This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
The data processing on this website is carried out by BRIDGEHOUSE Holding GmbH. You can find our contact details in the imprint of this website.
Types of data processed:
– Inventory data (e.g., names, addresses).
– Contact data (e.g., email, phone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., web pages visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of affected persons
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as “users”).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Answering contact requests and communication with users.
– Security measures.
– Reach measurement/marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by 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 natural person.
“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data.
“Pseudonymization” means the processing of personal data in such a way 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 organizational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
“Controller” means the natural 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 natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
Relevant legal bases
The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 DSGVO, the legal basis for processing for the performance of our services and implementation of contractual measures and responding to requests is Art. 6(1)(b) DSGVO, the legal basis for processing for the performance of our legal obligations is Art. 6(1)(c) DSGVO, and the legal basis for processing for the protection of our legitimate interests is Art. 6(1)(f) DSGVO. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.
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, transfer, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, deletion of data, and response to data compromise. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Article 25 of the GDPR).
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (order processors or third parties), transmit it to them or otherwise grant them 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, such as payment service providers, is required for the performance of the contract pursuant to Art. 6 (1) lit. b DSGVO), 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 agreement”, this is done on the basis of Art. 28 DSGVO.
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 is done in the context of using third-party services or disclosing or transferring data to third parties, this is only done if it is done to fulfill our (pre-) contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. DSGVO are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection that corresponds to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
Rights of the data subjects
You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 DSGVO.
You have according to Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
In accordance with Article 17 of the GDPR, you have the right to demand that the data in question be deleted without delay or, alternatively, to demand restriction of the processing of the data in accordance with Article 18 of the GDPR.
You have the right to request to receive the data concerning you that you have provided to us in accordance with Article 20 of the GDPR and to request its transfer to other data controllers.
You also have the right to lodge a complaint with the competent supervisory authority pursuant to Art. 77 DSGVO.
Right of withdrawal
You have the right to revoke given consents according to Art. 7 paragraph 3 DSGVO with effect for the future
Right of objection
You may object to the future processing of data relating to you in accordance with Art. 21 DSGVO at any time. The objection can be made in particular against the processing for purposes of direct marketing.
Cookies and right to object to direct advertising
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. “Temporary cookies”, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie may store, for example, the contents of a shopping cart in an online store or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if it is only their cookies, it is called “first-party cookies”).
If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 DSGVO. Unless expressly stated within the scope of 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 i.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
According to legal requirements in Germany, the storage takes place in particular for 10 years in accordance with §§ 147 Abs. 1 AO, 257 Abs. 1 No. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting vouchers, commercial books, for taxation relevant documents, etc.) and 6 years in accordance with § 257 Abs. 1 No. 2 and 3, Abs. 4 HGB (commercial letters).
According to legal requirements in Austria, storage is carried out in particular for 7 years in accordance with Section 132 (1) BAO (accounting records, vouchers/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real property and for 10 years for records in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
In addition, we process:
– contractual data (e.g., subject matter of the contract, term, customer category).
– payment data (e.g., bank details, payment history)
of our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Order processing in the online store and customer account
We process the data of our customers in the context of the order processes in our online store to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.
The processed data includes inventory data, communication data, contract data, payment data and the persons affected by the processing include our customers, prospective customers and other business partners. The processing is carried out for the purpose of providing contractual services in the context of operating an online store, billing, delivery and customer services. Here, we use session cookies to store the shopping cart content and permanent cookies to store the login status.
The processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. In this context, the information marked as required is necessary for the justification and fulfillment of the contract. We disclose the data to third parties only in the context of delivery, payment or in the context of legal permissions and obligations to legal advisors and authorities. The data is only processed in third countries if this is necessary for the fulfillment of the contract (e.g. at the request of the customer for delivery or payment).
Users can optionally create a user account, in which they can view their orders in particular. As part of the registration process, users are 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 with regard to the user account will be deleted, subject to their retention is necessary for commercial or tax reasons in accordance with Art. 6 para. 1 lit. c DSGVO. Information in the customer account remains until its deletion with subsequent archiving in the event of a legal obligation. It is the responsibility of the users to save their data in the event of termination before the end of the contract.
