This data protection declaration explains the type, scope and purpose of the processing of personal data (hereinafter referred as "data") within our online offers and the websites, functions and content associated with it as well as external online presences, such as our social media profile (hereinafter referred as “Online Offering”). With regard to the terms used, such as "processing" or "person responsible", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
E-Mail-Adress: : datenschutz(at)zp-schulung.de
Managing directors: Annett Reimann, Steffen Reimann
Link to imprint: https://www.zp-schulung.de/en/imprint/
Contact to Data Protection Officer: firstname.lastname@example.org
Types of data processed:
- inventory data (e.g. names, adresses)
- contact details (e.g. mail-adresses, phone numbers)
- content data (e.g. text, photographs, videos)
- Usage data (e.g. websites visited, interests in content, access times)
- Meta/communication data (e.g. device informations, IP addresses)
Categories of data subjects:
Visitors and users of our online offers (hereinafter the persons concerned are collectively referred to as "users").
Purpose of processing:
- Provision of the online offer, its functions and content
- Answering contact requests and communicating with users
- Safety measures
- Reach measurement/marketing
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Processing" is any process or series of processes carried out with or without the aid of automated processes in connection with personal data. The term is broad and encompasses practically every handling of data.
"Pseudonymization" means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is stored separately and is subject to technical and organizational measures that ensure that the personal data not assigned to an identified or identifiable natural person.
"Profiling" is any type of automated processing of personal data, which consists in using this personal data to evaluate certain personal aspects relating to a natural person, in particular aspects related to work performance, economic situation, health, personal Analyze or predict that natural person’s preferences, interests, reliability, behavior, whereabouts or relocation.
The "responsible person" is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
"Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the person responsible.
Relevant legal bases:
In accordance with Art. 13 GDPR, we will inform you of the legal basis for our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 (1) lit. a and Art Answering inquiries is Article 6(1)(b) GDPR, the legal basis for processing to fulfill our legal obligations is Article 6(1)(c) GDPR, and the legal basis for processing to safeguard our legitimate interests is Article 6(1)(c) GDPR 6 Paragraph 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 Paragraph 1 lit. d GDPR serves as the legal basis.
In accordance with Art. 32 GDPR, we take appropriate technical measures, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk for the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.
The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, transfer, securing availability and their separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, deletion of data and reaction to data threats. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Article 25 GDPR).
Cooperation with processors and third parties:
If, as part of our processing, we disclose data to other people and companies (processors or third parties), transmit it to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if the data is transmitted to third parties, as to payment service providers, pursuant to Art. 6 Para. 1 lit. b GDPR is required for the fulfillment of the contract), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts etc.).
If we commission third parties to process data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 GDPR.
Transfers to third countries:
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA) or if this happens as part of the use of third-party services or disclosure or transmission of data to third parties, this will only take place if it is to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or have the data processed in a third country if the special requirements of Art. 44 et seq. GDPR are met. This means that the processing takes place e.g. on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to that of the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
Rights of data subjects:
You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
You have accordingly Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately, or alternatively, in accordance with Art. 18 GDPR, to demand a restriction of the processing of the data.
You have the right to request that you receive the data that you have provided to us in accordance with Art. 20 GDPR and to request that it be transmitted to other responsible parties.
You also have the right, in accordance with Article 77 GDPR, to lodge a complaint with the competent supervisory authority.
Right of withdrawal:
You have the right to revoke your consent in accordance with Article 7 (3) GDPR with effect for the future.
Right to object:
You can object to the future processing of data relating to you at any time in accordance with Art. 21 GDPR. The objection can be made in particular against processing for direct advertising purposes.
Cookies and right to object to direct advertising:
"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the content of a shopping cart in an online shop or a login status can be saved. "Permanent" or "persistent" refers to cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users can also be stored in such a cookie, which are used for range measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only their cookies, we speak of "first-party cookies").
We can use temporary and permanent cookies and explain this in our data protection declaration.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of data:
The data processed by us will be deleted or their processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage requirements. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
According to legal requirements in Germany, storage takes place in particular for 10 years in accordance with §§ 147 Paragraph 1 AO, 257 Paragraph 1 No. 1 and 4, Paragraph 4 HGB (books, records, management reports, accounting documents, trading books, relevant for taxation documents, etc.) and 6 years in accordance with Section 257 Paragraph 1 Nos. 2 and 3, Paragraph 4 HGB (commercial letters).
In addition, we process
- Contract data (e.g. subject matter, term, customer category)
- Payment data (e.g. bank details, payment history)
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
We process our customers data as part of our contractual services, which include conceptual and strategic advice, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.
