Privacy Policy

We use the services of Salesforce.com Germany GmbH for building and managing our relationship with external partners and potential partners and for communicating with them. Salesforce is a software company based in Germany, subsidiary of a holding based in the USA. We use this integrated software solution as a CRM and for communication purposes. With the Salesforce Sales email extension, we log emails sent from outside of Salesforce to the CRM automatically.

The legal basis for this processing is our legitimate interest in maintaining contacts made in the course of business transactions beyond the initial contact and in using them to establish business relationships and to remain in contact with the persons for this purpose according to Art. 6 para. 1 s. 1 lit. (f) GDPR.

We have concluded a Data Processing Agreement with the service provider in which we oblige it to protect the data of our customers and not to pass them on to third parties. 

Since a transfer of personal data by Salesforce to affiliates and sub-processors to countries outside the EU and EEA is possible, further appropriate safeguards are required to ensure the level of data protection under the GDPR. For the U.S., there is an adequacy decision of the EU Commission pursuant to Art. 45 (1) GDPR regarding companies with certification under the EU-U.S. Data Privacy Framework. Salesforce is certified under the EU-U.S. Data Privacy Framework and is therefore committed to compliance with adequate data protection standards, which can be verified via the following link: dataprivacyframework.gov/s/participant-search 

For potential transfers to other countries outside the EU and the EEA, for which no adequacy decision of the EU Commission exists, we have concluded standard contractual clauses with the provider in accordance with Art. 46 (2) lit. (c) GDPR. These oblige the recipient of the data in the country outside the EU to process the data in accordance with the level of protection in Europe.

The terms of use of Salesforce and information on data protection can be accessed via the following links: 

salesforce.com/company/legal/sfdc-website-terms-of-service 
salesforce.com/company/legal/agreements  
‍salesforce.com/de/company/privacy

b. Slack Connect

Should you be interested in becoming a Student at Kiron, you can apply and register using the form you will find on Campus, using either your personal email address or third-party application (SSO) such as Google and DAAD/Mein DAAD. 

Google – If you opt to register with an existing Google account,you agree that we will obtain validation of the password from Google. In this case, Google will ask for your permission to share certain information from your Google account with Kiron. This includes your name, your Google email address, your language preference and your profile pictures. This information is collected by Google and made available to us under the terms of the Google Privacy Policy. You can control the information provided to us by Google via your Google activity controls.
DAAD – You can also log in to Kiron with your DAAD ID. In this case DAAD shares certain information from your DAAD account with Kiron. This includes your full name, your email address and DAAD ID. This information is collected by DAAD and made available to us under the terms of the Data Privacy Statement “Mein DAAD”.

When you fill in the form, you agree that the information you give us will be used for the purpose of giving you access to the courses offered by Kiron, helping you succeed with your online studies with Kiron and providing you with the services suiting your situation and needs. In this section we explain which personal information we collect in the application process, for what purpose and how such personal information is processed.

a. Our Policy concerning Minors

We recognize the privacy interests of children. Currently Kiron Campus is not intended to be used by individuals younger than 18 years of age. Individuals that are under the age of 18 may not set up an account as a Student. On Campus we do not collect knowingly data of individuals younger than 18. If we learn that an individual younger than under the age of 18 has set up an account, or that we’ve collected personal data from a minor under that age, we will take reasonable steps to delete the account and the data as quickly as possible.

If you have reason to believe that we may have collected personal data from an individual under that age, you can inform us and you can also submit a request that it be removed to privacy@kiron.ngo.

b. Data Collected and legal basis

The following information is collected by a form on the apply page as part of your application and will later be used to create your account as a Student at Kiron:

• Personal details: name (first and last name), email address,nationality, country of residence as well as, if you wish to fill in also these details, city of residence, gender, age (birthday), phone number. 
• Document proving your status as a “refugee”, seeker or beneficiary of international protection, or documents qualifying you to participate in certain programs  
• the project you participated into or the organization from which you found out about Kiron

The information gathered in the application process is used to prepare your registration, to ensure that you are eligible for our free services (see. the paragraph Your Status below), to provide you access to our online courses and to optimize our services and guidance for you. This may include e.g. information on specialized programs for female students (“gender”) and additional student services (for instance those indicated in the following paragraphs). If consent is given, the legal basis for data processing is Art. 6 para. 1 s. 1 lit. (a) GDPR or Art. 6 para. 1 s. 1 lit. (b) GDPR, insofar as the processing is necessary for the provision of the requested services.

