Privacy Policy Version 1.2 (Archive)

Kiron Terms of Service


The UN High Commissioner for Refugees identified thatrefugees and students in crisis regions face particular challenges accessinghigher education due to lack of legal documentation, school certificates,payment of international student fees, and available university placements. Thisreality prohibits people from living up to their potential and produces highintegration costs for hosting countries.

Kiron Open Higher Education is a non-governmentalnon-profit organization (gGmbH) whose mission is to reduce the barriers refugeesface accessing higher education. Kiron’s primary goal is to help integraterefugees into the higher education system the fastest way possible.

Article 1:General 

These general terms and conditions (hereinafterreferred to as “Terms”) shall govern the relationship between you and Kiron withregard to the use of Kiron’s platform, currently available under Kiron’s website (hereinafter referred to as“Platform”), Kiron’s apps and/or any other services that Kiron may offer fromtime to time (collectively hereinafter referred to as “Services”).

Article 2: Study Service and CourseProgram

1. The Kiron Platform was designed to assist refugees incommencing studies in certain subjects prior to being able to complete allformal requirements to officially enrol in public or privateuniversities.

2. Kiron maintains partnerships with various providers ofmassive open online courses (“MOOCS”). This enables Kiron to offer its usersspecial terms and exclusive offers for the use of and enrolment in theseMOOCS.

3. Kiron aggregates MOOCS from various providers to compilecomprehensive curricula in various subjects (“Kiron Course Programs”). The KironCourse Programs may attribute credit points to each MOOC. These are mereestimations of the expected credit points to be recognized byuniversities.

4. Kiron has entered into memoranda of understanding withvarious universities and is looking to reach agreement with these universitieswith regard to enabling Kiron users to enrol into these universities. Theprimary goal is to reach agreement with these universities on the recognition ofcredits and qualifications obtained by our users from our partnering MOOCproviders.

5. In addition to aggregating relevant course information,offering special terms with MOOC providers and liaising with universitiesregarding the recognition of courses, Kiron also offers further services to itsusers from time to time. The Services may include a buddy-programme, mentoring,language school, career service, study hubs, and corporate mentorship. TheServices may be offered during the time of preparation for enrolment atuniversities, during enrolment and (as an alumni network or in other forms) forthe time after completing a university degree.

6. Kiron is also activelypursuing partnerships with other service providers that may assist Kiron usersin their activities and careers (e.g. mentoring, coaching, development ofspecific skills). Certain Services may be provided by or in collaboration withsuch third party service providers.

7. We point out that MOOCS are offeredby third parties and that the user will have to enter into additional serviceagreements with the respective provider of a MOOC. Kiron cannot assume anyliability for the performance of such third party MOOC providers. Kironspecifically highlights that any course can be cancelled, interrupted,rescheduled or modified in its content and that this may, amongst others, affectthe likelihood of such course being recognized at all or the ECTS valueassociated to it by any university.

8. Kiron does not itself offeruniversity degrees, nor is Kiron directly involved in the selection orapplication process used by any university. Kiron’s involvement is strictlylimited to identifying and/or proposing suitable universities and trying toreach a common understanding and/or assessment with regard to the recognition ofcredit points obtained by users in MOOCS. Kiron cannot however guarantee or takeany responsibility for a university’s decision whether or not to admit aPlatform user or whether or not to recognize specific courses or a certainnumber of credit points obtained by a Platform user.

Article 3:Registration Requirements

Users need to create an account on the Platformto use the Platform itself and to benefit from the Services. To complete theregistration process submission of the following items shall berequired:

1. Confirmation of refugee status:

a. Access to thePlatform and to the Services is strictly limited to refugees. For the purposesof these Terms a “refugee” shall be any person who is recognized by any state asa refugee or as applicant for refugee status. Kiron may request evidence toverify the user’s refugee status by requesting copies of one or more of thefollowing documents:

i. residence permit (German:“Aufenthaltserlaubnis”)

ii. permission to reside (German:“Aufenthaltsgestattung”)

iii. a confirmation of temporary suspension ofdeportation (German: “Duldung”)

iv. the recognition of refugee status fromany state

v. the recognition of refugee status from the United NationsHuman Rights Council (UNHCR)

vi. a document certifying subsidiaryprotection status

vii. a document that states the start of an asylumapplication

viii. a certification of a representative of astate-organization or a renowned NGO,

ix. a self-certification of Germanresidence (accepted only for refugees living in a refugee camp and when suchcertification is countersigned by the camp manager).

b. At least oneof the above documents shall be submitted with the user’s application. Kironreserves the right to request additional documents or to suspend or reject aregistration application, until further evidence is provided.

