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Privacy Police

 

1) Information on the collection of personal data and contact details of the person responsible.

1.1 We are pleased that you are visiting our website and thank you for your interest. In the following, we inform you about the handling of your personal data when using our website. Personal data is any data that can be used to identify you personally.

1.2 The controller of data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Eva Eulenstein, Eulenstein Coaching, Rotunda Simón Bolívar, 8500-820 Portimão, Portugal  Tel.: +351922263037, e-mail: info@eulenstein-coaching.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.

1.3 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 person responsible). You can recognize an encrypted connection by the string "https://" and the lock symbol in your browser line.

 

2) Data collection when visiting our website

During the mere informational use of our website, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (so-called "server log files"). When you call up 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 came to the site - Browser used
- Operating system used
- IP address used (if applicable: in anonymized form)

The processing is carried out in accordance with Art. 6 para. 1 lit. f DSGVO on the basis of our legitimate interest in improving the stability and functionality of our website. A transfer or other use of the data does not take place. However, we reserve the right to check the server log files retrospectively if there are concrete indications of illegal use.

 

3) Hosting

Hosting by Wix
We use the website building system of Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo, Israel ("Wix") for the purpose of hosting and displaying the website on the basis of processing on our behalf. All data collected on our website is processed on Wix's servers. As part of the aforementioned services provided by Wix, data may also be transferred to Wix Inc, 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA, as part of further processing on our behalf. In the event that data is transferred to Wix in Israel, the appropriate level of data protection is guaranteed by adequacy decision of the European Commission. For further information on data protection by Wix, please visit the following website: https://de.wix.com/about/privacy.
The scope of the processing of personal data is described below. Further processing on servers other than the aforementioned of Wix takes place only within the framework communicated below.

 

4) Cookies

In order to make visiting our website more attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your terminal device. Some of the cookies we use are deleted after the end of the browser session, i.e. after you close your browser (so-called session cookies). Other cookies remain on your terminal device and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). If cookies are set, they collect and process certain user information such as browser and location data and IP address values to an individual extent. Persistent cookies are automatically deleted after a specified period of time, which may vary depending on the cookie.

If personal data is also processed by individual cookies implemented by us, the processing is carried out in accordance with Art. 6 (1) lit. b DSGVO either for the execution of the contract or in accordance with Art. 6 (1) lit. f DSGVO to protect our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.

We may work with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). If we cooperate with aforementioned advertising partners, you will be informed individually and separately about the use of such cookies and the scope of the information collected in each case within the following paragraphs.

Please note that you can set your browser so that you are informed about the setting of cookies and can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general. Each browser differs in the way it manages cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You can find these for the respective browsers under the following links:

Internet Explorer: http://windows.microsoft.com/de-DE/windows-vista/Block-or-allow-cookies
Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
Chrome: http://support.google.com/chrome/bin/answer.py?hl=de&hlrm=en&answer=95647 Safari: https://support.apple.com/de-de/guide/safari/sfri11471/mac
Opera: http://help.opera.com/Windows/10.20/de/cookies.html

Please note that if you do not accept cookies, the functionality of our website may be limited.

 

5) Contacting

When contacting us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. The legal basis for the processing of this data is our legitimate interest in responding to your request in accordance with Art. 6 (1) lit. f DSGVO. If your contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b DSGVO. Your data will be deleted after final processing of your request. This is the case when the circumstances indicate that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

 

6) Online appointment

Calendly
This website uses the "Calendly" software of the provider Calendly, LLC, BB&T Tower, 271 17th St NW, Atlanta, GA 30363, USA to provide an online appointment booking function.
For the purpose of assigning appointments, first and last name as well as email address (and possibly the telephone number, if a telephone appointment is desired) are collected in accordance with Art. 6 Para. 1 lit. b DSGVO and transmitted to Calendly in accordance with Art. 6 Para. 1 lit. f DSGVO on the basis of our legitimate interest in effective customer management and efficient appointment management and stored there for the appointment organization. This may also result in data transfers to the servers of Calendly, LLC, in the USA.

After the appointment has been held or after the agreed appointment period has expired, your data will be deleted by Calendly. We have concluded an order processing agreement with Calendly, in which we oblige Calendly to protect the data of our customers in accordance with the legal requirements. Details of Calendly's privacy policy can be found here: https://calendly.com/de/pages/privacy

 

7) Use of customer data for direct advertising 7.1 Registration for our e-mail newsletter

If you subscribe to our e-mail newsletter, we will send you information about our offers on a regular basis. Mandatory information for sending the newsletter is only your e-mail address. The provision of further data is voluntary and will be used to address you personally. For sending the newsletter we use the so-called double opt-in procedure. This means that we will only send you an e-mail newsletter after you have expressly confirmed that you consent to receiving newsletters. We will then send you a confirmation e-mail asking you to confirm that you wish to receive the newsletter in the future by clicking on an appropriate link.

By activating the confirmation link, you give us your consent for the use of your personal data in accordance with Art. 6 para. 1 lit. a DSGVO. When you register for the newsletter, we store your IP address entered by your 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 e-mail address at a later date. The data collected by us when you register for the newsletter is used exclusively for the purpose of addressing you in an advertising manner by way of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the person responsible mentioned at the beginning. After unsubscribing, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data or we reserve the right to use your data in a manner that goes beyond this, which is permitted by law and about which we inform you in this declaration.

7.2 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, such as those already purchased, from our range by e-mail. In accordance with Section 7 (3) of the German Unfair Competition Act (UWG), we do not need to obtain your separate consent for this. In this respect, the 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 DSGVO. If you have initially objected to the use of your e-mail address for this purpose, no e-mails will be sent by us. You are entitled to object to the use of your e-mail address for the aforementioned advertising purpose at any time with effect for the future by notifying the responsible person named at the beginning. For this, you will only incur transmission costs according to the prime rates. After receipt of your objection, the use of your e-mail address for advertising purposes will cease immediately.

 

8) Use of social media: social plugins 8.1 Instagram plugin as shariff solution

Our website uses so-called social plugins ("plugins") of the online service Instagram, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland ("Facebook").

In order to increase the protection of your data when visiting our website, these buttons are not unrestricted plugins, but are only integrated into the page using an HTML link. This type of integration ensures that when you call up a page of our website that contains such buttons, no connection is yet established with the servers of Instagram. When you click on the button, a new browser window opens and calls up the Instagram page, where you can interact with the plugins there (possibly after entering your login data).

For the purpose and scope of the data collection and the further processing and use of the data by Instagram, as well as your rights in this regard and setting options for protecting your privacy, please refer to Instagram's privacy policy: https://help.instagram.com/155833707900388/

8.2 LinkedIn plugin as shariff solution

Our website uses so-called social plugins ("plugins") of the online service LinkedIn, which is operated by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ("LinkedIn").

In order to increase the protection of your data when visiting our website, these buttons are not unrestricted plug-ins, but are only integrated into the page using an HTML link. This type of integration ensures that when you call up a page of our website that contains such buttons, no connection is yet established with the servers of LinkedIn. When you click on the button, a new browser window opens and calls up the LinkedIn page, where you can interact with the plugins there (possibly after entering your login data).

For the purpose and scope of the data collection and the further processing and use of the data by LinkedIn, as well as your rights in this regard and setting options for protecting your privacy, please refer to LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy

 

9) Tools and other

- Zoom
We use the "Zoom" service of Zoom Video Communications Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA (hereinafter "Zoom") to conduct online meetings, video conferences and/or webinars.
In the case of the use of Zoom, different data are processed. Here, the scope of the processed data depends on the data you provide before or during participation in an online meeting or video conference or webinar. In the course of using Zoom, data of communication participants is processed and stored on Zoom servers. This data may include, in particular, your login data (name, email address, phone (optional) and password) and meeting data (topic, participant IP address, device information, description (optional)). In addition, visual and auditory contributions of the participants, as well as voice input in chats may be processed.
When processing personal data that is necessary for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures), Art. 6 (1) lit. b DSGVO serves as the legal basis. If you have given us your consent for the processing of your data, the processing is based on Art. 6 (1) a DSGVO. Consent given can be revoked at any time with effect for the future.
Otherwise, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest pursuant to Art. 6 (1) lit. f DSGVO in the effective conduct of the online meeting, webinar or video conference. For more information on Zoom's use of data, please see Zoom's privacy policy at https://zoom.us/docs/de-de/privacy-and-legal.html.

 

10) Rights of the data subject

10.1 The applicable data protection law grants you comprehensive data subject rights (rights of access and intervention) vis-à-vis the controller with regard to the processing of your personal data, which we inform you about below:

- Right to information pursuant to Art. 15 DSGVO: You have in particular the right to information about your personal data processed by us, the processing purposes, the categories of personal data processed, the recipients or categories of recipients to whom your data have been or will be disclosed, the planned storage period or criteria for determining the storage period. the criteria for determining the storage period, the existence of a right to rectification, erasure, restriction of processing, objection to processing, complaint to a supervisory authority, the origin of your data if it has not been collected from you by us, the existence of automated decision-making, including profiling, and, if applicable, meaningful information about the logic involved and the scope and intended effects of such processing that concern you, as well as your right to be informed about what guarantees exist in accordance with Art. 46 of the GDPR if your data is transferred to third countries;
- Right to rectification pursuant to Art. 16 DSGVO: You have the right to have any inaccurate data relating to you corrected without delay and/or to have any incomplete data stored by us completed;

- Right to erasure pursuant to Art. 17 DSGVO: You have the right to request the erasure of your personal data if the requirements of Art. 17 (1) DSGVO are met. However, this right does not exist in particular if the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims;
- Right to restriction of processing pursuant to Art. 18 GDPR: You have the right to request the restriction of the processing of your personal data as long as the accuracy of your data, which you dispute, is being verified; if you refuse the erasure of your data due to unlawful data processing and instead request the restriction of the processing of your data; if you require your data for the assertion, exercise or defense of legal claims after we no longer need this data after the purpose has been achieved; or if you have lodged an objection for reasons relating to your particular situation as long as it has not yet been determined whether our legitimate grounds prevail;
- Right to information in accordance with Art. 19 DSGVO: If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients.
- Right to data portability pursuant to Art. 20 DSGVO: You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another controller, insofar as this is technically feasible;
- Right to revoke consent given in accordance with Art. 7 (3) DSGVO: You have the right to revoke consent to the processing of data once given at any time with effect for the future. In the event of revocation, we will delete the data concerned without delay, unless further processing can be based on a legal basis for processing without consent. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation;
- Right to lodge a complaint pursuant to Art. 77 GDPR: If you consider that the processing of personal data concerning you infringes the GDPR, you have - without prejudice to any other administrative or judicial remedy - the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the

Location of the alleged violation.

 

10.2 RIGHT OF OBJECTION

IF WE PROCESS YOUR PERSONAL DATA IN THE CONTEXT OF A BALANCING OF INTERESTS ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE AT ANY TIME ON GROUNDS ARISING FROM 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 PROCESSING THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING IS FOR THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH MARKETING. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

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

11) Duration of the storage of personal data

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

When processing personal data on the basis of explicit consent pursuant to Art. 6 (1) a DSGVO, this data is stored until the data subject revokes his or her consent.

If there are statutory retention periods for data that is processed within the scope of legal or quasi-legal obligations on the basis of Art. 6 Para. 1 lit. b DSGVO, this data will be routinely deleted after expiry of the retention periods, insofar as it is no longer required for the fulfillment or initiation of the contract and/or there is no continued legitimate interest on our part in further storage.

When processing personal data on the basis of Art. 6(1)(f) DSGVO, this data is stored until the data subject exercises his or her right to object pursuant to Art. 21(1) DSGVO, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

When processing personal data for the purpose of direct marketing based on Art. 6 (1) lit. f DSGVO, this data is stored until the data subject exercises his or her right to object pursuant to Art. 21 (2) DSGVO.

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

 

Copyright © 2021, IT-Recht-Kanzlei - Alter Messeplatz 2 - 80339 Munich Tel: +49 (0)89 / 130 1433 - 0- Fax: +49 (0)89 / 130 1433 - 60

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