Data Protection Declaration
This data protection declaration clarifies the type, scope and purpose of the processing of
personal data (hereinafter referred to as “data”) within our online offer and the associated
websites, functions and content as well as external online presences, such as our social media
profile (hereinafter collectively referred to as “online offer”). With regard to the terms used, such
as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection
Regulation (GDPR).
Responsible Person
Annegret Unterbusch-Schwarzkopf (Owner)
Language Coach Excellence
Erich-Weinert-Straße 22
10439 Berlin
www.lce-berlin.de
info@lce-berlin.de
Types of data processed:
- Inventory data (e.g., names, addresses).
- Contact data (e.g., e-mail, telephone numbers).
- Content data (e.g., text entries, photographs, videos).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of Data Subjects
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively
as “users”).
Purpose of the processing
- Provision of the website, its functions and content.
- Answering contact enquiries and communicating with users.
- Security measures.
- Reach measurement/marketing
Terminology Used
“Personal data” means any information relating to an identified or identifiable individual
(hereinafter referred to as “data subject”); an identifiable individual is one who can be identified,
directly or indirectly, in particular by reference to an identifier such as a name, an identification
number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the
physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
“Processing” means any operation or set of operations which is performed on personal data or
on sets of personal data, whether or not by automated means. The term is broad and covers
practically any handling of data.
“Pseudonymisation” means the processing of personal data in such a manner that the personal
data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to
technical and organisational measures to ensure that the personal data are not attributed to an
identified or identifiable individual.
“Profiling” means any form of automated processing of personal data consisting of the use of
personal data to evaluate certain personal aspects relating to a individual, in particular to
analyse or predict aspects concerning that individual’s performance at work, economic situation,
health, personal preferences, interests, reliability, behaviour, location or movements.
Controller” means the individual or legal person, public authority, agency or other body which,
alone or jointly with others, determines the purposes and means of the processing of personal
data.
“Processor” means a individual or legal person, public authority, agency or other body which
processes personal data on behalf of the controller.
Relevant Legal Requirements
In accordance with Art. 13 GDPR, we inform you of the legal requirements of our data
processing. If the legal requirement is not stated in the privacy policy, the following applies; The
legal requirement for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal
requirement for processing to fulfil our services and implement contractual measures and
respond to enquiries is Art. 6 para. 1 lit. b GDPR, the legal requirement for processing to fulfil
our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal requirement for processing to
protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the
data subject or another individual require the processing of personal data, Art. 6 para. 1 lit. d
GDPR serves as the legal requirement.
Security Measures
We take appropriate technical and organisational measures in accordance with Art. 32 GDPR,
taking into account the state of the art, the costs of implementation and the nature, scope,
context and purposes of processing as well as the risk of varying likelihood and severity for the
rights and freedoms of individuals, in order to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of
data by controlling physical access to the data, as well as the access, input, disclosure,
safeguarding of availability and separation of the data. Furthermore, we have established
procedures that ensure the exercise of data subject rights, the deletion of data and the response
to data threats. Furthermore, we take the protection of personal data into account as early as
the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default
settings (Art. 25 GDPR).
Cooperation with Processors and Third Parties
If we disclose data to other persons and companies (processors or third parties) as part of our
processing, transfer it to them or otherwise grant them access to the data, this will only be done
on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment
service providers, is necessary for the fulfilment of the contract in accordance with Art. 6 para. 1
lit. b GDPR), 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 with the processing of 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 occurs in the context of the use of third-party services or
disclosure or transfer of data to third parties, this will only take place if it is done to fulfil 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 authorisations, 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, for example, that the processing takes place on the basis of
special guarantees, such as the officially recognised determination of a level of data protection
corresponding to the EU (e.g. for the USA through the “Privacy Shield”) or compliance with
officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of the Data Recipients
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 GDPR, you have the right to request the completion of data
concerning you or the rectification of inaccurate 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, to demand that the processing of the data be restricted in
accordance with Art. 18 GDPR.
You have the right to request to receive the data concerning you that you have provided to us in
accordance with Art. 20 GDPR and to request its transfer to other controllers.
You also have the right to lodge a complaint with the competent supervisory authority in
accordance with Art. 77 GDPR.
Right of Cancellation
You have the right to withdraw your consent in accordance with Art. 7 para. 3 GDPR with effect
in the future.
Right to Object
You can object to the future processing of data concerning you in accordance with Art. 21
GDPR at any time. In particular, you may object to processing for direct marketing purposes.