2. The usermust provide evidence of sufficient English skills. Such evidence may beprovided by any of the following documents:

a. by an English test offeredby Kiron in cooperation with a one of its partners.

b. other proof ofEnglish proficiency can be brought forward by other standards in consultationwith Kiron.

3. Trial MOOCS: The user shall successfully complete one ormore trial MOOC. This shall serve to demonstrate that the user is suitable forthe specific challenges of online studying.

4. Motivation Letter:The user must compose a motivation letter in which he/she shall lay out his/herinner drive, experience, qualifications and motivation. This is a formalrequirement only. The contents of the motivation letter will not be part of theevaluation process for the acceptance of an application.

5. A minormust submit the consent of his/her legal representative in textform.

Article 4: Application Process

1. In order to complete theregistration process the user must provide Kiron with his/her real name and theinformation requested in Kiron’s application form.

2. Uponcompletion of the application process, Kiron provides the user with an e-mailaddress in the format [username] This email addresswill be a mere forwarding email and will not have a pop3 or imap mailbox. Itshall serve providers of MOOCS for the purpose of verifying the user’seligibility to special conditions for Kiron users and to attribute the user’sresults to the Kiron user account.

Article 5: Participating in MOOCS

1. Tobe able to benefit from special terms for Kiron users, the user shall use hisKiron email address when registering with MOOC providers.

2. For thepurpose of benefiting from the Service and to participate in MOOCS a web-enableddevice (preferably a personal computer) with a high speed connection isrequired.

3. Kiron may from time to time provide users with computerhardware and/or software enabling them to use the Kiron Services or toparticipate in Kiron Course Programs. However, Kiron shall be not be under anobligation to do so and/or have a responsibility to secure such equipment forall users. It shall be the user’s sole responsibility to secure availability ofall necessary hardware, software and internet access to participate in MOOCS asand when he wishes to participate in MOOCS and/or to benefit from Services. Thisalso includes the need to maintain a sufficient internet connection and datatraffic plans as may be necessary at user’s sole cost.

Article 6: MiscellaneousProvisions

1. Kiron reserves the right to change theseTerms. Kiron will inform its users prior to making such changes and give you theopportunity to review the revised terms before continuing to use Kiron’sServices.

2. A user’s continued use of the Kiron Services, followingnotice of the changes to these Terms of use shall constitute an acceptance ofthe amended Terms.

3. Each Party may terminate this agreement at anytime.

4. If any provision of these terms of use is or becomes invalid,such invalidity shall not affect the validity of the remainingprovisions.

5. These terms of service and any claims resulting therefromshall be governed by the laws of the Federal Republic of Germany excluding theprovisions on international private law and excluding the provisions of theUnited Nations Convention on Contracts for the International Sale ofGoods.

6. Based on Regulation (EU) No 524/2013 on online disputeresolution for consumer disputes the European Commission has established anonline dispute resolution platform under the URL can use this platform to address any disputes they might have withKiron.


Effectiveon: 15th March 2016

Data Privacy is an important topic for us and we holdthe protection of your personal data in very high esteem. We comply with theprovisions of the German Federal Data Protection Act and the German TelemediaAct as well as with applicable EU privacy regulations and would like to informyou on the processing of your personal data in connection with the use of theKiron platform accessible under

1. Data controller

Personal data ofusers of the Kiron platform will be collected, processed and used bythe

Kiron Open Higher Education gGmbH(haftungsbeschränkt)

Am Festungsgraben 1

10117 Berlin,Germany

(hereinafter: “Kiron“ or We”).

2. Categories of data collected, processed and used byKiron

We collect, process and/or use your personal data only ifand where you have consented or such processing or use is permitted by law, e.g.if necessary to carry out our legal obligation resulting from your participationon the Kiron platform.

Kiron may collect, process and use the content andother information users provide when using the services, including the datasubmitted for signing up for an account, creating or sharing, and messaging orcommunicating with others on the website. Such information mayinclude:

− First and last name

− Date of birth

− Phonenumber (optional)

− Address (optional)

− Nationality


− Level of education

− Study program

− Refugeestatus

− Status paper

− E-mail address


Furthermore Kiron may receive information about the users andtheir academic activities on and off the service from third-party partners, suchas information from a partner-university on the choice of subject, study record,period of study, results of completion.

In addition, the followingdata may be collected during the use of the Kiron platform:

− Protocoldata,

o Browser type/browser version,

o The name of your internetprovider,

o The referrer, i.e. the site from which you visit us,

oThe name of the requested files and

o The retrieval time.

−Location-orientated data.

Protocol and location-orientated data is solelyused to improve our services and are not linked to your personalprofile.

In the event that you ordered the Kiron newsletter, the followingdata will be collected, processed and used by us:

− Name,

−E-mail address.

3. Purpose of thecollection, processing and use of personal data

Unless otherwiseindicated, Kiron collects, processes or uses the personal data you have providedvia the Kiron Platform or in handwritten form for the followingpurposes:

− for identification purposes and/or to ensure the users statusas “refugee”,

− to process your registration for the Kiron platform and tocreate a respective user account,

− to deliver our services, personalizecontent and to enable you to participate on the Kiron platform,

− to grantaccess to your profile on the Kiron platform,

− for anonymous, internal,statistic market research purposes in order to help us improving ourservices,

− to inform you about our products and recent developments andto contact you in case of questions in connection with the Kironplatform,

− for scientific purposes in order to conduct academic surveysand research, such as evaluating key performance indicators, social impact andscientifically analyse the services,

− to inform you on changes withregard to this Data Privacy Policy or our Terms of Services.

4. Disclosure of personal data to thirdparties

Kiron uses service providers in order to operate andmaintain the Kiron platform. The service providers will process the dataexclusively in accordance with the instructions of Kiron and have been obligedto comply with the applicable data protection regulations. Kiron and itsassigned service providers will take reasonable technical and organizationalprecautions in order to protect the data of the users.

Other than in theaforementioned cases Kiron will not transmit your personal data to any thirdparties, unless we are obliged to do so because of legal regulations (e.g.disclosure to courts or law enforcement authorities), you have given us yourexplicit consent, or the disclosure is permitted by law. A disclosure may forexample be permitted when such disclosure is required for us to be able torender our services to the user on the Kiron platform (e.g. transfer of personaldata to our MOOC-partners).


In order to optimize our services, we use cookies ondifferent pages of the Kiron platform. Cookies are small text files that arestored on your device. Some of the cookies will be deleted at the end of yourbrowser session (so-called session cookies). Other cookies may remain on yourdevice and allow us to identify your browser the next time you visit the Kironplatform (so-called persistent cookies).

You can set your browser so thatit enables you to decide in each case whether or not to accept or reject allcookies or specific cookies being installed by a webpage. In case ofnon-acceptance of cookies, the functionality of the Kiron platform may belimited.

6. GoogleAnalytics

We use Google Analytics, a web analytics serviceprovided by Google, Inc. (“Google”). Google Analytics also uses theaforementioned cookies, which are text files placed on your computer, to helpthe website analyze how users use the site. The information generated by thecookie about your use of the website will be transmitted to and stored by Googleon servers in the United States. In case IP-anonymization is activated on thiswebsite, your IP address will be truncated within the area of Member States ofthe European Union or other parties to the Agreement on the European EconomicArea. Only in exceptional cases will the whole IP address be first transferredto a Google server in the USA and truncated there. The IP-anonymization isactivated on this website.

Google will use this information on behalf ofKiron for the purpose of evaluating your use of the website, compiling reportson website activity and providing other services relating to website activityand internet usage to Kiron.

The IP-address that your browser transmitswithin the scope of Google Analytics will not be associated with any other dataheld by Google. You may refuse the use of cookies by selecting the correspondingsettings on your browser, however please note that if you do this you may not beable to use the full functionality of this website. You can also opt-out frombeing tracked by Google Analytics with effect for the future by downloading andinstalling Google Analytics opt-out browser addon for your current web browser:

Youmay also configure your browser in a way that permanently prevents it fromtransmitting any data to Google servers (e.g. by installing add-ons likeNoScript or Ghostery for Firefox).

As an alternative to the browser addonor for browsers on mobile devices, you can click this link[RA SSC1] in order toopt-out from being tracked by Google Analytics on this website in the future(the opt-out applies only for the browser in which you set it and for webpagesunder this domain). An opt-out cookie will be stored on your device, which meansthat you’ll have to click this link again, if you delete yourcookies.

7. Termination ofmembership

You may terminate your membership with the Kironplatform at any time. When terminating your membership, all your personal datawill be completely anonymized with the exception of the data, for which astatutory permission to retain exists.

8.Right to information

You have the right to be informed about yourpersonal data stored in connection with the Kiron platform free of charge. Youcan find the relevant contact details to request such information in Section 11of this Data Privacy Policy.

9.Modification of this data privacy policy

We may modify thisPolicy from time to time and adjust it according to the underlying dataprocessing. When we make changes to this Policy we will inform users on ourwebsite, via app or via e-mail.

10.Questions, suggestions and comments

If you have any queriesconcerning the processing of your personal data you may send us your query viaemail to or via mail to:

Kiron Open Higher EducationgGmbH (haftungsbeschränkt)

Am Festungsgraben 1

10117 Berlin,Germany