Your Status

Kiron’s student services are targeted primarily at refugees and to seekers or beneficiaries of international protection. In addition, we accept individuals qualifying for certain programs. . We must therefore assess your eligibility. The respective documents uploaded by you are safely stored separately from your account information. 

c. Retention and Deletion

Should an application not meet the minimum requirements to become a Kiron Student our support team will reach out to the applicant to clarify and evaluate if eligibility might still be possible (e.g. by providing additional documents). Until your application is deemed to meet all requirements, you may have access to Campus but possibly not to all courses and services.

Successful applicants will be notified by email and the information they have provided will be converted into a Kiron Student profile as the basis for the relationship between the Student and Kiron. In the event that an application is not accepted, all registration data will be deleted promptly.

d. Access to Data and Transferal

Within Kiron, until the applicant has been accepted, only the employees at Kiron in charge of reviewing applications will have access to the data provided with the application. All data is stored and processed on Kiron’ secure server infrastructure hosted by SysEleven. During the application process and until you have been accepted as a Student, we will not transfer your data to any external party. 

When your application is successful, regardless whether you have enrolled with a Google gmail account or another email address, your profile will be set up on Campus as Kiron Student. 

Students that have enrolled on Campus before this Privacy Policy has been published might have been assigned an email account with an address ending in @students.kiron.ngo. This account will be maintained by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google") and administered by Kiron as part of their Google-for-Nonprofits program. Effectively, the account entails a number of functions, which are part of Google Workplace. These email addresses are still active and the provisions hereunder apply to such email accounts as well.

a. Data Collected and legal basis 

The following information is collected when you log-in and use your student account:

• login and usage logs
• all personal information and data you may choose to upload to your student account or which is included in the material you may upload – including profile pictures, emails sent and received, files, videos, etc.

If consent is given, the legal basis for data processing is Art. 6 para. 1 s. 1 lit. (a) GDPR or Art. 6 para. 1 s. 1 lit. (b) GDPR, insofar as the processing is necessary for the provision of the requested services.The log files will be processed for the purpose of ensuring a smooth and stable connection of the Platform and a comfortable use of our Platform for the students as well as to evaluate the system security and stability and for other administrative purposes. The legal basis for data processing is Article 6 para. 1 s. 1 lit. (f) GDPR. Our legitimate interest follows from the purposes listed above for data collection.

b. Retention and Deletion

The log files may be retained until their storage is required for the above-mentioned purposes. So, generally login logs are not deleted but are anonymised when the Student requests deletion of their account (s. para 9); HTTP request logs are deleted on a regular basis, at the latest upon the next deploy on Campus, at least every two weeks.

All personal information and data you may have uploaded to your profile will be removed either when you delete it from your account or at latest when you will cease being a Kiron Student. For the deletion process see para 9 below.

c. Access and Transferal 

Your student profile on Campus is administered by Kiron. Kiron may access your profile or review the information stored therein for the purposes of providing and improving the services on Campus. Furthermore, Kiron administrators have the ability to reset an account password upon explicit request by the Student. 

All your data is stored on secured servers (S. above Section A 4). Within Kiron, access to your personal information is granted only to those departments and employees that need it to carry out their tasks and duties related to the functions of the Platform and the provision of the services on the Platform. 

Only for those Students that still have a @students.kiron.ngo account, the following applies:

Google Workplace employs automatic security mechanisms such as spam filters, login and usage logs and safety warning mechanisms. Kiron’s administrators have the possibility to view automatically collected logging information which are part of Google Workplace security and audit features. For more information about the security mechanism of Google Workplace please see workspace.google.com/faq

To use this service you will need to agree to Google’s terms of service (www.google.com/intl/en/policies/terms) and privacy policy (www.google.com/policies/privacy).

All information and data you chose to upload to your Google Workplace account – including profile pictures, emails sent and received, files, videos, etc. – is processed automatically by Google in one of their secure data centers. We have concluded a data processing agreement with Google Workplace. Through the use of Google Workplace, personal data may be transferred to the USA. In order to ensure an adequate level of data protection in accordance with the provisions of the GDPR, we have concluded standard contractual clauses with the provider in accordance with Art. 46 Para. 2 lit. (c) GDPR.

For further information see: apps.google.com/faq/security and cloud.google.com/security/whitepaper 

As a Kiron Student you have the possibility to study, following courses on different topics as well as language courses. Also, you are given access to a number of services and functionalities of the Platform, which may include:

• providing an overview and specific recommendations for free online courses (Massively Open Online Courses “MOOC”), which may match your interests and your goals;
• provide access and transfer to MOOC-platforms (such as Coursera etc.)
• providing information about our products and recent developments at Kiron
• inviting you to Student Events
• providing you with mentoring services
• providing you with tutorials and classes as live sessions
• offering the possibility for exchange and communication between students

We will need to collect personal information for some or all of these purposes. This section will explain which data is collected and how it is processed for these purposes. The information contained in this section applies to all purposes unless it is specified otherwise or more in detail in one of the following sections.

a. Data Collected and legal basis 

Kiron may collect, process and use the content and other information Students provide when accessing the Platform and using the services provided thereon, including the data submitted for signing up for a service (s. Section E 1.a.), creating or sharing content, and messaging or communicating with others on the website. Such information may include:

• name
• nickname
• email address
• gender
• country of residence
• city
• date of birth
• nationality
• phone number
• status as refugee, internal displaced person or qualifying member of a host community in Jordan or Lebanon and related documentation

Your data will be processed for the purpose of ensuring that Students access the Platform and to all services for the Students, to provide for an efficient, unhindered and comfortable use of the Platform, and to constantly improve the Platform and the services offered to the Students. If consent is given, the legal basis for data processing is Art. 6 para. 1 s. 1 lit. (a) GDPR or Art. 6 para. 1 s. 1 lit. (b) GDPR, insofar as the processing is necessary for the provision of the requested services.

Student Events

Kiron periodically organizes events for its Students and may collect specific information to facilitate the organization of such events. The participation in such events is optional and the information provided by you is used only for the organization of the specific event. Kiron may keep a record of which Students participated at Student Events. The legal basis for data processing is Art. 6 para. 1 s. 1 lit. (b) GDPR, insofar as the processing is necessary for the provision of the requested services.

Certificate of Enrollment

Kiron may provide you with a non-legally binding document which says that you are enrolled at Kiron. We may ask you about the purpose of the request and will use this information for statistics, in which case we will ask for your consent and your data will be anonymised, and to help us identify students with the potential to participate in certain programs. 

Community page

From time to time on the Community page on Campus we publish links to interesting opportunities to support you with your goals. The opportunities are provided by independent third parties and organizations. In these cases the data protection provisions of the respective website operator applies and we recommend that you obtain information on the respective website on how your personal data is collected and processed.  

b. Retention and Deletion

Your data and personal information will be removed from the Platform when you will cease being a Kiron Student. For the deletion process see para 9 below.

c. Data Access and Transferal

All your data is stored on secured servers (S. above Section A, para 4). Within Kiron, access to your personal information is granted only to those departments and employees that need it to carry out their tasks and duties related to the functions of the Platform and the provision of the services on the Platform. 

d. External service providers

We may use the support of external services in order to provide certain services to you or to contact you:

i. Location Data

Kiron will provide specific offers based on the country or city you are currently located. Kiron needs to know in which country you are currently located in order to offer these services. Additionally, you may provide your current city in order to further allow for tailoring of services.

ii. Zendesk 

Our Student communications, Support Ticketing system, Support Portal, Live Chat and Knowledge Base, Feedback and suggestions section are using a software solution by Zendesk Inc., 989 Market Street #300, San Francisco, CA 94102, USA. We have concluded a data processing agreement with Zendesk. 

The legal basis for the use of this service is our legitimate interest according to Art. 6 para. 1 s. 1 lit. (f) GDPR. Our legitimate interest in the use of this service is to be able to answer user enquiries quickly and efficiently.

