Privacy notice

​​​​This Privacy Notice explains how your personal data is processed in connection with the use of this website and the provided functionalities (hereinafter collectively referred to as the „Website“).

This Website uses SSL or TLS encryption for security and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries submitted to the data controller). You can recognize an encrypted connection by the string “https://” and the lock symbol in your browser line.

1 General

​1.1 Data Controller and Data Protection Officer 

​​This Website is operated by IU Group N.V., Square Ambiorix 10, BE-1000 Bruxelles („IU Group“). IU Group is the data controller for the processing of your personal data, and other processing operations described below.

IU Group processes your personal data on a subject-related basis in joint controllership with other companies belonging to the Group (all with their registered office at Mülheimer Straße 38, 53604 Bad Honnef, Germany, unless otherwise stated). Activities in connection with the operation of the IU International University are carried out in joint controllership with IU Internationale Hochschule GmbH, Juri-Gagarin-Ring 152, 99084 Erfurt ("IU"), also with regard to its study programs including getting into contact and the provision of information. For central services within the Group, such as controlling, accounting and personnel administration, office, process and quality management, purchasing and sales, as well as other services, the aforementioned companies receive support of IU Corporate Services GmbH, which is jointly responsible for data processing; IU IT Services GmbH, Ridlerstr. 57, c/o IU Group NV, 80339 Munich, with regard to the provision of the operational IT infrastructure including hardware and software, telecommunication and electronic communication; IU Examination Service GmbH for services in the field of examination supervision; IU Marketing Service GmbH as well as IU Sales Services GmbH, Ridlerstr. 57, c/o IU Group NV, 80339 Munich, for services in the area of marketing and sales (this also includes marketing via this website and the operation of the applicant portal for students); IU Commercial 1 GmbH for the management of the online campus and IU Commercial 2 GmbH for the management of the campus locations and with regard to the campus programs; IU Student Services GmbH together with the respective GmbH that exists for the respective location and is named after its city name, e.g. IU Dortmund GmbH or IU Bonn GmbH, for the support of prospective students and students, in particular student advising. 

We can provide you with excerpts from the joint controller agreement. If you would like to receive an excerpt, please contact datenschutz@iu.org. 

IU Group has appointed Dr. Annette Demmel, SPB DPO Services GmbH, An der Buche 4, 13465 Berlin, annette.demmel@spb-dpo-services.com, as the data protection officer for the aforementioned companies. You can contact IU Group either in writing or per email at datenschutz@iu.org.

1.2 Recipients 

Unless otherwise described in the context of a certain processing, only those IU employees, who are responsible for performing a specific task have access to your personal data. In addition, employees who are responsible for operating our IT systems may have access to some of your personal data as part of their job, e.g., administering an application or performing IT security control tasks. Our employees are obligated to maintain the confidentiality of all personal data.  

In the course of our business activities, we rely on the support of various service providers, in particular for the aforementioned purposes as well as for the operation of our IT systems. If the service providers we use have access to personal data, we have entered into the necessary agreements to protect your personal data; in particular, we have concluded data processing agreements in accordance with Art. 28 GDPR, in which we oblige our service providers to maintain confidentiality. Furthermore, banks may receive personal data for the purpose of processing payments, or lawyers, tax advisors and auditors may receive personal data in the course of their work for us. In some cases, we transmit personal data due to legal obligations. In the event of a suspected criminal offense or during investigative proceedings, data may be transmitted to the police and public prosecutor’s office. For further information about who has access to your personal data when using the individual applications, please refer to the description of the respective application. 

1.3 Transfers to Third Countries 

If we transfer data to service providers in so-called third countries, this is described for the respective application. Some of these third countries do not have an adequate level of data protection. An overview of third countries for which an adequate level of data protection has been established by the EU Commission can be found here: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en. Particularly in the case of data transfers to the USA, there is a risk that your personal data will be processed by the authorities there for control and monitoring purposes without you becoming aware of this or having sufficient legal remedies available to you. We routinely safeguard transfers to third countries by using the so-called EU standard contractual clauses. You can obtain a copy of these clauses at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=de. If some providers use binding internal corporate rules for data protection or the transfer is secured because a company is certified according to the Data Privacy Framework (see https://www.dataprivacyframework.gov/s/program-overview), this is explained in the individual applications. If the use of individual applications is optional or alternatives are available, we point this out and - if you do not want to use the alternatives - process your personal data in such cases only on the basis of your separate consent to legitimize the data transfer in accordance with Art. 49 (1) a) GDPR.

1.4 Consent 

If you have given your consent to a processing activity, you may withdraw this consent at any time with effect for the future without providing a reason. For this purpose, please use the methods for contacting IU mentioned above or change the switch settings if you have given your consent via the selected switch settings.  

1.5 Retention 

It is our general policy to delete your data as soon as it is no longer needed for the required purpose and if there are no retention obligations. We usually delete your personal data within a short period of time, e.g. within a few months after the conclusion of any counseling. Unless special circumstances regarding deletion are described for the respective application, we process your personal data in accordance with the various retention periods under university or federal law for up to 15 years or in accordance with retention periods under tax and commercial law for a period of six to ten calendar years after the conclusion of a transaction or after the end of the contract. If you object to any processing under Art. 21 (2) GDPR, we will delete your data within four weeks after your objection, unless otherwise required by law or if we are obligated to block the data. If the processing takes place on the basis of your consent and you withdraw your consent or the processing ends for other reasons, we will process the information necessary to prove that consent had previously been granted, i.e. date, time, details of the granting and subject of the consent, for a period of three years after the processing based on consent ends. 

2 Data collection when visiting the website

​When using our Website for informational purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (so-called „Server Log Files“). When you access our Website, we collect the following data, which is technically necessary in order to display the Website for you:

• Our Website visited

• Date and time of access

• Quantity of data transmitted in byte

• Source/reference from which you reached the page

• Browser used

• Operating system used

• IP address used

The processing takes place in accordance with Art.6(1)(b) of the General Data Protection Regulation (“GDPR”) on the basis of your use of our Website and our interest in improving the stability and functionality of our Website in accordance with Art.6(1)(f) GDPR.

