Version 2.1 effective on 13 October 2016
Kiron.ngo is a collection of free services by
Kiron Open Higher Education gGmbH (haftungsbeschränkt)
Am Festungsgraben 1
10117 Berlin, Germany
(hereinafter: “Kiron“ or We”).
Kiron allows you to
- access its public content (A.), where we also do some analytics.
- Apply and register as a member of our community,
- register for our newsletter (C.)
Data Privacy is an important topic for us and we hold the protection of your personal data in very high esteem. We comply with the provisions of the German Federal Data Protection Act and the German Telemedia Act as well as with applicable EU privacy regulations.
Depending on your use of the our services different sets of data may be stored, as is described in detail below.
Here is an overview of the different services at Kiron where personal data may be processed.
- Accessing content at Kiron.ngo
- IT Security
- Web analytics via Google Analytics
- Social Plugins
- Other external services
- Kiron Newsletter
III. Being a Kiron student
- a) Logging in
- b) Preparing the registration
- c) Refugee status
- d) Eligibility – Motivation
- Registration and login via Google Apps Account
- Student Services
- a) Recommendation of courses
- b) Transferal of Data from and to our MOOC-Partners
- c) Additional Information via mail, e-mail and other means
- d) Other disclosures
- e) Forum based on Discourse (optional)
- f) Location data
- g) Buddy Programme (optional)
- Data analysis for scientific purposes
- Termination of membership
- Right to information, Questions, suggestions and comments
Kiron uses service providers in order to operate and maintain the Kiron platform. The service providers will process the data exclusively in accordance with the instructions of Kiron and have been obliged to comply with the applicable data protection regulations. Kiron and its assigned service providers will take reasonable technical and organizational precautions in order to protect the data of the users.
Accessing content at Kiron.ngo
For providing the contents of the OER world map to you, our server will process your
- IP Address
- Browser type and version and your
- Operating System.
For the purpose of handling security incidents and to help diagnosing problems with our server, we automatically store a log file of the data, which your browser sends when visiting the page, specifically:
- IP Address (the number that is automatically assigned to your computer when you use the Internet)
- Browser type and -version
- Operating System
- Referrer URL (the page, from which this page was linked, including the search term, in case of a search engine)
- Time and date of the request.
Web analytics via Google Analytics
We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics also uses the aforementioned cookies, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. In case IP anonymization is activated on this website, your IP address will be truncated within the area of Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the whole IP address be first transferred to a Google server in the USA and truncated there. The IP anonymization is activated on this website.
Google will use this information on behalf of Kiron for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to Kiron.
You may also configure your browser in a way that permanently prevents it from transmitting any data to Google servers (e.g. by installing add-ons like NoScript or Ghostery for Firefox).
As an alternative to the browser add-on or for browsers on mobile devices, you can click this link in order to opt-out from being tracked by Google Analytics on this website in the future (the opt-out applies only for the browser in which you set it and for webpages under this domain). An opt-out cookie will be stored on your device, which means that you’ll have to click this link again, if you delete your cookies.
Kiron may also use social plugins from the services listed below. Please refer to the respective privacy policies for more information:
- Facebook Like Button: https://de-de.facebook.com/full_data_use_policy by Facebook Inc., 1601 S. California Avenue, Palo Alto, CA 94304, USA
- Google Plus: http://www.google.de/intl/de/policies/privacy/ by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
- Twitter Tweets: http://twitter.com/privacy by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA
Most of those services will not be contacted unless you specifically click on the respective buttons, but they may also establish a direct connection, which will allow the services to combine the information that you are accessing our service with your account information, if you are logged in to the respective service. Upon clicking the respective logo, the information will then be made publicly available, according to the specific policies of the service as well as your preferences within that service.
Other external services
We may use a number of other external services embedded in our website to better display certain content or deliver additional services. Below is a list of services and their respective privacy policies
- Maps and Fonts via Google: http://www.google.de/intl/de/policies/privacy/ by by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
- Donations via Betterplace: https://www.betterplace.org/c/privacy-policy by gut.org gemeinnützige Aktiengesellschaft, Schlesische Straße 26, 10997 Berlin, Germany and und via HalloAsso SAS: https://www.helloasso.com/confidentialite (french only), 6 rue Jean Bedouret 33100 Bordeaux.