Through the use of Zendesk, personal data may be transferred to the USA. Since a transfer of personal data by Zendesk to countries outside the EU and EEA is possible, further appropriate safeguards are required to ensure the level of data protection under the GDPR. For the U.S., there is an adequacy decision of the EU Commission pursuant to Art. 45 (1) GDPR regarding companies with certification under the EU-U.S. Data Privacy Framework. Zendesk, Inc. is certified under the EU-U.S. Data Privacy Framework and is therefore committed to compliance with adequate data protection standards, which can be verified via the following link: dataprivacyframework.gov/s/participant-search

For potential transfers to other countries outside the EU and the EEA, for which no adequacy decision of the EU Commission exists, we have concluded standard contractual clauses with the provider in accordance with Art. 46 (2) lit. (c)lit. c GDPR. These oblige the recipient of the data in the country outside the EU to process the data in accordance with the level of protection in Europe.

In order to ensure an adequate level of data protection in accordance with the provisions of the GDPR, Zendesk has Binding Corporate Rules according to Art. 47 GDPR.

More information on data protection terms, cookies and terms of use of Zendesk can be accessed via the following links:
zendesk.com/company/agreements-and-terms/cookie-notice
zendesk.com/company/customers-partners/privacy-and-data-protection
zendesk.com/company/agreements-and-terms/terms-of-use

iii. Mailjet

For contacting Students (i.e. information about campaigns, course reminders, etc.) Kiron uses a technical service provider to whom we pass on your email address you provide when you register for Kiron. This forwarding is carried out in accordance with Art. 6 para. 1 s. 1 lit. (f) GDPR and serves our legitimate interest in the use of effective, secure and user-friendly communication. Your email address will be stored on servers located in the EU.

We have concluded an order processing contract with our email service provider in which we oblige him to protect our customers' data and not to pass it on to third parties.

Email service provider:
Service provider: Mailjet
Address: Mailjet SAS,13-13 bis, rue de l’Aubrac, 75012 Paris, France
Privacy policy: mailjet.com/privacy-policy

iv. Contact and additional Information via phone, email and other means

Kiron may keep in contact with you or send you updated information via email or other messaging services for which the respective contact details are used.
‍
These services include:

• WhatsApp Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland: For certain services we may also ask you to communicate through WhatsApp Messenger service. Therefore your name and telephone number will be required. You will be asked for your specific consent to communicate via WhatsApp.
  More information: whatsapp.com/legal/#privacy-policy 
• Google Meet, a service by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"): This service may be used for phone conversations with Students and video calls within Kiron-organized group tutorial sessions. To use this, you must be logged in to your Google Account. This allows Google to store your activity data. You can view and manage this information in your Google Account. During the call, you will be in a real-time audio/video call that will not be recorded or transmitted by us to anyone else. 
  More information: google.com/+/policy/call-phones-terms.html
• Facebook Groups: May be used for recruiting purposes and for the organization of student events. 
  More information: facebook.com/policy.php
• Telegram: May be used to create and coordinate Student groups and communicate with group members.
  More information: telegram.org/privacy
• Mattermost: We use Mattermost as our chosen platform for communicating with students.
  More information: mattermost.com/privacy-policy

We may use the contact services indicated to send you messages that may include information about our products and recent developments or to create and coordinate Student groups about specific topics, interests and events. We may also contact you in case of questions in connection with the Kiron platform, as well as to inform you on changes with regard to this Privacy Policy or any other Terms of Services. 

v. Searching courses and content on Campus

We use the services of a technical service provider to power the search functionality within the campus, allowing Students to find courses and content. To this purpose the IP address of the user is transferred to Algolia. This forwarding is carried out in accordance with Art. 6 para. 1 s. 1 lit. (f) GDPR and serves our legitimate interest in the implementation of an efficient, quick and user-friendly searching functionality on Campus. Your IP address will be stored on servers located in the EU. We have concluded an order processing contract with this service provider.

For more information:
Service provider: Algolia SAS, 55 Rue  d’Amsterdam, 75008 Paris, France
Privacy policy: algolia.com/policies/privacy

vi. Surveys

For surveys between our users, we may use Mentimeter, a service provided by Mentimeter AB. You can find more information at mentimeter.com/trust/legal/terms 

If you use this service, you will be redirected to Mentimeter’s website, you may even have to register directly with the service provider. Your data will be collected and processed by the service provider itself. We then recommend that you read Mentimeter's privacy policy carefully: mentimeter.com/trust/legal/privacy-policy

vii. Providing consent

Kiron may ask you to give consent in certain cases (e.g. for usage of your image or name). To this purpose Kiron may use Google forms that are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

To use this service you will need to agree to Google’s terms of service (google.com/intl/en/policies/terms) and privacy policy (google.com/policies/privacy).

