
  • IT service provider and service provider: Specialized IT and auditing services, operation and provision of software and services
  • Processor (Art. 28 GDPR): Operation and provision of SaaS and specialized services, software maintenance
  • Internal positions of Brilliant-Skills GmbH: Efficient control of business processes and work tasks
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