Datenschutzerklärung

Last updated and effective as of April 16, 2026.

The following privacy notices (this “Privacy Policy”) is provided by the Retail Performance Company GmbH (“rpc” “our,” “us,” or “we”) to provide a simple overview of what happens to the personal data of our customers, visitors, and users (“you” or “your”) of this website, including the features available through the website, and other platforms and sites operated by Retail Performance Company that reference this Privacy Policy (collectively, the “Website”) and to provide you with information about rpc’s policies regarding the collection, use, storage, and disclosure of information when you visit our Website or use our products or services (together with the Website, the “Services”). This Privacy Policy also describes your choices about the collection and use of your personal data. Personal data is any data by which you can be personally identified.

1. Data Protection at a Glance (General Information on How We Collect, Use, and Disclose Your Information)

How do we collect your data?

Who is responsible for the data collection on the Partner Academy? The data processing on this website is carried out by RPC. You can find the contact details of RPC in the section "Information about the responsible party" below

We collect personal data from you both when you provide it voluntarily and also automatically when you use our Services, including as further described in “Data Collection on this Website” below.

On the one hand, your personal data is collected when you provide it directly to us. This can be, for example, data that you enter when registering an account on the Website, or data you enter into a contact or other webform on the Website.

We also collect personal data about you from third parties in connection with the Website and other Services, including from the following sources:

• Service providers (including our hosting provider)
• Data analytics service providers

Other data is collected automatically or after your consent when visiting the Services by our IT systems. This includes technical data (e.g. Internet browser, operating system or time of page view) that is collected automatically as soon as you enter this Website and is described in “Collection of Cookies and Device Data” below.

What information do we collect about you?

While using our website or our other Services, we may ask you to provide us with certain information that identifies, relates to, describes, can reasonably be associated with, or can reasonably be linked to you (“personal data”). Personal data does not include information that has been de-identified or is publicly available.

The following chart provides information about the types of personal data we may collect, the sources of the information, whether it was disclosed for a business purpose, and the categories of third parties to whom we have disclosed this information for a business purpose in the last twelve (12) months.

Type of Personal Data	Categories of Sources	Disclosed for a Business Purpose?	Third Parties to whom Disclosed for a Business Purpose
Identifiers such as name, e-mail address, postal address, photograph, unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers.	Direct contact with users through the Services, email, and web form; from subsidiaries and affiliates.	Yes	Service providers, marketing and promotional partners, third-party analytics providers, and affiliates.
Financial information, such as name, credit card number or debit card number, and billing address or other information related to a billing or payment transaction.	Direct contact with users through the Services; from subsidiaries and affiliates; and from service providers (including payment processors).	Yes	Service providers and affiliates.
Commercial information, including records of products or services obtained, or considered, or other purchasing or consuming histories or tendencies.	Direct contact with users through the Services; other tracking technologies; third-party data analytics providers.	Yes	Service providers, third-party analytics providers, and affiliates.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, Internal Protocol address, unique personal identifier, online identifier, and information regarding your interaction with an Internet web site, application, form submissions, email unsubscribes and subscribes, email engagement or advertisement.	Through users’ interactions with our Services or with us, including through web forms.	Yes	Service providers, marketing and promotional partners.
Sensory information, including visual information captured via video recordings.	Through users’ interactions with our Services or and our affiliates and subsidiaries.	Yes	Service providers, marketing and promotional partners.
Geolocation data.	Through users’ interactions with our Services.	Yes	Service providers, marketing and promotional partners.
Professional or employment-related information, including name, email address, company and job title.	Direct contact with users through the Services, email, web form, and from service providers or affiliates.	Yes	Service providers and affiliates.

What do we use your data for?

We will use your personal data for the purposes of:

• providing, maintaining, personalizing, monitoring, and improving our website and other Services
• reducing errors on the Website or otherwise for the Services
• detecting, preventing, and addressing technical issues
• maintaining the safety, security, and integrity of our Website, Services, and other technology assets
• monitoring the usage of our Services
• analyzing interests within the Services
• other purposes consistent with reasonable expectations given the nature of the data collected and services provided

We use your personal data, for example, to provide access to the documents required for training and online training in general, to send notifications about new training offers, to manage the attendance of participants at training courses, to contact you if necessary to fulfill a contractual obligation regarding booked training courses, and to create reports showing the data collected in the training history.

Purposes and legal basis of data processing

We collect and process your personal data to process your training and track your progress and otherwise to provide the Services. After the training we forward your results to the correct BMW Group contact person. If you have previously voluntarily given your consent to advertising, the data processing will also be carried out for the purposes and to the extent stated there.

Disclosure of your personal data

We may share non-personal data with third parties at our discretion. We do not sell your personal data and have not done so in the past twelve (12) months, though we may share it with our marketing partners or use it to help identify products or services that may be of interest to you. In connection with our Services, we may share your personal data with certain third parties who we engage to help us run our business, including under the following circumstances:

• Software and service providers we use to manage and process your information
• Affiliates and subsidiaries
• Marketing service providers we use to communication with you
• Hosting providers that provide database storage for our business
• Analytics and site management companies, such as Google Analytics
• Other third parties that you expressly request us to disclose your personal data to

Additionally, we will disclose your personal data with third parties where required by law, where it is necessary in connection with our website or other services, to protect the safety or property of RPC, our users, employees, or where we have another legitimate interest in doing so.

If we are subject to a merger or acquisition with/by another company, we may share information with them in connection with the transaction.

What rights do you have regarding your data?

Depending on where you live, you may have the right to request information free of charge about the origin, receipt and purpose of your stored personal data. You also may have a right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

Please see “Your rights and choices regarding your information” below for more information about these rights. You can contact us at any time as set forth in “How to Contact Us” below regarding this and other questions about data protection.

Sensitive personal data

We ask that you not send us, and you not disclose, any sensitive personal data as this term is defined under applicable data protection and privacy laws (for example, personal identification numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, precise geolocation, or criminal background) on our through the Services or otherwise to us.

2. Hosting

External hosting

This Website is hosted externally with a third-party service provider. The personal data collected on this Website is stored on the servers of the host(s). This may include, but is not limited to, IP addresses, contact requests, metadata and communication data, contractual data, contact details, names, Website accesses and other data generated via this Website.

External hosting is carried out for the purpose of contract fulfilment vis-à-vis our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f GDPR). If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 Para. 1 lit. a GDPR and § 25 Para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) as defined by the TTDSG. The consent can be revoked at any time.

Where required by law, our host(s) are required to only process your data to the extent necessary to fulfil their service obligations and follow our instructions regarding this data.

As of the publication of this Privacy Policy, we use the following host(s):

D2L Europe Ltd with a registered address in London (c/o Taylor Wessing LLP 5 New Street Square, London, England EC4A 3TW), uses Amazon Web Services’ (AWS) data centers located in the Republic of Ireland for data hosting.

