With this Privacy Policy, we, Constructor Academy AG, a company duly registered under the laws of Switzerland, with registered office at Heinrichstrasse 200, 8005 Zurich, Switzerland, registration number: CHE-246.121.247 ("we" or "us"), describe how we collect and process personal data of our customers ("you”) when using our website and Services. Constructor Academy AG is part of Constructor Group and as such affiliated with Constructor Academy AG, a company duly registered under the laws of Switzerland, with registered office at Rheinweg 9, 8200 Schaffhausen, Switzerland, registration number: CHE-422.961.341 and Propulsion Academy GmbH, a company duly registered under the laws of Germany, with registered office at Landsbergerstr. 110, 80339 München, Germany, registration number: HRB 263701 (together “Affiliates”). Constructor Academy AG, together with its Affiliates, offers educational programs, courses and related services (“Services”) to professionals under the business name of “Constructor Academy”. The data protection regulations form an integral part of our Terms and Conditions. Capitalized words have the same meaning as in the Terms and Conditions currently in force. By accessing and/or using our Services, you as a Customer or potential Customer agree to the terms set forth in this Privacy Policy. The term "Personal Data" in this Data Protection Statement shall mean any information that identifies or could reasonably be used to identify any person.
On our website you find Services offered by Constructor Academy AG and its Affiliates. For the personal data provided to us while using the website as well as using the Services, Constructor Academy AG and its Affiliates are joint data controllers. Academy AG and its Affiliates operate the website together, collect, and use the personal data for the provision and the enhancement of the Service (see Section 2). Our Platform contains links to third-party websites. These are not owned or controlled by us and we are not responsible for their content and their practices concerning data protection. Users are responsible for any third-party Personal Data obtained, published, or shared through this Website and confirm that they have the third party's consent to provide the Data to the Owner. For questions or complaints concerning the processing of your personal data, you can email academy@constructor.org.
By filling out the application form on our website, you authorize us to process your data for the provision and enhancement of Services. When you apply to an educational program on our website, we request the following personal data from you: name, email address, phone number, physical address, billing information, educational and professional background information (via CV or Linkedin). In addition, you may provide personal data in the contents you upload to the Service which we use to provide our Service. By filling in the contact form on our website, you authorize us to use these details to reply to requests for information, quotes or any other kind of request by you as indicated by the form’s header. When you fill out the contact form through our website, we request the following personal data from you: name, email address, phone number. By registering on the mailing list or for the newsletter, your email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address is also added to this list as a result of signing up to the Website or after making a purchase. The personal data processed are name, email address, phone number. You may cancel your subscription to our newsletters and mailing list at any time and object to further processing of your data. At the end of each newsletter and commercial or promotional email, there is an option to remove your name from the mailing list. By providing your phone number, you might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests. You can object at any time to the processing of your phone number for commercial or promotional purposes. When you are using our website and Services, we additionally collect cookie data, usage and traffic data. This data includes IP address, MAC address of your smartphone or computers, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data. We collect and use the contents of your interaction with our customer support or sales departments, which may include text/video/audio recording and transcripts. We use the collected personal data to manage Customer accounts and provide the Services (see Section 3).
We primarily use collected personal data in order to provide you Services based on your consent. If you have given us your consent to process your personal data for certain purposes, we will process your personal data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time. When you purchase Services from us, we process your personal data necessary for the performance of the contract. This includes the processing of your personal data for billing and account management. We also process personal data if required by law or any other regulation and if necessary for the establishment, exercise or defense of legal claims. We further use the personal data for improving, advertising and marketing our services based on the legitimate interest of the company to generate business revenues, develop our products, review and optimize procedures.
We use Hubspot, Inc. for the management of our customer database (CRM). Hubspot Email is an email address management and message sending service provided by HubSpot, Inc. It enables us to manage a database of email contacts, phone contacts or any other contact information to communicate with the user. HubSpot CRM is a user database management service provided by HubSpot, Inc. It enables us to build user profiles as well as to track user activities through analytics features. The personal data provided by you may also be matched with publicly available information about the user (such as social networks' profiles) and used to build profiles that we can use for improving our website and Services.
