Effective date: 20 July 2026

Applies to: Negentrix Holding GmbH and its affiliated educational companies.


1. Our Data Protection Principles

We take data protection seriously. The Negentrix Education Group adheres to six key privacy promises:
1. We will always answer your questions about how we process your personal data.
2. We will always process your data lawfully, fairly, and transparently.
3. We will always explain what information we collect, how we use it, and with whom we share it.
4. We will always provide easy ways to opt out of marketing communications.
5. We will always protect your data, both online and offline.
6. We will always take appropriate technical and organizational measures to prevent unauthorized access.


2. Scope of this Privacy Policy

This Privacy Policy applies to all processing of personal data carried out by Negentrix Holding GmbH,
including its educational subsidiaries and affiliated entities (collectively the Negentrix Education Group):

- Negentrix Holding GmbH (Head office)
- ICH – IT Career Hub GmbH
- DWW – Digitale Westfälische Wirtschaftsakademie GmbH
- BIT – Beam Institute of Technology GmbH
- MBIA – Medizinische Berufsintegrations-Akademie GmbH
- AABI – ABI - Arts, Business and Innovation - Academy GmbH

established by Negentrix Holding GmbH or its affiliates, provided that these entities operate in the field of education, training, or career development.


3. Data Controller and Contact Details

The companies of the Negentrix Education Group act as joint controllers according to Art. 26 GDPR. Negentrix Holding GmbH sets the group-wide data protection standards and exercises central control, while the respective subsidiary (e.g., ICH, DWW, BIT, MBIA, AABI) is responsible for implementing these standards, operating the educational services, and directly processing your data. The central point of contact for data protection matters and the exercise of your data subject rights is:

Negentrix Holding GmbH, Genthiner Straße 40, 10785 Berlin, Germany
Email: privacy@negentrix.com | Phone: +49 (0)30 9158 8492
Data Protection Officer: Denis Tylibtsev – dpo@negentrix.com


4. When Do We Collect and Process Your Data?

We collect personal data directly from you when you register for courses, visit our websites, contact us, or participate in surveys.
We may also receive information from publicly available sources, educational partners, or marketing service providers in compliance with GDPR.


5. Purposes and Legal Basis of Processing

We process personal data for the following purposes:
- Provision of educational services (Art. 6(1)(b) GDPR)
- Customer communication (Art. 6(1)(f) GDPR)
- Marketing communication (Art. 6(1)(a) GDPR)
- Analytics and performance (Art. 6(1)(a) or (f) GDPR)
- Compliance and legal obligations (Art. 6(1)(c) GDPR)


5.1 Legitimate Interests

Where processing is based on our legitimate interests under Art. 6(1)(f) GDPR, these interests include:
- ensuring the security and integrity of our IT systems and educational platforms;
- maintaining relationships with existing students and clients;
- improving our services, content, and user experience;
- communicating with existing students about similar educational offerings.
We always balance these interests against your rights and freedoms and process data only where our interests do not override your fundamental rights.


6. Data Sharing Within the Negentrix Education Group

We may share your personal data among Negentrix Holding GmbH, ICH, DWW, BIT, MBIA, AABI. Regardless of the internal allocation of responsibilities, you may exercise your rights under the GDPR against any of these entities.
Shared data includes contact details, enrollment information, and consent preferences.
All entities are bound by joint controller agreements (Art. 26 GDPR) and identical data protection standards.


6.1 Third-Party Processors and Recipients

In addition to internal data sharing within the Negentrix Education Group, we may use external service providers (“processors”) who process personal data on our behalf in accordance with Art. 28 GDPR.
These include, for example:
- IT infrastructure and web hosting providers;
- CRM and marketing automation systems;
- Payment and invoicing processors;
- Analytics and communication service providers.
All processors are contractually bound to confidentiality and data protection obligations equivalent to those of Negentrix Holding GmbH.
Personal data is never sold or transferred to third parties for independent commercial use.


