This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as "Data") within our online offering and the related websites, features and content, as well as external online presence, e.g. our Social Media Profile (collectively referred to as the "Online Offering"). With regard to the terminology used, e.g. "Processing" or "Responsible", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
ResponsibleTomas M. Mielke, M. A.
Keplerstr. 3
10589 Berlin
Germany
info@sprachdesign.de
Legal Notice: https://sprachdesign.de/en-ln.html Types of Processed Data:
- Inventory data (e.g names, addresses)
- contact information (e.g. e-mail, phone numbers)
- content data (e.g. text input, photographs, videos)
- usage data (e.g. websites visited, interest in content, access times)
- meta / communication data (e.g. device information, IP
addresses)
Categories of Persons AffectedVisitors and users of the online offer (hereinafter we refer to the affected persons as "users").
Purpose of Processing
- Providing the online offer, its features and content
- Answering contact requests and communicating with users
- Safety measures
- Audience measurement / marketing
Terms Used"Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "data subject"); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
"Processing" means any process performed with or without the aid of
automated procedures or any such process associated with personal
data. The term includes virtually
every handling of data.
"Pseudonymisation" 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 additional information being provided,
provided that such additional information is kept separate and subject
to technical and organizational measures to ensure that the personal
data
are
not assigned
to an identified or identifiable natural person.
"Profiling" means any kind of automated processing of personal data
which involves the use of such personal data to evaluate certain
personal aspects relating to a natural person, in particular aspects
relating to job performance, economic situation, health, personal
to
analyze or predict preferences, interests, reliability, behavior,
whereabouts or relocation of that natural person.
"Responsible person" means the natural or legal person, public
authority, body or body that decides, alone or in concert with others,
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
controller.
Relevant Legal Bases
In accordance with Art. 13 GDPR, we inform you about
the legal basis of our data processing. Unless
the legal basis in the data protection declaration is mentioned, the
following applies: The legal basis for obtaining consent is Article 6
(1) lit. a and Art. 7 GDPR, the legal basis for
the processing for the performance of our services and the execution
of contractual measures as well as the response to inquiries is Art. 6
(1) lit. b GDPR, the legal basis for processing
in order to fulfill our legal obligations is Art. 6 (1) lit.
c GDPR, and the legal basis for processing in order to
safeguard our legitimate interests is Article 6 (1) lit.
f GDPR. In the event that vital interests of the data
subject or another natural person require the processing of personal
data, Art. 6 para. 1 lit. d GDPR as legal
basis. Security Measures
Subject to Art. 32 GDPR, we shall take appropriate technical measures,
taking into account the state of the art, the implementation costs and
the nature, scope, circumstances and purposes of the processing and
the different likelihood and severity of the risk to the rights and
freedoms of individuals and organizational measures to ensure a level of protection
appropriate to the risk.
Measures include, in particular, ensuring the confidentiality,
integrity and availability of data by controlling physical access to
the data, as well as their access, input, disclosure, availability and
separation.
We have also set up procedures to ensure the enjoyment of data subject
rights, data deletion and data vulnerability.
Furthermore, we consider the protection of personal data already in
the development, or selection of hardware, software and procedures,
according to the principle of data protection through technology
design and privacy-friendly default settings (Article 25 GDPR).
Collaboration with Processors and
Third Parties
If, in the context of our processing, we disclose data
to other persons and companies (contract processors or third parties),
transmit them to them or otherwise grant access to the data, this will
only be done on the basis of a legal permission (e.g.
if a transmission of the data to third parties,
as required by payment service providers, pursuant to Art. 6 (1) (b)
GDPR to fulfill the contract), you have consented to a legal
obligation or based on our legitimate interests (e.g.
the use of agents, webhosters, 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 (ie outside the European Union
(EU) or the European Economic Area (EEA)) or in the context of the use
of third party services or disclosure or transmission of data to third
parties, this will only be done 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 process or have the
data processed in a third country only in the presence of the special
conditions of Art. 44 ff. GDPR. That the processing is e.g.
on the basis of specific guarantees, such as the officially recognized
level of data protection (e.g.
for the US 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 ask for confirmation as to whether relevant data are
being processed and for information about this data as well as for
further information and a copy of the data according to Art. 15 GDPR.