We process your data in order to provide you with a functional website, retain the data for the duration specified by IU for this purpose and delete your data thereafter.

Only employees of IU who are responsible for maintaining the Website receive access to your personal data.

We use third-party services on our Website. Further information about these services and the related data processing is found in this Privacy Policy or the cookie settings.

3 Cookies

​Depending on your browser settings and whether you have given us your consent, cookies may be used when you visit this Website in order to extend the functionality of the Website and make it more convenient for you to use. Cookies are small text files that are stored on your computer. Most of the cookies used by IU are deleted from your hard drive at the end of the browser session („Session Cookies”). In addition, IU uses so-called permanent cookies („Persistent Cookies”), which remain on your device in order to recognize you the next time you visit the Website. If cookies are used, they collect and process to an individual extent certain user information such as browser and location data, IP address values and as described in the Server Log Files. Persistent cookies are automatically deleted after a specified period of time, which may differ depending on the cookie.

An overview of the cookies used and the duration of the respective cookie storage can be found in the cookie settings in our Cookie Consent Tool.

If personal data is also processed through individual cookies used by us, the processing takes place in accordance with Art. 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our Website (so-called „Necessary Cookies”) or in accordance with Art. 6(1)(a) GDPR on the basis of your consent for all other cookies (marketing and analysis cookies).

Please note that you can configure your browser in such a way that you are informed about the use of cookies and can decide individually whether to accept or to refuse to accept them in certain cases or in general. Each browser differs in the way it manages cookie settings. Cookie settings are described in the help menu of each browser, which explains how you can change your cookie settings.

Please note that if you do not accept cookies, the functionality of our Website may be limited.

4 Cookie Consent Tool

​​This website uses a so-called cookie consent tool of Usercentrics GmbH, Rosental 4, 80331 Munich, Germany (the „Cookie Consent Tool“) to obtain consent to the use of cookies and cookie-based applications that require consent.

By integrating a corresponding JavaScript code, users are shown a banner when they access our Website, in which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box.

The Cookie Consent Tool blocks the use of all cookies requiring consent until the respective user grants the corresponding consent by ticking the appropriate box. This ensures that cookies of this type are only placed on the user’s device if consent has been granted.

In order for the Cookie Consent Tool to be able to clearly assign page views to individual users and to individually record, log and store the consent settings chosen by the user for a session duration, certain user information, as described in the Server Log Files and including the IP address, is collected by the Cookie Consent Tool when our Website is accessed, transmitted to servers of the Cookie Consent Tool and stored there. For further details, please refer to the information provided in each case in the Cookie Consent Tool.

The data processing carried out by the Cookie Consent Tool takes place in accordance with Art. 6(1)(f) GDPR on the basis of our legitimate interest in a legally compliant, user-specific and user-friendly consent management for cookies and thus our legitimate interest in our Website being lawfully designed.

We have concluded a data processing agreement with Usercentrics GmbH, which obligates Usercentrics GmbH to protect the data of visitors to our Website and to refrain from disclosing such data to third parties.

We process your data for this purpose for the duration of your session and delete your data thereafter, unless you have given your consent to the use of cookies, in which case we process your data for the duration specified for each cookie.

For further information on the use of data by Usercentrics GmbH, please refer to Usercentrics’ Privacy Policy at https://usercentrics.com/privacy-policy/.

5 Contact (e.g. by email)

If you contact us by e-mail, we process the information necessary to answer your contact requrest, e.g. your e-mail address, the information you provide and the date and time of the contact. If you also provide us with your name and other personal data, we also process these.  

If you conduct an online meeting with us or request consultation with regard to the studies, we additionally process your name displayed, if applicable your profile picture, preferred language, date, time, meeting ID, if applicable your phone number, as well as exchanged texts, audio and video data. To handle our communications, we use Microsoft 365, Microsoft Teams, both services are provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA ("Microsoft") and Zoom Video Communications, Inc., 55 Almaden Boulevard, Suite 600, San Jose, CA 95113, USA („Zoom“). 

The legal basis for this processing is Art. 6 (1)(b) GDPR or Art. 6 (1)(a) GDPR for such information that is not absolutely necessary for the meeting and that you provide to us voluntarily. We process your data in order to respond to your inquiry or conduct a consultation. Your personal data will be retained in each case for the period determined by IU in order to perform the task and will be deleted thereafter. This is based on the retention periods under commercial and tax law. Only employees of IU who are responsible for responding to contact requests will receive access to your personal data. 

We have concluded data processing agreements with Microsoft and Zoom based on the EU Standard Contractual Clauses. You can access the EU Standard Contractual Clauses at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en. For more information on data processing by Microsoft, please visit https://privacy.microsoft.com/de-de/privacystatement and for Zoom https://explore.zoom.us/en/privacy/.

5.1 Free Call-Back Service

If you use our free call-back service, we will process your first and last name, your email address, if applicable, your telephone number, the desired call-back time (date and time) and a message to us in order to call you back about the matter you have specified. The legal basis for this processing is Art. 6(1)(b) GDPR. If we do not reach you by telephone and you have given us your consent to do so in accordance with Art. 6(1)(a) GDPR, we will contact you by email. Your personal data will be retained in each case for the period determined by IU in order to perform the task and then deleted. Only employees of IU who are responsible for handling corresponding inquiries receive access to your data. As part of our telephone customer support, we may occasionally record telephone calls for training and quality control purposes. Should this be the case, you will be informed about this separately and can give your consent in this regard.

5.2 WhatsApp

​​If you decide to communicate with us via WhatsApp as part of your application for admission or during your studies, we will process your personal data, such as your telephone number, your picture, your status information and your name if you provide us with this information. In addition, we process any personal data that you communicate to us via WhatsApp. In this regard, we recommend that you only provide us with the information that is absolutely necessary to answer your request and refrain from providing any additional information. We use a chat bot based on artificial intelligence in our WhatsApp channel. The functionality and data processing of this is described in the following section.Whether you use WhatsApp is up to you, and you can receive the same information by phone, electronically and/or regular mail.