Within the scope of registration and renewed logins as well as the use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the users’ protection against misuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c DSGVO.
The deletion takes place after the expiry of legal warranty and comparable obligations, the necessity of keeping the data is reviewed every three years; in the case of legal archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation).
We process the data of our customers within the framework of our contractual services, which include conceptual and strategic consulting, implementation of training concepts/coaching/processes/handling, consulting services and training services.
In doing so, we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing. Data subjects include our customers, prospective customers as well as 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 is from Art. 6 para. 1 lit. b DSGVO (contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimization, security measures). We process data that is necessary for the justification and fulfillment of the contractual services and point out the necessity of their indication. 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 as well as the legal requirements of a commissioned processing pursuant to Art. 28 DSGVO and do not process the data for any other purposes 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, deletion takes place after their expiry (6 years, in accordance with § 257 para. 1 HGB, 10 years, in accordance with § 147 para. 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.
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 (1) lit. b) DSGVO in order to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose and the necessity of the processing, are determined by the underlying contractual relationship. The processed data basically includes inventory and master data of the clients (e.g., name, address, etc.), as well as contact data (e.g., e-mail address, telephone, etc.), contract data (e.g., services used, fees, names of contact persons, etc.), coaching content (documentation for the preparation and/or follow-up of the sessions), and payment data (e.g., bank details, payment history, etc.).
The deletion of the data takes place when the data is no longer required for the fulfillment of contractual or legal duties of care as well as dealing with any warranty and comparable obligations, whereby the necessity of the retention of the data is reviewed every three years; in all other respects, the legal retention obligations apply.
We process the data of our contractual partners and interested parties as well as other clients, customers, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. DSGVO, in order to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose and the necessity of its 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).
As a matter of principle, we do not process special categories of personal data, unless these are components of a commissioned or contractual processing.
We process data that is necessary for the justification and fulfillment of the contractual services and point out the necessity of its disclosure, unless this is evident for the contractual partners. Disclosure to external persons or companies is made only if it is necessary in the context of a contract. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client as well as the legal requirements.
When using our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of users in protection against abuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims pursuant to Art. 6 para. 1 lit. f. DSGVO or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. DSGVO.
The deletion of the data takes place when the data is no longer required for the fulfillment of contractual or legal duties of care as well as for dealing with any warranty and comparable obligations, whereby the necessity of the retention of the data is reviewed every three years; otherwise, the legal retention obligations apply.
Business analyses and market research
In order to operate our business economically and to be able to identify market trends and the wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc… In doing so, we process inventory data, communication data, contract data, payment data, usage data, and metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with details, for example, of the services they have used. The analyses serve us to increase the user-friendliness, the optimization of our offer and the business management. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated values.
If these analyses or profiles are personal, they will be deleted or anonymized upon termination by the user, otherwise after two years from the conclusion of the contract. Otherwise, the macroeconomic analyses and general tendency determinations are created anonymously, if possible.
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user’s details are processed for the purpose of handling the contact request and its processing pursuant to Art. 6 (1) lit. b) DSGVO. The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.
We delete the requests if they are no longer necessary. We review the necessity every two years. Furthermore, the legal archiving obligations apply.
The hosting services used by us serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services, which we use for the purpose of operating this online offering.
We, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer pursuant to Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO. Art. 28 DSGVO (conclusion of order processing contract).
Collection of access data and log files
We, or rather our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data about each 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.
Log file information is stored for security reasons (e.g. to clarify acts of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and the Internet. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with IP anonymization enabled. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser is not merged with other data from Google. Users may prevent the storage of cookies by selecting the appropriate settings on their browser software; users may 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 plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
Users’ personal data is deleted or anonymized after 14 months.
Integration of third-party services and content
Within our online offer, we use content or service offers of third-party providers on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) 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 requires that the third-party providers of this content perceive the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information 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, time of visit and other information about the use of our online offer, as well as be combined with such information from other sources.
Created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke