Record of Processing Activities

This Record of Processing Activities, in line with Article 30(1) of the General Data Protection Regulation (GDPR), offers a compilation of processes where personal data is processed by the controller, alongside the technical and organizational measures in accordance with Article 35 GDPR.

Controller:

Breathwork Breakthroughs GmbH
C/O Invisible Advisory GmbH
Französische Straße 47
10117 Berlin

Registration Number: HRB 253206 B
VAT ID: DE361406280

Date: April 3, 2024

Legal text by Dr. Schwenke - please click for further information.

 

Index

I. Information on the controller
II. Records of Processing Activities
1. Preamble
2. Security Precautions
3. Transmission of Personal Data
4. Erasure of data
5. Changes and Updates to the Privacy Policy
6. Terminology and Definitions
7. Business services
7.1. Coaching
8. Provision of online services and web hosting
8.1. Provision of online offer on rented hosting space
8.2. Collection of Access Data and Log Files
8.3. DomainFactory
8.4. GoDaddy
9. Use of Cookies
9.1. Processing Cookie Data on the Basis of Consent
9.2. BorlabsCookie
10. Blogs and publication media
10.1. Spotify
10.2. Apple Podcasts
10.3. YouTube
11. Contact and Inquiry Management
11.1. Contact form
11.2. Perspective
12. Communication via Messenger
12.1. Instagram
12.2. WhatsApp
13. Video Conferences, Online Meetings, Webinars and Screen-Sharing
13.1. Google Hangouts / Meet
13.2. Zoom
13.3. calendly
14. Audio Content
14.1. Spotify
14.2. Apple Podcasts
14.3. YouTube
14.4. Spotify
14.5. Apple Podcasts
14.6. Spotify
14.7. Apple Podcasts
15. Cloud Services
15.1. Google Workspace
16. Newsletter and Electronic Communications
16.1. Mailchimp
16.2. calendly
17. Web Analysis, Monitoring and Optimization
17.1. calendly
18. Online Marketing
18.1. Perspective
19. Profiles in Social Networks (Social Media)
19.1. Instagram
19.2. LinkedIn
19.3. YouTube
19.4. Spotify
19.5. Apple Podcasts
19.6. YouTube
19.7. YouTube

 

I. Information on the controller

 

CONTROLLER
___________________
Name and Address: Breathwork Breakthroughs GmbH
C/O Invisible Advisory GmbH
Französische Straße 47
10117 Berlin

Registration Number: HRB 253206 B
VAT ID: DE361406280

URL of the legal notice (imprint): https://www.reallyalign.com/imprint/
Email Address: [email protected]

 

II. Records of Processing Activities

 

1. PREAMBLE
___________________
Preamble text: With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as “data”) we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online services”).

The terms used are not gender-specific.

 

2. SECURITY PRECAUTIONS
___________________
Description: We take appropriate technical and organisational measures in accordance with the legal requirements, 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, 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 and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

 

3. TRANSMISSION OF PERSONAL DATA
___________________
Description: In the course of processing personal data, it may happen that this data is transmitted to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include service providers tasked with IT duties or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and particularly conclude relevant contracts or agreements that serve to protect your data with the recipients of your data.

 

4. ERASURE OF DATA
___________________
Description: The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose). If the data is not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. In the context of our information on data processing, we may provide users with further information on the deletion and retention of data that is specific to the respective processing operation.

 

5. CHANGES AND UPDATES TO THE PRIVACY POLICY
___________________
Description: We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.

 

6. TERMINOLOGY AND DEFINITIONS
___________________
Description: In this section, you will find an overview of the terminology used in this privacy policy. Where the terminology is legally defined, their legal definitions apply. The following explanations, however, are primarily intended to aid understanding.

 

7. BUSINESS SERVICES
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Description: We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the context of contractual and comparable legal relationships as well as associated actions and communication with the contractual partners or pre-contractually, e.g. to answer inquiries.

We process this data in order to fulfill our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and economical business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this privacy policy.

Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.

We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons of archiving. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore the record was made or the other documents were created.

Processed data types: Inventory data (e.g. names, addresses); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. e-mail, telephone numbers); Contract data (e.g. contract object, duration, customer category.
Data subjects: Prospective customers; Business and contractual partners.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Contact requests and communication; Office and organisational procedures; Managing and responding to inquiries.
Rechtsgrundlagen: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR.
7.1. Coaching

We process the data of our clients and interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to provide them with our services. The data processed, the type, scope and purpose of their processing and the necessity of their processing are determined by the underlying contractual and client relationship.

