Privacy Policy:
www.scoolio.de

With the following Privacy Policy, we, Scoolio GmbH, Goetheallee 24, 01309 Dresden as the controller within the meaning of the General Data Protection Regulation (GDPR), explain which personal data we process when our website is visited. We would like to point out that by default all data transmissions in connection with our website take place via an encrypted connection.

We reserve the right to occasionally adapt our data protection information so that it always complies with current legal requirements or to represent changes to our services. We therefore recommend that you regularly read the data protection information in order to stay up to date on the protection of the personal data we process.

When accessing our website, several technical data are logged. This general data and information is stored in the log files of the server. The IP address, the accessed address, the date and time of the retrieval, as well as the transmission time are recorded in a log file. The processing of personal data takes place for the provision of the website as well as for troubleshooting and clarification of abuse or fraud acts on the basis of a legitimate interest pursuant to Art. 6 (1) sentence 1 lit. f) GDPR. The log files will be deleted after 30 days.

We use cookies on our website. By means of a cookie, the information and offers on our website can be optimized in the sense of the user. On the basis of § 25(2) TDDDG, only strictly necessary cookies are used. The necessity within the meaning of § 25(2) TDDDG consists in the secure confirmation of forms and to secure our website ("__RequestVerificationToken", storage period: until the end of the session) and in the deactivation of information banners on mobile devices ("sb-closed" or "sb-installed", storage period: 15 days). A transmission of information to third parties does not take place.

On our website there is a contact form, which can be used for electronic contact. Furthermore, it is possible to contact us by e-mail via the ‘Contact’ tab as well as via the contact details provided in the imprint. When contacting us, we process the personal data provided to clarify the respective request, in particular the name, the e-mail address and the request expressed.

The processing of the listed personal data takes place on the basis of the legitimate interest in satisfactorily responding to contact and enquiries in accordance with Art. 6 (1) sentence 1 lit. f) GDPR or in the case of quotation requests and contractual matters on the basis of the contract or pre-contractual measures in accordance with Art. 6 (1) sentence 1 lit. b) GDPR.

The personal data provided will be treated confidentially by us, serve exclusively to process the request and will not be passed on to third parties, unless this is absolutely necessary in individual cases due to the nature of your request. The deletion of the personal data takes place after final clarification of your request or on the basis of an objection by the data subject. Insofar as the data processing is carried out on the basis of consent, the personal data will be deleted with the revocation of consent. The deletion periods shown here only apply insofar as they do not conflict with any statutory retention periods.

In the "Future" section, you have the opportunity to learn more about yourself as part of a skill test. You answer 16 questions about relevant character traits, which you can answer in the affirmative or in the negative. Your answers will be sent to the scoolio backend in the form of numerical values. This will then assign you a personality type from a catalog of predefined personality types that will be displayed to you. In order to carry out the skill test, we only process your IP address and the numerical values described (Art. 6 (1) sentence 1 lit. b) GDPR). Your answers and results will not be saved.

Through the homework help AI function, you can direct tasks and questions to us, which we have answered for you through an AI model. For this purpose, we forward your entered text in our name and in a closed context to a secure text completion interface of OpenAI (OpenAI OpCo, LLC, 3180 18th St., San Francisco, CA 94110, USA). Each of these requests is processed independently as a new text completion that is completed immediately after the response and therefore cannot be continued or referenced as a conversation.

For the transmission of the entered text to OpenAI, your personal usage data is expressly not transmitted to OpenAI. The communication with the text completion interface of OpenAI takes place exclusively via a secured channel between the Scoolio servers and OpenAI. The data processing takes place on the basis of an express request for use within the framework of the functionalities provided by us (Art. 6 (1) sentence 1 lit. b) GDPR). Requests and answers are not stored by scoolio. On the part of OpenAI, the respective requests and answers are stored for as long as it is necessary to answer the requests. However, OpenAI reserves the right to anonymised further processing for statistical and research purposes. The information is passed on by OpenAI to affiliated companies, service providers, service providers, law enforcement authorities and persons involved in the transactions.

In order to ensure that the requests to the homework AI are not inappropriate in accordance with our terms of use (Art. 6 (1) sentence 1 lit. b) GDPR), we have the text content assessed on the basis of a point evaluation procedure. For investigation, the text content on our behalf is passed on to a secure and calibrated moderation interface from OpenAI. The text content without information to the user is checked for hatred, threat, self-harm, sexualization or violence and excluded from the execution of the text completion in case of violations.

