Privacy Policy

General terms of use for the Circular Learning Space platform (

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General terms of use for the public online learning platform »Circular Learning Space« provided by the EIT RawMaterials GmbH

The following terms are valid for all users of the Circular Learning Space platform (, including EIT RawMaterials and other project affiliates and users of guest accounts. Usage of the learning platform (Moodle Workplace) is approved by the EIT RawMaterials data protection officer.

Storage of personal information

The following personal data need to be electronically stored for the creation of a personal account on the learning platform.

  • Username
  • E-mail address
  • First name and surname
  • City/Town
  • Country
  • Age / Date of Birth
  • Gender
  • Course Language

These data are subject to the applicable data protection rules. Users can create a user account by self-registration. The login data include a username and password, which must be set within the registration process.

Users have the right to be informed, without charge, about stored personal information upon written request.

Disclosure of Personal Information

We are committed to safeguarding your personal information and ensuring that your privacy is protected. Personal information collected through our learning platform is used exclusively for purposes directly related to the operation and improvement of the services we offer. Access to your personal data is strictly limited to parties directly involved in promoting and maintaining the learning platform. These parties are equally committed to protecting your data and are bound by appropriate confidentiality and data protection obligations. They include:

  • JA Europe (Junior Achievement Europe) and Their Local Network Members: For users affiliated with a school that has officially registered with the platform (providing their own tenant URL to users), personal data may be shared with the locally relevant JA member organization. This sharing is specifically for the purpose of monitoring students' progress and providing necessary support to enhance the learning experience. Access is limited to the member organization relevant to the user's geographic location and school affiliation, ensuring that only the necessary data is shared to support the project locally.

  • brainshuttle GmbH: We have commissioned brainshuttle GmbH to assist in the organizational and technical management of the platform. They have access to personal data as necessary to fulfill these responsibilities, ensuring the platform's efficient operation and security.

Apart from the above, personal information will not be passed on to third parties unless you have explicitly permitted the disclosure of your data, or when disclosure is required by legal regulations, such as in response to a lawful request by public authorities.

Edit and delete personal information

Users have the right to have incorrect data corrected, blocked or deleted upon written request. Users can edit their personal data within their accounts at any time. Users may delete their account through the Settings function within the platform or by emailing the provider at

Manual deletion of user accounts during the project results in anonymization and sanitization of all personal data, while statistical user data remains stored for further fulfillment of project-related performance and success monitoring. This data does not allow any subsequent or retroactive identification of the deleted user.

Personal information is stored for the lifetime of the Girls Go Circular project. After the project’s end it is permanently deleted.

Moodle courses and their content will also be stored during the project lifetime.

Storage of further information

On request of a web file within the learning platform the following access information is saved.

  • IP address of the accessing client
  • Date and time of the access
  • Accessed web page
  • Return status code of the web server to the request
  • Size of the delivered file
  • Website that links to the distributing web page („Referer“)
  • In case of an error: error message issued by the web server (information related to errors are stored in a seperate error log).

These data are exclusively saved for technical and statistical purposes. The information, not even parts of it, is not matched to further databases or passed on to third parties. Neither people in charge of courses (e. g. teachers) nor other course participants can access these data. All data transfer is performed under secure conditions.

In addition, all information stated optionally by the user as well as data arising from platform usage is stored. These include learning activity data (progress data related to the consumption of learning lessons, as well as performance data related to conducting of knowledge assessments). These data can be used by teachers and participants only for teaching and learning purposes such as for the completion of  tasks within the courses.

Storage of examination data

Learning data (progress and performance data as well as acquired certificates) is exclusively stored on the learning platform Moodle Workplace, allocated to the respective registered user. These data are lost when the Moodle Workplace data bank is deleted.

Deletion of data

Moodle courses and their content are not deleted during the project lifetime due to the following reasons:

  1. Students can access study-relevant materials even after completion of the respective courses.
  2. Over the lifetime of the project additional courses will be published and users will be able to take these new courses.

Usage of cookies

Cookies (short text information) are used in Moodle Workplace in two forms:

  1. Moodle Session: This cookie is necessary for the login to persist when different pages of the Moodle Workplace platform are accessed. This cookie is deleted as soon as the cache of the user’s web browser is deleted or the user logs out of the Moodle Workplace platform. Usage of this cookie is mandatory.
  2. Moodle Tenant: if this cookie is used, the tenant information affiliated with the user is saved upon first usage and is saved on the Moodle Workplace platform even after logout. Usage of this cookie is mandatory.
  3. Embedded video content from YouTube: embedded videos from YouTube use tracking cookies which transfer data to YouTube/Google. Usage of this cookie is mandatory to ensure accessibility functions (subtitles). Further information provided below.

