FRÖBEL takes the protection of personal data very seriously. This policy has been written to inform you, whether you are parents, prospective partners, future employees or visitors to our website, about the personal data we collect from you and what we do with it. It also informs you of your rights under data privacy laws and whom to contact if you have any questions.
In our capacity as Controller, as defined in the General Data Protection Regulation (GDPR),
FRÖBEL Bildung und Erziehung gGmbH
Data Protection Officer
- parents and their children under our care
- all other natural persons in contact with our company, e.g. legal guardians, representatives and employees of legal persons, applicants, but also visitors to our website and persons who register on the websites or on our apps.
What personal data do we collect from you?
We collect your personal data if you contact us, for example if you are interested in our online services, if you subscribe to our newsletters, submit requests or contact us by e-mail or telephone, or if you use our services as part of a contractual relationship.
Personal data are personal or factual details regarding an identified or identifiable natural person. This includes information such as your correct name, your address, your telephone number and your date of birth. Personal data do not include information that is not directly connected with your actual identity such as favourite web pages or number of users per page.
We collect the following data from you on this website:
- the page from which the file was requested,
- the name of the file accessed,
- the date and time of the request,
- the amount of data transferred,
- the access status (file transferred, file not found, etc.),
- a description of the type of web browser used and/or the operating system used,
- the anonymised IP address of the computer generating the request,
- the referrer URL (the page visited previously).
Other personal details such as your name, your address, telephone number or e-mail address are not recorded unless you provided this information voluntarily, for example during registration, a survey, competition, an application, in order to implement a contract or an information request. Data provided voluntarily will not be passed on to third parties without your express permission.
The web analytics service Matomo (www.matomo.org; formerly known as Piwik), a service provided by InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand, (“Matomo”) is used to collect and store data on the basis of our legitimate interest in the statistical analysis of user behaviour for optimisation and marketing purposes in accordance with point (f) of Art. 6 (1) GDPR. These data can be used to create and analyse specially pseudonymised usage profiles. Cookies may be used for this. Cookies are small text files that are stored locally in the Internet browser cache of the person visiting the site. Cookies allow, for example, the Internet browser to be identified during repeat visits. The data collected using Matomo technology (including your pseudonymised IP address) are processed on our servers in Germany.
The information generated by the cookie in the pseudonymised user’s internal profile are not used to personally identify the visitor to this website and they are not merged with personal data about the bearer(s) of the pseudonym.
If you do not agree with the storage and analysis of these data from your visit, you can withdraw your consent to the storage and use of the data by clicking on the link below at any time. If you do, an “opt-out” cookie is placed in your browser which prevents Matomo from collecting any session data. Please note that deleting all your cookies means that the opt-out cookie is also deleted and you may have to re-enable it.
Please click this link designed specifically for browsers on mobile devices to prevent Matomo from collecting anonymized data in future on our website with the aid of so-called “opt-out cookies” for your browser:
Who receives your data?
Within the FRÖBEL Group (FRÖBEL e. V., FRÖBEL Bildung und Erziehung gGmbH, FRÖBEL Akademie gGmbH, FRÖBEL International GmbH) your data is only accessible to those units or departments who require it to uphold our legitimate interests or to fulfil our contractual or legal obligations.
We can only disclose information about you if this is required by legal provisions or contractual agreements with you, or if you have given your consent. A legal obligation to pass on your personal data to external bodies may apply for example to justice or law enforcement bodies (police, public prosecutor’s office, courts).
We do not sell personal data to third parties.
Where do we use your data and what is the legal basis for this?
When a contractual relationship between us is to be created, its contents compiled or amendments made to it, we use your data to fulfil our contractual obligations. In order to implement the contractual relationship we need your address, your telephone number (or your e-mail address). This applies, for example, to childcare contracts and the associated login procedure or applications.
If you submit a request to us, we collect and use your personal data where this is necessary for these purposes (inventory data).
We only collect, process and use personal data to the extent that this is necessary to allow you to use the website (usage data).
We use the personal data you provide solely for the purpose of technical administration of the website and to fulfil your requests and requirements. This will normally be to expedite the contract signed with you and to respond to your enquiries.
We will only use these data for product-related surveys and marketing purposes if you have given prior consent or if you have not lodged an objection where this is provided for by law.