Insofar as it is necessary for the fulfilment of our contractual obligations, the protection of vital interests or by law, or with theclients’s consent, we disclose or transfer the clients’s data to third parties or agents, such as public authorities, accounting offices and in the field of IT, office or comparable services, in compliance with professional regulations.

  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR);

 

8. PROVISION OF ONLINE SERVICES AND WEB HOSTING
___________________
Description: We process user data in order to be able to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.
Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status.
Data subjects: Users (e.g. website visitors, users of online services.
Purposes of processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).); Security measures.
Rechtsgrundlagen: Legitimate Interests (Article 6 (1) (f) GDPR.
8.1. Provision of online offer on rented hosting space

For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a “web hoster”.

  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
8.2. Collection of Access Data and Log Files

The access to our online services is logged in the form of so-called “server log files”. Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a general rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability and optimal load balancing of the servers.

  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.;
8.3. DomainFactory

Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities.

  • Service Provider: Domainfactory GmbH, c/o WeWork, Neuturmstrasse 5, 80331 München, Germany.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://www.df.eu;
  • Privacy Policy: https://www.df.eu/de/datenschutz;
8.4. GoDaddy

Domain registration and web hosting services.

  • Service Provider: Go Daddy Operating Company, LLC, 14455 N. Hayden Road, Scottsdale, Arizona 85254, USA.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://www.godaddy.com/;
  • Privacy Policy: https://www.godaddy.com/legal/agreements/privacy-policy;

 

9. USE OF COOKIES
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Description: Cookies are small text files or other types of storage markers that store information on end devices and read information from them. For example, to save the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed, or the functions used of an online offer. Furthermore, cookies can be used for various concerns, such as for the functionality, security, and comfort of online offers as well as the creation of analyses of visitor flows.

Notes on Consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless it is not required by law. Permission is particularly not necessary if the storage and reading of information, including cookies, are absolutely necessary to provide a telemedia service (i.e., our online offer) expressly requested by the users. The revocable consent is clearly communicated to them and contains information on the respective cookie usage.

Notes on the legal basis for data protection: The legal basis on which we process users’ personal data with the help of cookies depends on whether we ask them for consent. If users accept, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies are based on our legitimate interests (e.g., in a commercial operation of our online offer and its usability improvement) or, if this occurs within the fulfillment of our contractual obligations, when the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which the cookies are used by us in the course of this data protection declaration or within the scope of our consent and processing processes.

Storage Duration: Regarding the storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after closing the end device. For example, the login status can be saved and preferred content can be displayed directly when the user revisits a site. Similarly, user data collected via cookies can be used for reach measurement. Unless we provide users with explicit information about the nature and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and the storage duration can be up to two years.

General notes on revocation and objection (Opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing according to legal requirements, also via the privacy settings of their browser.

Rechtsgrundlagen: Legitimate Interests (Article 6 (1) (f) GDPR); Consent (Article 6 (1) (a) GDPR.
Processed data types: Usage data (e.g. websites visited, interest in content, access times.
Data subjects: Users (e.g. website visitors, users of online services.
Purposes of processing: Provision of our online services and usability.
9.1. Processing Cookie Data on the Basis of Consent

We implement a consent management solution that obtains users’ consent for the use of cookies or for the processes and providers mentioned within the consent management framework. This procedure is designed to solicit, log, manage, and revoke consents, particularly regarding the use of cookies and similar technologies employed to store, read from, and process information on users’ devices. As part of this procedure, user consents are obtained for the use of cookies and the associated processing of information, including specific processing and providers named in the consent management process. Users also have the option to manage and withdraw their consents. Consent declarations are stored to avoid repeated queries and to provide proof of consent according to legal requirements. The storage is carried out server-side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to associate the consent with a specific user or their device.If no specific details about the providers of consent management services are provided, the following general notes apply: The duration of consent storage is up to two years. A pseudonymous user identifier is created, which is stored along with the time of consent, details on the scope of consent (e.g., relevant categories of cookies and/or service providers), as well as information about the browser, system, and device used.