In accordance with Art. 16 GDPR
you have the right to demand the completion of
the data concerning you or the correction of the incorrect data
concerning you.
In accordance with Art. 17 GDPR, they have the right to
demand that the relevant data be deleted without delay, or,
alternatively, to require a restriction on the processing of the data
in accordance with Art. 18 GDPR.
You have the right to demand that the data relating to
you provided to us be obtained in accordance with Art. 20 GDPR and to
request their transmission to other persons responsible.
In accordance with Art. 77 GDPR
you have the right to file a complaint with the
competent supervisory authority.
Right of Revocation
You have the right to revoke granted consent
in accordance with Art. 7 (3) GDPR with effect for the future.
Right
of Objection
You may
at any time object to the future processing of your data in accordance
with Art. 21 GDPR. The objection may in
particular be made against processing for direct marketing purposes.
Cookies and Right to Object
in Direct Mail
"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 the information about a user (or
the device on which the cookie is stored) during or after his visit to
an online offer. Temporary cookies, or "session cookies" or "transient cookies", are
cookies that are deleted after a user leaves an online service and
closes his browser. In such a cookie, e.g.
the contents of a shopping cart in an online shop or a login status
are saved. The term "permanent" or "persistent" refers to cookies that remain
stored even after the browser has been closed.
Thus, e.g. the login status will be saved if users visit it after several days.
Likewise, in such a cookie the interests of the users can be stored,
which are used for range measurement or marketing purposes.
A "third-party cookie" refers to cookies that are offered by providers
other than the person who manages the online offer (otherwise, if it
is only their cookies, this is called "first-party cookies").
We can use temporary and permanent cookies and clarify this in the
context of our privacy policy.
If users do not want cookies stored on their computer, they will be
asked to disable the 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.
A general contradiction to the use of cookies used for online
marketing purposes can be found in a variety of services, especially
in the case of tracking, via the US website
http://www.aboutads.info/choices/ or the EU site
http://www.youronlinechoices.com/ be explained.
Furthermore, the storage of cookies can be achieved by switching them
off in the settings of the browser.
Please note that not all features of this online offer may be used.
Deletion of Data
The data
processed by us are deleted or restricted in their processing in
accordance with Art. 17 and 18 GDPR. Unless explicitly stated in this
privacy policy, the data stored by us are deleted as soon as they are
no longer required for their purpose and the deletion does not
conflict with any statutory storage requirements. Unless the data is
deleted because it is required for other and legitimate purposes, its
processing will be restricted. That The data is blocked and not
processed for other purposes. This applies, for example for data that
must be kept for commercial or tax reasons.
According to legal requirements in Germany, the storage takes place in
particular for 10 years according to sections 147 Abs. 1 AO, 257 Abs.
1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports,
accounting documents, trading books, relevant for taxation Documents,
etc.) and 6 years in accordance with section 257 (1) no. 2 and 3,
para. 4 HGB (commercial letters).
According to legal regulations in Austria the storage takes place
especially for 7 years according to section 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 in the case of
documents relating to electronically supplied services,
telecommunications, broadcasting and television services provided to
non-entrepreneurs in EU Member States and for which the
Mini-One-Stop-Shop (MOSS) is used. Agency Services
We process our clients' data as part of our contractual services,
which include conceptual and strategic consulting, campaign planning,
software and design development / consulting or maintenance, campaign
/ process / handling implementation, server administration, data
analysis / consulting services, and training services.
Here we process stock data (e.g. customer master data, such as names or
addresses), contact data (e.g.e-mail, telephone numbers), content data (e.g. text inputs, photographs, videos), contract data (e.g. subject matter,
term), payment data (bank account, payment history), usage and metadata (e.g. in the context of the evaluation and success measurement of marketing
measures). In principle, we do not process special categories of personal data,
unless these are components of a commissioned processing. Those affected include our customers, prospects and their customers,
users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contract services,
billing and our customer service. The legal basis of the processing results from Art. 6 para. 1 lit. b
GDPR (contractual benefits), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that are necessary for the establishment and
performance of the contractual services and indicate the necessity of
their information. Disclosure to external parties will only be made if required by an
order. When processing the data provided to us within the framework of an
order, we act in accordance with the instructions of the client as
well as with the legal requirements of order processing pursuant to
Art. 28 GDPR and process the data for no other purpose than the order.
We delete the data after expiry of legal warranty and comparable
obligations. The necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place
after its expiry (6 years, pursuant to section 257 (1) HGB, 10 years, in accordance with section
147 (1) AO). If data have been disclosed to us in the context of an order by the
client, we delete the data according to the specifications of the
order, in principle after the end of the order.
Therapeutic Services and
Coaching
We process
the data of our clients and interested parties and other clients or
contractual partners (uniformly referred to as "clients") in
accordance with Art. 6 para. 1 lit. b) GDPR in order to provide them
with our contractual or pre-contractual services. The data processed,
the nature, scope and purpose and necessity of their processing are
determined by the underlying contractual relationship. The processed
data basically include stock and master data of the clients (e.g.
name, address, etc.), as well as the contact data (e.g., e-mail
address, telephone, etc.), the contract data (e.g., services used,
Fees, names of contact persons, etc.) and payment details (e.g. bank
details, payment history, etc.).
As part of our services, we can also special categories of data acc.
Art. 9 para. 1 GDPR, in particular information on the health of
clients, possibly with reference to their sexual life or sexual
orientation, ethnic origin or religious or ideological convictions.
For this we get, if necessary, gem. Art. 6 para. 1 lit. a., Art. 7,
Art. 9 para. 2 lit. a. GDPR expressly consent the clients and process
the special categories of data otherwise for health care purposes on
the basis of Art. 9 (2) (h). GDPR, section 22 para. 1 no. 1 b. Federal
Data Protection Act (Germany).
If required or required by law to perform the contract, we disclose or
disclose client information in the context of communication with other
professionals, those required or typically required to perform the
contract, such as, but not limited to, third parties. Billing agencies
or comparable service providers, provided that this is in line with
the provision of our services in accordance with Art. Art. 6 para. 1
lit b. GDPR serves, legally gem. Art. 6 para. 1 lit c. GDPR is
required by our interests or those of clients in an efficient and
cost-effective health care as legitimate interest. Art. 6 para. 1 lit.
F. GDPR serves or gem. Art. 6 (1) lit. d. GDPR is necessary. to
protect the vital interests of clients or any other natural person, or
in the context of consent in accordance with. Art. 6 para. 1 lit. a.,
Art. 7 GDPR.
The data is deleted if the data for the fulfillment of contractual or
legal duties of care and handling of any warranty and similar
obligations is no longer required, with the necessity of preserving
the data every three years is checked; otherwise the statutory storage
obligations apply.
Contractual Services
We process the data of our contractual partners and interested parties
as well as other clients, customers, clients, clients or contractual
partners (uniformly referred to as "contractual partners") in
accordance with Art. 6 para. 1 lit. b.
GDPR to provide them with our contractual or pre-contractual services.
The data processed, the nature, scope and purpose and necessity of
their processing are determined by the underlying contractual
relationship.
The processed data includes the master data of our contractual
partners (e.g. names and addresses), contact data (e.g. e-mail addresses
and telephone numbers) as well as contract data (e.g. services used,
contract contents, contractual communication, names of contact
persons) and payment data (e.g.bank details, payment history).
In principle, we do not process special categories of personal data,
unless they are part of a contracted or contractual processing.
We process data which are necessary for the establishment and
fulfillment of the contractual services and point out the necessity of
their indication, if this is not evident for the contractual partners.
Disclosure to external persons or companies will only be made if
required by a contract. When processing the data provided to us within the framework of an
order, we act in accordance with the instructions of the client as
well as the legal requirements.
As part of the use of our online services, we can save the IP address
and the time of each user action.
The storage is based on our legitimate interests, as well as the
interests of the user in the protection against misuse and other
unauthorized use.
A transfer of these data to third parties does not take place, unless
it is to pursue our claims according to Art. 6 para. 1 lit. f.
GDPR required or there is a legal obligation according to Art. 6 para. 1 lit. c.
The data will be deleted if the data is no longer required for the
fulfillment of contractual or statutory duties of care and for the
handling of any warranty and comparable obligations, whereby the
necessity of keeping the data is reviewed every three years; otherwise the statutory storage obligations apply.
Google Analytics
Based on our legitimate interests (i.e., interest in the analysis,
optimization and economic operation of our online offer as defined in
Art. 6 (1) f., GDPR) Google Analytics uses 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 users are usually transmitted to a Google server in the
USA and stored there.
Google is certified under the Privacy Shield Agreement, which provides
a guarantee to comply with European privacy legislation (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 further services related to
the use of this online offer and the internet usage. In this case,
pseudonymous usage profiles of the users can be created from the
processed data.
We only use Google Analytics with activated IP anonymization. This
means that the IP address of the users will be 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 US and shortened there.
The IP address submitted by the user's browser will not be merged with
other data provided by Google. Users can prevent the storage of
cookies by setting their browser software accordingly; Users may also
prevent the collection by Google of the data generated by the cookie
and related to its use of the online offer and the processing of such
data by Google by downloading and installing the browser plug-in
available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
For more information about Google's data usage, hiring and disparaging
options, please read Google's Privacy Policy (https://policies.google.com/technologies/ads)
and Google's Ads Ads Settings
(https://adssettings.google.com/authenticated).
The personal data of users will be deleted or anonymized after 14
months.
Targeting with Google Analytics
We use
Google Analytics to display advertisements displayed within Google and
its affiliate advertising services, only those users who have shown an
interest in our online offering or who have certain characteristics
(e.g. interests in specific topics or products visited by them) that we submit to Google (so-called "remarketing" or
"Google Analytics audiences"). With Remarketing
Audiences, we also want to make sure that our ads meet the potential
interest of users.
Google AdWords and Conversion
Measurement
We use the services of Google LLC, 1600
Amphitheater Parkway, Mountain View, CA 94043 on the basis of our
legitimate interests (i.e. interest in the analysis, optimization and
economic operation of our online service within the meaning of Art. 6
(1) (f) GDPR) , USA, ("Google").Google is certified under the Privacy
Shield Agreement, which provides a guarantee to comply with European
data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use Google's online AdWords marketing tool "AdWords" to place ads
on the Google advertising network (e.g., in search results, in videos,
on websites, etc.) so that they are displayed to users who have a
suspected interest in the ads.
This allows us to more specifically display ads for and within our
online offering so that we only present ads to users that potentially
match their interests. If, e.g., a user
are shown ads for products he's been looking for on other online offers
this
is called remarketing.
For these purposes, upon access to our and other websites where Google Advertising Network is active, Google will immediately execute
a Google code and become so-called (re)marketing tags (invisible
graphics or code, also known as "web beacons") incorporated into the website.
With their help, the user is provided with an individual cookie, i.e.
a small file is saved (instead of cookies, comparable technologies can
also be used).In this file is noted which websites the user visited, for what
content he is interested and what offers the user has clicked, as well
as technical information about the browser and operating system,
referring websites, visit time and other information on the use of the
online offer.
Furthermore, we receive an individual "conversion cookie". The information obtained through the cookie is used by Google to
generate conversion statistics for us.
However, we only hear the anonymous total number of users who clicked
on our ad and were redirected to a conversion tracking tag page.
However, we do not receive any information that personally identifies
users.
The data of the users are pseudonym-processed within the Google
advertising network. I.e. Google stores and
processes e.g. not the name or e-mail address of the users, but processes the
relevant data cookie-related within pseudonymous user profiles. I.e. from the perspective of Google, the ads are not managed and displayed
to a specifically identified person, but to the cookie owner,
regardless of who that cookie owner is.
This does not apply if a user has explicitly allowed Google to process
the data without this pseudonymization. The information collected about users is transmitted to Google and
stored on Google's servers in the United States.
For more information about Google's data usage, hiring and opt-out
options, please refer to Google's Privacy Policy (https://policies.google.com/technologies/ads)
as well as in the settings for the display of
advertising impressions by Google (https://adssettings.google.com/authenticated).
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