Privacy Vogel Specialist books

Updated: 2023/09/21

For us, privacy comes first. With this privacy policy, we would like to inform you how we process your personal data when you use these websites and the services offered there.

Content

Controller and privacy officer
Purposes and legal basis for the processing of personal data
What personal data is processed?
Storage duration of your personal data
Recipients of data
Your Rights
Can the processing of personal data or this privacy policy change?

Cookie policy
–How are cookies used?
–Your options regarding cookies and the legal basis for cookie use

Other special processing

Payment processing in the shop
Payment processing subscriptions
Contact form, contact via email
Support queries regarding BFE study programs (download and multi-slot licenses)
Ordering multi-slot licenses via BFE
Verification of sales tax identification number (sales tax ID)
Email newsletter and success measurement
Online meetings, conference calls, and web-based seminars via “Zoom”

Controller and privacy officer

The Vogel Communications Group GmbH & Co. KG (hereinafter: “Vogel”), Max-Planckstr. 7-9, 97082 Würzburg, https://vogel-fachbuch.de/en/support/ is the controller for the processing of personal data within the scope of these websites and the services offered on these websites in accordance with the EU General Data Protection Regulation (“GDPR”).

For questions or comments on the topic of data protection, please contact Vogel’s privacy officer (address: see above, datenschutz@vogel.de).

Purposes and legal basis for the processing of personal data

As part of our range of services we process your personal data in order to be able to offer customer-oriented services. Wherever possible, we give you the opportunity to decide for yourself, which data you would like to share with us.

We process your data for the purposes mentioned below on the legal basis provided for each case:

For analyses, statistical evaluations, targeting and re-targeting on these websites, e.g. in order to advertise to you, we use products from other providers, which are based on the so-called cookie technology and other things. The basis for this is your consent. Information on data processing using cookie-based technologies and the tools used for this purpose, as well as on your rights to halt the use of these technical processes, can be found in the cookie policy section.

You can revoke your respective consent at will. Information on this can be found in the Your Rights section and the following sections, specifically detailing consent-based processing (e.g. in the cookie policy section).

If a contract is concluded between you and us, we will process your data for the purpose of fulfilling this contract on the basis of Art. 6 sec. 1 lit. b GDPR. In particular, this is necessary for the following purposes:

  • Purchasing products or services via our shop or via our e-learning platform which constitutes the basis for a contractual relationship with you.
  • Personalization of our offers to provide a special user experience on our portals.
  • Processing and billing in case you use one of our charged services.

In cases other than those mentioned above, the basis for processing is the protection of our legitimate interests according to art. 6 sec. 1 lit. f GDPR, in particular offering customer-oriented services and advertising identical and similar products from our product portfolio. In these cases, processing occurs for the following purposes:

  • Advertising products and offers to better provide users or customers with information tailored to their interests and needs.
  • Adequate design of our offers.
  • Conducting advertisement success studies.
  • Market research, e.g. online surveys.
  • Acquisition of new customers
  • Contacting for event advertising.
  • Advertising via e-mail to promote similar products or services, granted your e-mail address was provided in the course of the sale of a product or service (cf. art. 7 sec. 3 of the German Act against Unfair Competition (UWG)).
  • Ensuring the security of our own IT systems, the optimisation, and the functionality of our websites by saving technical usage data in log files

Generally, you have a corresponding right to object if the processing takes place on the basis of our legitimate interests (see Your rights section below). There is no right to object in the case of the collection of technical usage data for the display of our websites and the storage of this data in log files for the purposes listed in this section.

Some data needs to be collected and processed by us due to mandatory legal regulations. The basis for this case is art. 6 sec. 1 lit. c GDPR. This is the case, if, for example, we are obligated to transfer data, e.g. to law enforcement on the basis of a legal obligation or if we have to store data for a certain period of time on the basis of legal regulations such as commercial or tax regulations.

What personal data is processed?

We process the data that we need for the purposes stated in this privacy policy.

If you want to purchase products in our shop, we request and process the following data:

  • Private customer/company
  • Salutation
  • First and last name
  • Street
  • Zip code/town
  • Email
  • Password (only applicable when creating a customer account during the order process)
  • Telephone (optional), password

A fee-based subscription is required to use digital products such as our e-learning offers. For this, the following data will be collected via a separate order form in the shop:

  • First and last name
  • Company
  • Street, house number
  • Zip code/town
  • Email
  • elephone (optional)
  • Fax (optional)
  • Number of employees (optional)

We collect and process the following data when you register for our digital products such as our e-learning offers:

  • Salutation
  • First and last name
  • Subscription number
  • Role (e.g. trainee, instructor, teacher, member of the examination board)
  • Email
  • User name (optional)
  • password

As part of the success measurement of our editorial newsletters (see section email newsletters and success measurement), we process information on news and offers you access and click on.

Some data is also transmitted automatically (mainly technical usage data). Your computer automatically shares information with us, such as IP address, browser type, or access times for your use of our online portals. This data is vital for us to optimally present our offers in accordance with your hardware.

Storage duration of your personal data

We store your data as long as required in order to provide our services, meet contract obligations, or if we have a legitimate interest in longer storage.

If  processing is based on your consent or on one of our legitimate interests, the data concerned will no longer be processed for the associated purpose after your revocation or objection has been receives and will be deleted if necessary, excluding legal grounds for data storage. Regardless, data stored on the basis of commercial or tax law will only be deleted after the statutory periods have expired.

With the regular limitation period being three years, the duration of storage also depends on statutory limitation periods, which can be up to thirty years, for example according to §§ 195 ff. of the German Civil Code (BGB).

Under certain circumstances, your data must also be stored longer, e.g. if, in case of official or legal procedures, data deletion is prohibited for the duration of the procedure.

Information on the storage period of the cookies we use can be found in the cookie policy.

Recipients of data

Order processing

We sometimes hire service providers to help us process personal data on our behalf. We have bound these service providers to us by an order processing contract in such a way that they may only process the data for our business purposes and on our instructions. These service providers primarily include technical service providers (including affiliated companies) for the maintenance, hosting, and support of our IT infrastructure including this website, as well as service providers for mailings, other marketing measures, e-learning products, and the digital report portfolio.

Tracking and other cookie technology service providers

Tracking and other technical procedures based on cookie technology and implemented on our websites are provided by third parties and data is also passed on to them. For information on the cookie procedures in use and the corresponding third party providers offering the technical tools, please refer to the section Cookie policy.

Transfer of your data to third parties

Your personal data is only transferred to third parties when the transfer is necessary for fulfilling the contract, billing, or collection of payments (e.g. shipping companies or payment service providers), or given your express consent. Furthermore, we are entitled to transfer personal data for the purpose of debt collection.

Transfer of data to third countries

Generally, we do not transfer your data to other countries or third countries (countries that are neither members of the European Union nor of the European Economic Area) or to international organizations. Exceptionally, data may be transferred to third countries if this is necessary to provide services to you, if it is required by law, or if we have your consent. Some of the service providers that process personal data on our behalf are located in third countries that do not offer the same level of protection for your personal data as in the EU, due to – amongst others – the lack of laws, lack of rights, or lack of supervision in said countries. Some recipients, especially the providers of social media channels or registered users who process your data, are also located in said third countries. Personal data is only transferred to said third countries outside of the EU if the European Commission has adopted a so-called adequacy decision in this regard (article 45 sec. 3 GDPR) (see here) or if safeguards in accordance with article 46 GDPR are in place, in particular standard data protection clauses issued by the European Commission in accordance with article 46 sec. 2 lit. c GDPR (see here). You can obtain a copy of these upon request (e.g. by e-mail) – for contact details see section controller and data protection officer above or at https://vogel-fachbuch.de/en/support/.

Information on possible transfers of your data to third countries can also be found in the privacy policies of the recipients that make transfers to third countries. You can also find information on this under advanced settings of our cookie management tool, where our cookie-based processing is explained.

Your Rights

Provided that the legal requirements are met, you as a data subject are entitled to the following rights in accordance with articles 12 to 21 GDPR.

Information:

You have the right to request information about your personal data stored and the scope of our data processing and transfer and to receive a copy of your stored personal data.

Rectification:

You have the right to request without delay the rectification of personal data concerning you and stored about you, if this data is incomplete or incorrect.

Erasure:

You have the right to demand the immediate erasure of your personal data stored by us if the legal requirements are met.

This is particularly the case if

  • your personal data are no longer needed for the purposes for which they were collected;
  • the exclusive legal basis for data processing was consent which you since have revoked.
  • you have objected to processing on the basis of legitimate interests (Art. 6 sec. 1 lit. f GDPR) for personal reasons and we are unable to prove that there are overriding legitimate reasons for processing;
  • your personal data have been processed unlawfully; or
  • your personal data must be erased in order to comply with laws.

If we have passed on your data to third parties, we will inform them about the erasure, within the scope required by law.

Please note the restrictions regarding your right of erasure. For example, we are not allowed to erase data that we are required to retain by law. Data that we need to assert, exercise, or defend legal claims are also excluded from your right of erasure.

Restriction of processing:

You have the right to request restriction of processing if one of the following conditions is met:

  • You dispute the accuracy of the personal data and we need to verify the accuracy of the personal data.
  • The processing is unlawful, you object to the erasure of personal data and instead demand the use of personal data be restricted.
  • Whereas we no longer need your personal data for the purposes of processing, you need the data to assert, exercise, or defend legal claims.
  • You have filed an objection to the processing and it is yet to be determined whether our legitimate reasons override yours.

In the event of a restriction of processing, the data will be blocked centrally and – apart from your own copies – processed only with your consent or for the purpose of asserting, exercising, or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest of the EU or an EU Member State.

Data transferability:

If we automatically process the personal data you have provided to us on the basis of your consent or a contract with you (including your employment contract), you have the right to receive the data in a structured, common, and machine-readable format and to transfer this data to another controller without our interference. You also have the right to request direct transfer of personal data to another controller, given technical feasibility.

Objection:

If we process your personal data for legitimate interests or in the public interest, you have the right to object to the processing of your data for personal reasons. Furthermore, you have an unlimited objection right if we process your data for our direct advertising. Please see our separate note in the section “Your right of objection” below.

Revocation of consent:

If you have given your consent to the processing of your personal data, you can revoke this consent at any time. Please note that the revocation is only effective for the future. Processing prior to the revocation is not affected.

Specific information on how you may revoke your consent can be found in our online offers when your consent is specifically requested and in the section cookie policy of this privacy policy.

Complaints:

Additionally, you have the right of lodging a complaint with a supervisory authority in accordance with Art. 77 GDPR, § 19 Bundesdatenschutzgesetz (BDSG), if you believe that your personal data is being processed unlawfully. The right of complaint is independent of any other administrative or judicial remedy.

Your right to objectBased on your personal situation, you have the right to object to the processing of your personal data which is carried out on the basis of article 6, sec. 1, lit. f GDPR at any time, including profiling based on these provisions.

We will no longer process your personal data unless we can provide compelling reasons worthy of protection for processing which outweigh your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims.

If your personal data are processed for the purpose of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of said marketing, including profiling related to said direct advertising.

If you object to processing for direct advertising purposes, your personal data will no longer be processed for these purposes.

You may exercise your right to object in connection with the use of information society services by means of automated procedures involving technical specifications, regardless of directive 2002/58/EC.

To exercise your rights, you can contact the controller. The contact details can be found in the section Controller and Privacy Officer or by using the contact form https://vogel-fachbuch.de/en/support/.

Can the processing of personal data or this privacy policy change?

We constantly monitor the handling of personal data based on privacy regulations and make adjustments if necessary. Please take regular note of our privacy policy which presents the current status of our handling of personal data. Any changes will be announced here as well as in your user account. In the case of contractual changes, which affect e.g. the processing of your data for the fulfilment of the contract and the personalization of our offer, we will additionally inform you separately via e-mail.

“Cookies” are files stored on your computer when you visit this website and which your browser “remembers”. A cookie file is saved in your web browser and allows the website or a third-party provider to identify you and to better tailor the website to you on your next visit. Cookies and tracking pixels allow us to better and more efficiently provide our services to you, and to optimize your experience on our website.

Counting pixels are small graphics files that are connected to our servers and allow us to track your use of our website and its features. Additionally, we use tracking pixels or GIF files to support online advertising and to measure reach if necessary. Thus, we can evaluate the number of visitors to our website and the advertisements accessed by them. The information collected through cookies or GIF files does not contain your name, address, telephone number, or e-mail address.

How are cookies used?