Cookies and Right to Object to Direct Marketing
“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 service. Temporary cookies, or
“session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an
online service and closes their browser. The content of a shopping basket in an online shop or a
login status, for example, can be stored in such a cookie. “Permanent” or “persistent” cookies
are cookies that remain stored even after the browser is closed. For example, the login status
can be saved if the user visits the website after several days. The interests of users can also be
stored in such a cookie and used for reach measurement or marketing purposes. “Third-party
cookies” are cookies that are offered by providers other than the controller who operates the
online service (otherwise, if they are only their cookies, they are referred to as “first-party
cookies”).
We may use temporary and permanent cookies and clarify this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the
corresponding option in the system settings of their browser. 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.
A general objection to the use of cookies used for online marketing purposes can be declared
for a large number of services, especially in the case of tracking, via the US website
http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/.
Furthermore, the storage of cookies can be achieved by switching them off in the browser
settings. Please note that you may then not be able to use all the functions of this website.
Deletion of Data
The data processed by us will be deleted or its processing restricted in accordance with Art. 17
and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be
deleted as soon as it is no longer required for its intended purpose and the deletion does not
conflict with any statutory retention obligations. 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 is blocked and not processed for other purposes. This applies, for example, to data that
must be retained for commercial or tax law reasons.
According to legal requirements in Germany, data is stored in particular for 10 years in
accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records,
management reports, accounting vouchers, commercial books, documents relevant for taxation,
etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial
letters).
According to legal requirements in Austria, storage is carried out in particular for 7 years in
accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts,
receipts, business papers, statement of income and expenses, etc.), for 22 years in connection
with real estate and for 10 years for documents in connection with electronically provided
services, telecommunications, radio and television services that are provided to
non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is
used.
Business-Related Processing
We also process;
- Contract data (e.g., subject matter of the contract, term, customer category).
- Payment data (e.g. bank details, payment history) of our customers, interested parties and
business partners for the purpose of providing contractual services, service and customer care,
marketing, advertising and market research.
Agency Services
We process our customers’ data as part of our contractual services, which include conceptual
and strategic consulting, campaign planning, software and design development/consulting or
maintenance, implementation of campaigns and processes/handling, server administration, data
analysis/consulting services and training services.
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 entries, photographs, videos),
contract data (e.g., subject matter of the contract, term), payment data (e.g., bank details,
payment history), usage and metadata (e.g., in the context of analysing 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. The data subjects include our
customers, interested parties and their customers, users, website visitors or employees as well
as third parties. The purpose of the processing is the provision of contractual services, billing
and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b
GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimisation, security
measures). We process data that is required for the justification and fulfilment of contractual
services and point out the necessity of its disclosure. Disclosure to external parties only takes
place if it is necessary in the context 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 of order processing in accordance with Art. 28 GDPR and do not process the data
for any purposes other than those specified in the order.
We delete the data after the expiry of statutory warranty and comparable obligations. The
necessity of storing the data is reviewed every three years; in the case of statutory archiving
obligations, the deletion takes place after their expiry (6 years, in accordance with Section 257
(1) HGB, 10 years, in accordance with Section 147 (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.
Administration, financial accounting, office organisation, contact management
We process data as part of administrative tasks and the organisation of our business, financial
accounting and compliance with legal obligations, such as archiving. In doing so, we process
the same data that we process as part of the provision of our contractual services. The
processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers,
interested parties, business partners and website visitors are affected by the processing. The
purpose and our interest in the processing lies in the administration, financial accounting, office
organisation, archiving of data, i.e. tasks that serve to maintain our business activities, perform
our tasks and provide our services. The deletion of data with regard to contractual services and
contractual communication corresponds to the information specified in these processing
activities.
We disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors
as well as other fee centres and payment service providers.
We also store information on suppliers, event organisers and other business partners on the
basis of our business interests, e.g. for the purpose of contacting them at a later date. We
generally store this mainly company-related data permanently.
Data Protection Information in the Application Process
We process the applicant data only for the purpose and within the scope of the application
procedure in accordance with the legal requirements. Applicant data is processed to fulfil our
(pre-)contractual obligations as part of the application process within the meaning of Art. 6 para.
1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR if the data processing becomes necessary for us, e.g. in
the context of legal proceedings (in Germany, § 26 BDSG also applies).
The application procedure requires that applicants provide us with the applicant data. If we offer
an online form, the necessary applicant data is labelled, otherwise it results from the job
descriptions and basically includes personal details, postal and contact addresses and the
documents belonging to the application, such as cover letter, CV and certificates. Applicants can
also voluntarily provide us with additional information.
By submitting their application to us, applicants consent to the processing of their data for the
purposes of the application process in accordance with the type and scope set out in this
privacy policy.
Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are
voluntarily communicated as part of the application process, their processing is also carried out
in accordance with Art. 9 para. 2 lit. b GDPR (e.g. health data, such as severely disabled status
or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para.
1 GDPR are requested from applicants as part of the application process, their processing is
also carried out in accordance with Art. 9 para. 2 lit. a GDPR (e.g. health data if this is
necessary for the exercise of the profession).
If provided, applicants can send us their applications using an online form on our website. The
data is transmitted to us in encrypted form in accordance with the state of the art.
Applicants can also send us their applications by e-mail. Please note, however, that emails are
generally not sent in encrypted form and applicants must ensure that they are encrypted
themselves. We therefore cannot accept any responsibility for the transmission path of the
application between the sender and receipt on our server and therefore recommend using an
online form or sending it by post. Instead of applying via the online form and e-mail, applicants
still have the option of sending us their application by post.
The data provided by applicants may be processed by us for the purposes of the employment
relationship if the application is successful. Otherwise, if the application for a job offer is
unsuccessful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an
application is withdrawn, which applicants are entitled to do at any time.
Subject to a justified cancellation by the applicant, the deletion will take place after a period of
six months so that we can answer any follow-up questions about the application and fulfil our
obligations to provide evidence under the Equal Treatment Act. Invoices for any reimbursement
of travel expenses will be archived in accordance with tax law requirements.
Making Contact
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user’s
details are processed to process the contact enquiry and its handling in accordance with Art. 6
para. 1 lit. b) GDPR. The user’s details may be stored in a customer relationship management
system (“CRM system”) or comparable enquiry organisation.
We delete the enquiries if they are no longer required. We review the necessity every two years;
the statutory archiving obligations also apply.
Google Analytics
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic
operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use Google
Analytics, a web analytics service. GDPR) Google Analytics, a web analytics service provided
by Google LLC (“Google”). Google uses cookies. The information generated by the cookie
about the use of the online offer by the user is usually transmitted to a Google server in the USA
and stored there.
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 analyse the use of our online offer by users, to
compile reports on the activities within this online offer and to provide us with further services
associated with the use of this online offer and the use of the Internet. Pseudonymised user
profiles can be created from the processed data.
We only use Google Analytics with activated IP anonymisation. This means that the IP address
of users is truncated by Google within member states of the European Union or in other
signatory states to the Agreement on the European Economic Area. Only in exceptional cases
will the full IP address be transmitted to a Google server in the USA and truncated there.
The IP address transmitted by the user’s browser will not be merged with other Google data.
Users can prevent the storage of cookies by setting their browser software accordingly; users
can also prevent the collection of data generated by the cookie and related to their use of the
online offer to Google and the processing of this data by Google by downloading and installing
the browser plug-in available at the following link:
http://tools.google.com/dlpage/gaoptout?hl=de.
Further information on the use of data by Google, setting and objection options, can be found in
Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for the
display of advertisements by Google (https://adssettings.google.com/authenticated).
Users’ personal data is deleted or anonymised after 14 months.
Online Presence in Social Media
We maintain an online presence within social networks and platforms in order to communicate
with the customers, interested parties and users active there and to inform them about our
services. When accessing the respective networks and platforms, the terms and conditions and
data processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process users’ data if they communicate with
us within the social networks and platforms, e.g. write posts on our online presences or send us
messages.
Integration of Third-Party Services and Content
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic
operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or
service offers from third parties within our online offer. GDPR) content or service offers from
third-party providers in order to integrate their content and services, such as videos or fonts
(hereinafter uniformly referred to as “content”).
This always presupposes that the third-party providers of this content recognise the IP address
of the user, as they would not be able to send the content to their browser without the IP
address. The IP address is therefore required to display this content. We endeavour to only use
content whose respective providers only use the IP address to deliver the content. Third-party
providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”)
for statistical or marketing purposes. Pixel tags can be used to analyse information such as
visitor traffic on the pages of this website. The pseudonymous information may also be stored in
cookies on the user’s device and may contain, among other things, technical information about
the browser and operating system, referring websites, visit time and other information about the
use of our online offer, as well as being linked to such information from other sources.
Google Fonts
We integrate the fonts (“Google Fonts”) of the provider Google LLC, 1600 Amphitheatre
Parkway, Mountain View, CA 94043, USA. Privacy policy:
https://www.google.com/policies/privacy/, Opt-Out:
https://adssettings.google.com/authenticated.
Functions and content of the LinkedIn service, offered by inkedIn Ireland Unlimited Company
Wilton Place, Dublin 2, Ireland, may be integrated into our online offering. This may include, for example, content such as images, videos or text and buttons with which users can share
content from this online offering within LinkedIn. If the users are members of the LinkedIn
platform, LinkedIn can assign the access to the above-mentioned content and functions to the
users’ profiles there. LinkedIn privacy policy: https://www.linkedin.com/legal/privacy-policy..
LinkedIn 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=a2zt0000000L0UZAA0&status=Active). Privacy
policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Created with Datenschutz-Generator.de by RA Dr Thomas Schwenke