  • Legal Basis: Consent (Article 6 (1) (a) GDPR);
9.2. BorlabsCookie

Cookie Consent Management: Procedures for obtaining, recording, managing, and revoking consents, particularly for the use of cookies and similar technologies for storing, accessing, and processing information on users’ devices as well as their processing.

  • Service Provider: Executed on servers and/or computers under our controllership.
  • Website: https://borlabs.io/borlabs-cookie/;
  • Further Information: An individual user ID, language as well as types of consent and the time of their submission are stored on the server and in the cookie on the user’s device;

 

10. BLOGS AND PUBLICATION MEDIA
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Description: We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this privacy policy.
Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status.
Data subjects: Users (e.g. website visitors, users of online services.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability; Web Analytics (e.g. access statistics, recognition of returning visitors); Conversion tracking (Measurement of the effectiveness of marketing activities); Profiles with user-related information (Creating user profiles.
Rechtsgrundlagen: Legitimate Interests (Article 6 (1) (f) GDPR.
10.1. Spotify

Spotify – Music hosting and Widget.

  • Website: https://podcasters.spotify.com.
  • Privacy Policy: https://www.spotify.com/legal/privacy-policy.
  • Service Provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden.
10.2. Apple Podcasts

Podcast hosting and statistical analysis of podcast performance.

  • Website: https://www.apple.com/apple-podcasts.
  • Privacy Policy: https://www.apple.com/legal/privacy.
  • Service Provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA.
10.3. YouTube

Social network and video platform.

  • Privacy Policy: https://policies.google.com/privacy.
  • Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

 

11. CONTACT AND INQUIRY MANAGEMENT
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Description: When contacting us (e.g. via mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.
Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status.
Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services.
Purposes of processing: Contact requests and communication; Managing and responding to inquiries; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability; Direct marketing (e.g. by e-mail or postal); Web Analytics (e.g. access statistics, recognition of returning visitors); Conversion tracking (Measurement of the effectiveness of marketing activities); A/B Tests; Marketing; Affiliate Tracking.
Rechtsgrundlagen: Legitimate Interests (Article 6 (1) (f) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR.
11.1. Contact form

When users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request.

  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR);
11.2. Perspective

Creation of so-called “marketing funnels”, i.e. websites, online forms and procedures for contacting and closing deals with potential interested parties for offered products or services as well as their management, supported by export as well as analysis functions.

  • Website: https://www.perspective.co.
  • Privacy Policy: https://www.perspective.co/privacy-policy.
  • Service Provider: Perspective Software GmbH, Müggelstraße 22, 10247 Berlin, Germany.

 

12. COMMUNICATION VIA MESSENGER
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Description: We use messenger services for communication purposes and therefore ask you to observe the following information regarding the functionality of the messenger services, encryption, use of the metadata of the communication and your objection options.

You can also contact us by alternative means, e.g. telephone or e-mail. Please use the contact options provided to you or use the contact options provided within our online services.

In the case of encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attachments) is encrypted end-to-end. This means that the content of the messages is not visible, not even by the messenger service providers themselves. You should always use a current version of the messenger service with activated encryption, so that the encryption of the message contents is guaranteed.

However, we would like to point out to our communication partners that although messenger service providers do not see the content, they can find out that and when communication partners communicate with us and process technical information on the communication partner’s device used and, depending on the settings of their device, also location information (so-called metadata).

Information on Legal basis: If we ask communication partners for permission before communicating with them via messenger services, the legal basis of our processing of their data is their consent. Otherwise, if we do not request consent and you contact us, for example, voluntarily, we use messenger services in our dealings with our contractual partners and as part of the contract initiation process as a contractual measure and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners for communication via messenger services. We would also like to point out that we do not transmit the contact data provided to us to the messenger service providers for the first time without your consent.

Withdrawal, objection and deletion: You can withdraw your consent or object to communication with us via messenger services at any time. In the case of communication via messenger services, we delete the messages in accordance with our general data retention policy (i.e. as described above after the end of contractual relationships, archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and there are no legal obligations to store the messages to prevent their deletion.

Reservation of reference to other means of communication: Finally, we would like to point out that we reserve the right, for reasons of your safety, not to answer inquiries about messenger services. This is the case if, for example, internal contractual matters require special secrecy or if an answer via the messenger services does not meet the formal requirements. In such cases we refer you to more appropriate communication channels.