IU processes your personal data in order to communicate with you. The legal basis for this data processing by IU is your use of our WhatsApp channels in accordance with Art. 6(1)(a) GDPR.You can withdraw your consent to the processing of your personal data at any time. The withdrawal can be made via the specified contact options. The declaration of withdrawal does not affect the lawfulness of the processing carried out so far.The data processing by WhatsApp is governed by the Privacy Policy of WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, which can be found at https://www.whatsapp.com/legal/?lg=de&lc=DE&eea=1#privacy-policy. WhatsApp is a telecommunications service offered by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, and a company of Facebook Inc.

Access to your personal data is granted to those IU employees who manage our WhatsApp channels. IU uses a software solution of the provider Messenger People, which does not require an app installation. Even if the use of the software solution largely excludes access to data by WhatsApp, it cannot be ruled out that employees of WhatsApp or Facebook may also receive access to your personal data. Likewise, it cannot be ruled out that your data will be stored on WhatsApp servers in the United States of America. WhatsApp LLC and Meta are certified under the Data Privacy Framework. You can find further information in this regard in WhatsApp’s Privacy Policy, if applicable. Your personal data will be retained in each case for the period determined by IU in order to perform the task and then deleted.

 5.3 Online Chat (Syntea)

IU uses a chat bot that can help with questions on operational topics. Chat bots are programs that simulate an online dialog. During processing, responses are generated that mimic natural human speech patterns when answering text-based queries. This means that you are not chatting with an employee, but with a computer program. To answer your query, we use a knowledge database where the contextual relevance is recognized, and the dialogue is conducted with the help of deep learning technology and natural language processing. We process the answers entered into the chat, e.g. education and professional experience. The chat bot uses AI-supported technology that uses deep learning algorithms and is provided by OpenAI, L.L.C., 3180 18th Street, San Francisco, CA 94110, USA ("OpenAI") and is operated in a protected environment at IU on servers of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA ("Microsoft"). Further information on securing international data transfers can be found in the section "Transfers of personal data to third countries". Information on data processing by Microsoft can be found at: https://privacy.microsoft.com/de-de/privacystatement.

Your entries in the chat will not be transferred to the OpenAI database for general reuse outside the IU. Excerpts of the content of the chat with you are used to train the chatbot. Only anonymized components are used for this, never e.g. your telephone number or your name. Furthermore, your data is used to personalize the service offered and to send you offers tailored to your interests. The legal basis for this processing is your consent in accordance with Art. 6 par. 1 (a) GDPR. Furthermore, with your consent pursuant to Art. 6 par. 1 (a) GDPR, information from the chat will be stored together with your name in Salesforce, Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, England ("Salesforce"), and URLs with parameters for tracking and user guidance on the website will be created. Please also read the section on profiling.

Your personal data and the history of the chat will be stored for the duration specified by IU with regard to the fulfillment of the task and then deleted. The purpose of this is to save you from having to go into the history of your request if you contact us with a query.

To analyze the interaction of the chats, we use the service provider Dashbot, Inc, 548 Market Street, San Francisco, California 94104, USA ("Dashbot"), which is operated on servers of Amazon Web Services, Inc, 410 Terry Avenue North, Seattle, WA 98109-5210, USA ("AWS"). Both Dashbot and AWS are certified according to the Data Privacy Framework. You can find more information here: https://www.dataprivacyframework.gov/s/program-overview.

5.4 Typeform

​​We use typeform provided by TYPEFORM SL, C/Bac de Roda, 163 (Local), 08018 Barcelona, Spain (“Typeform”) for some contact forms. You can tell that we use Typeform because “Typeform” is displayed as a logo at the bottom right of the screen. Typeform allows us to provide you with an easy way to contact us.

For this purpose, we share the following personal data with Typeform:

• Email address*

• First name*

• Last name*

• Telephone number

Mandatory fields are marked with *.

Typeform is a recipient of your personal data and acts as a processor for us, which is why we have concluded a data processing agreement with Typeform. The legal basis for these processing operations is your consent in accordance with Art. 6(1)(a) GDPR. You can withdraw your consent to the processing of your personal data at any time. The withdrawal can be made via the specified contact options. Your data will be processed until your request has been answered. By withdrawing your consent, the legality of the processing that has taken place so far will not be affected.

The data is retained exclusively for the purpose of transmitting and responding to requests. The mandatory data is used for assigning and responding to your requests. You can also choose not to provide us with your personal data using such a contact form. Alternatively, you can contact us at the email address provided in this Notice.

In addition to the data mentioned above, Typeform collects the following personal data with the help of cookies: Information about your device (IP address, device information, operating system, browser settings). Furthermore, usage data is collected, such as the date and time when you used the contact form. Further information can be found at: https://help.typeform.com/hc/en-us/articles/360029581691-What-happens-to-my-data.

For further information regarding objection and deletion options in relation to Typeform, please refer to: https://admin.typeform.com/to/dwk6gt.

6 Online Information Events

​​​If you register to participate in an online information event via our Website, then we process your first and last name and your email address in addition to the data mentioned under Server Log Files. We process your data on the basis of Art. 6(1)(b) GDPR in order to send you an invitation to our online information event. Your personal data will be retained in each case for the period determined by IU in order to perform the task and then deleted. You will receive information on the processing of your data by the provider of the video conferencing tool when you receive the invitation.

We will store information about your completed registration in your browser and, by using a cookie, information in the fields you populated subject to your consent, so that you can use the pre-filled fields when you register again and you will be shown for which event you are already registered. We process your data on basis of Art. 6 (1) (a) GDPR. You can withdraw your consent for the local storage in the browser and the processing of your data for the purpose of pre-filling the fields separately at any time with future effect. You can declare your withdrawal by using the cookie consent tool and declare it by emailing datenschutz@iu.org.