When you access and use our websites, several cookie files are saved in your web browser which are essential to the operation and presentation of our websites. These cookies are absolutely technically necessary, e.g. session cookies or cookies that store certain settings for your device (e.g. language, resolution, volume, page transitions). Additionally, we use not absolutely technically necessary cookies which are mainly implemented by third parties in order to compile statistics on the use of the website and to make our marketing efforts more targeted.

Detailed information regarding cookie-based applications can be found in the advanced settings of our cookie management tool. You will find a list of cookies used on our websites under cookies in our cookie management tool.

Adjust Cookie Seetings

Your options regarding cookies and the legal basis for cookie use

Each time you visit our websites, you can actively consent to the use of cookies that are not technically necessary for our websites to run (normally all third-party cookies) via the cookie management tool that is displayed. Cookies that are not necessary for our websites to run will not be set until you give consent. Once given, your consent to the use of cookies and the resulting processing can be revoked at any point using the cookie management tool.

Adjust Cookie Seetings

The legal basis for this permission-based cookie-based processing is § 25 para. 1 p. 1 TTDSG, Art. 6 para. 1 letter a DS-GVO, otherwise art. 6 sec.1 lit. f GDPR (our legitimate interest in the purposes described in detail in our cookie management tool).

In order to delete cookies yourself or to set up your web browser to delete or prevent cookies, access the help section of your web browser and choose the appropriate settings.

Other special processing

Payment processing in the shop

For payment processing in our shop, we use the payment system provided by the external payment service provider PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal“). If you want to pay via PayPal, PayPal is directly connected to the order process in our shop: A PayPal pop-up shows after completing your order which then prompts you to provide your PayPal access information in order to authorize your payment via PayPal. The payment authorization is transferred to and saved for payment at PayPal via an interface after you provide your PayPal access information.

Furthermore, we process credit card payments via the external payment service provider Stripe, Inc., 510 510 Townsend Street, San Francisco CA 94103, USA (hereinafter “Stripe“). If you want to pay using a credit card, a connection to Stripe’s online payment system is established via a technical interface. Payment information provided by you is transferred to Stripe via an encrypted connection solely for the purpose of payment processing, where it is saved and processed. Data processing exclusively occurs for the above-mentioned purpose of payment processing for your order, during which it is possible that Stripe is required to pass on the payment information to the bank indicated by you in order to trigger and authorize the payment process. For further privacy information, please access Stripe’s privacy policy at https://stripe.com/en-gr/privacy.

Payment processing subscriptions

For the payment processing of subscriptions, mandatory for the use of our e-learning offers, we offer SEPA direct debit. For this, we transfer the data you provide during the order of a subscription to your bank in order to authorize the direct debit.

Contact form, contact via email

We provide a contact form on our websites which you can use to contact us and tell us your requests electronically and hassle-free. We only collect your name and email address via the contact form. Providing a phone number is optional.

Alternatively, contact using the email address provided is possible. In this case, the user’s personal data sent in the email is saved.

We only use your data to process your request and can use the provided contact data to contact you for this purpose. Such data are not used for advertisement purposes and are not transferred to third parties.

The legal basis for the processing of data collected using the contact form or any email received from you is art. 6 sec. 1 lit. f, GDPR. In case the purpose of the contact is to enter into a contract, the additional legal basis for processing is art. 6 sec.1 p. 1 lit. b, GDPR.

Processing personal data from the input form is solely used for processing the contact. For contacts via email, this also constitutes the required justified interest for data processing.

Data will be deleted as soon as the reason for their collection no longer exists. For personal data from the input form of the contact form and those provided via email, this is the case as soon as the conversation with the user is over. The conversation is over when it can be told that the issue at hand has been resolved.

Right of revocation

When contacting us via the contact form or via email, you can revoke your consent to the storing of your personal data at any point. The conversation cannot be continued in this case. In order to object to the use of your data, please use the central contact form https://vogel-fachbuch.de/en/support/.

Any personal data collected during the contact will be deleted in this case.

Support queries regarding BFE study programs (download and multi-slot licenses)

Our websites feature a special query form at https://vogel-fachbuch.de/en/support/ for all support queries regarding BFE study programs. You can use this form to ask questions about the product which we will then forward to our partner, the Bundestechnologiezentrum für Elektro- und Informationstechnik e.V., Donnerschweer Straße 184, 26123 Oldenburg („BFE“). You will be prompted to provide certain data when using the form, including first and last name, email address, and telephone number (optional) which we will then process and forward to BFE in order to handle your query and to contact you.

We will ask you to consent to this processing prior to forwarding your query including your data. The processing is then based on your consent according to art. 6, sec. 1, sent. 1, lit. a, GDPR.

Revocation of consent

You can revoke your consent at any point using our contact form https://vogel-fachbuch.de/en/support/. Revocation does not change the lawfulness of data processing that occurred up to revocation.

Ordering multi-slot licenses via BFE

Network versions

We cooperate with BFE to handle requests regarding the order of network versions of BFE’s study programs and you can submit said requests using a special form at https://vogel-fachbuch.de/en/support/. We will forward to BFE this order form including the data provided by you (first and last name, address, email address, telephone number (optional), query details).

We only process your data for the purpose of handling your query and for the aforementioned forwarding to BFE. Any potential transaction regarding network versions is then concluded directly via BFE without our involvement. Thus, concerning data privacy, BFE is solely responsible for corresponding processing. For further information, please see BFE’s privacy policy: https://www.bfe.de/servicemenue/datenschutz/

We will ask you to consent to this processing prior to forwarding your query including your data. The processing is then based on your consent according to art. 6, sec. 1, sent. 1, lit. a, GDPR.

Revocation of consent

You can revoke your consent at any point using our contact form https://vogel-fachbuch.de/en/support/. Revocation does not change the lawfulness of data processing that occurred up to revocation.

Ordering of SCORM modules

We sell so-called SCORM modules on our websites. These are data packages of individual study modules that you can integrate into your own study management system. For this purpose, the BFE provides us with access to their download center, where we compile your data and provide you with the chosen study modules.

We accept related order queries via the same form used for network versions (see section above), collecting the same data from you at https://vogel-fachbuch.de/bfe-mehrplatzlizenz.

Processing is based on art. 6, sec. 1, sent. 1, lit. b, GDPR, for the purpose of handling your query, to initiate conclusion of contract, and to fulfilling the contract given you’ve ordered SCORM modules.

Verification of sales tax identification number (sales tax ID)

We use the web service of the European Commission to verify the sales tax ID (https://ec.europa.eu/taxation_customs/vies/#/vat-validation). To facilitate this, your sales tax ID is transferred to the web service of the European Commission. For this, we integrated a plugin in the registration process that directly accesses the web service of the European Commission. The following data are used for the verification: Company name, street, street number, area code, and place. Usually, the data transferred via the plugin are not personal data, but purely company data.

Providing the sales tax ID in the registration form is voluntary, yet it serves as a reliable verification that your company has been assigned a sales tax ID. Furthermore, the plugin allows us to not include any sales tax for commercial customers from other EU countries if they provide a sales tax ID.

Email newsletter and success measurement

When ordering products via our shop or subscribing to our e-learning offers, you automatically receive information regarding potentially interesting similar or equal products in our product portfolio via email (hereinafter “newsletter”) sent to the email address you provide during the order process or during registration. When collecting your email address, meaning during the order process or when registering to our e-learning offers, we explicitly state the use of your email address for advertising purposes and your resulting right of revocation. Data shall not be transferred to third parties in connection to data processing. Data shall exclusively be used for sending newsletters and for advertising similar or equal products therein.

Legal basis for sending newsletters is § 7 sec. 3, Act against Unfair Competition, in connection with art. 13 sec. 2, Directive on privacy and electronic communications.

Your e-mail address is collected in order to send the newsletter. Data will be deleted as soon as the reason for their collection no longer exists or if you exercise your right of revocation. Your email address is thus saved for the duration of the customer relationship.

Right of revocation

You can revoke your consent to receiving newsletters at any point via email without incurring any additional costs. For this, every newsletter contains a corresponding link which can be used to unsubscribe.

In our newsletters, performance is measured by evaluating the access rate and the click through rate. We use this to determine the level of interest in certain topics and to measure the effectiveness of our communication measures. Herein lies our legitimate interest in performance measurement in accordance with art. 6, sec. 1, lit. f, GDPR.