Job processing

We have concluded a contract on order processing (AVV) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that this processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

3. General Notes and Mandatory Information (Data Protection) under GDPR

How we safeguard your data

We take the protection of your personal data very seriously. We treat your personal data confidentially and strive to use commercially acceptable means to protect your personal data.

We would like to point out that data transmission on the Internet (e.g. communication by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible. Any transmission of personal data is at your own risk.

Data Controller information

For all data originating for individuals in the European Union, United Kingdom, and Switzerland, the data controller for the Services is :

The Retail Performance Company
Sucursal en Espana
Calle de Javier Ferrero 10
28002 Madrid

The main establishment of the controller is:

The Retail Performance Company GmbH
Pelkovenstraße 145
80992 Munich
Tax ID: DE286981171
Represented by the managing directors: Christian Feilmeier, Jan Schemuth

E-mail: info@rpc-partners.com
Phone: +49 89 2000 5080

If you have any question regarding the use of your personal data, you can contact our data protection officer at any time:
privacy@rpc-partners.com

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses, etc.).

Storage period

Unless a more specific storage period has been specified within this Privacy Policy or you expressly consent otherwise, your personal data will remain with us until the purpose for the data processing no longer applies unless a longer retention period is required by law. If you assert a legitimate request for deletion or revoke your consent to data processing, your personal data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the personal data will be deleted once these reasons no longer apply.

We also will retain de-identified usage information for internal analysis purposes.

General information on the legal basis for data processing

If you have consented to data processing, we process your personal data on the basis of Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR, if special categories of data are processed according to Art. 9 (1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out based on Art. 49 (1) a GDPR. If you have consented to the storage of cookies or to the access to information in your terminal device (e.g. via device fingerprinting), the data processing is additionally carried out on the basis of Section 25 (1) TTDSG. This consent can be revoked at any time.

If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data based on Art. 6 (1) lit. b GDPR. Furthermore, if your data is required for the fulfilment of a legal obligation, we process it on the basis of Art. 6 (1) lit. c GDPR. Furthermore, data processing may be carried out on the basis of our legitimate interest pursuant to Art. 6 (1) f GDPR. Information about the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

4. Note on Data Transfer to the USA and Other Third Countries

Among other things, we use tools from companies and service providers based in the USA or other countries that may not have the same data protection laws as your country of residence. If these tools are active, your personal data may be transferred to these countries and processed there. Because of the nature of our services, you may not have the same rights regarding your personal data that you would have interacting with a company in your jurisdiction.

By providing us with personal data, you consent to the transfer of information about you, including your personal data, to the USA and other countries outside your home country, and the use and disclosure of information about you, including your personal data, as described in this Privacy Policy.

5. Your Rights and Choices Regarding Your Information

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke an already given consent at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Marketing and Advertising Preferences

By providing your telephone number and/or email address to us via the Services, you consent to receive phone calls and/or emails from us in connection with the Services. You can opt out from receiving future marketing communications from us at any time, for example, by using the unsubscribe function in the email you receive from us, replying “STOP” to a text message, or by contacting us as set forth in “How to Contact Us” below. Even if you opt out of receiving marketing messages, we may still contact you for transactional purposes like confirming or following up on an order or service request. If you later opt back into getting marketing communications from us, we will remove your information from our opt-out databases.

You may opt out of how companies unaffiliated with us use tracking tools and collect your information while visiting our websites by visiting each of their privacy policies and following instructions there. Please note that we and other companies may still collect information when you are online, and opting out through these mechanisms does not opt you out of being served advertising. You will continue to be served generic ads while online.

Additionally, some web browsers have “Do Not Track” settings that enable you to request that our website does not track your movement within our website. However, these features are not yet uniform, so we do not currently respond to such settings when transmitted to and detected by our website. Therefore, if you opt to activate your browser’s “do not track” feature in your web browser, we and our third-party providers may continue collecting information about your online activities as described in this Privacy Policy. This does not change our compliance in any other way with our Privacy Policy. You may opt to activate your browser’s do not track settings.

Country-Specific Rights (GDPR)

Right to object to the collection of data in specific cases and to direct marketing (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT BY US ON THE BASIS OF ART. 6 PAR. 1 LIT. E OR F OF GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS DATA PROTECTION DECLARATION. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CANNOT VERIFY YOUR IDENTITY, OR IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS (OBJECTION PURSUANT TO ARTICLE 21 (1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS CONNECTED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA. 2 GDPR).

Right of appeal to the competent supervisory authority

In the event of a breach of the GDPR, data subjects have a right of appeal to a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged breach. The right of appeal is without prejudice to other administrative or judicial remedies. You can reach the competent supervisory authority at the following address:

Agencia Española de Protección de Datos | AEPD
C/ Jorge Juan, 6.
28001-Madrid
https://www.aepd.es
Telefon: 900 293 183

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, deletion and correction

Within the scope of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if applicable, a right to correction or deletion of this data. For this as well as for further questions about personal data, you can contact us at any time.

Right to restrict processing

You have the right to request the restriction of the processing of your personal data. For this purpose, you can contact us at any time. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.

If the processing of your personal data happened/is happening unlawfully, you can request the restriction of the data processing instead of the deletion.

If we no longer need your personal data, but you need it to exercise, defend or enforce legal claims, you have the right to request restriction of the processing of your personal data instead of deletion.

If you have lodged an objection under Article 21(1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, such data may - apart from being stored - only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

Country-Specific Rights (Mexico)

Under Mexico’s Federal Law on Protection of Personal Data Held by Private Parties (the “LFPDPPP”), you have certain rights with respect to your personal data that we have collected and used under certain circumstances, including the following:

• The right to request access to your personal data. Under the right to access, you have the right to request that we provide a portable copy of the personal data that we collect, use, disclose, and (to the extent applicable) sell.
• The right to request the correction of your inaccurate personal data. You also may update or change your information under your account settings.
• The right to request the cancellation (deletion) of your personal data.
• The right to object to our processing of your personal data, including the right to request that we limit our use or disclosure of your personal data.

To make a request under the LFPDPPP and the regulations enacted thereunder, please submit a verifiable request to us by sending us an email at privacy@rpc-partners.com.

State-Specific Rights in the United States

Depending on where you live in the United States, you may have certain rights with respect to personal data that we have collected and used under certain circumstances, which may include the following:

• The right to know particular information regarding our use of your personal data in the past 12 months. Under the right to know, you can request a listing of:
  • Categories of personal data that we have collected
  • Purpose of such use
  • Categories of sources for that information
  • Categories of third parties to whom we have disclosed your personal data
  • Expected retention period for the categories of your personal data
  • If we have collected personal data from another source, available information about that source
  • If we have disclosed your personal data for a business purpose, a list identifying the personal data categories that each category of recipient obtained
  • If we have sold or shared your personal data, a list identifying the personal data categories that each category of recipient purchased or received
• The right to request access to your personal data. Under the right to access, you have the right to request that we provide a portable copy of the personal data that we collect, use, disclose, and (to the extent applicable) sell.
• The right to request deletion of your personal data when we no longer need such data in connection with our Website or Services.
• The right to request the correction of your inaccurate personal data. You may also update or change your information under your account settings.
• The right to opt out of sales or sharing of your personal data. For clarity, RPC does not sell the personal data of any consumers, nor does it sell or share personal data of minors under 16 years of age and has no actual knowledge of any such sales or disclosures.
• The right to limit the use or disclosure of your sensitive personal information. For clarity, we do not collect or use sensitive personal information.
• The right to non-discrimination for exercising your rights.

When you or someone legally authorized to act on your behalf makes a consumer request related to your personal data, you can expect the following:

1. We will verify your identity. You will need to provide us with certain information, as relevant, so that we can verify that you are who you say you are. Which information may depend on the type and sensitivity of information subject to the request.
2. We will confirm our receipt of your request.
3. We will respond to your request within the legally required amount of time. If necessary, we may need additional time to respond where allowed by law, but we will reply either way within the legally required period and, if we need an extension, we will explain why.
4. In certain cases, a request may be denied. For example, if we cannot verify your identity or if providing you with the information could create an unreasonable risk to someone’s security (for example, we do not want very sensitive information disclosed inappropriately). If we deny your request, we will explain why we denied it. If we deny a request, we will still try to provide you as much of the information as we can, but we will withhold the information subject to denial.

To make a request under the California Consumer Privacy Act, as amended by the California Privacy Rights Act and the regulations enacted thereunder (collectively, the “CCPA”) or other U.S. state data privacy law applicable to the Services, please submit a verifiable request to us by sending us an email at privacy@rpc-partners.com.

6. Data Collection on this Website

Collection of Cookies and Device Data

We may use tracking technologies such as “cookies” on the Website. Cookies are small data packets or files that are downloaded onto your computer or mobile device when you use our Website, which are unique to your device or account. Cookies do not cause any damage to your end device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your end device. Session cookies are automatically deleted at the end of your visit when the web browser is closed. Permanent cookies retain user preferences for a particular website, app, or service, allowing those preferences to be used in future sessions, and remain valid until a set expiration date, until you delete them yourself, or until they are automatically deleted by your web browser.

In some cases, cookies from third-party companies also may be used on our Website. These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain Website functions would not work without them (e.g. the shopping cart function or the display of videos). Cookies make it easier for you to use our Website by saving your preferences so that we can use these to improve your subsequent visits to our Website. Cookies help us learn which areas of our Website are useful and which areas need improvement by allowing us and our service providers to determine how many people visited our websites, the pages that were accessed, and whether there were any technical problems in loading pages. We also use cookie information for security purposes and to display information more effectively, and we may use cookie information to provide advertising content that we think may be of interest to you.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions that you have requested (e.g., for the shopping cart function) or to optimize the Website (e.g., cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 (1) lit. f of GDPR, unless another legal basis is specified. The Website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. Insofar as consent to the storage of cookies and comparable recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG); the consent can be revoked at any time.

You can choose whether to accept cookies by changing the settings on your browser or device. For example, you can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or generally and activate the automatic deletion of cookies when closing the browser. You also can choose whether to accept cookies by interacting with the banner on our Website. If you deactivate cookies, the functionality of this Website may be limited.

If cookies are used by third parties, we will inform you separately within the framework of this data protection declaration and, if necessary, request your consent.

Contact form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6 (1) lit. b GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR) if this has been requested; the consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory legal provisions - in particular retention periods - remain unaffected.

7. Policy on Children’s Information

Our Services are not created for anyone under the age of 13 (“Children” or “Child”). By using the Services, you represent that you are at least 13 years old.  If you do not meet this age requirement, then you must not access or use our Services.

We do not target the Services to Children. If you are a parent or guardian and you are aware that your Child has directly provided us with personal data, please contact us though one of the methods listed under “How to Contact Us” below. If we become aware that we have collected personal data directly from Children without verification of parental consent, we will take reasonable steps to remove that information from our servers.

8. Plugins and Other Sites

Google Analytics

This Website uses Google Analytics, a web analytics service provided by Google, Inc (hereinafter: Google). Google Analytics uses cookies that enable an analysis of your use of and interaction with the Website. The information generated by the cookie about your use of the Website will be transmitted to and stored by Google on servers in the United States. In the case of activation of IP anonymization on this Website (see below), however, your IP address (if originating outside of the United States) will be truncated beforehand by Google within the Member States of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and then shortened there. On behalf of the operator of this Website, Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services relating to Website activity and internet usage to the Website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this Website. You can also prevent the collection of data generated by the cookie and related to your use of the Website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de. We use Google Analytics to analyze the use of our Website in order to regularly improve the user experience. The statistics obtained allow us to improve our offer and make it more interesting for you. The legal basis for the processing of your data is the consent you have given via the cookie consent tool (Art. 6 para. 1 sentence 1 lit. a) DSGVO).

You can find more information about Google Analytics here:

Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. user terms: https://marketingplatform.google.com/about/analytics/terms/us/, as well as the privacy policy: https://www.google.de/intl/de/policies/privacy.

Other Sites

The Website may contain links to other internet websites. When you click on one of these links, you will be transferred out of the Website and connected to the website of the organization or company that you selected. We are not responsible for the nature, quality or accuracy of the content or opinions expressed on such websites, or of the services provided through such websites. Such websites are not investigated, monitored or checked for quality, accuracy or completeness by us. Inclusion of any linked website on the Website does not imply or express an approval or endorsement of the linked website by us, or of any of the content, opinions, products or services provided on these websites. Even if an affiliation exists between the Website and a third-party website or application, we exercise no control over linked sites. Each of these linked sites maintains its own independent privacy and data collection policies and procedures. We encourage you to visit these websites to find additional related information. We are not responsible for the privacy practices or the content of such websites. Please read the privacy statement of any website you may visit.

9. How to Contact Us

You may update your preferences and information by contacting us at the e-mail address or phone number below. Additionally, if you have any questions or concerns about our use of your Personal Information (defined below), please do not hesitate to contact us through any of the methods below.

Email: privacy@rpc-partners.com

Last updated and effective as of October 4, 2024.

The following privacy notices (this “Privacy Policy”) is provided by the Retail Performance Company GmbH (“RPC,” “our,” “us,” or “we”) to provide a simple overview of what happens to the personal data of our customers, visitors, and users (“you” or “your”) of this website, including the features available through the website, and other platforms and sites operated by Retail Performance Company that reference this Privacy Policy (collectively, the “Website”) and to provide you with information about RPC’s policies regarding the collection, use, storage, and disclosure of information when you visit our Website or use our products or services (together with the Website, the “Services”). This Privacy Policy also describes your choices about the collection and use of your personal data. Personal data is any data by which you can be personally identified.