We use "cookies" and similar techniques on our websites and apps, which allow for an identification of your browser or device. You may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are pre-set to accept cookies. A cookie is a small text file that is sent to your computer and automatically saved by the web browser on your computer or mobile device, when you visit our website or install our app. If you revisit our website or use our app, we may recognize you, even if we do not know your identity. Besides cookies that are only used during a session and deleted after your visit of the website ("session cookies"), we use cookies in order to save user configurations and to understand how you use our services and content, and to enable to show you customized offers and advertisement ("permanent cookies"). . If you block functional cookies, it is possible that certain functions (such as, e.g., language settings, shopping basket, ordering processes) are no longer available to you. In accordance with applicable law, we may include visible and invisible image files in our newsletters and other marketing emails. If such image files are retrieved from our servers, we can determine whether and when you have opened the email, so that we can measure and better understand how you use our offers and customize them. You may disable this in your email program, which will usually be a default setting. We use Google Analytics and similar services (see below) on our website. These are services provided by third parties that allow us to measure and evaluate the use of our website on an anonymized basis. For this purpose, permanent cookies are used, which are set by the service provider. The service provider does not receive (and does not retain) any personal data from us, but the service provider may track your use of the website, combine this information with data from other websites you have visited and may use this information for its own purposes (e.g. controlling of advertisements). The service provider only provides us with data on the use of the respective website (but not any personal data of you).
We use the “Custom Audience pixel” of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) on our website. With its help, we can keep track of what users do after they see or click on a Facebook advertisement. This enables us to monitor the effectiveness of Facebook ads for purposes of statistics and market research. Data collected in this way is anonymous to us, which means we cannot see the personal data of individual users. However, this data is saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook's Data Policy which can be found at https://www.facebook.com/about/privacy/.
Our website uses Google Analytics, a web analysis service of Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, www.google.com (“Google Analytics” or “Google”). Google Analytics employs cookies that are stored on your computer to facilitate an analysis of your use of the site. The information generated by these cookies, such as time, place, and frequency of your visits to our site, including your IP address, is transmitted to Google's location in the US and stored there. In using Google Analytics our website employs the extension “anonymizeIp”. In doing so, Google abbreviates and thereby anonymizes your IP address before transferring it from EU/EEA member states. Google uses this information to analyse your use of our site, to compile reports for us on internet activity and to provide other services relating to our website. Google may also transfer this information to third parties where required to do so by law or where such third parties process this data on Google's behalf. Google states that it will never associate your IP address with other data held by Google. You can prevent cookies from being installed by adjusting the settings on your browser software accordingly as noted elsewhere in this Privacy Policy. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our website. Google Analytics also offers a deactivation add-on for most current browsers that provides you with more control over what data Google can collect on websites you access. The add-on tells the JavaScript (ga.js) used by Google Analytics not to transmit any information about website visits to Google Analytics. However, the browser deactivation add-on offered by Google Analytics does not prevent information from being transmitted to us or to other web analysis services we may engage. Google Analytics also uses electronic images known as web beacons (sometimes called single pixel gifs) and are used along with cookies to compile aggregated statistics to analyse how our site is used. You can find additional information on how to install the browser add-on referenced above at the following link. For the cases in which personal data is transferred to the US, this is based on the standard contractual clauses of the European Commission. You can opt-out of Google's use of cookies by visiting the Ads Preferences Manager, or through the Network Advertising Initiative opt-out page.
Google Tag Manager ("GTM") is a tag management system to manage JavaScript and HTML tags used for tracking and analytics on websites. Tags are small code elements that, among other things, are used to measure traffic and visitor behaviour: to understand the effect of online advertising and social channels; to set up remarketing and orientation towards target groups; and to test and optimize websites. GTM makes it easier for us to integrate and manage our tags. We use GTM on our website to include the following tracking tools (as in described in detail this Section 11): - Google Analytics - Google AdWords - Facebook Conversion Pixels - LinkedIn Conversion Pixels - Hotjar If you have performed deactivation, GTM takes this deactivation into account. For more information about GTM's privacy practices can be found here and terms of use here.