6.2 Data from Publicly Available Sources

We may collect limited professional contact information from publicly available sources (e.g., company websites, LinkedIn, educational directories)
for the purpose of offering educational cooperation or business communication.
Such processing is based on our legitimate interest under Art. 6(1)(f) GDPR in establishing and maintaining business relationships.


7. Marketing Communication and Consent

By giving your consent, you agree to receive information and offers from Negentrix Holding GmbH and its educational projects (ICH, DWW, BIT, MBIA).
You can withdraw consent anytime via the Unsubscribe link or privacy@negentrix.com.
Negentrix maintains a centralized marketing database to manage preferences consistently across all brands.


7.1 Children and Minors

Our websites and services are intended for adults. We do not knowingly collect personal data from individuals under the age of 16.
If we become aware that a minor has submitted personal information without parental consent, we will delete such data immediately.
Parents or guardians can contact us at privacy@negentrix.com to request deletion of such data.


8. Cookies and Analytics

We use cookies and analytics tools (e.g., Google Analytics 4) to improve user experience and personalize content.
Details about the cookies and tracking technologies we use, including their types, purposes, and storage periods, are provided in our Cookie Policy.
Essential cookies are used to ensure the functionality of our websites.
All non-essential cookies (such as analytics or marketing cookies) are activated only with your explicit consent in accordance with Art. 6(1)(a) GDPR and §25 TDDDG.
You may withdraw or modify your consent at any time through the “Cookie Settings” link on our websites.


9. Data Retention

We retain personal data only as long as necessary for the purposes outlined above or as required by law.
Typical retention periods are as follows:
- Course registrations, contracts, and invoices: 6 years (commercial and tax obligations);
- Marketing consents: until withdrawn, plus 2 years for compliance evidence;
- Customer inquiries and correspondence: 3 years after last interaction;
- Cookie and consent preferences: 12 months;
- Backup and security logs: up to 12 months.


10. Your Rights Under GDPR

You have rights to access, correction, deletion, restriction, objection, data portability, and consent withdrawal.
To exercise your rights, contact privacy@negentrix.com or write to Negentrix Holding GmbH, Genthiner Straße 40, 10785 Berlin, Germany.


11. Data Security

We maintain strict technical and organizational measures to protect your personal data, including SSL encryption and limited authorized access.


12. International Data Transfers

Transfers to third-party providers outside the EEA (e.g., Google LLC) occur under EU Standard Contractual Clauses or the EU–US Data Privacy Framework.


13. Automated Decision-Making and Profiling

We do not use automated decision-making processes or profiling that produce legal or similarly significant effects on individuals.
If in the future any automated evaluations or course recommendations are introduced, they will serve only to improve your learning experience and will not have any legal or adverse impact on you.


14. Updates to This Policy

We may update this Privacy Policy. You will be notified of any significant changes, especially if new entities are added or processing purposes are modified.


15. Supervisory Authority and Complaints

If you believe that the processing of your personal data violates applicable data protection law, you have the right to lodge a complaint with a supervisory authority, in particular with the authority responsible for your habitual residence or with the authority responsible for the place of our registered office.

The competent supervisory authority for Negentrix Holding GmbH is:

Berlin Commissioner for Data Protection and Freedom of Information
Friedrichstraße 219, 10969 Berlin, Germany.


16. Accountability and Data Protection Governance

Negentrix Holding GmbH and its affiliated companies maintain internal data protection policies, records of processing activities, and conduct Data Protection Impact Assessments (DPIAs) for high-risk processing operations in accordance with Art. 24, 30, and 35 GDPR.
Internal data transfers within the Negentrix Education Group are governed by Joint Controller Agreements ensuring compliance with Art. 26 GDPR.


17. Language and Interpretation

This Privacy Policy is provided in English for international accessibility.
A German version is available upon request. In case of discrepancies, the German version shall prevail.

Address:

Contacts:

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