- Videos via Youtube: https://www.google.de/intl/de/policies/privacy
- Videos via Vimeo: https://vimeo.com/privacy
You can set your browser so that it enables you to decide in each case whether or not to accept or reject all cookies or specific cookies being installed by a webpage. In case of non-acceptance of cookies, the functionality of the Kiron platform may be limited.
Our website contains links to other websites. Please note that when you click on one of these links you are entering another website, for which Kiron is not responsible.
Via our website you can also register for our Newsletter. In this case, you will have to consent to the following:
You are giving your consent to processing your email address for the purpose of sending a Newsletter with information about Kiron.
We will not transfer the email address we have received for newsletters to any third party, except for the purpose of sending out the newsletter, where we may work with a specialised provider contracted by us.
You can, of course, unsubscribe from the newsletter at any time via [email protected], or better by following the instructions provided at the bottom of each newsletter. After unsubscribing, your email address will be removed from the system handling the newsletter.
If you did not make this subscription request, or do not want to receive a newsletter you may safely ignore this message, your data will be deleted within two weeks after we have send this E-Mail.
III. Being a Kiron student
Should you be interested in applying and registering to become a Kiron Student, you will have to agree to the following data processing taking place as part of the service.
Before you can actually register as a Kiron student, you must successfully apply.
- First, we collect a set of information to prepare the registration, which will be later used as a Kiron student.
The application process meets also two more goals:
- To ensure that your are eligible for our free service, by providing some proof of your status as a “refugee”
- To ensure that you meet our eligibility criteria as a Kiron student, according to your qualifications and motivation.
When applying, you are asked to provide your email address and a new password. This password and email address can then be used to log back into the application service in order to complete the application. The password is stored only in a hashed format, which allows us to verify that the correct password has been entered, but does not allow us to get access to the password itself.
Preparing the registration
The following pieces of data are collected and used to be later transferred to your student account, in case your application was successful:
- E-mail address
- First and last name
- Date of birth
- Level of education
- Study programme
Optionally you may also provide additional information already, which will be used in accordance with the information further below:
- Phone number (optional)
Kiron’s student services are targeted only at refugees; therefore we must assess your eligibility. For this purpose during the application process we ask you to upload a scan of a status paper, which can be signed by a number of different entities.
The respective paper is stored separately from your account information.
Eligibility – Motivation
Eligibility to participate in Kiron requires filling out a form describing your motivation for becoming a Kiron student. After approving the application the data collected on your motivation is only used for scientific purposes and to further improve the service.
Registration and login via Google Apps Account
When your application is successful you will be provided an E-Mail account with an address having two letters, representing the first initial of your first and last names, and a number. For instance, the name “your name” could be used to assing an email address such as [email protected]. This account will be maintained by Google Inc., and administered by us as part of their Google-for-Nonprofits programme.
The data is transferred to Google Inc., under an agreement, which includes the standard-clauses predefined by the European Commission, as a possible legal basis for such transferal.
Effectively, the account entails a number of functions, which are part of the Google-App-Suite. A core functionality, besides E-Mail, is the use of the login-mechanism, i.e. you will need to login via this account, when wanting to access our services.
For further information see:
Kiron students are given access to a number of services and functionalities of the platform, for which personal data needs to be collected. Specifically:
- to provide recommendations for online courses
- to transfer and provide access to MOOC-platforms such as edX and udacity
- to provide further information about our products and recent developments at Kiron
- to deliver a possibility for exchange through our forum
- to allow you to find other people, wanting to support you in your experience through our Buddy Programme
Kiron may collect, process and use the content and other information users provide when using the services, including the data submitted for signing up for an account, creating or sharing, and messaging or communicating with others on the website. Such information may include:
- First and last name
- Date of birth
- Phone number (optional)
- Address (optional)
- Level of education
- Study programme
- Status paper
- E-mail address
Recommendation of courses
Kiron aims at providing a overview and specific recommendations for free online courses (Massively Open Online Courses, MOOCs), which fit your interests. Such recommendations may be selected by taking into account data Kiron has collected about you.