7 Newsletter

​​​​​With your consent, you can subscribe to our newsletter, which we use to inform you about 1) our degree programs, discount campaigns on tuition fees and study-related information events 2) entrepreneurship 3) alumni, discount campaigns for alumni and other activities for our graduates 4) events and publication information from members of the research network. We will personalize such information, based on your interests as well as your previous use of our website and our offers, provided that you have given us separate consent to do so via the cookie selection. You can withdraw your consent to receive the newsletter at any time. You can withdraw your consent by clicking on the link located at the end of the newsletter or by sending an email to loeschung@iu.org.

If you register to receive our newsletter, we use the so-called double opt-in procedure: after receiving your registration, we send an email to the specified email address. In this email we ask you to confirm that you wish to receive the newsletter. If you confirm your registration to our newsletter, we store your email address, IP address and the time of registration and confirmation. The purpose of this processing is to be able to prove your registration and, if necessary, to clarify any possible misuse of your personal data. The legal basis for this processing is your consent in accordance with Art. 6(1)(a) GDPR. In order to send you our newsletters, we use the services of external service providers, some of which are located outside the EU. In such situations, we conclude data processing agreements that incorporate EU Standard Contractual Clauses. You can access the EU Standard Contractual Clauses at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en. We store your consent for three years after the end of the year in which you withdraw your consent.  

8 Request for free info brochure and finance check

​​​​If you request information material to be sent to you electronically, we will process your title, first and last name, email address, telephone number (if applicable) and details of the subject of the requested information in order to provide you with the information material. The legal basis for this processing is Art. 6(1)(b) GDPR. If we do not reach you by email and you have provided us with your consent in accordance with Art. 6(1)(a) GDPR, we will contact you by telephone. Access to your data will be granted to those employees who are responsible for managing and processing such requests as part of their job.

To collect your personal data described above, we use Google Lead Form Ads, an application provided by Google Ireland Ltd. ("Google"), with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland. The information you enter in the form to request information material may be transferred to a Google server in the US. The data entered in the form is encrypted and stored by Google for up to 60 days. Only the IU has access to this data. To secure this data transfer, the IU has entered into a data processing agreement with Google, which includes EU Standard Contractual Clauses. You can access the EU Standard Contractual Clauses at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en.


We provide a financing check on our website which you may use to obtain information tailored to your personal situation on financing options for your studies. With your consent, we will save your entries and send you a code by email, which you can use to access your data again later. Legal basis for data processing is your consent in accordance with Art. 6 par. 1 a) GDPR, which you can revoke at any time with effect for the future by contacting datenschutz@iu.org.

IU employees who are responsible for supporting prospective students will have access to your personal data. We store your data, which we have received in connection with your financial check, in the software of our service provider Salesforce, Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, England. In exceptional cases, Salesforce employees, possibly also from the U.S., may have access to your personal data. IU has entered into a data processing agreement with Salesforce. Salesforce Inc. is certified in accordance with the Data Privacy Framework.

9 Enrollment for studies

9.1 Enrollment via Website
If you register for a course of study via the website, we process your name, date of birth, nationality, address, contact information (including, for example, your phone number), details of your previous education in the form of certificates, letters of recommendation, and a resume, your desired field of study, and payment details such as account information, as well as data for the preparation and execution of the education contract concluded with you.

Please note that when uploading a copy of your official ID document, you must redact all fields except your last name, first name, date of birth and nationality as well as the photo and the validity of your ID.

We require additional information to check whether you are eligible to study and whether there are any obstacles to enrolment, e.g. parallel enrolment at another university in the same degree program. Any further information you provide, e.g. in a CV, which is not mandatory for checking your university entrance qualification, is voluntary. However, if you, for example, wish to have ECTS points transferred and credited it is advantageous to provide information on previous stages in your education. We will process the additional information in your CV in order to draw your attention to the possibility of crediting previous educational achievements as part of your studies and to advise you on your choice of studies. If you have obtained your university entrance qualification through a high school diploma (German Abitur), we do not necessarily need information on your professional experience. If you have completed vocational training or a course of study in a subject that has no connection or overlap with the desired course of study, we do not require any information in this respect either. However, please bear in mind that our academic advisors have specialized knowledge regarding possible credits that you may not consider but could nevertheless be beneficial to you.

We process the data required for the examination of the university entrance qualification on the basis of Art. 6  (1)(c) GDPR in conjunction with sec. 70 par. 1 Thuringian Higher Education Act and the General Admission and Enrolment Regulations of the IU (AZE). We process information that is also required for the conclusion of the study contract, e.g. your bank account details, in order to prepare the conclusion and execution of the study contract in accordance with Art. 6 (1)(b) GDPR. We process any further voluntary information you provide for the purpose of receiving advice on the basis of your consent in accordance with Art. 6 (1)(a) GDPR. You can withdraw your consent to the processing of voluntary information at any time with future effect. Please use the IU contact channels mentioned at the beginning. 

If you decide to cache your online application and complete it at a later date, we will send you a link to the storage location to your email address where we will retain the incomplete application for you for 30 days to access for completion. If you wish to receive a study contract by postal mail, we will use your data to summarize the information you have provided so far in a draft and send it to you by postal mail.

If you fill out the online application for recognition/credit for previous achievements via the Website, we collect your contact data, including name and postal address, email address, your telephone number, desired course of study, information on your previous education and your previous professional career, information on other qualifications, evaluations, training and work references.

The legal basis in this regard is Art. 6(1)(b) GDPR. You will receive detailed information on the processing of your personal data during the registration and recognition process. Access to your personal data is granted to those employees who are responsible for supporting applicants in the Enrollment Office or the Admissions Office of IU.

We process the phone number you provide for conducting multi-factor authentication as part of your logins to our systems. This is to ensure adequate security measures are in place according to the current state of technology, aimed at preventing unauthorized access to our systems, your user accounts with us, and ultimately your data. As part of multi-factor authentication, you may receive a code via SMS to your phone number when logging into our system, which you can then enter in the login area to verify that it is a legitimate access request. The processing is carried out pursuant to Art. 6(1)(f) GDPR to safeguard our legitimate interest in the secure operation of our systems. We utilize the services of external IT providers to maintain the multi-factor authentication system. Where these providers have access to personal data, we have made the necessary agreements to protect your personal data. If data is transferred to so-called third countries, we have concluded the EU Standard Contractual Clauses (you can retrieve a copy at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en) or the EU-US Data Privacy Framework applies (https://www.dataprivacyframework.gov/s/program-overview).