We reserve the right to update or change this Privacy Policy at any time by posting the amended version, including the effective date of the updated version. You should regularly review this Privacy Policy whenever you access, visit, and/or use the Website or other Services. By using the Website or our Services, you agree to the terms of this Privacy Policy and consent to the collection and use of information in accordance with this Privacy Policy. If you do not agree to be bound by this Privacy Policy, then do not access or use the Website or disclose any personal information to us.

This Privacy Policy contains the following information:

1. Data Protection at a Glance (General Information on How We Collect, Use, and Disclose Your Information)
2. Hosting
3. General Notes and Mandatory Information (data protection)
   • How we safeguard your data
   • Data Controller information
   • Storage Period
   • General information on the legal basis for data processing
4. Note on Data Transfer to the USA and Other Third Countries
5. You Rights and Choices Regarding Your Information
6. Data Collection on this Website
7. Policy on Children’s Information
8. Plugins and Other Sites
9. How to Contact Us

1. Data Protection at a Glance (General Information on How We Collect, Use, and Disclose Your Information)

How do we collect your data?

Who is responsible for the data collection on this Website? The data processing on this Website is carried out by the Website operator. You can find the contact details of the Website operator in the section "Information about the responsible party" below

We collect personal data from you both when you provide it voluntarily and also automatically when you use our Services, including as further described in “Data Collection on this Website” below.

On the one hand, your personal data is collected when you provide it directly to us. This can be, for example, data that you enter when registering an account on the Website, or data you enter into a contact or other webform on the Website.

We also collect personal data about you from third parties in connection with the Website and other Services, including from the following sources:

• Service providers (including our hosting provider)
• Data analytics service providers

Other data is collected automatically or after your consent when visiting the Services by our IT systems. This includes technical data (e.g. Internet browser, operating system or time of page view)that is collected automatically as soon as you enter this Website and is described in “Collection of Cookies and Device Data” below.

What information do we collect about you?

While using our Website or our other Services, we may ask you to provide us with certain information that identifies, relates to, describes, can reasonably be associated with, or can reasonably be linked to you (“personal data”). Personal data does not include information that has been de-identified or is publicly available.

The following chart provides information about the types of personal data we may collect, the sources of the information, whether it was disclosed for a business purpose, and the categories of third parties to whom we have disclosed this information for a business purpose in the last twelve (12) months.

Type of Personal Data	Categories of Sources	Disclosed for a Business Purpose?	Third Parties to whom Disclosed for a Business Purpose
Identifiers such as name, e-mail address, postal address, photograph, unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers.	Direct contact with users through the Services, email, and web form; from subsidiaries and affiliates.	Yes	Service providers, marketing and promotional partners, third-party analytics providers, and affiliates.
Financial information, such as name, credit card number or debit card number, and billing address or other information related to a billing or payment transaction.	Direct contact with users through the Services; from subsidiaries and affiliates; and from service providers (including payment processors).	Yes	Service providers and affiliates.
Commercial information, including records of products or services obtained, or considered, or other purchasing or consuming histories or tendencies.	Direct contact with users through the Services; other tracking technologies; third-party data analytics providers.	Yes	Service providers, third-party analytics providers, and affiliates.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, Internal Protocol address, unique personal identifier, online identifier, and information regarding your interaction with an Internet web site, application, form submissions, email unsubscribes and subscribes, email engagement or advertisement.	Through users’ interactions with our Services or with us, including through web forms.	Yes	Service providers, marketing and promotional partners.
Sensory information, including visual information captured via video recordings.	Through users’ interactions with our Services or and our affiliates and subsidiaries.	Yes	Service providers, marketing and promotional partners.
Geolocation data.	Through users’ interactions with our Services.	Yes	Service providers, marketing and promotional partners.
Professional or employment-related information, including name, email address, company and job title.	Direct contact with users through the Services, email, web form, and from service providers or affiliates.	Yes	Service providers and affiliates.

What do we use your data for?

We will use your personal data for the purposes of:

• providing, maintaining, personalizing, monitoring, and improving our Website and other Services
• reducing errors on the Website or otherwise for the Services
• detecting, preventing, and addressing technical issues
• maintaining the safety, security, and integrity of our Website, Services, and other technology assets
• monitoring the usage of our Services
• analyzing interests within the Services
• other purposes consistent with reasonable expectations given the nature of the data collected and services provided

We use your personal data, for example, to provide access to the documents required for training and online training in general, to send notifications about new training offers, to manage the attendance of participants at training courses, to contact you if necessary to fulfill a contractual obligation regarding booked training courses, and to create reports showing the data collected in the training history.

Purposes and legal basis of data processing

We collect and process your personal data to process your training and track your progress and otherwise to provide the Services. After the training we forward your results to the correct BMW Group contact person. If you have previously voluntarily given your consent to advertising, the data processing will also be carried out for the purposes and to the extent stated there.

Disclosure of your personal data

We may share non-personal data with third parties at our discretion. We do not sell your personal data and have not done so in the past twelve (12) months, though we may share it with our marketing partners or use it to help identify products or services that may be of interest to you. In connection with our Services, we may share your personal data with certain third parties who we engage to help us run our business, including under the following circumstances:

• Software and service providers we use to manage and process your information
• Affiliates and subsidiaries
• Marketing service providers we use to communication with you
• Hosting providers that provide database storage for our business
• Analytics and site management companies, such as Google Analytics
• Other third parties that you expressly request us to disclose your personal data to

Additionally, we will disclose your personal data with third parties where required by law, where it is necessary in connection with our Website or other Services, to protect the safety or property of RPC, our users, employees, or where we have another legitimate interest in doing so.

If we are subject to a merger or acquisition with/by another company, we may share information with them in connection with the transaction.

What rights do you have regarding your data?

Depending on where you live, you may have the right to request information free of charge about the origin, receipt and purpose of your stored personal data. You also may have a right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

Please see “Your rights and choices regarding your information” below for more information about these rights. You can contact us at any time as set forth in “How to Contact Us” below regarding this and other questions about data protection.

Sensitive personal data

We ask that you not send us, and you not disclose, any sensitive personal data as this term is defined under applicable data protection and privacy laws (for example, personal identification numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, precise geolocation, or criminal background) on our through the Services or otherwise to us.

2. Hosting

External hosting

This Website is hosted externally with a third-party service provider. The personal data collected on this Website is stored on the servers of the host(s). This may include, but is not limited to, IP addresses, contact requests, metadata and communication data, contractual data, contact details, names, Website accesses and other data generated via this Website.

External hosting is carried out for the purpose of contract fulfilment vis-à-vis our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f GDPR). If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 Para. 1 lit. a GDPR and § 25 Para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) as defined by the TTDSG. The consent can be revoked at any time.