Processed data types: Contact data (e.g. e-mail, telephone numbers); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status.
Data subjects: Communication partner (Recipients of e-mails, letters, etc.
Purposes of processing: Contact requests and communication; Direct marketing (e.g. by e-mail or postal.
Rechtsgrundlagen: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR.
12.1. Instagram

Messaging via the social network Instagram.

  • Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://www.instagram.com;
  • Privacy Policy: https://instagram.com/about/legal/privacy;
12.2. WhatsApp

WhatsApp Messenger with end-to-end encryption.

  • Service Provider: WhatsApp Ireland Limited, Merrion Road 4, D04 X2K5 Dublin, Ireland.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://www.whatsapp.com/;
  • Privacy Policy: https://www.whatsapp.com/legal;

 

13. VIDEO CONFERENCES, ONLINE MEETINGS, WEBINARS AND SCREEN-SHARING
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Description: We use platforms and applications of other providers (hereinafter referred to as “Conference Platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “Conference”). When using the Conference Platforms and their services, we comply with the legal requirements.

Data processed by Conference Platforms: In the course of participation in a Conference, the Data of the participants listed below are processed. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific Conference (e.g., provision of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ Data may also be processed by the Conference Platforms for security purposes or service optimization. The processed Date includes personal information (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants’ end devices, their operating system, the browser and its technical and linguistic settings, information on the content-related communication processes, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the Conference Platforms, then further data may be processed in accordance with the agreement with the respective Conference Provider.

Logging and recording: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are recorded, this will be transparently communicated to the participants in advance and they will be asked – if necessary – for their consent.

Data protection measures of the participants: Please refer to the data privacy information of the Conference Platforms for details on the processing of your data and select the optimum security and data privacy settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a Conference (e.g., by notifying roommates, locking doors, and using the background masking function, if technically possible). Links to the conference rooms as well as access data, should not be passed on to unauthorized third parties.

Notes on legal bases: Insofar as, in addition to the Conference Platforms, we also process users’ data and ask users for their consent to use contents from the Conferences or certain functions (e.g. consent to a recording of Conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g. in participant lists, in the case of reprocessing of Conference results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status.
Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services); Persons depicted.
Purposes of processing: Provision of contractual services and fulfillment of contractual obligations; Contact requests and communication; Office and organisational procedures.
Rechtsgrundlagen: Legitimate Interests (Article 6 (1) (f) GDPR.
13.1. Google Hangouts / Meet

Conference and communication software.

  • Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://hangouts.google.com/;
  • Privacy Policy: https://policies.google.com/privacy;
13.2. Zoom

Conference and communication software.

  • Service Provider: Zoom Video Communications, Inc., 55 Almaden Blvd., Suite 600, San Jose, CA 95113, USA.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://zoom.us;
  • Privacy Policy: https://zoom.us/docs/de-de/privacy-and-legal.html;
13.3. calendly

Online scheduling and calendar management.

  • Website: https://calendly.com.
  • Privacy Policy: https://calendly.com/pages/privacy.
  • Service Provider: Calendly LLC., 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA.

 

14. AUDIO CONTENT
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Description: We use hosting and analysis services of service providers to offer our audio content for listening to or downloading and to obtain statistical information on the request of the audio content.
Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status.
Data subjects: Users (e.g. website visitors, users of online services.
Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Conversion tracking (Measurement of the effectiveness of marketing activities); Profiles with user-related information (Creating user profiles); Provision of our online services and usability.
Rechtsgrundlagen: Legitimate Interests (Article 6 (1) (f) GDPR.
14.1. Spotify

Spotify – Music hosting and Widget.

  • Service Provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://podcasters.spotify.com/;
  • Privacy Policy: https://www.spotify.com/legal/privacy-policy/;
14.2. Apple Podcasts

Podcast hosting and statistical analysis of podcast performance.

  • Service Provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA.
  • Website: https://www.apple.com/apple-podcasts/;
  • Privacy Policy: https://www.apple.com/legal/privacy/;
14.3. YouTube

Social network and video platform.

  • Privacy Policy: https://policies.google.com/privacy.
  • Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
14.4. Spotify

Spotify – Music hosting and Widget.

  • Service Provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://podcasters.spotify.com/;
  • Privacy Policy: https://www.spotify.com/legal/privacy-policy/;
14.5. Apple Podcasts

Podcast hosting and statistical analysis of podcast performance.

  • Service Provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA.
  • Website: https://www.apple.com/apple-podcasts/;
  • Privacy Policy: https://www.apple.com/legal/privacy/;
14.6. Spotify

Spotify – Music hosting and Widget.

  • Service Provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://podcasters.spotify.com/;
  • Privacy Policy: https://www.spotify.com/legal/privacy-policy/;
14.7. Apple Podcasts

Podcast hosting and statistical analysis of podcast performance.

  • Service Provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA.
  • Website: https://www.apple.com/apple-podcasts/;
  • Privacy Policy: https://www.apple.com/legal/privacy/;

 

15. CLOUD SERVICES
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Description: We use Internet-accessible software services (so-called “cloud services”, also referred to as “Software as a Service”) provided on the servers of its providers for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with certain recipients or publication of content and information).

Within this framework, personal data may be processed and stored on the provider’s servers insofar as this data is part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This data may include in particular master data and contact data of data subjects, data on processes, contracts, other proceedings and their contents. Cloud service providers also process usage data and metadata that they use for security and service optimization purposes.

If we use cloud services to provide documents and content to other users or publicly accessible websites, forms, etc., providers may store cookies on users’ devices for web analysis or to remember user settings (e.g. in the case of media control).

Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status.
Data subjects: Customers; Employees (e.g. Employees, job applicants); Prospective customers; Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services.
Purposes of processing: Office and organisational procedures; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).
Rechtsgrundlagen: Legitimate Interests (Article 6 (1) (f) GDPR.
15.1. Google Workspace

Cloud storage, cloud infrastructure services and cloud-based application software.

  • Service Provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://workspace.google.com/;
  • Privacy Policy: https://policies.google.com/privacy;
  • Further Information: https://cloud.google.com/privacy;

 

16. NEWSLETTER AND ELECTRONIC COMMUNICATIONS
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Description: We send newsletters, e-mails and other electronic communications (hereinafter referred to as “newsletters”) only with the consent of the recipient or a legal permission. Insofar as the contents of the newsletter are specifically described within the framework of registration, they are decisive for the consent of the user. Otherwise, our newsletters contain information about our services and us.

In order to subscribe to our newsletters, it is generally sufficient to enter your e-mail address. We may, however, ask you to provide a name for the purpose of contacting you personally in the newsletter or to provide further information if this is required for the purposes of the newsletter.

Double opt-in procedure: The registration to our newsletter takes place in general in a so-called Double-Opt-In procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can register with external e-mail addresses.

The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes storing the login and confirmation times as well as the IP address. Likewise the changes of your data stored with the dispatch service provider are logged.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to provide evidence of prior consent. The processing of these data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of an obligation to permanently observe an objection, we reserve the right to store the e-mail address solely for this purpose in a blocklist.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status); Usage data (e.g. websites visited, interest in content, access times); Content data (e.g. text input, photographs, videos.
Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services.
Purposes of processing: Direct marketing (e.g. by e-mail or postal); Office and organisational procedures.
Rechtsgrundlagen: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR.
Contents: Information about us, our services, promotions and offers.
16.1. Mailchimp

Email marketing, automation of marketing processes, collection, storage and management of contact information, measurement of campaign performance, recording and analysis of recipient interaction with content, personalisation of content.

  • Service Provider: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://mailchimp.com;
  • Privacy Policy: https://mailchimp.com/legal/;
  • Further Information: Special safety measures: https://mailchimp.com/help/Mailchimp-european-data-transfers/;
16.2. calendly

Online scheduling and calendar management.

  • Website: https://calendly.com.
  • Privacy Policy: https://calendly.com/pages/privacy.
  • Service Provider: Calendly LLC., 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA.

 

17. WEB ANALYSIS, MONITORING AND OPTIMIZATION
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Description: Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online services or their components.

Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

Unless otherwise stated below, profiles, that is data summarized for a usage process or user, may be created for these purposes and stored in a browser or terminal device (so-called “cookies”) or similar processes may be used for the same purpose. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data or profiles to us or to the providers of the services we use, these may also be processed, depending on the provider.

The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos.
Data subjects: Users (e.g. website visitors, users of online services.
Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles); Office and organisational procedures.
Security measures: IP Masking (Pseudonymization of the IP address.
Rechtsgrundlagen: Legitimate Interests (Article 6 (1) (f) GDPR.
17.1. calendly

Online scheduling and calendar management.