Personal data that you provide in the course of enrolling for a course of study will be retained for the duration of your studies and in accordance with statutory retention periods (for a period of six to ten years under the German Fiscal Code and the German Commercial Code). Data collected in the context of an application for possible recognition/credit of prior achievements will be stored for twelve months from the date of submission of the application. If matriculation does not take place during this period, the application together with all documents will be deleted.

For further information, please refer to the privacy notice for students, which you will receive with the documents to enroll in a degree program.

9.2 Reminders

We process your phone number to inform you about circumstances that may lead to an early termination of the contract. We do this, among other things, to fulfill our transparency obligations and to avoid unnecessary disadvantages for you. The legal basis for the processing is Art. 6(1)(c) GDPR. For this purpose, we send messages via WhatsApp and use the services of the processor Twilio Inc, 101 Spear St FL 5, San Francisco, CA 94105, USA. Twilio Inc. is certified under the Data Privacy Framework. For more information on data processing by Twilio Inc., please visit https://www.twilio.com/en-us/legal/privacy.


10 Data processing in the course of our Firstbird employee referral program

​​If you register with our firstbird employee referral program, we process the following personal data: To create your user profile, we process your name, e-mail address, a password of your choice, employee ID, time zone as well as location and field of activity. You also have the option of uploading a photo of yourself to your profile, which is visible to other firstbird users when you make a recommendation. Should you select in the notification settings that you wish to receive notifications on certain topics at different intervals, we will process your data to generate and deliver the notification in accordance with your selection. If you recommend a job, we process information about the recommended position, the date and time of the recommendation, and information about the selected medium through which the link to the recommended position is shared. If someone applies for an advertised position based on your recommendation, we process the information that you made the corresponding recommendation. In the case of a successful application, we additionally process information about the bonuses that are credited to you, as well as information about the redemption of the bonuses. The legal basis for this processing is a user relationship concluded with you for this purpose regarding participation in firstbird in accordance with Art. 6 (1) (b) GDPR. Your personal data will be processed by us during the activity of your account and deleted thereafter, unless rewards have been credited to you. In this case, we process information about this in firstbird for three years from the end of the year of the last credit. Information about billing of rewards is stored for 10 years in accordance with tax regulations.

Employees of the IU who are entrusted with the management of the firstbird employee referral program have access to your personal data. IU uses various IT service providers, including firstbird GmbH, Gertrude-Fröhlich-Sandner-Str. 2-4, Spaces, Tower 9, 1100 Vienna, Austria, and has concluded a data processing agreement with the service provider in accordance with Art. 28 GDPR.

11 Processing of data in the case of further training purchases

If you purchase a training course via our webshop, in addition to the data mentioned in the server log files, we will process your title, name, address, e-mail address, telephone number (if provided), date of birth, location of birth, nationality and further documents that you have uploaded (CV), the training course you have booked, the purchase price and the payment method of your purchase, as well as the time stamp of the purchase, and information in relation to the use of an education voucher, in case the training course is supported by the Federal Labor Agency or the Jobcenter.  

If you use the option offered on the website to save your data for the purpose of completing your application at a later date, you will receive an e-mail link from us to complete your data and upload additional documents. We use a hash key in the URL to pre-fill the application form with data already entered by you as part of your expression of interest (title, first name, last name, telephone number, e-mail address). We store the data entered for later completion of the application for 30 days. 

IU employees who are entrusted with the supervision of the advanced training course will have access to your personal data. IU uses various IT service providers, such as our Salesforce software solution from the provider Salesforce, headquarters: Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, England (“Salesforce”). Your data, which we received in connection with your license purchase, will be saved on our Salesforce platform. In exceptional cases, Salesforce employees may have access to your personal data.. IU has concluded an order processing contract with its CRM service provider, which includes EU standard contractual clauses. A copy of the EU standard contractual clauses is available upon request.Salesforce is certified under the Data Privacy Framework.

IU stores the named personal data for the duration of your advanced training course, in accordance with statutory retention periods according to § 147 Tax Code and § 257 Commercial Code, for a period of six to ten years.

Your payment data will be transmitted by IU to the payment service provider you have selected for processing the payment.

If you decide to pay via Stripe, the payment will be processed by Stripe Payments Europe Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland. IU will transmit to Stripe the information communicated during the ordering process as well as your name, address, account number, bank code, credit card number, invoice amount, currency and transaction number (if applicable).

The data processing takes place on the basis of Art. 6 Para. 1 lit. b) GDPR. The data is transmitted solely for the purpose of processing payments; the data will be deleted after it has been delivered, unless our service providers are obliged to store the data for legal reasons themselves. Stripe processes your personal data in accordance with the contract you have concluded with Stripe. You can find more information on Stripe’s data protection policy at: https://stripe.com/de/privacy#translation.

If you decide to pay via PayPal, the payment will be processed via PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg. IU will transmit your name, address, email address, telephone and mobile number, and IP address to PayPal. The data processing takes place on the basis of Art. 6 Para. 1 lit. b) GDPR. The legal basis for the data processing is Art. 6 Para. 1 b) GDPR, since the processing of the data is necessary for the payment with PayPal and therefore is required for the fulfilment of the contract. The data is transmitted solely for the purpose of processing payments; the data will be deleted after it has been delivered, unless our service providers are obliged to store the data for legal reasons themselves.
 PayPal processes your personal data in accordance with the contract you have concluded with PayPal. PayPal may also pass on your data to third parties if this is necessary in order to fulfil contractual obligations, or if the data is required to be processed on their behalf by a service provider. You can find PayPal's privacy policy at: https://www.paypal.com/de/webapps/mpp/ua/privacy-full/.

12 Use of payment-provider

​​We process your payment information for the purpose of payment processing, e.g. when you purchase or use a service and/or a license.

Your payment data will be transmitted by IU to the payment service provider you have selected for processing the payment. You can find more Information below.