Where required by law, our host(s) are required to only process your data to the extent necessary to fulfil their service obligations and follow our instructions regarding this data.

As of the publication of this Privacy Policy, we use the following host(s):

D2L Europe Ltd with a registered address in London (c/o Taylor Wessing LLP 5 New Street Square, London, England EC4A 3TW), uses Amazon Web Services’ (AWS) data centers located in the Republic of Ireland for data hosting.

Job processing

We have concluded a contract on order processing (AVV) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that this processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

3. General Notes and Mandatory Information (Data Protection) under GDPR

How we safeguard your data

We take the protection of your personal data very seriously. We treat your personal data confidentially and strive to use commercially acceptable means to protect your personal data.

We would like to point out that data transmission on the Internet (e.g. communication by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible. Any transmission of personal data is at your own risk.

Data Controller information

For all data originating for individuals in the European Union, United Kingdom, and Switzerland, the data controller for the Services is :

The Retail Performance Company
Sucursal en Espana
Calle de Javier Ferrero 10
28002 Madrid

The main establishment of the controller is:

The Retail Performance Company GmbH
Pelkovenstraße 145
80992 Munich
Tax ID: DE286981171
Represented by the managing directors: Christian Feilmeier, Jan Schemuth

E-mail: info@rpc-partners.com

• Phone: +49 89 2000 5080

If you have any question regarding the use of your personal data, you can contact our data protection officer at any time:

• privacy@rpc-partners.com

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses, etc.).

Storage period

Unless a more specific storage period has been specified within this Privacy Policy or you expressly consent otherwise, your personal data will remain with us until the purpose for the data processing no longer applies unless a longer retention period is required by law. If you assert a legitimate request for deletion or revoke your consent to data processing, your personal data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the personal data will be deleted once these reasons no longer apply.

We also will retain de-identified usage information for internal analysis purposes.

General information on the legal basis for data processing

If you have consented to data processing, we process your personal data on the basis of Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR, if special categories of data are processed according to Art. 9 (1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out based on Art. 49 (1) a GDPR. If you have consented to the storage of cookies or to the access to information in your terminal device (e.g. via device fingerprinting), the data processing is additionally carried out on the basis of Section 25 (1) TTDSG. This consent can be revoked at any time.

If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data based on Art. 6 (1) lit. b GDPR. Furthermore, if your data is required for the fulfilment of a legal obligation, we process it on the basis of Art. 6 (1) lit. c GDPR. Furthermore, data processing may be carried out on the basis of our legitimate interest pursuant to Art. 6 (1) f GDPR. Information about the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

4. Note on Data Transfer to the USA and Other Third Countries

Among other things, we use tools from companies and service providers based in the USA or other countries that may not have the same data protection laws as your country of residence. If these tools are active, your personal data may be transferred to these countries and processed there. Because of the nature of our services, you may not have the same rights regarding your personal data that you would have interacting with a company in your jurisdiction.

By providing us with personal data, you consent to the transfer of information about you, including your personal data, to the USA and other countries outside your home country, and the use and disclosure of information about you, including your personal data, as described in this Privacy Policy.

5. Your Rights and Choices Regarding Your Information

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke an already given consent at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Marketing and Advertising Preferences

By providing your telephone number and/or email address to us via the Services, you consent to receive phone calls and/or emails from us in connection with the Services. You can opt out from receiving future marketing communications from us at any time, for example, by using the unsubscribe function in the email you receive from us, replying “STOP” to a text message, or by contacting us as set forth in “How to Contact Us” below. Even if you opt out of receiving marketing messages, we may still contact you for transactional purposes like confirming or following up on an order or service request. If you later opt back into getting marketing communications from us, we will remove your information from our opt-out databases.

You may opt out of how companies unaffiliated with us use tracking tools and collect your information while visiting our websites by visiting each of their privacy policies and following instructions there. Please note that we and other companies may still collect information when you are online, and opting out through these mechanisms does not opt you out of being served advertising. You will continue to be served generic ads while online.

Additionally, some web browsers have “Do Not Track” settings that enable you to request that our Website does not track your movement within our Website. However, these features are not yet uniform, so we do not currently respond to such settings when transmitted to and detected by our Website. Therefore, if you opt to activate your browser’s “do not track” feature in your web browser, we and our third-party providers may continue collecting information about your online activities as described in this Privacy Policy. This does not change our compliance in any other way with our Privacy Policy. You may opt to activate your browser’s do not track settings.

Country-Specific Rights (GDPR)

Right to object to the collection of data in specific cases and to direct marketing (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT BY US ON THE BASIS OF ART. 6 PAR. 1 LIT. E OR F OF GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS DATA PROTECTION DECLARATION. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CANNOT VERIFY YOUR IDENTITY, OR IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS (OBJECTION PURSUANT TO ARTICLE 21 (1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS CONNECTED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA. 2 GDPR).

Right of appeal to the competent supervisory authority

In the event of a breach of the GDPR, data subjects have a right of appeal to a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged breach. The right of appeal is without prejudice to other administrative or judicial remedies. You can reach the competent supervisory authority at the following address:

Agencia Española de Protección de Datos | AEPD

• C/ Jorge Juan, 6.
• 28001-Madrid
• https://www.aepd.es
• Telefon: 900 293 183

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, deletion and correction

Within the scope of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if applicable, a right to correction or deletion of this data. For this as well as for further questions about personal data, you can contact us at any time.

Right to restrict processing

You have the right to request the restriction of the processing of your personal data. For this purpose, you can contact us at any time. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.

If the processing of your personal data happened/is happening unlawfully, you can request the restriction of the data processing instead of the deletion.

If we no longer need your personal data, but you need it to exercise, defend or enforce legal claims, you have the right to request restriction of the processing of your personal data instead of deletion.

If you have lodged an objection under Article 21(1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, such data may - apart from being stored - only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

Country-Specific Rights (Mexico)

Under Mexico’s Federal Law on Protection of Personal Data Held by Private Parties (the “LFPDPPP”), you have certain rights with respect to your personal data that we have collected and used under certain circumstances, including the following:

• The right to request access to your personal data. Under the right to access, you have the right to request that we provide a portable copy of the personal data that we collect, use, disclose, and (to the extent applicable) sell.
• The right to request the correction of your inaccurate personal data. You also may update or change your information under your account settings.
• The right to request the cancellation (deletion) of your personal data.
• The right to object to our processing of your personal data, including the right to request that we limit our use or disclosure of your personal data.

To make a request under the LFPDPPP and the regulations enacted thereunder, please submit a verifiable request to us by sending us an email at privacy@rpc-partners.com.

State-Specific Rights in the United States

Depending on where you live in the United States, you may have certain rights with respect to personal data that we have collected and used under certain circumstances, which may include the following:

• The right to know particular information regarding our use of your personal data in the past 12 months. Under the right to know, you can request a listing of:
  • Categories of personal data that we have collected
  • Purpose of such use
  • Categories of sources for that information
  • Categories of third parties to whom we have disclosed your personal data
  • Expected retention period for the categories of your personal data
  • If we have collected personal data from another source, available information about that source
  • If we have disclosed your personal data for a business purpose, a list identifying the personal data categories that each category of recipient obtained
  • If we have sold or shared your personal data, a list identifying the personal data categories that each category of recipient purchased or received
• The right to request access to your personal data. Under the right to access, you have the right to request that we provide a portable copy of the personal data that we collect, use, disclose, and (to the extent applicable) sell.
• The right to request deletion of your personal data when we no longer need such data in connection with our Website or Services.
• The right to request the correction of your inaccurate personal data. You may also update or change your information under your account settings.
• The right to opt out of sales or sharing of your personal data. For clarity, RPC does not sell the personal data of any consumers, nor does it sell or share personal data of minors under 16 years of age and has no actual knowledge of any such sales or disclosures.
• The right to limit the use or disclosure of your sensitive personal information. For clarity, we do not collect or use sensitive personal information.
• The right to non-discrimination for exercising your rights.

When you or someone legally authorized to act on your behalf makes a consumer request related to your personal data, you can expect the following:

1. We will verify your identity. You will need to provide us with certain information, as relevant, so that we can verify that you are who you say you are. Which information may depend on the type and sensitivity of information subject to the request.
2. We will confirm our receipt of your request.
3. We will respond to your request within the legally required amount of time. If necessary, we may need additional time to respond where allowed by law, but we will reply either way within the legally required period and, if we need an extension, we will explain why.
4. In certain cases, a request may be denied. For example, if we cannot verify your identity or if providing you with the information could create an unreasonable risk to someone’s security (for example, we do not want very sensitive information disclosed inappropriately). If we deny your request, we will explain why we denied it. If we deny a request, we will still try to provide you as much of the information as we can, but we will withhold the information subject to denial.

To make a request under the California Consumer Privacy Act, as amended by the California Privacy Rights Act and the regulations enacted thereunder (collectively, the “CCPA”) or other U.S. state data privacy law applicable to the Services, please submit a verifiable request to us by sending us an email at privacy@rpc-partners.com.

6. Data Collection on this Website

Collection of Cookies and Device Data

We may use tracking technologies such as “cookies” on the Website. Cookies are small data packets or files that are downloaded onto your computer or mobile device when you use our Website, which are unique to your device or account. Cookies do not cause any damage to your end device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your end device. Session cookies are automatically deleted at the end of your visit when the web browser is closed. Permanent cookies retain user preferences for a particular website, app, or service, allowing those preferences to be used in future sessions, and remain valid until a set expiration date, until you delete them yourself, or until they are automatically deleted by your web browser.

In some cases, cookies from third-party companies also may be used on our Website. These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain Website functions would not work without them (e.g. the shopping cart function or the display of videos). Cookies make it easier for you to use our Website by saving your preferences so that we can use these to improve your subsequent visits to our Website. Cookies help us learn which areas of our Website are useful and which areas need improvement by allowing us and our service providers to determine how many people visited our websites, the pages that were accessed, and whether there were any technical problems in loading pages. We also use cookie information for security purposes and to display information more effectively, and we may use cookie information to provide advertising content that we think may be of interest to you.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions that you have requested (e.g., for the shopping cart function) or to optimize the Website (e.g., cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 (1) lit. f of GDPR, unless another legal basis is specified. The Website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. Insofar as consent to the storage of cookies and comparable recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG); the consent can be revoked at any time.

You can choose whether to accept cookies by changing the settings on your browser or device. For example, you can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or generally and activate the automatic deletion of cookies when closing the browser. You also can choose whether to accept cookies by interacting with the banner on our Website. If you deactivate cookies, the functionality of this Website may be limited.

If cookies are used by third parties, we will inform you separately within the framework of this data protection declaration and, if necessary, request your consent.

Contact form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6 (1) lit. b GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR) if this has been requested; the consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory legal provisions - in particular retention periods - remain unaffected.

7. Policy on Children’s Information

Our Services are not created for anyone under the age of 13 (“Children” or “Child”). By using the Services, you represent that you are at least 13 years old.  If you do not meet this age requirement, then you must not access or use our Services.

We do not target the Services to Children. If you are a parent or guardian and you are aware that your Child has directly provided us with personal data, please contact us though one of the methods listed under “How to Contact Us” below. If we become aware that we have collected personal data directly from Children without verification of parental consent, we will take reasonable steps to remove that information from our servers.

8. Plugins and Other Sites 

Google Analytics

This Website uses Google Analytics, a web analytics service provided by Google, Inc (hereinafter: Google). Google Analytics uses cookies that enable an analysis of your use of and interaction with the Website. The information generated by the cookie about your use of the Website will be transmitted to and stored by Google on servers in the United States. In the case of activation of IP anonymization on this Website (see below), however, your IP address (if originating outside of the United States) will be truncated beforehand by Google within the Member States of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and then shortened there. On behalf of the operator of this Website, Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services relating to Website activity and internet usage to the Website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this Website. You can also prevent the collection of data generated by the cookie and related to your use of the Website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de. We use Google Analytics to analyze the use of our Website in order to regularly improve the user experience. The statistics obtained allow us to improve our offer and make it more interesting for you. The legal basis for the processing of your data is the consent you have given via the cookie consent tool (Art. 6 para. 1 sentence 1 lit. a) DSGVO).

You can find more information about Google Analytics here:

Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. user terms: https://marketingplatform.google.com/about/analytics/terms/us/, as well as the privacy policy: https://www.google.de/intl/de/policies/privacy.

Other Sites

The Website may contain links to other internet websites. When you click on one of these links, you will be transferred out of the Website and connected to the website of the organization or company that you selected. We are not responsible for the nature, quality or accuracy of the content or opinions expressed on such websites, or of the services provided through such websites. Such websites are not investigated, monitored or checked for quality, accuracy or completeness by us. Inclusion of any linked website on the Website does not imply or express an approval or endorsement of the linked website by us, or of any of the content, opinions, products or services provided on these websites. Even if an affiliation exists between the Website and a third-party website or application, we exercise no control over linked sites. Each of these linked sites maintains its own independent privacy and data collection policies and procedures. We encourage you to visit these websites to find additional related information. We are not responsible for the privacy practices or the content of such websites. Please read the privacy statement of any website you may visit.

9. How to Contact Us

You may update your preferences and information by contacting us at the e-mail address or phone number below. Additionally, if you have any questions or concerns about our use of your Personal Information (defined below), please do not hesitate to contact us through any of the methods below.