All information and data that you will input in the Google form is processed automatically by Google in one of their secure data centers. We have concluded a data processing agreement with Google. Through the use of Google Forms, personal data may be transferred to the USA. Google (Google LLC) is certified under the EU-U.S. Data Privacy Framework and is therefore committed to complying with appropriate data protection standards, which can be viewed at the following link: dataprivacyframework.gov/s/participant-search

For potential transfers to other third countries outside the EU and the EEA for which there is no adequacy decision by the EU Commission, the provider states that it uses standard data protection clauses in accordance with Art. 46 para. 2 lit. (c)lit. c GDPR. These oblige the recipient of the data in the third country to process the data in accordance with the level of protection in Europe, see here: policies.google.com/privacy?hl=de&gl=de 

For further information see: apps.google.com/faq/security and cloud.google.com/security/whitepaper

viii. Google Maps

On Campus we use the online map service provider Google Maps via an interface. Provider of the map service is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. This allows us to display interactive maps directly on the website and on Campus and it makes it easy for you to use the map function. To use the functionalities of Google Maps it is necessary to save your IP address.

Google uses Cookies, to collect information about user behaviour. The legal basis for the processing of your personal data is your given consent according to Art. 6 para. 1 lit. a GDPR, Sect. 25 para. 1 TTDSG.

Since a transfer of personal data by Google to affiliates and sub-processors to countries outside the EU and EEA is possible, further appropriate safeguards are required to ensure the level of data protection under the GDPR. For the U.S., there is an adequacy decision of the EU Commission pursuant to Art. 45 (1) GDPR regarding companies with certification under the EU-U.S. Data Privacy Framework. Google LLC is certified under the EU-U.S. Data Privacy Framework and is therefore committed to compliance with adequate data protection standards, which can be verified via the following link: dataprivacyframework.gov/s/participant-search 

For potential transfers to other countries outside the EU and the EEA, for which no adequacy decision of the EU Commission exists, we have concluded standard contractual clauses with the provider in accordance with Art. 46 (2) lit. c GDPR. These oblige the recipient of the data in the country outside the EU to process the data in accordance with the level of protection in Europe.

Further information on the handling of user data can be found in Google's privacy policy: google.de/intl/de/policies/privacy 
Opt-out: google.com/settings/ads

ix. Other disclosures

Other than in the aforementioned cases Kiron will not transmit your personal data to any third parties, unless we are obliged to do so because of German legal regulations (e.g. disclosure to courts or law enforcement authorities), you have given us your explicit consent, or the disclosure is permitted by law. A disclosure may for example be permitted when such disclosure is required for us to be able to render our services to the user on the Kiron platform.

Kiron may analyze the data collected from its Students for scientific purposes in order to conduct academic surveys and research, such as evaluating key performance indicators, social impact and scientifically analyze the services offered on the Platform. 

a. Data Collected and legal basis

Such research will be conducted by Kiron or its research partners either in accordance with the respective legislation, using anonymized and pseudonymised data, whenever possible, or after you have explicitly consented to be part of such research. If consent is given, the legal basis for data processing is Art. 6 para. 1 s. 1 lit. (a) GDPR.

b. Retention and Deletion

The data and personal information collected for research purposes will be either anonymised or removed from the server where it is stored when you will cease being a Kiron Student. For the deletion process see Section 9 below.

c. Access and Transferal

The data selected for research purposes is copied and stored on a separate server environment, which is dedicated to research only, on Kiron’s secure data servers. Only certain Kiron’s selected employees are authorized to access this data. 

As a Kiron Student you will be granted access to different free online courses on different topics, which are offered by external partners (“External Partners”; e.g. MOOC providers like Coursera, platforms like LinkedIn, language courses providers like Inlingua). You can access these courses through Campus.

a. Exchange of Data with External Partners

In certain cases we will have to provide our External Partners with certain personal data in order to inform the partner that you are a Kiron Student and to identify you so that the External Partner will grant you access to its services. This is the case for instance of the MOOC provider Coursera.

