Privacy Policy

Content

1) Introduction and contact details of the controller

1.1 We are pleased that you are visiting our website and thank you for your interest. In the following, we will inform you about how we handle your personal data when you use our website. Personal data is all data with which you can be personally identified

1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Franziska Bewer, Let’s Talk German, Reinickendorfer Straße 67, 13347 Berlin, Deutschland, Tel.: 030/72291901, E-Mail: f.bewer@lets-talk-german.com. The controller of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

2) Data collection when visiting our website

2.1 If you use our website for information purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the data that your browser transmits to the site server (so-called “server log files”). When you visit our website, we collect the following data, which is technically necessary for us to display the website to you:

– Our visited website

– Date and time at the time of access

– Amount of data sent in bytes

– Source/reference from which you reached the page

– Browser used

– Operating system used

– IP address used (if applicable: in anonymized form)

Processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files retrospectively if there are concrete indications of unlawful use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string “https://” and the lock symbol in your browser line.

2.3 This website is hosted by an external service provider (hoster). The personal data collected on this website is stored on the hoster’s servers. Our hoster will only process your data to the extent necessary to fulfill its performance obligations and follow our instructions with regard to this data.

We use the following hoster:

manitu GmbH
Welvertstraße 2
66606 St. Wendel
Germany

Data processing

We have concluded an data processing contract (DPA) with the above-mentioned provider. This is a contract prescribed by data protection law, which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3) Contact and communication

3.1 We use the services of the following provider to provide an online appointment booking function: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA

For the purpose of making appointments, first and last name and email address (and telephone number if a telephone appointment is requested) are collected in accordance with Art. 6 para. 1 lit. b GDPR and transmitted to the provider in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in effective customer management and efficient appointment management and stored there for the purpose of organizing appointments.

After the appointment has been held or after the agreed appointment period has expired, your data will be deleted by the provider.

We have concluded an data processing contract with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.

For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

3.2 When you contact us (e.g. via contact form or email), personal data is processed exclusively for the purpose of processing and responding to your request and only to the extent necessary for this purpose.

The legal basis for the processing of this data is our legitimate interest in responding to your request in accordance with Art. 6 para. 1 lit. f GDPR. If your contact is aimed at a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR. Your data will be deleted if it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

We use the following systems for these purposes

a) Pipedrive of the provider Pipedrive OÜ. Pipedrive OÜ is a limited liability company under Estonian law (EU) with the address Mustamäe tee 3a, 10615 Tallinn, Estonia, registered in the Estonian Commercial Register under the code 11958539. You can access Pipedrive’s privacy policy here: https://www.pipedrive.com/en/privacy.

b) Microsoft365 of the provider Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18 D18 P521 (hereinafter: “Microsoft”). Further information on the handling of your data can be found in Microsoft’s privacy policy (https://privacy.microsoft.com/de-de/privacystatement)

4) Data processing when opening a customer account

In accordance with Art. 6 para. 1 lit. b GDPR, personal data will continue to be collected and processed to the extent necessary if you provide it to us when opening a customer account. The data required to open an account can be found in the input mask of the corresponding form on our website.

Deletion of your customer account is possible at any time and can be done by sending a message to the above-mentioned address of the controller. After deletion of your customer account, your data will be deleted, provided that all contracts concluded through it have been fully processed, there are no legal retention periods to the contrary and we have no legitimate interest in further storage.

5) Use of customer data for direct advertising

5.1 Registration for our email newsletter

If you register for our e-mail newsletter, we will send you regular information about our offers. The only mandatory information for sending the newsletter is your e-mail address. The provision of further data is voluntary and is used to address you personally. We use the so-called double opt-in procedure for sending newsletters, which ensures that you only receive newsletters if you have expressly confirmed your consent to receive the newsletter by clicking on a verification link sent to the email address provided

By activating the confirmation link, you give us your consent to use your personal data in accordance with Art. 6 para. 1 lit. a GDPR. We store your IP address entered by the Internet service provider (ISP) as well as the date and time of registration in order to be able to trace any possible misuse of your email address at a later date. The data we collect when you register for the newsletter is used strictly for the intended purpose.

You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending a corresponding message to the controller named at the beginning. Once you have unsubscribed, your email address will be deleted from our newsletter mailing list immediately, unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law and about which we inform you in this declaration.

5.2 Sending the e-mail newsletter to existing customers

If you have provided us with your e-mail address when purchasing goods or services, we reserve the right to regularly send you offers for similar goods or services to those already purchased from our range by e-mail. In accordance with Section 7 (3) UWG, we do not need to obtain separate consent from you for this. In this respect, data processing is carried out solely on the basis of our legitimate interest in personalized direct advertising in accordance with Art. 6 para. 1 lit. f GDPR. If you have initially objected to the use of your email address for this purpose, we will not send you any emails.

You are entitled to object to the use of your email address for the aforementioned advertising purpose at any time with effect for the future by sending a message to the controller named at the beginning. You will only incur transmission costs for this in accordance with the basic rates. Upon receipt of your objection, the use of your e-mail address for advertising purposes will be discontinued immediately.

6) Data processing for order processing

6.1 Insofar as necessary for contract processing for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 para. 1 lit. b GDPR.

If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we process the contact data (name, address, email address) provided by you when placing the order in order to inform you personally by suitable means of communication (e.g. by post or email) about upcoming updates within the legally prescribed period as part of our statutory information obligations pursuant to Art. 6 para. 1 lit. c GDPR. Your contact details will be used strictly for the purpose of notifying you of updates owed by us and will only be processed by us for this purpose to the extent necessary for the respective information.

Zur Abwicklung Ihrer Bestellung arbeiten wir ferner mit dem / den nachstehenden Dienstleister(n) zusammen, die uns ganz oder teilweise bei der Durchführung geschlossener Verträge unterstützen. An diese Dienstleister werden nach Maßgabe der folgenden Informationen gewisse personenbezogene Daten übermittelt.

6.2 Use of payment service providers (payment services)

– Paypal

One or more online payment methods of the following provider are available on this website: PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg

If you select a payment method of the provider for which you make advance payment, the payment data you provide during the ordering process (including name, address, bank and payment card information, currency and transaction number) as well as information about the content of your order will be passed on to the provider in accordance with Art. 6 para. 1 lit. b GDPR. In this case, your data will only be passed on for the purpose of payment processing with the provider and only to the extent that it is necessary for this purpose.

If you select a payment method for which we make advance payments, you will also be asked to provide certain personal data (first and last name, street, house number, zip code, city, date of birth, e-mail address, telephone number, data on an alternative means of payment, if applicable) during the order process.

In order to safeguard our legitimate interest in determining your solvency in such cases, we will forward this data to the provider for the purpose of a credit check in accordance with Art. 6 para. 1 lit. f GDPR. On the basis of the personal data provided by you and other data (such as shopping cart, invoice amount, order history, payment experience), the provider checks whether the payment option you have selected can be granted with regard to payment and/or bad debt risks.

The credit report may contain probability values (so-called score values). If score values are included in the result of the credit report, they are based on a scientifically recognized mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data.

You can object to this processing of your data at any time by sending a message to us or to the provider. However, the provider may still be entitled to process your personal data if this is necessary for contractual payment processing.

– WooCommerce Payments

One or more online payment methods from the following provider are available on this website: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110-4929, USA

If you select a payment method of the provider for which you make an advance payment (such as credit card payment), the payment data you provide during the ordering process (including name, address, bank and payment card information, currency and transaction number) and information about the content of your order will be passed on to the provider in accordance with Art. 6 para. 1 lit. b GDPR. In this case, your data will only be passed on for the purpose of payment processing with the provider and only to the extent that it is necessary for this purpose.

For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

7) Web analysis services

Matomo

This website uses a web analysis service from the following provider: InnoCraft Ltd, 150 Willis St, 6011 Wellington, New Zealand, (“Matomo”)

To protect site visitors, Matomo uses a so-called “config_id” to enable various analyses of site usage within a short time window of up to 24 hours. The site’s “config_id” is a randomly set, time-limited hash of a limited set of the visitor’s settings and attributes. The config_id or config hash is a string that is calculated for a visitor based on their operating system, browser, browser plugins, IP address and browser language. Matomo does not use device fingerprinting and uses an anonymized IP address of the site visitor to create the “config_id”.

If the information processed in this way includes personal user data, the processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in the statistical analysis of user behavior for optimization and marketing purposes. To object to the future processing of your visitor data, we provide you with a separate opt-out option on our website.

If data collected using Matomo technology (including your pseudonymized IP address) is transferred to Matomo servers in New Zealand and processed for usage analysis purposes, we inform you that the European Commission has issued a so-called adequacy decision for New Zealand, which certifies compliance with European data protection standards for international data transfers.

If data is also transferred to the provider’s server and the web analysis service is not installed locally on our server, we have concluded an order processing contract with the provider that ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.

Cookie-free analysis

We have configured Matomo so that it does not store any cookies in your browser.

Hosting

We host Matomo with us.

Opt-out

You have the option of completely deactivating the analysis of your use of our website:

  • You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.

8) Video conferences

8.2 Jitsi Meet

We use this provider to conduct online meetings, video conferences and/or webinars: 8×8, Inc, 675 Creekside Way, Campbell, California 95008, USA

The provider processes different data, whereby the scope of the data processed depends on the data you provide before or during participation in an online meeting, video conference or webinar. Your data is processed as a communication participant and stored on the provider’s servers. In particular, this may include your login data (name, email address, telephone number (optional) and password) and session data (topic, participant IP address, device information, description (optional)).

In addition, image and audio contributions from participants and voice input in chats may be processed.

Art. 6 para. 1 lit. b GDPR serves as the legal basis for the processing of personal data required for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures). If you have given us your consent to process your data, the processing is carried out on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time with effect for the future.

In addition, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest in the effective conduct of the online meeting, webinar or video conference in accordance with Art. 6 para. 1 lit. f GDPR.

We have concluded an order processing contract with the provider, which ensures the protection of the data of our site visitors and prohibits unauthorized disclosure to third parties.

