Privacy Notice

1. Who is responsible?

Contact: Rico Kerstan
Email: rk@krintl.biz

KR International Services LLC is the designated provider for customers outside the European Union. KR Krisensicher Risikoberatung GmbH provides the Germany/EU offering. The company identified in your actual offer or contract is relevant; using a .com domain does not by itself select your provider or remove mandatory privacy protections.

For the Germany/EU provider, see the German Privacy Notice. If a separate organization provides your training and determines how your information is used, its own notice and the agreed division of responsibilities also apply.

2. Public website, contact form and optional statistics

The homepage announces learning topics. Online purchases and payments are not yet enabled here. Fonts, images and scripts are served from our hosting.

Contact form

We process your name, email address, enquiry category, message and optional organization to answer your enquiry. An acknowledgement is sent to your email address. Hosting, the delivery queue and email delivery use STRATO. Where the GDPR applies, processing is based on Article 6(1)(b) for your own contract enquiry or Article 6(1)(f) for business contacts and other enquiries (interest: handling correspondence). Random form tokens and a daily, domain-specific HMAC identifier derived from IP address and date protect the form from abuse under Article 6(1)(f). The raw IP address is not retained for this purpose.

Form tokens expire after 15 minutes and rate-limit data after ten minutes. Technical message copies are erased seven days after both emails have been sent, or at the latest 30 days after receipt if delivery remains incomplete. Minimal queue metadata is erased after 30 days. Correspondence handled in our mailbox is generally erased six months after the matter is closed; legally required business correspondence and records follow the periods below.

Our own optional usage statistics

Statistics start only after you select “Allow statistics” in the footer. Where applicable, the legal basis is your consent under Article 6(1)(a) GDPR and Section 25(1) TDDDG for access to device information. You can withdraw consent there at any time for the future. DNT and Global Privacy Control are respected. Declining does not affect access to the website.

We collect the page path without query parameters, language, referring domain without the full URL, time, active reading duration and scroll depth. The IP address is used immediately to derive a daily, domain-specific HMAC identifier and, optionally, to determine a country using a local database; it is not stored in the statistics. Browser identifiers, form contents and eCampus learning accounts are not combined with these statistics. There are no advertising profiles or external analytics services. Raw statistical events including the pseudonymous daily identifier are erased after 30 days; daily aggregates without that identifier after 13 months. These are operational maximum periods, not legal minimum periods. Data is hosted at STRATO.

Local browser storage holds only your statistics choice under ecampus_statistics_consent until you change it or clear browser storage. This entry preserves the setting you requested and contains no visitor identifier; where applicable, Section 25(2)(2) TDDDG applies.

3. Information used by the actual service

We do not request government identity numbers, payment-card security codes, health information or other sensitive personal information through this public homepage. Do not include credentials or unnecessary sensitive information in a message, learning example, uploaded file or help request.

4. Why information is processed

The relevant purposes are providing the website, responding to inquiries, administering course contracts and access, delivering learning activities and feedback, conducting the assessment you select, supplying requested materials, resolving support issues, maintaining security, and meeting applicable recordkeeping or legal obligations.

Information supplied by an employer may identify you as a participant or eligible user. An employer’s purchase does not automatically entitle it to all raw answers, private reflections or assessment details. Any agreed organizational reporting must have its own defined scope and lawful basis. Where participant information is obtained from another organization, its source and the relevant use must be explained to the participant.

5. Learning, assessment and live participation

An account may contain verification status, password verification data, permissions, optional profile information and course activity. Guest participation can use a random identifier, pseudonym and avatar. A pseudonym does not make participation anonymous. Private work, group work and content deliberately released for presentation or a workbook have different visibility rules.

The documented group-assignment function can use a derived check value for a known organizational email domain to help distribute people from the same organization across groups. This is not a marketing profile. Requested materials may require name, email and a confirmation link; a marketing opt-in is not a condition of the documented material-access function.

Where transfer follow-ups are enabled, the service can retain your action plan, reflections, scheduled follow-up and deliberately requested external feedback. Inviting a feedback giver uses their necessary contact details and the limited information designated for the invitation; it does not release your entire learning record. The invited person must receive the relevant information about the source and purpose. Course/role administration and authorized reports support delivery, not unrestricted employer monitoring.

Assessment functions may maintain evidence, reviews, a final result and certificate status. The reviewed workflow includes human final responsibility; a practice score is not by itself an exclusively automated legally significant qualification decision. A material change to automated assessment requires a fresh explanation and legal assessment.

6. Audio, video, rooms and recordings

If conferencing is provided, it processes your enabled media, shared content, room assignment and necessary connection/moderation events. The reviewed architecture uses a self-operated LiveKit media server; using that software is not evidence that LiveKit Cloud is used. Media and participation visibility depend on room membership and authorized moderation functions.

Some events may have a disclosed camera rule. The implementation can check receipt of a small number of camera frames and process limited activity or attendance-confirmation events. It does not establish a person’s identity through biometric recognition. The need for the rule and available participation arrangements must be explained for the actual event. Browser permission is a device control, not blanket legal consent for every subsequent use.

The reviewed recording feature deliberately records only the presenter’s own local microphone track. It is not a room mix, does not automatically upload to a server, and does not include a participant download function. Other people’s speech in the presenter’s physical environment may still be audible; recording requires an appropriate basis and notice. The presenter controls downloaded files and separate backups. The platform cannot centrally promise their deletion.

The documented text chat is held in memory and cleared at session end. Saved whiteboard material and deliberately released results have a different lifecycle.

7. Integrated interface help using OpenAI

The eCampus interface help uses the OpenAI API. When you request assistance, your question, limited conversation context where needed, and relevant product, role and page information are processed to provide an answer. The public homepage does not itself send AI requests.

This help explains platform functions. It does not operate your account or make assessment decisions. Do not enter passwords, health information, confidential case files or unnecessary information about other people.

For processing within GDPR scope, the legal basis for user-requested interface assistance is Article 6(1)(f): our legitimate interest in understandable and accessible assistance. Additional AI learning activities are separate functions with their own purpose and legal basis.

OpenAI states that API data is not used for training by default without an explicit opt-in. Abuse monitoring logs may normally be retained for up to 30 days, subject to legal or security exceptions. Feature-specific application state may involve additional retention. We do not promise zero retention or exclusively European processing. See OpenAI API Data Controls.

Our internal retention requirements specify store=false, no training opt-in and no persistent KR content logs for this help. These requirements do not mean that KR can immediately delete all provider-held information. Actual project settings and contractual arrangements determine provider processing. Contact us for information about applicable safeguards.

8. STRATO, Stripe, OpenAI and other recipients

Based on the operator’s confirmed setup, STRATO provides hosting and is also the designated email provider, Stripe provides payment processing, and OpenAI powers the integrated interface-help function. STRATO GmbH is located at Otto-Ostrowski-Straße 7, 10249 Berlin, Germany; its hosting information describes German data centers. See STRATO’s privacy information.

Stripe receives the payment, billing, transaction and device/security information needed for the selected payment method and fraud prevention. The eCampus needs the associated payment reference and status to allocate a purchase. Which information is entered directly with Stripe depends on the actual integration. Stripe acts as a processor for some functions and as an independent controller for others, including its own regulatory and fraud-prevention purposes.

The Stripe entity depends on the merchant account and service. Stripe’s published materials identify, among others, Stripe Payments Europe, Limited in Ireland for European arrangements and Stripe, LLC for U.S. arrangements. The exact account/contract chain for each KR company must be documented. See the Stripe Privacy Policy, Privacy Center and DPA. Stripe describes international processing and transfer mechanisms; applicability to a specific transfer is not established solely by linking its public terms.

OpenAI receives the help-request content described in section 7 and may process it internationally. The two KR companies remain separate entities. The German GmbH can act on the LLC’s instructions for a defined technical service if that arrangement is actually established; an executed processing arrangement has not been evidenced here.

Participants and instructors receive only the information allowed for the relevant activity and role. Disclosures may also be required by applicable law, subject to its limits. The reviewed homepage has no advertising pixel or personal-data sale function; the distinct Firebase contact workflow at krintl.biz has not been imported into eCampus.

9. Cookies and browser storage

The public homepage does not set cookies or persist a cart. The connected learning platform can use necessary sign-in, challenge, live-participation and material-access cookies. It can also retain selected display preferences or local work drafts in browser storage.

Examples in the reviewed implementation include ECAMPUS_SESSION, ECAMPUS_LOGIN_CHALLENGE and function-bound live/material access, plus local preferences for collapsed navigation, reduced motion and camera background blur. A local-storage preference can remain until you reset it or clear browser data. The complete enabled storage inventory and actual token lifetimes need to match the production version.

Where applicable law requires prior consent for a storage use, that requirement must be implemented before the use starts. The statistics preference and withdrawal control are described in section 2.

10. How long information is kept

Retention depends on the purpose and record type. Short-lived access tokens are distinct from active course content, assessment/certificate records, accounting documents and backups. Inquiry data is needed to resolve the request and for any justified subsequent evidence period. Learning data supports the agreed access and learning activity; after those purposes end it must not remain indefinitely without another valid reason.