12.1 SEPA direct debit

​If you wish to make payments by SEPA direct debit, we will process the data categories requested on the direct debit collection form (surname, first name, address, name and registered office of your credit institution, IBAN, etc.) for the purpose of collecting the debt. Legal basis for processing is your consent in accordance with Art. 6 (1) a) GDPR. Once the SEPA mandate has been issued, we will forward the data you have provided to our house bank for the debiting of the selected direct debit receivables. Access to your personal data in connection with the direct debit procedure is granted to employees who are entrusted with payment processing. We also use the services of external IT service companies. We process your personal data within the EU, unless your account-holding entity is located outside the EU. Your data used in connection with the direct debit procedure will be stored for up to 10 years in order to fulfill legal retention obligations in accordance with the German Fiscal Code. If you revoke your consent to the use of the data prior to debiting, we will delete the data after receiving your consent.

​13 Use of our blog

​​Different topics relating to IU are published on our blog. If you participate in a discussion or publish a contribution yourself, we process the data described in the Server Log Files as well as your name and photograph in order to introduce you. The legal basis for this processing is your consent in accordance with Art. 6(1)(a) GDPR. You can withdraw your consent at any time with effect for the future. We will then delete your blog post within two weeks of receiving your withdrawal. Please bear in mind that posts and your photograph may be stored locally on blog readers’ devices and we have no way of deleting any locally stored data. We recommend that you use a pseudonym instead of your real name. Please keep in mind that your posts are visible to everyone worldwide. We reserve the right to delete contributions if third parties object that they are illegal. Our employees who maintain the Website will receive access to your personal data. 

 14 Bring a friend

​Through our site, you may recruit friends to study at IU, and receive rewards for doing so. For this purpose, we process your name and email address, as well as the data entered by your friend. You can create a personalized link through our website and send it to your friend. This e-mail contains an affiliate link which contains a pseudonymized referral code in the URL. If your friend clicks on the link, he or she will be taken to a website form for sending information material. The form is used to query whether your friend was recruited by you. The processing is carried out in accordance with Art. 6 par. 1 f) GDPR to pursue our legitimate interest in attracting new customers. The purpose of the processing is to reward customer acquisition. Access to your personal data is granted to employees of IU who are responsible for the customer acquisition program. We process your personal data for the period of time determined by the IU with regard to the performance of the task. We base this on the retention obligations under commercial and tax law. 



15 Web Analysis Services

​​Our website uses analysis services in order to collect information about our website, provided you have consented to the setting of the corresponding cookies. The data obtained with the help of these analysis services, such as the location of the visitors or their length of stay on our website, gives us information about visitor behaviour on our website. With the help of this data, we can not only eliminate website issues, but also improve the efficiency of our website. Further information on the analysis services used on our website can be found below. For information on the processing of personal data by the cookies set for this purpose, such as the storage duration of the cookies, please refer to our cookie settings.

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15.1 Google Analytics and Google Signals

We use Google Analytics to get an overview of the behaviour of website visitors, and gain insights regarding our digital marketing efforts. Google Analytics allows us to collect and evaluate the data specifically relevant to IU, for example how far down a webpage was scrolled, which button was clicked, etc. Google Analytics also helps us, for example, understand user demographic characteristics such as age, gender and interests, geographic characteristics such as language and location, as well as technical characteristics such as device type, browser and operating system, search history, YouTube history as well as data from Google partner sites.

With the help of this data we can not only optimise our website, but can also recognise how the respective user sessions ended (e.g. simple website visit, request for information material, application for studies). Google Analytics also helps us recognise which webpage a user is accessing and via which channel the users come to our website from (e.g. via a paid or unpaid ad, a Google search, a Facebook post or direct access to the website). With the help of this information, IU can identify which marketing channels are working and which are not. Google Analytics also allows us to recognise user paths, i.e. where users are moving on our website, whether they are going back to the start page and how many users access our website. With the help of this information, we can, for example, recognise whether the jumping off of a large number of users is due to a technical defect in the website. The above data gives us a good overview of our website and how it is used. Even if we collect user data, we cannot draw any conclusions about your identity from this data, as we receive reports from Google Analytics that are based on aggregated data sets.

This also applies to data collected through our contact forms (for instance, when requesting informational material, subscribing to the newsletter, registering for online informational events, participating in info sessions, and using application forms), which are used by Google Analytics in hashed form to model website usage. The processed data, such as email addresses, telephone numbers, names, and address data, are hashed using SHA256 prior to transmission. The matching of these hash values with Google accounts is conducted exclusively by Google.

Since we have also activated the Google Signals service offered by Google, i.e. so-called cross-device tracking, your aforementioned data is analyzed across devices and processed for personalizing ads. Google can thus recognize whether you visit our website first via a smartphone and later via a laptop. We ourselves only receive reports with anonymous data from which we can recognize patterns in user behavior. Google Signals is active if you have a Google account and are logged into it when you visit our website. Furthermore, you must have agreed to "personalized advertising" with Google. If you do not want cross-device tracking, you must deactivate "personalized advertising" in your Google account. Google Signals allows us to launch cross-device remarketing campaigns. This means that we also show you our advertising on third-party websites. You may access your data or delete them at Google in “My Activity”. Google LLC is certified under the Data Privacy Framework.

Additional information on Google Analytics plus the Google data privacy policy is available here. The contact information for GDPR claims (e. g. right to erasure) against the Google Ireland Limited is also available there.

Information on the provider, the cookies set, the legal basis for cookie collection, international data transfers and storage times of the cookies can be found in our cookie settings.

15.2 Mouseflow

​​We use Mouseflow to analyse user behaviour on our website, provided you have consented to the setting of the corresponding cookies. Mouseflow observes website users, records session videos and uses these videos to show how users behave on the website (e.g. how far down they scroll). Mouseflow does not collect any clear data for this purpose (e.g. if you enter data in a contact form, Mouseflow does not collect this data because the fields on the contact form are hidden from it). Using Mouseflow, we can also create what is known as heat maps for website use. This is summarised data on all visitors that helps us evaluate scroll, click and mouse behaviour. Mouseflow also shows us exactly at which point in a form users have stopped filling out the form. This user data analysis gives us insights into the use of our website without being able to draw any conclusions about your identity, as we receive reports from Mouseflow based on aggregated data sets. Mouseflow is certified under the Data Privacy Framework.

Information on the provider, the cookies set, the legal basis for cookie collection, international data transfers and storage times of the cookies can be found in our cookie settings.

15.3 Contentsquare

​We use ContentsSquare to analyze usage behavior on our website, provided you have consented to the setting of corresponding cookies. Contentsquare collects interaction data of your visit to our website (such as duration of visit, clicks or scrolling). By means of this data, which we process in pseudonymous form, we gain insight into the way our website is used and can base measures for optimizing user-friendliness or develop marketing measures on this.​ Contentsquare is certified under the Data Privacy Framework.

Information on the provider, the cookies set, the legal basis, international data transfers and storage times of the cookies can be found in our cookie settings.

15.4 Amplitude

To improve the quality and performance of our services, we use Amplitude, an analytics service provided by Amplitude Inc. ("Amplitude"), located at 201 3rd Street, Suite 200, San Francisco, CA 94103, USA. Amplitude uses cookies and similar technologies to collect and analyze data about the use of our website. This data may include information about the device used to access the website, such as IP address, browser type, operating system, as well as interactions with the website. This information is anonymized and aggregated to identify trends and improve user experience. By giving your consent, you agree that we may send data about your interactions to Amplitude for analytical purposes. For more information on how Amplitude collects and uses data, as well as your rights regarding your data, please refer to Amplitude's privacy policy at https://amplitude.com/privacy. The legal basis for this data processing is your consent in accordance with Art. 6 para. 1 lit. a) GDPR. Where Amplitude is used within the scope of technically necessary cookies, only anonymized and/or aggregated data is processed. Further information about Amplitude, the cookies used, the legal basis, international data transfers, and cookie storage times can be found here.

IU has also concluded a data processing agreement with Amplitude Inc., which incorporates the EU Standard Contractual Clauses. You can request the main content of the agreement from us at datenschutz@iu.org. Amplitude is also certified under the Data Privacy Framework, for which you can find more information here: https://www.dataprivacyframework.gov/s/program-overview.   

16 Google Tag Manager

​​This website uses Google Tag Manager („GTM”), a service provided by Google Ireland Ltd. („Google”), with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland. Through the use of GTM, tags such as code snippets or pixels are used on our own Website by means of a so-called container, which inserts a kind of placeholder into the source code and in which the tools that are to be used are stored without IU having to interfere with the source code of our Website. Using GTM, tools can be used on our own Website without having to include each of them in the source code. Instead, only the code of GTM has to be included, and then GTM can be used as a central place to launch or disable the desired tools.

GTM works on the Website when a defined user behavior triggers a tag (i.e. a pixel tag, web beacon, or html code) for the tool. GTM collects the relevant data for the built-in tool and forwards it to the tool. Information about the tools used on our Website that are loaded via GTM can be found here. In this context, not only are the data categories described for the respective tools transferred to the respective tool providers; Google Ireland Ltd. also receives information about your usage behavior on our Website. Since a large number of the tool providers are located in countries outside the EU, please refer to the description of the respective tools if you would like to receive information on the transfer mechanisms agreed with IU. IU has also entered into a data processing agreement with Google Ireland Ltd., which incorporates the EU standard contractual clauses. The main content of this agreement is available for review here: https://policies.google.com/privacy/frameworks?hl=en.Google LLC is certified under the Data Privacy Framework.

IU uses GTM to deploy not only statistical tools but also marketing tools. Accordingly, GTM is a statistics and marketing tool, and the use of GTM is based on your consent in accordance with Art. 6(1)(a) GDPR, which you may withdraw at any time with effect for the future by sending an email to datenschutz@iu.org.

17 Social Media
For the purpose of increasing our reach, we maintain social media online presences on Facebook, Instagram, LinkedIn and YouTube. If you click on a link embedded in our website, you will be redirected to the respective page: Facebook: https://www.facebook.com, Instagram: https://www.instagram.com, LinkedIn: https://de.linkedin.com, YouTube: www.youtube.com. Plugins of these social networks are integrated on our website. When you visit our website, a direct connection between your browser and the server of the social network is established via the plugins. The social network thereby receives the information that you have visited this website with your IP address. If you are logged into your account with the social network, the social network can assign the visit to this website to your user account. Details on data collection (purpose, scope, further processing, use) as well as your rights and setting options can be found in the privacy policy of the social network. The deletion of your personal data by the social network takes place as described in the respective privacy policy. If there is joint responsibility with Instagram or Facebook, the contract on joint responsibility applies. You can find the contract at https://de-de.facebook.com/legal/terms/page_controller_addendum. For more information on the respective responsibilities, please refer to the Facebook Page Insights Supplement (https://de-de.facebook.com/legal/terms/page_controller_addendum). The legal basis for the processing of the data is Art. 6 para. 1 f) GDPR. Our legitimate interest in this respect is to increase the reach of our online presence on the social media channels. The purpose of the processing is to increase our presence on the Internet. Access to the data is granted to employees of IU who are active in the support of the social media channels and, if applicable, to employees of the respective provider. Your personal data is transferred to the companies listed below in the USA or can be accessed from there. For more information on safeguarding the international transfer of data, please refer to the section "Transfers of personal data to third countries". Information on data processing can be found at: LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) - Privacy Policy https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) - Privacy Policy/Opt-Out: http://instagram.com/about/legal/privacy. Facebook (Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland) - Privacy Policy (Opt-Out: https://www.facebook.com/about/privacy/legal_bases). Meta is certified under the Data Privacy Framework. YouTube (Google Ireland Limited Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.). Google LLC is certified under the Data Privacy Framework.We process your personal data for the duration determined by the IU with regard to the performance of the task. In this regard, we take the retention obligations under commercial and tax law as a basis. Clicking on a link, such as to Facebook, Instagram, Twitter, YouTube, TikTok or LinkedIn, will take you to the respective websites of the different providers. Data processing on the respective website is governed by the data protection information applicable there. The IU has no influence on the data processing carried out there.