In some cases you are redirected to the External Partner’s platform or website, where you should login with your Kiron Student account in order to come in favor of full functionality of these websites. Such websites and platforms are governed by their own separate privacy policies and terms of services, which you will have to accept in order to be able to use the services offered by the websites. Information about the data collected by such websites, how such data is processed, the purpose and legal basis of processing, your rights and other relevant data related information is specified in the respective privacy policies of the External Partners. 

Furthermore, Kiron may receive information about the users and their activities (e.g. participation and completion of courses and programs) on and off the service from the External Partners.

b. Data Collected and legal basis

Depending on the partner and of the services, we may share the data strictly necessary as requested by the External Partner to identify you and to offer you certain courses and services, such as:

• name
• email address
• date of birth
• country of origin
• Spoken language(s)

If consent is given, the legal basis for data processing is Art. 6 para. 1 s. 1 lit. (a) GDPR or Art. 6 para. 1 s. 1 lit. (b) GDPR, insofar as the processing is necessary for the provision of the requested services.

External Partners (e.g. a MOOC-partner like Coursera) may share with us such information as

• the choice of subject
• study record
• period of study
• results of completion
• your language test results, etc. 
• attendance

The processing of this information is necessary for the purposes of the legitimate interests in accordance with art. 6 para. 1 s. 1 lit. (f) GDPR.

c. Retention and Deletion

The data and personal information collected for research purposes will be either anonymised or removed from the server where it is stored when you cease being a Kiron Student. For the deletion process see para 9 below.

d. Access and Transferal

The data selected for research purposes is copied and stored on a separate server environment, which is dedicated to research only, on Kiron’s secure data servers. Only certain Kiron’s selected employees are authorised to access this data. 

Currently, on Campus Students have the possibility to chat and communicate with other Students through a Community page. Also, if you registered as a Student in the past and received a students.kiron.ngo account, Kiron has offered to you the possibility to register for and participate in our internal discussion forum (“Forum”) based on the Discourse platform. The Forum remains only accessible via login with such email address granted by Kiron. 

Forum and the Community page (“Channels”) are meant to exchange your experience with other students or with members of the team at Kiron. Using the Channels is optional and if you opted to join, Kiron created an account for you. 

a. Data collected and legal basis

Kiron may collect, process and use the content and other personal information Students may provide when accessing and being active on the Channels. Such information may include:

• login and usage logs
• name
• email address
• profile image
• all personal information and data you may share on the Channels.

If consent is given, the legal basis for data processing is Art. 6 para. 1 s. 1 lit. (a) GDPR or Art. 6 para. 1 s. 1 lit. (b) GDPR, insofar as the processing is necessary for the provision of the requested services.

The mentioned data will also be processed for the purpose of ensuring a comfortable use of our the Channels for Kiron Students as well as to evaluate the system security and stability and for the purpose of moderating the Channels and ensure that no inappropriate content is uploaded which violates the Channel or the Forum’s code of conduct. The legal basis for data processing is Art. 6 para. 1 s. 1 lit. (f) GDPR. Our legitimate interest follows from the purposes listed above for data collection. 

b. Retention and Deletion

Your data and personal information will be removed from the Channels either when you delete it from your account and correspondence or at latest when you will cease being a Kiron Student. For the deletion process see para 9 below.

c. Data Access and Transferal

At Kiron, only employees that are authorised to administer and / or moderate the Channels will have access to your data on the Channels. However you need to be aware that content you provide within the Channels may be accessed by a larger audience of other Students, who register on the Channels and join the groups or channels, on which you share information. 

The Channels are not accessible by any external search engines, such as Google or Bing, or by any other third parties other than those mentioned herein, if any. 

Kiron offers its Students the possibility to use an online counseling service, which is provided in partnership with Mentorink (www.mentorink.com). If you want to use this service you will create a separate user account on Mentorink’s website. The way your data is collected and processed by Mentorink is specified in Mentorink’s Policy on their website, for any information in this respect you can go to mentorink.com/privacy-policy.

a. Data collected and legal basis

When you show interest and when you attend the counseling service, we will collect the following data:

• Name
• Email address
• Place of residence
• Form of first contact (e.g. via mail, event)
• Registration date
• Dates of all mentoring sessions or no-show
• Additional comments if needed (e.g. if a student has special preferences)
• Any other information you may decide to share with us.

The mentioned data will be collected and processed for the purpose of facilitating your registration with Mentorink, to provide you the mentoring service and to support and assist you when you participate in this mentoring service. We will collect this data only subject to your explicit consent. The legal basis for data processing is Art. 6 para. 1 s 1 lit. (a) GDPR. Also, we may collect information about the attendance to the sessions for statistical purposes and to evaluate the usage and effectiveness of this service. In this case the legal basis for data processing is Article 6 para. 1 lit. (f) GDPR. Our legitimate interest follows from the purposes listed above for data collection. In no case we will receive any information about the content of the counseling sessions, which will remain fully confidential. 

b. Retention and Deletion

All the personal data related to the mentoring process is stored on Kiron’s space on the Mentorink's platform, and / or in our Backend, in a separate section dedicated to this purpose. In case you contacted us through the email student-support@kiron.ngo, some data and information you may have provided may be stored on our customer relationship management system Zendesk. The data will be removed from Mentorink, from the Backend and from Zendesk when you cease being a Kiron student (S. para 9 below).

c. Data Access and Transferal

Only Kiron employees with authorization can access Kiron’s space on the Mentorink platform and the specific section of the Backend, where your personal information about the counseling service is held. Also Mentorink’s administrators may access the reserved space on Mentorink platform solely for the purpose to ensure the functionality of the platform. No data collected in the context of this purpose will be made available to third parties, other than to Mentorink.

Kiron offers its Students the possibility to attend tutorials on topics of their interest with Kiron’s volunteer staff. This service is offered to Students upon their request. In order to support you and to connect you as a Student with the suitable tutor, we may collect specific data and we may ask for your approval to communicate with tutors.

a. Data collected and legal basis

When you show interest and when you attend the live sessions tutorials, we will collect the following data:

• Name
• Email address
• Telephone number (optional)
• Your personal interests for the tutorials 

The mentioned data will be collected and processed for the purpose of organising and facilitating your attendance of tutorials and to support and assist you when you participate in this service. We will collect this data only subject to your explicit consent. The legal basis for data processing is Article 6 para. 1 lit. (a) GDPR. Also, we may collect information about the attendance to the tutorial sessions for statistical purposes and to evaluate the usage and effectiveness of this service. In this case the legal basis for data processing is Article 6 para. 1 lit. (f) GDPR. Our legitimate interest follows from the purposes listed above for data collection. In no case we will receive any information about the content of the tutorial sessions, which will remain fully confidential. 

b. Retention and Deletion

All the personal data related to the tutoring process is stored in our Backend in a separate section dedicated to this purpose. The data and information you have sent to the e-mail student-support@kiron.ngo, may be stored on our customer relationship system Zendesk. We may retain the data collected for the purposes of this service also on digital files which will be stored in a dedicated section of our Google Drive system.

The data will be removed from the Backend, from Zendesk and from Drive when you cease being a Kiron student (S. para 9 below).

c. Data Access and Transferal

Only Kiron employees with authorization can access the Backend. No data collected in the context of this purpose will be made available to third parties, other than your e-mail address and name which will be shared, after you have provided your explicit consent, to the instructors.

You may terminate your membership with the Kiron Platform at any time. For this purpose please send an email to student-support@kiron.ngo. Further to your request of deletion: 

• Your Student account will be removed from our platform and live systems within a maximum of 30 days.
• Data related to your account may remain in our backup systems for a period of time but will be irreversibly deleted or anonymised after 12 months at the latest.
• All your personal data and references to you will be completely anonymized with the exception of the data, for which a legal requirement to retain exists.
• Your profile in our forum (campus.kiron.ngo/community) will be anonymized. Any content you contributed to the forum, however, will remain, unless specifically deleted by you, and will be deleted after a maximum period of 12 months.
• Upon account deletion, if you have received a students.kiron.ngo account provided by Kiron, this will be closed including  the email box and the Drive cloud storage and all information will be deleted from Google’s and Kiron’s servers. The data cannot be recovered once it is deleted.