Transferal of Data from and to our MOOC-Partners
Kiron will allow you to get access to different free online courses, which are governed by their own separate privacy policies and terms of services: such as
- edX Inc., 141 Portland Street, Camebridge, MA 02139, USA, cf. https://www.edx.org/edx-privacy-policy and https://www.edx.org/edx-terms-service
- udacity Inc., 2465 Latham Street, 3rd Floor Mountain View, CA 94040, USA cf. https://www.udacity.com/legal
- Coursera Inc, 381 E Evelyn Ave, Mountain View, CA, 94041
- https://www.coursera.org/about/terms and https://www.coursera.org/about/privacy
Usually access to these services is granted via your Google-apps login with [email protected] account.
Furthermore, Kiron may receive information about the users and their academic activities on and off the service from third-party partners, such as information from a partner-university on the choice of subject, study record, period of study, results of completion.
Additional Information via mail, e-mail and other means
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 (e.g. see above: transfer of personal data to our MOOC-partners).
Forum based on Discourse (optional)
Kiron also offers access to a forum based on the discourse platform to exchange your experience with other students, with members of the team at Kiron, or with buddies.
Using the forum is optional, but you need to be aware that content you provide within the forum may be accessed by a larger audience.
The forum is not accessible by external search engines, such as google or Bing. The forum is only accessible via login with an email address granted by Kiron.
Kiron will provide specific offers based on the country or city you are currently located in. It allows you to optionally enter a more precise location to support a number of other features. It is up to you to decide the granularity of the location data you intend to provide. You could either provide a country, state, a city, or even a specific part or street in a city.
Buddy Programme (optional)
Via the Kiron Platform you can also register to become a Kiron Buddy. The Buddy Programme aims to socially integrate Kiron students by introducing interested participants to students.
If you want to participate in the buddy Programme, you will have to consent to the following:
For participation in the Buddy Programme as a Buddy, you need to register with your email-address. When registering your email-address you are also asked to provide a password. Password and email-address can then be used to log back into the application service to complete the application. The password is stored only in a hashed format, which allows us to verify that the correct password has been entered, but does not allow us to get access to the password itself.
Kiron may offer you to get in touch with other people in your vicinity.
Both the student and the Buddy have to explicitly register to be part of the Buddy Programme. Kiron will then try to find a suitable Buddy for the student and will then establish contact via email between student and Buddy.
Registered Buddies may provide the following types of information, which Kiron may use to match the Buddy to a suitable student:
– languages spoken, and languages you are interested in learning
– gender and preferred gender of student
– location, according to the level of detail of your choice
– your expectations
– university name
– your hobbies
The selection of Buddy-Student pairs will be based on a matching algorithm developed by Kiron, taking the information above into account, but can also be conducted by individuals working at Kiron.
3. Establishing contact
After Kiron has found a match between a Buddy and a Kiron Student, Kiron will support you in getting in touch. For this purpose the matched student will receive an email with the following information:
– your name
– email address
– phone number (if provided)
– you city (but not your address, even if you were more specific on the location details)
– your gender
– as well as all the other information you had provided for matching (i.e. expectations, hobbies, etc., see above)
4. Additional Information via mail, email and other means
Data analysis for scientific purposes
Kiron may analyze the data collected for scientific purposes in order to conduct academic surveys and research, such as evaluating key performance indicators, social impact and scientifically analyze the services. Such research will be conducted either in accordance with the respective legislation, using anonymized and pseudonomized data, whenever possible, or after you have explicitly consented to be part of such research.
Termination of membership
You may terminate your membership with the Kiron platform at any time. When terminating your membership, all your personal data will be completely anonymized with the exception of the data, for which a statutory permission to retain exists. All other data and references to you will be deleted. Any content you contributed to the forum, however, will remain.
Right to information, Questions, suggestions and comments
You have the right to be informed about your personal data stored in connection with the Kiron platform free of charge.
If you have any such or other queries concerning the processing of your personal data you may send us your query via email to [email protected] or via mail to:
Kiron Open Higher Education gGmbH (haftungsbeschränkt), Am Festungsgraben 1, 10117 Berlin, Germany
We may modify this Policy from time to time and adjust it according to the underlying data processing. When we make changes to this Policy we will inform users on our website, via app and via e-mail.
This is modified second version of this policy (2.1) as of October 13th 2016.