Hierbei verarbeiten wir Bestandsdaten (z.B., Kundenstammdaten, wie Namen oder Adressen), Kontaktdaten (z.B., E-Mail, Telefonnummern), Inhaltsdaten (z.B., Texteingaben, Fotografien, Videos), Vertragsdaten (z.B., Vertragsgegenstand, Laufzeit),
In doing so, we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text input, photographs, videos), contract data (e.g., subject of the contract, term), payment data (e.g., Bank details, payment history), usage and metadata (e.g. in the context of evaluating and measuring the success of marketing measures). In principle, we do not process special categories of personal data, unless these are part of commissioned processing. Those affected include our customers, interested parties and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is to provide contractual services, billing and our customer service. The legal bases for the processing result from Article 6 Paragraph 1 Letter b GDPR (contractual services), Article 6 Paragraph 1 Letter f GDPR (analysis, statistics, optimisation, security measures). We process data that is required to justify and fulfill the contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is required as part of an order. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client and the legal requirements for order processing in accordance with Article 28 GDPR and do not process the data for any purposes other than the order-related purposes.
We delete the data after the statutory warranty and comparable obligations have expired. the need to keep the data is reviewed every three years; in the case of legal archiving obligations, the deletion takes place after their expiry (6 years, according to § 257 paragraph 1 HGB, 10 years, according to § 147 paragraph 1 AO). In the case of data disclosed to us by the client as part of an order, we delete the data in accordance with the specifications of the order, generally after the end of the order.
Therapeutic services and coaching:
We process the data of our clients and prospects and other clients or contractual partners (uniformly referred to as "clients") in accordance with Article 6 Paragraph 1 Letter b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed here, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. The processed data basically includes inventory and master data of the client (e.g. name, address, etc.), as well as contact data (e.g. e-mail address, telephone number, etc.), contract data (e.g. services used, fees, names of contact persons, etc.) and payment data (e.g., bank details, payment history, etc.).
As part of our services, we can also process special categories of data in accordance with Article 9 Paragraph 1 GDPR, in particular information on the health of the client, possibly with reference to their sex life or sexual orientation, ethnic origin or religious or ideological beliefs . To this end, if necessary, we will obtain, in accordance with Article 6 Paragraph 1 Letter a., Article 7, Article 9 Paragraph 2 Letter a. GDPR an explicit consent of the client and otherwise process the special categories of data for health care purposes on the basis of Art. 9 Para. 2 lit h. GDPR, Section 22 Paragraph 1 No. 1 b. GDPR.
If necessary for the fulfillment of the contract or by law, we disclose or transmit the data of the clients in the context of communication with other specialists, third parties who are required or typically involved in the fulfillment of the contract, such as billing offices or comparable service providers, provided this is necessary for the provision of our services in accordance with Art. 6 paragraph 1 letter b. GDPR serves, according to Art. 6 Para. 1 lit c. GDPR is prescribed, serves our interests or those of our clients in efficient and cost-effective healthcare as a legitimate interest pursuant to Article 6 Paragraph 1 lit f. GDPR or pursuant to Article 6 Paragraph 1 lit d. GDPR is necessary. to protect the vital interests of the client or another natural person or within the scope of consent in accordance with Article 6 Paragraph 1 Letter a., Article 7 GDPR.
The data will be deleted if the data is no longer required to fulfill contractual or legal duties of care or to deal with any warranty and comparable obligations, with the necessity of storing the data being checked every three years; Otherwise, the statutory retention requirements apply.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the user is processed in order to process the contact request and its processing in accordance with Article 6 (1) (b) GDPR. User information can be stored in a customer relationship management system ("CRM system") or comparable inquiry organization.
We delete the requests if they are no longer necessary. We review necessity every two years; furthermore, the statutory archiving obligations apply.
Hosting and email delivery:
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services that we use for the purpose of operating this online offer.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data from customers, interested parties and visitors to this online offer on the basis of our legitimate interests in making this online offer available efficiently and securely in accordance with Art. 6 Para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract).
Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and internet usage. Pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; In addition, users can prevent the data generated by the cookie and related to their use of the online offer being collected by Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de. You can find more information on data use by Google, setting and objection options in Google's data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
The personal data of the users will be deleted or made anonymous after 14 months.
Integration of third-party services and content:
We use content or service offers from third-party providers within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. GDPR) in order to improve their content and Integrate services such as videos or fonts (hereinafter uniformly referred to as "content").
This always presupposes that the third-party providers of this content perceive the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, visiting times and other information on the use of our online offer, as well as being linked to such information from other sources.
We embed the videos from the "YouTube" platform provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data protection declaration: https://policies.google.com/privacy , opt-out: https://myadcenter.google.com/home?sasb=true&ref=ad-settings
We integrate the maps of the “Google Maps” service provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually as part of the settings on their mobile devices). The data can be processed in the USA. Data protection declaration: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.