Right to object with regard to performance measurement

When exercising your right to revoke consent granted in order to receive newsletters (see above), you can also object to the processing of your data for the purpose of performance measurement.

Online meetings, conference calls, and web-based seminars via “Zoom”

Purpose: We use the tool “Zoom” for conference calls, online meetings, video conferences, and/or web-based seminars (hereinafter: “online meetings”). “Zoom” is a service provided by Zoom Video Communications, Inc., located in the USA.

Responsible party for processing data directly connected to “online meetings” is Vogel Communications Group GmbH & Co. KG, Max-Planck-Str. 7/9, 97082 Würzburg.

If you access the “Zoom” website, the provider of “Zoom” is responsible for data processing. However, accessing the website in order to use “Zoom” is only necessary to download the software required to use “Zoom”. You can also use “Zoom” by entering the respective meeting ID and potential additional access data for the meeting directly in the “Zoom” app.

In case you do not wish to use the “Zoom” app, all basic functions are available using a browser version which can also be found at the “Zoom” website.

Different types of data are being processed when using “Zoom”. The range of data depends on your personal data preferences specified prior to or during your participation in an “online meeting”.

The following personal data are subject to processing:

User information: First name, last name, telephone (optional), email address, password (if “Single-Sign-On” is not being used), profile picture (optional), department (optional)

Meeting meta data: Topic, description (optional), participants’ IP addresses, device / hardware information

For recorded sessions (optional): MP4 file of all video, audio, and presentation recordings, M4A file of all audio recordings, text file of the online meeting chat.

Joining via telephone: Information regarding Inbound and outbound phone number, country name, start and end time. Further connection data such as the device’s IP address can be saved where necessary.

Text, audio, and video data: You may have the option to use the chat, question, and survey features during an “online meeting”. In this case, your messages will be processed in order to display them in the “online meeting” and to log them if necessary. In order to allow video or audio to be played, the respective data of your device’s microphone and video camera will be processed for the duration of the meeting. Using the “Zoom” app, you can personally turn off or mute the camera or the microphone at any point.

In order to participate in an “online meeting” or to enter the “meeting room”, you need to at least provide information regarding your name.

Range of processing: We use “Zoom” to have “online meetings”. To ensure transparency, we will inform you ahead of time if we wish to record “online meetings” and will ask for your consent if needed. Additionally, the “Zoom” app will inform you of any recording taking place.

We will log chat files in case they are vital to protocol the outcomes of an online meeting. Usually, however, this will not be the case.

For web-based seminars, we can also process the questions asked by seminar participants for recording and post-processing purposes.

For registered “Zoom” users, “online meeting” reports (meeting meta data, telephone data, questions and answers in web-based seminars, survey feature in web-based seminars) can be stored for up to one month at “Zoom”.

An automated individual decision-making according to Art. 22 GDPR is not used.

Legal basis of data processing: In case of Vogel Communications Group employees processing personal data, §26 BDSG (Federal Data Protection Act) is the legal basis of data processing. If, in connection with the use of “Zoom”, personal data is not required for the establishment, realization, or termination of the employment relationship, but is nevertheless an integral part of the use of “Zoom”, art. 6 sec. 1 lit. f GDPR constitutes the legal basis for data processing. We are focused on the effective conduct of “online meetings” in these cases.

Additionally, the legal basis for data processing in connection with “online meetings” is art. 6 sec. 1 lit. b GDPR for meetings held within the framework of contractual relationships.

If no contractual relationship exists, the legal basis is art. 6 sec. 1 lit. f GDPR. Here too, we are focused on the effective conduct of “online meetings”.

Recipient / transfer of data: Personal data processed in connection with participation in “online meetings” will strictly not be shared with third parties, unless they are explicitly intended to be shared. Please note that contents from “online meetings” – as is the case with personal meetings – are often used to share information with customers, interested parties, or third parties and are therefore intended to be shared.

Other recipients: The provider of “Zoom” necessarily obtains knowledge of the above-mentioned data, within the scope of our data processing agreement with “Zoom”.

Data processing outside of the European Union: “Zoom” is a service offered by a provider from the USA. Thus, personal data is also processed in a third country. We have formed a data processing contract with the provider of “Zoom” which meets the requirements of art. 28 GDPR and is based on the standard EU contract clauses.