If it is necessary to transmit the personal data to an external service provider to render the service or respond to an enquiry, we shall implement technical and organisational measures to ensure that we comply with the legal provisions of the data protection law. FRÖBEL shall also require the external service providers to comply with the relevant legal provisions on data privacy, confidentiality and the requirement to erase personal data immediately after they are no longer required.
Additional information about how we use your data
Please note that contents that you send us by e-mail (for example via the Internet mailroom) are transmitted without encryption. This means that the security of legally protectable data and contents cannot be assured against unauthorised access and falsification during transmission. The same applies to e-mails which are triggered when an online form is sent. The forms themselves have SSL encryption.
Given that protecting children’s privacy is our priority, we do not wish to collect, process or use any personal data from persons under 18. If you are a parent or legal guardian and you discover that your children have transmitted their personal data to us, you can contact us at the address stated in the Legal Information section to arrange for the data to be erased.
We need a valid e-mail address from you so you can receive our newsletter. After you subscribe you will receive an e-mail asking you to confirm your subscription including the storage and use of your data for the newsletter mailout (double opt-in procedure). When you click on the link in the e-mail your e-mail address will be included on our newsletter mailing list and the time of confirmation by the owner of the e-mail address recorded. No other data will be collected. You can withdraw your consent at any time by sending an e-mail to firstname.lastname@example.org.
If, in exceptional cases, we also have to store personal data in a cookie, we will obtain your express consent in advance. Please note also that browsers generally include features that allow cookies to be managed.
FRÖBEL implements all technical and organisational measures required to protect your personal data against loss and misuse. Your data are stored in a secure operating environment which is not accessible to the public. If you wish to contact FRÖBEL by e-mail, please note that we cannot guarantee complete data security and so we recommend sending confidential information by post.
FRÖBEL is neither willing nor obliged to participate in alternative dispute resolution proceedings at a Consumer Conciliation Centre.
What rights do you have?
You have various rights under Articles 15 to 21 of the General Data Protection Regulation in relation to the processing of your personal data. We’d like to respond as quickly as possible to any questions you might have. Please use the contact details for our Data Protection Officer provided above.
Your right to withdraw your consent
Where your personal data are processed on the basis of your prior consent, you have the right to withdraw this consent at any time. The processing of personal data remains lawful until we receive a statement from you withdrawing your consent.
Your right to access, notification and correction
You can obtain access to your personal data processed by us. If your data are not accurate or are no longer accurate, you can obtain a correction from us. If your data are incomplete, you can have them completed. If we have passed on your data to third parties we shall inform these third parties of your correction where prescribed in law.
Your right to erasure of your personal data
You have the right to obtain the erasure of your personal data where:
- your personal data are no longer necessary in relation to the purposes for which they were collected;
- you withdraw your consent and there is no other legal ground for the processing;
- you object to the processing and there are no overriding legitimate grounds for the processing;
- your personal data have been unlawfully processed;
- your personal data have to be erased for compliance with a legal obligation.
You are not entitled to obtain an erasure if there are legal grounds that require the data to be processed.
Your right to restriction of processing of your personal data
You have the right to obtain a restriction of the processing of your personal data where:
- the accuracy of your personal data is contested by you, until we can verify the accuracy of the personal data;
- the processing is unlawful;
- your data is no longer required for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
- you have objected to the processing, pending the verification of whether your interests override it.
Your right to object
We may process your data based on legitimate interests or in the public interest. In such cases you have the right to object to the processing of your data. If you object we no longer process your personal data unless compelling legitimate grounds for the processing of such data override your interest in not processing them.
Your right to lodge a complaint
If you are dissatisfied with our response to your concerns, you are entitled to lodge a complaint with the FRÖBEL Data Protection Officer and the competent data protection authorities.
Your right to data portability
You have the right to receive your personal data from us in a transmittable and commonly used format.
How long do we store your data?
All personal data shall only be stored for as long as required for the stated purpose. Where the data are no longer required to fulfil contractual (processing your enquiry or expediting a contract) or legal obligations, they shall be erased unless they are required to be retained for a longer period. They may be required to be retained for a longer period, for example, to comply with retention periods stipulated by tax regulations or commercial law, or to obtain evidence for legal disputes within the statutory limitation periods. The limitation period for civil law may range from three to thirty years.