To implement our homework help AI function, we use the services of OpenAI OpCo, LLC, based in the USA. The USA is a third country under data protection law in which the level of data protection does not correspond to that within the European Union. We would like to point out any risks in this regard, such as extended access to personal data by investigating authorities and, if necessary, a lack of redress options. In order to ensure an appropriate level of data protection, we have concluded data protection contracts with OpenAI (data processing agreement, standard contractual clauses (Article 46(2)(c) GDPR). In addition, we have ensured that no personal usage data is transmitted to OpenAI. You can find more information about OpenAI's terms of use here, information about OpenAI's privacy policy can be found here.

NOTE: We would like to explicitly point out that OpenAI can process entered texts for training and research purposes. For this reason, the use of our homework help AI function is only permitted without providing personal data. Personal data are, for example, names of living persons, address data, telephone numbers, e-mail addresses or other information that can be clearly assigned to a living person.

Chat & Chat Groups

The chat and group function allows you to communicate with individual users of the scoolio app or in groups with several users simultaneously via text, voice (see ‘Chat Voice Messages’) and image messages. Voice messages require app access to the microphone, picture messages require app access to the smartphone's gallery.

You can join various existing public or private chat groups or create new public or private chat groups. Depending on the particular characteristics of the chat group, we process certain profile information from you (Art. 6 (1) sentence 1 lit. b) GDPR): For example, to provide a school chat group, the scoolio app processes school affiliation. Please be careful what information you provide about yourself to others within chat and chat groups. Although you are generally free to decide what information you would like to provide about yourself as part of your use of the app from the age of 16, we recommend that you first talk to your parents about whether and what further information you would like to disclose about yourself.

In order to ensure that no inappropriate content is disseminated within chat messages in accordance with our terms of use (Art. 6 (1) sentence 1 lit. b) GDPR), we reserve the right not to transmit inappropriate images and documents (see "Inspection of images and documents") as well as message content with telephone numbers and e-mail addresses. Furthermore, all users have the possibility to report chat messages, which are then checked by the scoolio support.

Use the search function to search for existing chat groups. For the environment-relevant presentation of different chat groups (Art. 6 (1) sentence 1 lit. f) GDPR), we use the location of your school or alternatively the location of the ‘Welcome Campus’, based on your region, which you have indicated in the context of setting up the scoolio app. As a member of a chat group, you can also view the other members of the chat group and access their profiles.

You can leave chat groups at any time or delete them as the creator of a chat group. If you delete your profile, the messages will be kept in chats and chat groups, but the author will only be shown as "deleted user" and no longer your username.

Taking into account various functional and security aspects as well as existing risks when transferring personal data to third countries under data protection law, we have opted for the cloud solution from Google, a global company. We have concluded the necessary data protection contracts with Google (data processing agreement, contract for joint controllers). If personal data is transferred to the USA, this transfer is based on an adequacy decision (Art. 45(1) GDPR) and Google's certification under the EU-U.S. Data Privacy Framework. In addition, we ensure in the development that, if possible, only pseudonymized or anonymized data is processed by Google. Further information about data processing at Google can be found here.

Cloud

The cloud function of scoolio allows you to connect the scoolio app with the scoolio web. You can store various files, such as photos or documents, on it and retrieve them across devices. You can also share the files with your classmates, your class, or the whole school. The use of the cloud function of scoolio is subject to our terms of use (Art. 6 (1) sentence 1 lit. b) GDPR). To log in, you can scan the displayed QR code via a QR code reader. Depending on the application and your personal settings, the provider of the QR code reader may then receive information about you. The respective provider is then responsible for this data processing. If necessary, inform yourself in advance accordingly with this provider. Even if you are generally free to decide what information you would like to provide about yourself as part of your use of the app from the age of 16, we recommend that you talk to your parents about it beforehand.

To use the cloud, you can create different folders ("boxes"). Please note that there are different boxes with different access permissions. The school box can be accessed by all users of the scoolio app who have specified your school when registering. On the other hand, only you can access the Favorites or Done box. You can always create, change or delete your own boxes as well as share them with your classmates and friends, assign and revoke permissions.

Taking into account various functional and security aspects as well as existing risks when transferring personal data to third countries under data protection law, we have opted for the cloud solution from Google, a global company. We have concluded the necessary data protection contracts with Google (data processing agreement, contract for joint controllers). If personal data is transferred to the USA, this transfer is based on an adequacy decision (Art. 45(1) GDPR) and Google's certification under the EU-U.S. Data Privacy Framework. In addition, we ensure in the development that, if possible, only pseudonymized or anonymized data is processed by Google. Further information about data processing at Google can be found here.

Inspection of images and documents

If you decide to upload a profile picture of yourself, provide an offer with an image or provide pictures or documents in groups and chats, we would of course like to ensure that this does not contain nudity, racist, sexist or violence-glorifying elements and complies with our terms of use (Art. 6 (1) sentence 1 lit. b) GDPR). For the analysis of the uploaded images, we use the Azure Cognitive Services of Microsoft Ireland Operations Limited with server location in Ireland or the Google Vision API from Google. The image and document data without information about the user are checked by the respective service and provided with a corresponding note for scoolio support or the upload is completely denied. The stored image is usually deleted immediately after processing by Google.

Taking into account various functional and security aspects as well as existing risks when transferring personal data to third countries under data protection law, we have opted for Microsoft's Azure Cognitive Services and Google's Google Vision API, two global companies. We have concluded the necessary data protection contracts with Microsoft and Google (data processing agreement, contract for joint controller). As far as a transfer of personal data to the USA takes place, this transfer is based on an adequacy decision (Art. 45 (1) GDPR) as well as the certification of Microsoft and Google under the EU-U.S. Data Privacy Framework. In addition, we ensure in the development that, if possible, only pseudonymized or anonymized data is processed by Google and Microsoft. You can find more information about data processing at Microsoft here, about Google here and here.

Corporate account

For the creation of campaigns and for the purposes of the registration required for this purpose in the scoolio online portal for companies, we process information about the company (name and address), information about the contact person (name, e-mail address and telephone number), information about the booked package, payment information and any communications on the basis of an existing contractual relationship or on the basis of pre-contractual measures pursuant to Article 6 (1) sentence 1 lit. b) GDPR. A processing of personal data for previously clearly highlighted sales purposes always takes place on the basis of consent in accordance with Art. 6 (1) sentence 1 lit. a) GDPR.

The personal data provided will be treated confidentially by us, serve exclusively the initiation and execution of the contract or the presented sales purposes. A transfer to third parties takes place exclusively insofar as this is absolutely necessary to achieve the processing purposes (e.g. banks, tax authorities) or we must transmit the data for legal reasons.

The deletion of personal data takes place with the deletion of the company account. Insofar as the data processing is carried out on the basis of consent, the personal data will be deleted with the revocation of consent. The deletion periods shown here only apply insofar as they do not conflict with any statutory retention periods. These are usually six to ten years for accounting documents in accordance with the standards of the German Commercial Code (HGB) and the German Tax Code (AO).

In order to provide our services, we use service providers who process personal data on our behalf or through whom access to personal data cannot be excluded. This initially applies to the necessary hosting services, for which we cooperate with Hetzner Online GmbH and use the Google Cloud from Google (Google Cloud Platform, GCP) for the technical implementation of the chat. Google Cloud uses the regions of Germany and Belgium (europe-west3 and europe-west1). Google Cloud works in a multi-tenant environment. Data is replicated between multiple geographically distributed data centers (data center resilience).

The aforementioned service providers only act according to our instructions and have been contractually obliged to comply with the data protection regulations within the meaning of Art. 28 GDPR. More information about the data processing by Google Cloud is available here.

Data subjects can request information about their personal data as well as correction or deletion or restriction of processing or object to processing at any time. In addition, there is a right to data portability in their favour. In addition, if the data processing is carried out on the basis of consent, it can be revoked at any time for the future. To exercise your rights, our data protection officer is available at datenschutz[at]scoolio.de.

In addition, pursuant to Article 77 GDPR, there is a right to lodge a complaint with a data protection supervisory authority if it is suspected that the processing of personal data is unlawful. A supervisory authority that can be contacted, for example, is the Saxon Data Protection and Transparency Commissioner..