We use the “LinkedIn Insight Tag” of LinkedIn Corporation, 1000 W Maude Ave, Sunnyvale, CA 94085, USA (“LinkedIn”) on our website. It helps us with in-depth campaign reporting and insights about our website visitors. It can also be used to track conversions, retarget website visitors, and unlock additional insights about members interacting with our ads on LinkedIn. The LinkedIn Insight Tag enables the collection of data regarding members' visits to our website, including the URL, referrer, IP address, device, and browser characteristics (User Agent), and timestamp. This data is encrypted, the IP addresses are truncated, and members' direct identifiers are removed within seven days to make the data pseudonymous. This remaining, pseudonymized data is then deleted within 90 days. LinkedIn does not share personal data with us, it only provides aggregated reports about the website audience and ad performance. LinkedIn also provides retargeting for website visitors, enabling us to show personalized ads off our website by using this data, but without identifying the member. LinkedIn members can control the use of their personal data for advertising purposes through their account settings. All this in accordance with LinkedIn terms and cookie policies.
We use AdWords and Remarketing Lists features of Google Analytics for Display Advertisers to remarket to individuals who visit our program pages. Third-party vendors, such as Google, show our ads on sites across the internet, and in some cases, use cookies to serve ads based on someone's past visits to our website. You can opt out of Google's use of cookies by visiting Google's Ads Settings. You can also opt out of all third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.
We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
We use so-called Web Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google's servers will not be established in conjunction with this application.
YouTube is a video content visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages. This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when users do not use it.
In line with the purposes of the data processing set out in Section 2, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In some cases, we use external service providers to process data on our behalf. These service providers have been carefully selected by us, commissioned in writing and are bound by our instructions. They are regularly monitored by us. The service providers will not pass this data on to third parties, but will delete it once the contract has been fulfilled and the statutory storage periods have been completed, unless consent has been given to store it beyond this. Certain Recipients may be within Switzerland, but they may be located in outside Switzerland or the European Union. If we transfer data to a country without adequate legal data protection, we ensure an appropriate level of protection as legally required by way of using appropriate contracts (in particular on the basis of the standard contract clauses of the European Commission) or binding corporate rules or we rely on the statutory exceptions of consent, performance of contracts, the establishment, exercise or enforcement of legal claims, overriding public interests, published personal data or because it is necessary to protect the integrity of the persons concerned. You can obtain a copy of the mentioned contractual guarantees at any time by sending a request to academy@constructor.org. We reserve the right to redact copies for data protection reasons or reasons of secrecy or to produce excerpts only.
We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations in accordance with legal retention and documentation obligations. Personal data is be retained for the period during which claims can be asserted against our company or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g., for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible. Shorter retention periods of no more than twelve months apply for operational data (e.g., system logs).
We have taken appropriate technical and organizational security measures to protect your personal data from unauthorized access and misuse. However, we cannot and do not guarantee the absolute protection and security of any Personal Data.
In the context of our business relationship, you must provide us with any personal data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations (see above Section 2). Without this information, we will usually not be able to enter or carry out a contract with you. In addition, the website cannot be used unless certain information is disclosed to enable data traffic (e.g. IP address).
We may partially process your personal data automatically with the aim of evaluating certain personal aspects (profiling). In particular, profiling allows us to inform and advise you about products possibly relevant for you more accurately. For this purpose, we may use evaluation tools that enable us to communicate with you and advertise you as required, including market and opinion research.
In accordance with and as far as provided by applicable law you have: 1) the right to access your personal data, 2) the right to rectify your personal data, 3) the right to request the erasure of your personal data, 4) the right to restrict of processing or 5) the right to object to our data processing and 6) the right to receive certain personal data for transfer to another controller (data portability). In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch). A list of the German state data protection authorities can be found here. Please note that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data, have an overriding interest (insofar as we may invoke such interests) or need the data for asserting claims. Please further note that the exercise of these rights may be in conflict with your contractual obligations, and this may result in consequences such as premature contract termination. If this is the case, we will inform you in advance unless it has already been contractually agreed upon. In general, exercising these rights requires that you are able to prove your identity (e.g., by a copy of identification documents where your identity is not evident otherwise or can be verified in another way). To assert these rights, please contact us at academy@constructor.org and privacy@constructor.org.
We may amend this Data Protection Statement at any time without prior notice. The current version published on our website shall apply. If the Data Protection Statement is part of an agreement with you, we will notify you by e-mail to the e-mail address that you provided during registration or other appropriate means in case of substantial changes.
Version effective as of 16.03.2023