Data protection guidelines in accordance with GDPR

Status 14.12.2021

This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offering 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 offering"). With regard to the terms used, such as "personal data" or their "processing", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Controller:
Coaching Change UG (haftungsbeschränkt)
Neanderstraße 18
40233 Düsseldorf
Phone: +49 211 176092-30
Email: mail(at)coaching-change.de

Contact person for questions regarding data protection as of 14 December 2021:
Jörg Brockhausen
Coaching Change UG (haftungsbeschränkt)
Neanderstraße 18
40233 Düsseldorf
Phone: +49 211 176092-30
Email: mail(at)coaching-change.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).
• Contract data (e.g., subject matter of the contract, term, customer category).
• Payment data (e.g., bank details, payment history).
• Usage data (e.g., websites visited, interest in content, access times).
• Meta/communication data (e.g., device information, IP addresses).

Processing of special categories of data (Art. 9 para. 1 GDPR):
In principle, no special categories of data are processed unless they are provided by users for processing, e.g. entered in online forms.

Categories of data subjects affected by the processing:

• Customers / interested parties / suppliers.
• Visitors and users of the online offer.

In the following, we also refer to the data subjects collectively as "users".

Purpose of the processing:

• Provision of the online offering, its content and functions.
• Provision of contractual services, service and customer care.
• Answering contact enquiries and communicating with users.
• Marketing, advertising and market research.
• Security measures.

1. relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. If the legal basis is not stated in the privacy policy, the following applies The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing to fulfil our services and implement contractual measures and respond to enquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis 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 natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

2. changes and updates to the privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

3. security measures

3.1 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 natural persons, appropriate technical and organisational measures to ensure a level of security appropriate to the risk; the measures include, in particular, ensuring 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 their separation. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted and we respond 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).

3.2 The security measures include in particular the encrypted transmission of data between your browser and our server.

4 Cooperation with processors and third parties

4.1 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 a legal authorisation (e.g. if a transfer of the data to third parties, such as to payment service providers, is necessary for the fulfilment of the contract pursuant to 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.).

4.2 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.

5 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").

6 Rights of the data subjects

6.1 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.

6.2 You have in accordance with. Art. 16 GDPR, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.

6.3 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.

6.4 You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 GDPR and to request that it be transferred to other data controllers.

6.5 You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.

7. right of cancellation

You have the right to withdraw your consent in accordance with Art. 7 para. 3 GDPR with effect for the future.

8. right to object

You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection can be made in particular against processing for direct marketing purposes.

9. cookies and right to object to direct advertising

We use temporary and permanent cookies, i.e. small files that are stored on users' devices (for an explanation of the term and function, see the last section of this privacy policy). Some of the cookies are used for security purposes or are necessary for the operation of our online services (e.g. to display the website) or to save the user's decision when confirming the cookie banner. In addition, we or our technology partners use cookies for reach measurement and marketing purposes, about which users are informed in the course of the privacy policy.
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 www.aboutads.info/choices/ or the EU website 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 online service.

10 Deletion of data

10.1 The data processed by us will be deleted or restricted in their processing 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 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.

10.2 In accordance with legal requirements, data is stored in particular for 6 years in accordance with Section 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with Section 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.).

11. provision of contractual services

11.1 We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 para. 1 lit b. GDPR. GDPR. The entries marked as mandatory in online forms are required for the conclusion of the contract.

11.2 Users can optionally create a user account in which they can view their orders in particular. As part of the registration process, users will be provided with the required mandatory information. The user accounts are not public and cannot be indexed by search engines. If users have cancelled their user account, their data will be deleted with regard to the user account, subject to their retention is necessary for commercial or tax law reasons in accordance with Art. 6 para. 1 lit. c GDPR. It is the responsibility of users to back up their data before the end of the contract in the event of cancellation. We are authorised to irretrievably delete all user data stored during the term of the contract.

11.3 We store the IP address and the time of the respective user action as part of the registration and renewed logins and utilisation of our online services. This data is stored on the basis of our legitimate interests and those of the user in protection against misuse and other unauthorised use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. c GDPR.

11.4 We process usage data (e.g., the websites visited on our online offering, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile, e.g., to display product information to users based on the services they have used to date.

11.5 The deletion takes place 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 (end of commercial law (6 years) and tax law (10 years) retention obligation); information in the customer account remains until its deletion.

12. making contact

12.1 When contacting us (via contact form or e-mail), the user's details are processed to process the contact enquiry and its handling in accordance with Art. 6 para. 1 lit. b) GDPR.

12.2 The user's details may be stored in our customer relationship management system ("CRM system") or comparable enquiry organisation.

12.3 We delete the enquiries if they are no longer required. We review the necessity every two years; we store enquiries from customers who have a customer account permanently and refer to the details of the customer account for deletion. In the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation).

13 Comments and contributions

13.1 When users leave comments or other contributions, their IP addresses are stored on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR for 7 days. GDPR for 7 days.

13.2 This is done for our security in the event that someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or post and are therefore interested in the identity of the author.

14 Collection of access data and log files

14.1 On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

14.2 Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum period of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

15 Online presence in social media

15.1 On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we maintain online presences within social networks and platforms in order to communicate with 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.

15.2 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.

16. cookies & reach measurement

16.1 Cookies are information that is transferred from our web server or third-party web servers to the user's web browser and stored there for later retrieval. Cookies may be small files or other types of information storage.

16.2 We use "session cookies", which are only stored for the duration of the current visit to our online presence (e.g. to enable the storage of your login status or the shopping basket function and thus the use of our online offer at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and, for example, log out or close the browser.

16.3 Users will be informed about the use of cookies in the context of pseudonymous reach measurement in the context of this data protection declaration.

16.4 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.

16.5 You can object to the use of cookies for reach measurement and advertising purposes via the deactivation page of the Network Advertising Initiative(optout.networkadvertising.org/) and additionally the US website(www.aboutads.info/choices or the European website(www.youronlinechoices.com/uk/your-ad-choices/).

16.6 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.

16.7 Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active

16.8 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.

16.9 We use Google Analytics to display adverts placed by Google and its partners within advertising services only to those users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Google (so-called "remarketing" or "Google Analytics audiences"). With the help of remarketing audiences, we also want to ensure that our adverts correspond to the potential interest of users and are not annoying.

16.10. 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.

16.11. 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 Google from collecting the data generated by the cookie and relating to their use of the online offer and from processing this data by Google by downloading and installing the browser plug-in available under the following link: tools.google.com/dlpage/gaoptout?hl=en.

16.12. For more information about Google's use of data, setting and objection options, please visit Google's websites: www.google.com/intl/de/policies/privacy/partners ("Google's use of data when you use our partners' websites or apps"), policies.google.com/technologies/ads ("Use of data for advertising purposes"), adssettings.google.com/authenticated ("Manage information that Google uses to show you advertising").

16.13. Otherwise, the personal data will be anonymised or deleted after 26 months. Each new visit to our website leads to a reset of the storage period.

17 Facebook social plugins

17.1 We do not use Facebook social plugins. There is only a link to our Facebook pages on our website.

17.2 Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active

17.3 When a user accesses a link on this website, their device establishes a direct connection to the Facebook servers. User profiles can be created from the processed data. We have no influence on the scope of the data that Facebook collects with the help of this link and therefore inform users according to our level of knowledge.

17.4 The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and setting options for protecting the privacy of users, can be found in Facebook's data protection information: www.facebook.com/about/privacy/

17.5 If a user is a Facebook member and does not want Facebook to collect data about them via this online service and link it to their membership data stored on Facebook, they must log out of Facebook and delete their cookies before using our online service. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: www.facebook.com/settings; or via the US site optout.aboutads.info or the EU site www.youronlinechoices.com. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

18 Integration of third-party services and content

18.1 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.

18.2 The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (so-called opt-out):

• Maps of the "Google Maps" service provided by the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: www.google.com/policies/privacy/, Opt-Out: www.google.com/settings/ads/
• Fonts provided by the "Google Fonts" service of the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: www.google.com/policies/privacy/, opt-out: www.google.com/settings/ads/
• Videos from the "YouTube" platform of the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: policies.google.com/privacy, opt-out: adssettings.google.com/authenticated
• Functions of the Twitter service or platform may be integrated into our online offering (hereinafter referred to as "Twitter"). Twitter is a service provided by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The functions include the presentation of our posts within Twitter within our online offering, the link to our profile on Twitter and the possibility to interact with the posts and the functions of Twitter, as well as to measure whether users reach our online offering via the adverts placed by us on Twitter (so-called conversion measurement). Twitter is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active
• Privacy policy: www.twitter.com/de/privacy, opt-out: twitter.com/personalisation
• External code of the JavaScript framework "jQuery", provided by the third-party provider jQuery Foundation, www.jquery.org