• Email: privacy@rpc-partners.com

Last updated and effective as of Nov 6, 2025.

The following privacy notices (this “Privacy Policy”) is provided by the Retail Performance Company GmbH (“RPC,” “our,” “us,” or “we”) to provide a simple overview of what happens to the personal data of our customers, visitors, and users (“you” or “your”) of this website, including the features available through the website, and other platforms and sites operated by Retail Performance Company that reference this Privacy Policy (collectively, the “Website”) and to provide you with information about RPC’s policies regarding the collection, use, storage, and disclosure of information when you visit our Website or use our products or services (together with the Website, the “Services”). This Privacy Policy also describes your choices about the collection and use of your personal data, in accordance with the Personal Information Protection Law (PIPL) of the People's Republic of China, as well as other applicable laws such as the Cybersecurity Law (CSL) and the Data Security Law (DSL).

We reserve the right to update or change this Privacy Policy at any time by posting the amended version, including the effective date of the updated version. You should regularly review this Privacy Policy whenever you access, visit, and/or use the Website or other Services. By using the Website or our Services, you agree to the terms of this Privacy Policy and consent to the collection and use of information in accordance with this Privacy Policy. If you do not agree to be bound by this Privacy Policy, then do not access or use the Website or disclose any personal data to us.

In this Privacy Policy, “personal data” refers to various types of data that are recorded by electronic or other means and related to any identified or identifiable natural person, which excludes anonymized data. “Sensitive personal data” refers to the personal data that is likely to result in damage to one’s dignity or personal or property safety once disclosed or illegally used, such as biometric identification, religious beliefs, specific identity, medical health, financial account and whereabouts and tracked locations, as well as the personal data of minors under the age of 14. Sensitive personal data will be marked in bold for your attention.

Data Controller information

For all data originating for individuals in China the data controller for the Services is :

rpc China

The main establishment of the controller is:

rpc China

• Address: 12-01 Unit, 12th Floor, No. 533 Loushanguan Road, Changning District, Shanghai

E-mail:info@rpc-partners.com

Phone: 021-52319005

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses, etc.).

This Privacy Policy contains the following information:

1. How We Collect and Use Your Data？
• How do we collect your data?
• What information do we collect about you and what do we use your data for?
• Google Analytics
2. How We Share Your Data？
3. Collection of Cookies and Device Data
4. How We Protect and Store Your Data?
   • How we safeguard your data
   • Other Sites
   • Storage Period
   • General information on the legal basis for data processing
5. Cross-Border Data Transfers
• External hosting
6. Your Rights and Choices Regarding Your Information, Art. 44-49 PIPL
• Revocation of your consent to data processing
• Marketing and Advertising Preferences
7. Policy on Children’s Information
8. How to Contact Us

1. How We Collect and Use Your Data？

How do we collect your data?

Who is responsible for the data collection on this Website? The data processing on this Website is carried out by the Website operator. You can find the contact details of the Website operator in the section "Data Controller information".

We collect personal data from you both when you provide it voluntarily and also automatically when you use our Services, including as further described in this section below.

On the one hand, your personal data is collected when you provide it directly to us. This can be, for example, data that you enter when registering an account on the Website, or data you enter into a contact or other webform on the Website.

We also collect personal data about you from third parties in connection with the Website and other Services, including from the following sources:

• Service providers (including our hosting provider)
• Data analytics service providers

Other data is collected automatically or after your consent when visiting the Services by our IT systems. This includes technical data (e.g. Internet browser, operating system or time of page view)that is collected automatically as soon as you enter this Website and is described in “Collection of Cookies and Device Data” below.

What information do we collect about you and what do we use your data for?

The following chart provides information about the types of personal data we may collect, the sources of the information, whether it was disclosed for a business purpose, and the categories of third parties to whom we have disclosed this information for a business purpose in the last twelve (12) months.

Type of Personal Data	Categories of Sources	Purposes
Identifiers such as name, e-mail address, postal address, photograph, unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers.	Direct contact with users through the Services, email, and web form; from subsidiaries and affiliates.	Managing user registration and accounts.
Financial information, such as name, credit card number or debit card number, and billing address or other information related to a billing or payment transaction.	Direct contact with users through the Services; from subsidiaries and affiliates; and from service providers (including payment processors).	Processing payments and managing billing for services.
Commercial information, including records of products or services obtained, or considered, or other purchasing or consuming histories or tendencies.	Direct contact with users through the Services; other tracking technologies; third-party data analytics providers.	Analyzing user interests to recommend relevant services.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, Internal Protocol address, unique personal identifier, online identifier, and information regarding your interaction with an Internet web site, application, form submissions, email unsubscribes and subscribes, email engagement or advertisement.	Through users’ interactions with our Services or with us, including through web forms.	Ensuring website security, and optimizing and personalizing the user experience.
Sensory information, including visual information captured via video recordings.	Through users’ interactions with our Services or and our affiliates and subsidiaries.	Recording training events for documentation.
Professional or employment-related information, including name, email address, company and job title.	Direct contact with users through the Services, email, web form, and from service providers or affiliates.	Understanding users’ professional backgrounds to tailor content, and communicating with users.

Google Analytics

This Website uses Google Analytics, a web analytics service provided by Google, Inc (hereinafter: Google). Google Analytics uses cookies that enable an analysis of your use of and interaction with the Website. The information generated by the cookie about your use of the Website including your IP address is for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services relating to Website activity and internet usage to the Website operator. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this Website.

2. How We Share Your Data？

We may share non-personal data with third parties at our discretion. We do not sell your personal data and have not done so in the past twelve (12) months, though we may share it with our marketing partners or use it to help identify products or services that may be of interest to you. In connection with our Services, we may share your personal data with certain third parties who process it on our behalf to help us run our business, including under the following circumstances:

• Software and service providers we use to manage and process your information
• Affiliates and subsidiaries
• Marketing service providers we use to communication with you
• Hosting providers that provide database storage for our business
• Analytics and site management companies, such as Google Analytics
• Other third parties that you expressly request us to share your personal data to

Additionally, we will share your personal data with third parties where required by law, where it is necessary in connection with our Website or other Services, to protect the safety or property of RPC, our users, employees, or where we have another legitimate interest in doing so.

If we are subject to a merger or acquisition with/by another company, we may share information with them in connection with the transaction.

3. Collection of Cookies and Device Data

We may use tracking technologies such as “cookies” on the Website. Cookies are small data packets or files that are downloaded onto your computer or mobile device when you use our Website, which are unique to your device or account. Cookies do not cause any damage to your end device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your end device. Session cookies are automatically deleted at the end of your visit when the web browser is closed. Permanent cookies retain user preferences for a particular website, app, or service, allowing those preferences to be used in future sessions, and remain valid until a set expiration date, until you delete them yourself, or until they are automatically deleted by your web browser.

In some cases, cookies from third-party companies also may be used on our Website. These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain Website functions would not work without them (e.g. the shopping cart function or the display of videos). Cookies make it easier for you to use our Website by saving your preferences so that we can use these to improve your subsequent visits to our Website. Cookies help us learn which areas of our Website are useful and which areas need improvement by allowing us and our service providers to determine how many people visited our websites, the pages that were accessed, and whether there were any technical problems in loading pages. We also use cookie information for security purposes and to display information more effectively, and we may use cookie information to provide advertising content that we think may be of interest to you.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions that you have requested (e.g., for the shopping cart function) or to optimize the Website (e.g., cookies to measure the web audience) (necessary cookies) are stored in accordance with applicable national laws and regulations. The Website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. Insofar as consent to the storage of cookies and comparable recognition technologies has been requested; the consent can be revoked at any time.

You can choose whether to accept cookies by changing the settings on your browser or device. For example, you can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or generally and activate the automatic deletion of cookies when closing the browser. You also can choose whether to accept cookies by interacting with the banner on our Website. If you deactivate cookies, the functionality of this Website may be limited.

If cookies are used by third parties, we will inform you separately within the framework of this data protection declaration and, if necessary, request your consent.

4. How We Protect and Store Your Data?

How we safeguard your data

We take the protection of your personal data very seriously. We treat your personal data confidentially and strive to use commercially acceptable means to protect your personal data.

We would like to point out that data transmission on the Internet (e.g. communication by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible. Any transmission of personal data is at your own risk.

Other Sites

The Website may contain links to other internet websites. When you click on one of these links, you will be transferred out of the Website and connected to the website of the organization or company that you selected. We are not responsible for the nature, quality or accuracy of the content or opinions expressed on such websites, or of the services provided through such websites. Such websites are not investigated, monitored or checked for quality, accuracy or completeness by us. Inclusion of any linked website on the Website does not imply or express an approval or endorsement of the linked website by us, or of any of the content, opinions, products or services provided on these websites. Even if an affiliation exists between the Website and a third-party website or application, we exercise no control over linked sites. Each of these linked sites maintains its own independent privacy and data collection policies and procedures. We encourage you to visit these websites to find additional related information. We are not responsible for the privacy practices or the content of such websites. Please read the privacy statement of any website you may visit.

Storage period

Unless a more specific storage period has been specified within this Privacy Policy or you expressly consent otherwise, your personal data will remain with us until the purpose for the data processing no longer applies unless a longer retention period is required by law. If you assert a legitimate request for deletion or revoke your consent to data processing, your personal data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the personal data will be deleted once these reasons no longer apply.

We also will retain de-identified usage information for internal analysis purposes.

General information on the legal basis for data processing

We process personal data only when one or more of the following legal bases apply:

• With the explicit and informed consent of the individual;
• Where necessary for the performance of a contract;
• Where required to fulfill legal obligations;
• In response to public health emergencies or to protect life, health, or property in emergencies;
• For news reporting or public interest purposes, within a reasonable scope;

• For the personal data collected from publicly available information within a reasonable scope.
• As otherwise permitted by applicable laws and regulations.

5. Cross-Border Data Transfers

External hosting

This Website is hosted externally with a third-party service provider. The personal data collected on this Website is stored on the servers of the host(s). As the host(s) is located overseas, your personal data will be transferred cross-border. The details of cross-border data transfer are listed as follows:

Name of the Overseas Recipient	Contact Information	Purpose of Processing	Method of Processing	Categories of Personal Data	Means and Procedures for Exercising Rights
D2L Europe Ltd with a registered address in London (c/o Taylor Wessing LLP 5 New Street Square, London, England EC4A 3TW).	[incident@d2l.com]	To provide website hosting, data storage, and infrastructure services.	Storing the data on the recipient’s servers (uses Amazon Web Services’(AWS) data centers located in the Republic of Ireland.	Name, email address and company	Please see Section 8 “How to Contact Us” of this Privacy Policy

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. In addition, an agreement has been concluded with the foreign data recipient on the basis of the Chinese Standard Contractual Clauses governing international data transfers. This is a contract required by data protection law, which ensures that this processes the personal data of our Website visitors only according to our instructions and in compliance with the PIPL, CSL and DSL.

6. Your Rights and Choices Regarding Your Information, Art. 44-49 PIPL

Individuals have the right to:

• Access and obtain a copy of their personal data;
• Request correction or deletion;
• Withdraw consent at any time;
• Restrict or object to certain processing activities;
• Request an explanation of automated decision-making.
• Transfer their personal data to the designated data controller.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke an already given consent at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Marketing and Advertising Preferences

By providing your telephone number and/or email address to us via the Services, you consent to receive phone calls and/or emails from us in connection with the Services. You can opt out from receiving future marketing communications from us at any time, for example, by using the unsubscribe function in the email you receive from us, replying “STOP” to a text message, or by contacting us as set forth in “How to Contact Us” below. Even if you opt out of receiving marketing messages, we may still contact you for transactional purposes like confirming or following up on an order or service request. If you later opt back into getting marketing communications from us, we will remove your information from our opt-out databases.

You may opt out of how companies unaffiliated with us use tracking tools and collect your information while visiting our websites by visiting each of their privacy policies and following instructions there. Please note that we and other companies may still collect information when you are online, and opting out through these mechanisms does not opt you out of being served advertising. You will continue to be served generic ads while online.

Additionally, some web browsers have “Do Not Track” settings that enable you to request that our Website does not track your movement within our Website. However, these features are not yet uniform, so we do not currently respond to such settings when transmitted to and detected by our Website. Therefore, if you opt to activate your browser’s “do not track” feature in your web browser, we and our third-party providers may continue collecting information about your online activities as described in this Privacy Policy. This does not change our compliance in any other way with our Privacy Policy. You may opt to activate your browser’s do not track settings.

7. Policy on Children’s Information

Our Services are not created for anyone under the age of 14 (“Children” or “Child”). By using the Services, you represent that you are at least 13 years old.  If you do not meet this age requirement, then you must not access or use our Services.

We do not target the Services to Children. If you are a parent or guardian and you are aware that your Child has directly provided us with personal data, please contact us though one of the methods listed under “How to Contact Us” below. If we become aware that we have collected personal data directly from Children without verification of parental consent, we will take reasonable steps to remove that information from our servers.

8. How to Contact Us

You may update your preferences and information by contacting us at the e-mail address or phone number below. Additionally, if you have any questions or concerns about our use of your personal data, please do not hesitate to contact us through any of the methods below.

Phone: 021-52319005

Email: info@rpc-partners.com

I have fully understood and consent to this Privacy Policy.

I have fully understood and consent to the processing of my sensitive personal data in accordance with this Privacy Policy.

I have fully understood and consent to provide my personal data to overseas recipient(s) in accordance with this Privacy Policy.