Use of embedded YouTube videos

This website uses embedded video content from YouTube, a service belonging to Google. YouTube videos are embedded in the courses for educational purposes to enrich the content which is the legitimate interest of this platform’s provider in accordance with the legal basis set out in Art. 6 (1) lit. f GDPR.

The embedded YouTube videos are equipped with subtitles for all languages other than English to make them easily accessible to the target group. Subtitles are displayed as an overlay of the video container. For the realisation of this functionality, a privacy-friendly embedding via YouTube's Privacy-Enhanced Mode (use of no cookie domain) is not possible.

If you open a page with an embedded video, a connection is made to the YouTube servers. At this point YouTube is notified which of our pages you have visited. Google will process and save various data (IP address, our platform’s page on which the video is embedded, etc.). If you are logged into your YouTube account, YouTube may assign your surfing habits to your personal profile. You can only prevent this if you log out of your YouTube account before viewing the video. The provider of this platform has no influence on the transfer of these data.

YouTube videos are embedded with the purpose of making our website more attractive.

Further information about how user data are handled is available in YouTube’s privacy policy:


All materials accessible from the learning platform are protected by copyright, as long as nothing else is explicitly stated. This means that the content provided by the learning platform is designated for personal use and may not be passed on to third parties nor may it be reproduced or changed. This is also true for material that was created by single or multiple users during a course.
All users agree that personally created materials may be used for course purposes. The operators of the learning platform are freed from claims of third parties arising from the noncompliance with copyright.

General usage responsibilities

By registering the user is granted a non-transferable, simple usage right for the learning platform. Activities performed on the platform include exclusively the creation and completion of Moodle Workplace courses in the context of the Girls Go Circular. Any other private or commercial use is expressly prohibited. In case storage space is made available to the user it is exclusively designed for the storage of content created for the learning platform.

All users are obliged to keep information on other participants they can access strictly confidential and must not pass this information on to third parties. Only written consent of the respectively concerned person can constitute an exclusion to this rule. All users of the learning platform may not delete, suppress or change data unauthorizedly. Data may not be used for purposes other than specified above.

In addition, users are obliged to adhere to the provisions of the law in general as well as concerning copyright and data protection. When creating links to external web pages, users have to check that these do not display illicit content.

Users may not put illicit, pornographic, obscene, defamatory, libelous, insulting, threatening, race baiting or racist content on the learning platform. It is also prohibited to put advertisements of any kind on the learning platform, to transfer information containing viruses, errors, manipulations or any other similar harmful element and to upload content that may be harmful to the reputation of EIT RawMaterials or its project partners.

Although only quality, safe and relevant external links should be included in the platform, users should always adopt a policy of caution before clicking any external web links mentioned throughout a web page. If users follow a link to any external web links mentioned throughout the platform, it is to be noted that these external websites have their own privacy policies and that the provider(s) do not accept any responsibility or liability for these policies. Users are advised to check these policies before submitting any personal data to these websites.

Exclusion from usage

If a user offends the terms of use, he or she is asked to abandon his or her behavior. If he or she does not follow this request, he or she is excluded from use of the learning platform for a certain period of time or permanently by the administrators of the learning platform. The user does not have a claim for readmission. A requirement for readmission is, among others, a written request containing a statement that the abusive behavior will, in the future, be refrained from.

Liability of the provider(s)

EIT RawMaterials GmbH is, as operator of the learning platform (together with synergy learning as the technical service provider), only liable for grossly negligent and intentionally committed violations of duty. This is especially true for damages occurring because of download of software or material.

Liability of the user

If a user non- accidently violates the terms of use or legal duties, he or she is liable according to legal regulations.

Changes in the terms of use

EIT RawMaterials GmbH reserves the right to make amendments to or change the terms of use.
Any changes in the terms of use will be announced in written form via the learning platform including a reference to where the changes can be accessed.

Legal effect

These terms of use are to be seen as part of the learning platform that links to this page. Should parts or specific phrases not correspond to the current legal situation, the rest of the document will not be affected by this in content or validity.

Consent to data protection regulations

I am familiar with the information concerning data protection and the terms of use and herewith accept them.

I have taken note of the fact that compulsory personal data are processed when I use the learning platform Circular Learning Space.

I give my consent to the processing of data saved in my user account (personal profile) and of contributions that I disclose under my name. I also give consent to the processing of data that arise from my participation in one or several courses.
This consent can be reviewed on the learning platform’s start page at any time.


Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to: