of SCAYLE GmbH, Domstraße 10, 20095 Hamburg (as at: April 2024).

In the following Privacy Policy, we inform you about the processing of personal information carried out by SCAYLE GmbH, Domstraße 10, 20095 Hamburg ("SCAYLE" and/or "Controller") in accordance with the General Data Protection Regulation ("GDPR") and the Federal Data Protection Act ("BDSG"). Our Privacy Policy applies to the following websites, applications and other services (hereinafter collectively referred to as ("SCAYLE Academy and/or "Services"): https://academy.scayle.dev/.

Please read our Privacy Policy carefully. If you have any questions or comments about our Privacy Policy, please contact us at datenschutzbeauftragter@scayle.com

Contents

You can easily jump directly to the section you are interested in by clicking on the respective chapter headings.

1. Name and Contact Details of the Controller

2. Contact Details of the Data Protection Officer

3. Purposes of Data Processing, Legal Bases and Legitimate Interests pursued by the Controller or a Third Party and Categories of Recipients

3.1 Accessing our Websites/Applications

3.1.1 Log Files

3.2. Registration, Login and User Account

3.3. Notifications about new Features and Content

3.4. Embedded Features and Content

3.5. Contacting

4. No Requirement to Provide Data

5. Recipients of Personal Data

5.1 Disclosure of Data to Third Parties

5.2 Disclosure to Processors

6. Storage Period and Data Deletion

7. Recipients outside the EEA

8. Your Rights

8.1 Overview

8.2 Rights of Objection

8.3 Right of Withdrawal

1. Name and Contact Details of the Controller

This Privacy Policy applies to data processing by

SCAYLE GmbH,
Domstraße 10, 20095 Hamburg
Telefon: 0800 / 30 15 085
E-Mail: hello@scayle.de

Website: www.scayle.com

for the following Services: https://academy.scayle.dev/

2. Contact Details of the Data Protection Officer

You can contact the Data Protection Officer of the Controller at

SCAYLE GmbH
Attn: Sebastian Herting - Data Protection Law Firm
Domstraße 10
20095 Hamburg Germany

E-Mail: datenschutzbeauftragter@scayle.de

3. Purposes of Data Processing, Legal Bases and Legitimate Interests pursued by the Controller or a Third Party and Categories of Recipients

3.1 Accessing our Websites/Applications

3.1.1 Log Files

Each time you access Services, information is sent to the server of our Service by the respective Internet browser of your respective end device and temporarily stored in log files. The data records stored in the log files contain the following data: date and time of access, name of the page accessed, IP address of the requesting device, device type, cfRayId, referrer URL (origin URL from which you came to our Service), the amount of data transferred, loading time, product and version information of the browser used in each case and the name of your internet access provider. We process the log files in order to be able to provide our Services reliably and securely.

Insofar as we process personal data (e.g. the IP address), the legal basis for this is Art. 6 (1) f) GDPR. Our legitimate interest arises from the

• Ensuring a smooth connection setup,

• To ensure convenient use of our Services,

• Evaluation of system security and stability.

It is not possible to draw any direct conclusions about your identity from the information and we will not do so. The information is stored and automatically deleted once the aforementioned purposes have been achieved. The standard periods for deletion are based on the criterion of necessity.

Insofar as we use cookies or similar technologies in connection with the processing of log files described above, this is absolutely necessary in order to provide the Services you have requested. We may use these cookies without your consent on the basis of Section 25 (2) No. 2 of the German Act on Data Protection and the Protection of Privacy in Telecommunications and Telemedia ("TTDSG").

3.2. Registration, Login and User Account

The creation of a user account is optional. If a user account is created, the data collected will be processed in order to provide the user account on the basis of contractual obligations (Article 6 (1) b) GDPR). In particular, the data processed includes the login information such as user name and password in order to gain access to your user account. Please treat your personal access data confidentially and do not make them available to unauthorized third parties. Please note that you will automatically remain logged in after leaving our website unless you actively log out.

Your data will be deleted as soon as it is no longer required for the performance of the contract. Please see Section 6. for more information.

3.3. Notifications about new Features and Content

As a user of the SCAYLE Academy, you will regularly receive notifications from us via email. In particular, these email notifications will include information about new features and updates with regard to the improvement and development of the SCAYLE Academy. We will also notify you of new content and videos (e.g. in case a new tutorial on a certain topic has been uploaded). In this context we use the email address we have generated for you to login to SCAYLE Academy. The legal basis for this data processing is Art. 6 par. (1) f) GDPR. We have a legitimate interest in keeping you informed of new features related to using SCAYLE Academy to ensure optimal usage..

We use the software solution of HubSpot Germany GmbH (“Hubspot”) to send the email notifications. As a Processor, Hubspot processes your data exclusively on our behalf and not for its own purposes.

Reference to the Right of Withdrawal

You can object to our notifications at any time free of charge with effect for the future at the end of each email

3.4. Embedded Features and Content

We use the video player from Wistia, Inc., 17 Tudor Street, Cambridge, Massachusetts, 02139 USA ("Wistia") on our Services. This is a service for hosting and embedding videos on websites. We use videos as part of the SCAYLE Academy to provide additional online courses for our products and services. The Wistia video player is only used in privacy mode on our services. This means that Wistia anonymizes users' IP addresses. Only when you interact with the videos (e.g., by clicking on them) is information collected about your use of the videos and the video player. In particular, this includes information such as the time the video was accessed, the page (URL) from which the embedded video was accessed, as well as information about how long the video was viewed, when it was paused, when parts of the video were skipped, when the video was terminated, and whether buttons and links in the video were interacted with.

The legal basis for this data processing is Art. 6 (1) f) GDPR. We have a legitimate interest in providing you with training videos tailored to our products and services.

3.5. Contacting

You have the option of contacting us in several ways. By e-mail, by telephone or by post. When you contact us, we use the personal data that you voluntarily provide to us in this context solely for the purpose of contacting you and processing your request.

The legal basis for this data processing is Art. 6 (1) a), Art. 6 (1) b) Art. 6 (1) c) GDPR and Art. 6 (1) f) GDPR. We have a legitimate interest in responding to inquiries from our users that are of a general nature and not directly related to a contractual relationship.

4. No Requirement to Provide Data

In principle, you are not obliged to provide us with your personal data. However, the use of certain areas of our Services may require the provision of personal data. If you do not wish to provide us with the data required for this, you will unfortunately not be able to use the relevant areas of the Services.

5. Recipients of Personal Data

5.1 Disclosure of Data to Third Parties

We will only pass on your data to Third Parties outside SCAYLE if this is legally permissible (e.g. because we or the Third Party have a legitimate interest in passing it on, we are legally obliged to pass it on or on the basis of your consent).

• If we are obliged to do so due to legal requirements or by enforceable official or court order in individual cases (vis-à-vis authorities);

• In connection with legal disputes (with courts or our lawyers) or tax audits (with auditors);

• When we work together with tax consultants;

• In connection with possible criminal acts to the competent investigating authorities;

• In the event of a sale of the business (to the purchaser).

If we pass on your data to Third Parties on the basis of your consent, the explanation can also be provided when consent is obtained.

5.2 Disclosure to Processors

We use so-called Processors in some areas of the processing of your data. A Processor is a natural or legal person who processes personal data on our behalf and on the basis of our instructions, whereby we remain responsible for the data processing. Processors do not use the data for their own purposes but carry out the data processing exclusively for the Controller.

Insofar as the Processors are not already named in this Privacy Policy, these are in particular the following categories of Processors:

• IT service provider (e.g. Hosting Provider)

6. Storage Period and Data Deletion

SCAYLE only stores personal data for as long as is necessary for the purposes stated in this Privacy Policy, in particular to fulfill our contractual and legal obligations. We may also store your personal data for other purposes if and for as long as further storage for certain purposes is permitted by law.

7. Recipients outside the EEA

We also pass on personal data to third parties or Processors based in countries outside the European Economic Area ("EEA"). In this case, we ensure that the recipient either has an adequate level of data protection or has your express consent before transferring the data.

An adequate level of data protection exists, for example, if the European Commission has adopted a so-called adequacy decision for the respective country (Art. 45 GDPR). For the USA, the European Commission has decided that an adequate level of data protection exists there if the data recipient participates in the EU-U.S. Data Privacy Framework (DPF) and has a current certification for this. If the recipients of your personal data are located in the USA and participate in the DPF, we therefore rely on this adequacy decision (Art. 45 GDPR).

Alternatively, we ensure an adequate level of data protection by agreeing the so-called EU standard contractual clauses of the European Commission with recipients (Art. 46 GDPR). In this case, we carry out transfer impact assessments and agree additional protective measures with the recipient or implement them where necessary. Specifically, we agree Module 1 of the EU standard contractual clauses with recipients who are (independent) Controllers and Module 2 of the EU standard contractual clauses with recipients who act as our Processors.

These are third parties or Processors based in the US (we rely on the "DPF" in this respect). You can obtain a copy of the specifically agreed regulations to ensure an adequate level of data protection from us. To do so, please contact datenschutzbeauftragter@scayle.com or to the contact information set out in Section 2. contact information.

8. Your Rights

8.1 Overview

In addition to the right to revoke your consent given to us, you have the following additional rights if the respective legal requirements are met:

• The right to information about your personal data stored by us (Art. 15 GDPR), in particular you can request information about the processing purposes, the categories of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the origin of your data if it has not been collected directly from you;

• The right to rectification of inaccurate or completion of incomplete data (Art. 16 GDPR),

• The right to erasure of your data stored by us (Art. 17 GDPR), provided that the applicable requirements for this are met and, in particular, no statutory or contractual retention periods or other statutory obligations or rights to further storage are to be observed by us,

• The right to restrict the processing of your data (Art. 18 GDPR) if the accuracy of the data is contested by you (for a period enabling us to verify the accuracy of the personal data); the processing is unlawful but you oppose its erasure; we no longer need the data, but you require it for the establishment, exercise or defense of legal claims or you have objected to processing pursuant to Art. 21 GDPR (pending the verification whether our legitimate grounds override yours),

• The right to data portability in accordance with Art. 20 GDPR, i.e. the right, in the case of processing based on your consent (Art. 6 (1) a) GDPR) or for the performance of a contract (Art. 6 (1) b) GDPR), which is carried out using automated procedures, to receive data stored by us about you in a common, machine-readable format or to request that it be transferred to another Controller (the latter, insofar as this is technically feasible),

You can assert the aforementioned rights to which you are entitled at datenschutzbeauftragter@scayle.com.

You also have the right to lodge a complaint with a supervisory authority. In particular, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters.

8.3 Right of Withdrawal

Insofar as we process data on the basis of your consent, you have the right to withdraw your consent at any time. Your revocation does not affect the legality of the data processing carried out on the basis of the consent(s) until the revocation.

You can generally assert your right to object at datenschutzbeauftragter@scayle.com.

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