Data protection declaration according to DSGVO
The person responsible in the sense of the data protection basic regulation and other national data protection laws of the member states as well as other data protection-juridical regulations is the:
Grow GH EDU Initiative Ltd.
P.O. BOX WJ842 WEIJA, GREATER ACCRA
Company Reg. No. CG062442019
Tax Identification Number: C0023886854
Adress: B22 Kokrobite-Tuba Road, Kokrobite, Greater Accra
Phone: +233 24 786 84 09
E-mail: info@growghana.org
Website: https://www.growghana.org/
Data Protection Officer: Benjamin Schunke (Grow GH EDU Initiative Ltd.)
General information on data processing
1. Scope of Processing of Personal Data
We process the personal data of our users only to the extent necessary to provide a functioning website as well as our content and services. The processing of personal data of our users regularly takes place only with the consent of the user. An exception applies in those cases in which it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by statutory provisions.
2. Legal Basis for the Processing of Personal Data
Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 Para. 1 lit. a EU Data Protection Basic Regulation (DSGVO) serves as the legal basis.
Art. 6 para. 1 lit. b DSGVO serves as the legal basis for the processing of personal data required for the performance of a contract to which the data subject is a party. This also applies to processing operations that are necessary for the implementation of pre-contractual measures.
Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c DSGVO serves as the legal basis.
Art. 6 para. 1 lit. d DSGVO serves as a legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data.
If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and fundamental freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f DSGVO serves as the legal basis for the processing.
3. Data Deletion and Storage Period
The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage no longer applies. In addition, the data may be stored if the European or national legislator has provided for this in EU ordinances, laws or other regulations to which the person responsible is subject. The data shall also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless it is necessary for further storage of the data for the conclusion or performance of a contract.
Provision of the website and creation of log files
1. Description and Scope of Data Processing
Each time you access our website, our system automatically collects data and information from the computer system of the accessing computer.
The following data will be collected:
(1) Information about the browser type and the version used
(2) The user’s operating system
(3) The User’s Internet Service Provider
(4) The IP address of the user
(5) Date and time of access
(6) Websites from which the User’s system accesses our Website
(7) Websites accessed by the User’s system through our Website
The data is also stored in the log files of our system. These data are not stored together with other personal data of the user.
2. Legal Basis for Data Processing
The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f DSGVO.
3. Purpose of Data Processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the IP address of the user must remain stored for the duration of the session.
The data is stored in log files in order to ensure the functionality of the website. The data is also used to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
These purposes also include our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f DSGVO.
4. Duration of Storage
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data to provide the website, this is the case when the session in question has ended.
If the data is stored in log files, this is the case after seven days at the latest. A storage going beyond this is possible. In this case the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.
5. Possibility of Objection and Removal
The collection of data for the provision of the website and the storage of data in log files is mandatory for the operation of the website. Consequently, there is no possibility for the user to object.
Use of cookies
a) Description and Scope of Data Processing
Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. When a user visits a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.
We use cookies to make our website more user-friendly and to enable an analysis of the surfing behaviour of the users. The following data is stored and transmitted in the cookies:
(1) Entered search terms
(2) Frequency of page views
(3) Use of website functions
(4) Language settings
Until now, it has been possible pursuant to Section 15 (3) of the German Telemedia Act (TMG) to pseudonymise the processed personal data for technically unnecessary cookies and to inform the user about the use of cookies and his right of objection and removal (“opt-out solution”). However, it is controversial in the legal literature whether this standard will continue to apply even after the DSGVO has come into force. In case of doubt, it must therefore be assumed that only the provisions of the DSGVO now apply. In this case, only Art. 6 (1) DSGVO applies. Even after this provision, a continuation of the previous practice is conceivable if it is based on a “legitimate interest” of the processor pursuant to Art. 6 para. 1 lit. f DSGVO. In other words, if the user’s consent is not obtained before the technically unnecessary cookies are set and retrieved:
The user data collected in this way is pseudonymised by technical precautions. It is therefore no longer possible to assign the data to the calling user. The data are not stored together with other personal data of the users.
When calling up our website, users are informed by an information banner about the use of cookies for analysis purposes and referred to this data protection declaration. In this context, there is also an indication as to how the storage of cookies in the browser settings can be prevented.
Whether the previous practice of the “opt-out solution” meets the requirements of Art. 6 para. 1 lit. f DGVO cannot be said with certainty at present. The planned e-privacy regulation could bring clarity in this respect. Until then, however, the legally most secure solution is to obtain the prior consent of the user (“opt-in solution”). In other words, if the user’s consent is obtained before the technically unnecessary cookies are set and retrieved:
When calling up our website, the user is informed about the use of cookies for analysis purposes and his consent to the processing of the personal data used in this context is obtained. In this context, there is also a reference to this data protection declaration.
b) Legal Basis for Data Processing
If only technically necessary cookies are used or if technically necessary cookies and technically not necessary cookies are used without the prior consent of the user:
The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f DSGVO.
If technically necessary and not necessary cookies are used with the prior consent of the user:
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f DSGVO.
The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.
c) Purpose of Data Processing
If technically necessary cookies are used:
The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these it is necessary that the browser is recognized also after a page change.
The analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus constantly optimize our offer.
Our legitimate interest in the processing of personal data in accordance with Art. 6 Para. 1 lit. f DSGVO also lies in these purposes.
e) Duration of Storage, Objection and Removal Options
Cookies are stored on the user’s computer and transmitted to our site by the user. Therefore, you as a user have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it is possible that all functions of the website can no longer be used to their full extent.
If Flash cookies are also used:
The transmission of Flash cookies cannot be prevented via the settings of the browser, but by changing the settings of the Flash Player.