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18 Cloudinary

​​On our Website we use a so-called Content Delivery Network („CDN“) of Cloudinary Ltd., 3400 Central Expressway, Suite 110, Santa Clara, CA 95051, USA („Cloudinary“). A CDN is an online service that is used in particular to load large media files (such as graphics, page content or scripts) through a network of regionally distributed servers connected via the Internet and display them on our Website. The use of the CDN helps us to optimize the loading speeds of our Website.

The processing takes place in accordance with Art. 6(1)(f) GDPR on the basis of our legitimate interest in a secure and efficiently functioning website as well as the improvement of the stability and functionality of our Website

We have concluded a data processing agreement with Cloudinary (Data Processing Addendum, available at https://cloudinary.com/gdpr/dpa, which incorporates the EU standard contractual clauses.

Further information can be found in Cloudinary’s privacy notice at https://cloudinary.com/privacy. Cloudinary is certified under the Data Privacy Framework.

19 Sentry, DataDog

In our offers we use the service Sentry. Sentry is operated by Functional Software, Inc, 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA. We use Sentry to improve the technical stability of our offerings by monitoring system stability and identifying code errors. For more information about the processing of your personal data by Sentry, please visit: https://sentry.io/privacy/. The processing is carried out in accordance with Art. 6 para. 1 f) GDPR to protect our legitimate interest in the secure operation of our offers. Access to your data is granted to administrative employees of IU, as well as employees of Sentry, who are responsible for the operation of the application and may gain access to personal data. We process your personal data for the duration of the error analysis and delete it afterwards.  Sentry is certified under the Data Privacy Framework.

In our offerings, we use the service DataDog. DataDog is operated by Datadog, Inc., 620 8th Ave Fl 45, New York, NY 10018, USA. We utilize DataDog to enhance the technical stability of our offerings by monitoring system stability and identifying code errors. Further information on the processing of your personal data by DataDog can be found at: https://www.datadoghq.com/legal/privacy/. The processing is carried out in accordance with Art. 6 para. 1 f) GDPR to safeguard our legitimate interest in the secure operation of our offerings. Administrative staff of IU and employees of DataDog, who are responsible for the operation of the application, may have access to your data and might gain access to personal data. DataDog is certified under the Data Privacy Framework. We process your personal data for the duration of the error analysis and delete it thereafter.


20 Survey questions on the website

​​When visiting our Website, we may ask you via a window that opens whether you already knew us before visiting our Website. For this purpose, we collect the data specified in the Server Log Files. If you answer the question, we also process your answer. This information is evaluated in aggregated form on the basis of our legitimate interest in being able to track the effectiveness of our marketing measures in accordance with Art. 6(1)(f) GDPR.

We retain information in this context for the duration specified by IU in order to perform the task and delete the data thereafter.

 21Rights of data subject

​You can contact IU in writing or per email at datenschutz@iu.org in order to exercise the following rights:

• Access your data in order to check and verify this data;

• Obtain a copy of your personal data;

• Rectification, erasure or restriction of processing, which also includes the right to complete incomplete or incorrect data by providing a supplementary statement;

• Right to object to the processing; please note that pursuant to Art. 21 GDPR you have the right to object to the processing of personal data processed by us on the basis of legitimate interests pursuant to Art. 6 (1) (f) DSGVO; you have a right to object to processing insofar as this is done on grounds relating to your particular situation; insofar as the objection is directed against the processing of personal data for the purpose of direct marketing, you have a general right to object without the requirement to specify a particular situation,

• You can receive your provided personal data in a structured, commonly used and machine-readable format and transmit this data to another controller, provided that you have given your consent to the processing or the processing is based on a contract;

• If you have given us your consent to process your personal data, you can withdraw this consent at any time with effect for the future.

You also have the right to lodge a complaint with a supervisory authority with regard to the processing of your personal data. To exercise this right, you can contact the authority responsible for your place of residence or for the location of the IU in Thuringia:

Der Thüringer Landesbeauftragte für den Datenschutz, Häßlerstraße 8, 99096 Erfurt.



22 Automated decision-making and profiling

​Except for the services described in the context of Google Analytics and Google Signals, your personal data will not be used by IU for automated decision-making.

​When visiting our Website, we place cookies from various providers, provided you have given your consent in this regard. By means of the cookies that you have allowed in each case, data is generated as described in the Server Log Files. This data is consolidated and combined by IU with the help of a Google solution. For this purpose, IU has concluded a data processing agreement with Google, with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland, which incorporates the EU standard contractual clauses. If we receive information about you through our Website, for example, because you ask us to send you informational materials or contact us, then we store your data and combine it with the data generated by cookies. In addition, we receive reports from Google Analytics with data that we also combine with your data. For further information, please refer to the section on Google Analytics.

With the help of your consent regarding the data generated via our website, we store it in a CRM solution. We analyze the data to determine whether you are only interested in a course of study offered by us or whether you have also applied, and we add the relevant information to your data record. We store this profile created about you in a salesforce solution provided by Salesforce, with its registered office at Floor 26 Salesforce Tower, 110 Bishopsgate EC2N 4AY London, England.

The legal basis for this data processing is your consent in accordance with Art. 6(1)(a) GDPR, which you can withdraw at any time with effect for the future by contacting datenschutz@iu.org.

23 Why do we collect your personal data?

​​You may choose not to provide us with your personal data or choose to provide incomplete data. In such a case, for example, if you prevent the storage of a cookie, you may not be able to use all the functionalities of the Website.

23.1 In the course of a study application procedure or an application for a job

​​If you do not provide us with your personal data or only provide us with incomplete personal data in the context of an admission procedure or a job application, we may not be able to accept you as a student or offer you the opportunity to participate in a job application procedure.

23.2 In the course of the purchasing process

​​If you do not provide us with your personal data or only provide us with incomplete personal data in the context of an purchasing process, we may not be able to purchase you a licence or a training.