For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

8.3 Microsoft Teams

We use this provider to conduct online meetings, video conferences and/or webinars: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA

The provider processes different data, whereby the scope of the data processed depends on the data you provide before or during participation in an online meeting, video conference or webinar. Your data is processed as a communication participant and stored on the provider’s servers. In particular, this may include your login data (name, email address, telephone number (optional) and password) and session data (topic, participant IP address, device information, description (optional)).

In addition, image and audio contributions from participants and voice input in chats may be processed.

Art. 6 para. 1 lit. b GDPR serves as the legal basis for the processing of personal data required for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures). If you have given us your consent to process your data, the processing is carried out on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time with effect for the future.

In addition, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest in the effective conduct of the online meeting, webinar or video conference in accordance with Art. 6 para. 1 lit. f GDPR.

We have concluded an order processing contract with the provider, which ensures the protection of the data of our site visitors and prohibits unauthorized disclosure to third parties.

For data transfers to the USA, the provider has signed up to the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

8.4 Zoom

We use this provider to conduct online meetings, video conferences and/or webinars: Zoom Video Communications Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA

The provider processes different data, whereby the scope of the data processed depends on the data you provide before or during participation in an online meeting, video conference or webinar. Your data is processed as a communication participant and stored on the provider’s servers. In particular, this may include your login data (name, email address, telephone number (optional) and password) and session data (topic, participant IP address, device information, description (optional)).

In addition, image and audio contributions from participants and voice input in chats may be processed.

Art. 6 para. 1 lit. b GDPR serves as the legal basis for the processing of personal data required for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures). If you have given us your consent to process your data, the processing is carried out on the basis of Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time with effect for the future.

In addition, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest in the effective conduct of the online meeting, webinar or video conference in accordance with Art. 6 para. 1 lit. f GDPR.

We have concluded an order processing contract with the provider, which ensures the protection of the data of our site visitors and prohibits unauthorized disclosure to third parties.

For the transfer of data to the USA, the provider relies on standard contractual clauses of the European Commission, which are intended to ensure compliance with the European level of data protection.

9) Training organization

We store relevant data for the organization of a smooth training run. This includes your name, email address, telephone number (if applicable) and your organization. We also store training information such as dates (date, time) and the thematic content of your training course.

For these purposes, we use the CRM system Pipedrive of the provider Pipedrive OÜ on the basis of contract fulfillment (Art. 6 para. 1 lit. b) GDPR).

Pipedrive OÜ is a limited liability company under Estonian (EU) law with the address Mustamäe tee 3a, 10615 Tallinn, Estonia, registered in the Estonian Commercial Register under the code 11958539. You can access Pipedrive’s privacy policy here: https://www.pipedrive.com/en/privacy. Die Datenschutzerklärung von Pipedrive können Sie hier abrufen: https://www.pipedrive.com/en/privacy.

10) Rights of the data subject

10.1 The applicable data protection law grants you the following data subject rights (information and intervention rights) vis-à-vis the controller with regard to the processing of your personal data, whereby reference is made to the stated legal basis for the respective exercise requirements:

– Right of access pursuant to Art. 15 GDPR;

– Right to rectification pursuant to Art. 16 GDPR;

– Right to erasure pursuant to Art. 17 GDPR;

– Right to restriction of processing pursuant to Art. 18 GDPR;

– Right to information pursuant to Art. 19 GDPR;

– Right to data portability pursuant to Art. 20 GDPR;

– Right to withdraw consent granted pursuant to Art. 7 para. 3 GDPR; 3 DSGVO;

– Right to lodge a complaint pursuant to Art. 77 GDPR.

10.2 RIGHT TO OBJECT

IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST IN THE CONTEXT OF A BALANCING OF INTERESTS, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME WITH EFFECT FOR THE FUTURE ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO CONTINUE PROCESSING IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS.

IF YOUR PERSONAL DATA IS PROCESSED BY US 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. YOU CAN EXERCISE YOUR RIGHT TO OBJECT AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

11) Duration of storage of personal data

The duration of the storage of personal data is determined by the respective legal basis, the purpose of processing and – if applicable – additionally by the respective statutory retention period (e.g. retention periods under commercial and tax law).

When processing personal data on the basis of express consent in accordance with Art. 6 para. 1 lit. a GDPR, the data concerned will be stored until you withdraw your consent.

If there are statutory retention periods for data that is processed within the scope of legal or similar obligations on the basis of Art. 6 para. 1 lit. b GDPR, this data will be routinely deleted after the retention periods have expired, provided that it is no longer required for contract fulfillment or contract initiation and/or we no longer have a legitimate interest in further storage.

When processing personal data on the basis of Art. 6 para. 1 lit. f GDPR, this data is stored until you exercise your right to object in accordance with Art. 21 para. 1 GDPR, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.

When processing personal data for the purpose of direct marketing on the basis of Art. 6 para. 1 lit. f GDPR, this data will be stored until you exercise your right to object in accordance with Art. 21 para. 2 GDPR.

Unless otherwise stated in the other information in this declaration on specific processing situations, stored personal data will be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.

Data protection declaration (German version) by IT-Recht-Kanzlei

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