Accounting and business records may be subject to applicable retention obligations. Assessment records can be needed for decisions, challenges and certificate verification. Account deletion therefore does not necessarily erase every required invoice or qualification record at the same moment. Specific target periods and starting events for logs, materials, support, assessment/certificates, email and backups are now documented in the processing record. Their production implementation still needs to be verified; a written schedule does not prove that deletion has occurred.

The documented text-chat lifecycle clears in-memory chat when the session ends; deliberately saved learning/whiteboard content is separate. Stripe and OpenAI can have their own storage obligations and arrangements for the processing they perform. Provider retention depends on the API endpoint, settings and applicable exceptions.

Backups must expire appropriately and deletion/restriction requirements must be reapplied after restoration. Downloads and local presenter recordings are separately controlled by their device/file owner.

11. Security

The reviewed platform includes role- and session-bound access checks, restricted storage paths, TLS at its public boundary, protected sessions, short-lived access links and controlled backup/restore procedures. These are implementation characteristics, not a certification of an unverified production deployment. No method of storage or transmission is perfectly secure.

Where a security incident affects personal information, applicable investigation, cooperation and notification duties must be followed. Wyoming breach-notification requirements can apply to covered incidents involving Wyoming residents; other jurisdictions may impose additional requirements. We do not apply a blanket Wyoming-only notification rule to all users.

12. Requests and privacy rights

Contact rk@krintl.biz to ask about information relating to you, request a correction or deletion, or raise a privacy concern. We may need proportionate information to verify your identity or an authorized representative’s authority. Legal obligations and the rights of others may limit what can be provided or deleted.

Depending on the law that applies, you may have rights to access, receive a copy of, correct or delete personal information; restrict or object to processing; withdraw consent; or opt out of specified sale, sharing or targeted-advertising practices. We will not deny rights available under applicable law or unlawfully discriminate for exercising them. Where a state law provides an appeal mechanism, we will explain the applicable route in our response.

This notice does not claim that a Wyoming company automatically falls within every state privacy statute, or that all users have the same statutory rights. Actual applicability depends on legal scope, including relevant activities and thresholds.

13. Where European data protection law applies

A non-EU offering or Wyoming business address does not by itself exclude the GDPR. For user-requested interface help, we rely on Article 6(1)(f), with the interest of providing understandable and accessible assistance; a documented balancing assessment and a valid transfer basis remain necessary. If processing falls within its scope, the relevant legal grounds are contract-related processing under Article 6(1)(b), appropriate legitimate interests under Article 6(1)(f), legal obligations under Article 6(1)(c), or valid consent for a genuinely optional use under Article 6(1)(a). A contact acting for a business is not automatically the individual contracting customer.

Relevant rights can include access, correction, erasure, restriction, portability, objection and withdrawal of consent, subject to their legal conditions. You may complain to a competent supervisory authority, including where you live or work. Required information about an EU representative or data protection officer must be added if a relevant appointment is required; no appointment is assumed in this notice.

Where Chapter V of the GDPR applies, transfers to recipients outside the EEA, including remote access from the United States, need a valid transfer basis and any required supplementary measures. This notice does not assert an existing Data Privacy Framework certification or signed standard contractual clauses. Information about actual safeguards must be made available for the processing concerned.

14. Location and international access

STRATO hosting is identified for eCampus and its provider materials describe German data centers. The LLC is based in Wyoming. Stripe can involve international recipients, including in the United States, and OpenAI can involve international processing. These are different data flows; German hosting is not a promise that all information stays in Germany.

Support, email routing, backups, third-party processing and any cross-border access must follow the actual service arrangements. The Firebase/Google stack described for krintl.biz is not evidence that eCampus uses that stack. Where European transfer rules apply, the applicable safeguards must be established and disclosed for each relevant transfer.

15. Children

This offering is for professional education and is not directed to children under 13. We do not seek children’s personal information through this website. If you believe such information has been provided, contact us so that we can investigate and take the steps required by applicable law. A children’s offering would require a separate assessment and appropriate notices and controls before launch.

16. Scope, U.S./Wyoming law and changes

This notice covers the public eCampus website and the entire eCampus tool, including accounts, learning, live participation, conferencing, materials, assessment, support, Stripe payments and integrated OpenAI help, where the relevant function is used.

For the LLC’s offering, applicable federal and Wyoming requirements, including relevant breach-notification duties, are considered. Other U.S. state and international requirements may apply. This notice is not an exclusive choice-of-law clause or a waiver of mandatory rights.

The notice will be updated for material processing changes. Specific contracts and merchant-account entities, retention schedules and OpenAI API/transfer arrangements remain to be substantiated. This notice does not turn unverified arrangements into operational promises.