  • Website: https://calendly.com.
  • Privacy Policy: https://calendly.com/pages/privacy.
  • Service Provider: Calendly LLC., 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA.

 

18. ONLINE MARKETING
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Description: We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedure is used by which the relevant user information for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, computer system used and information on usage times and used functions. If users have consented to the collection of their sideline data, these can also be processed.

The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user’s by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms. This means that we, as well as the providers of online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or similar memorizing procedures. These cookies can later, generally also on other websites that use the same online marketing technology, be read and analyzed for purposes of content display, as well as supplemented with other data and stored on the server of the online marketing technology provider.

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process.

As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities.

Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.

Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status.
Data subjects: Users (e.g. website visitors, users of online services.
Purposes of processing: Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Marketing; Profiles with user-related information (Creating user profiles.
Security measures: IP Masking (Pseudonymization of the IP address.
18.1. Perspective

Creation of so-called “marketing funnels”, i.e. websites, online forms and procedures for contacting and closing deals with potential interested parties for offered products or services as well as their management, supported by export as well as analysis functions.

  • Service Provider: Perspective Software GmbH, Müggelstraße 22, 10247 Berlin, Germany.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://www.perspective.co/;
  • Privacy Policy: https://www.perspective.co/privacy-policy;

 

19. PROFILES IN SOCIAL NETWORKS (SOCIAL MEDIA)
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Description: We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users’ rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time information, identification numbers, consent status.
Data subjects: Users (e.g. website visitors, users of online services.
Purposes of processing: Contact requests and communication; Feedback (e.g. collecting feedback via online form); Marketing; Web Analytics (e.g. access statistics, recognition of returning visitors); Conversion tracking (Measurement of the effectiveness of marketing activities); Profiles with user-related information (Creating user profiles); Provision of our online services and usability.
Rechtsgrundlagen: Legitimate Interests (Article 6 (1) (f) GDPR.
19.1. Instagram

Social network.

  • Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://www.instagram.com;
  • Privacy Policy: https://instagram.com/about/legal/privacy;
19.2. LinkedIn

Social network.

  • Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Website: https://www.linkedin.com;
  • Privacy Policy: https://www.linkedin.com/legal/privacy-policy;
  • Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out;
  • Further Information: We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data from visitors for the purposes of creating „Page-Insights” (statistics) for our LinkedIn profiles. This data includes information about the types of content that users view or interact with, or the actions they take, as well as information about the devices used by the users (e.g., IP addresses, operating system, browser type, language settings, cookie data) and details from the users’ profiles, such as job function, country, industry, seniority, company size, and employment status. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn’s privacy notices: https://www.linkedin.com/legal/privacy-policy
    We have concluded a special agreement with LinkedIn Irland, the ‘Page Insights Joint Controller Addendum (the ‘Addendum’)’ (https://legal.linkedin.com/pages-joint-controller-addendum), which specifically regulates the security measures that LinkedIn must observe and wherein LinkedIn has agreed to fulfill the rights of the affected parties (i.e., users can, for example, direct requests for information or deletion directly to LinkedIn). The rights of the users (in particular to access to information, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transmission to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, particularly regarding the transmission of data to the parent company LinkedIn Corporation in the USA.;
19.3. YouTube

Social network and video platform.

  • Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Privacy Policy: https://policies.google.com/privacy;
  • Opt-Out: https://myadcenter.google.com/personalizationoff;
19.4. Spotify

Spotify – Music hosting and Widget.

  • Website: https://podcasters.spotify.com.
  • Privacy Policy: https://www.spotify.com/legal/privacy-policy.
  • Service Provider: Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden.
19.5. Apple Podcasts

Podcast hosting and statistical analysis of podcast performance.

  • Website: https://www.apple.com/apple-podcasts.
  • Privacy Policy: https://www.apple.com/legal/privacy.
  • Service Provider: Apple Inc., Infinite Loop, Cupertino, CA 95014, USA.
19.6. YouTube

Social network and video platform.

  • Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Privacy Policy: https://policies.google.com/privacy;
  • Opt-Out: https://myadcenter.google.com/personalizationoff;
19.7. YouTube

Social network and video platform.

  • Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR);
  • Privacy Policy: https://policies.google.com/privacy;
  • Opt-Out: https://myadcenter.google.com/personalizationoff;