This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “Data”) within our online offering and the related websites, features and content, as well as external online presence, e.g. our Social Media Profile (collectively referred to as the “Online Offering”). With regard to the terminology used, e.g. “Processing” or “Responsible”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Responsible
Tomas M. Mielke, M. A.
Keplerstr. 3
10589 Berlin
Germany
Email: info@sprachdesign.de
Legal Notice: https://sprachdesign.de/en/legal-notice
Types of Processed Data:
- Inventory data (e.g names, addresses)
- contact information (e.g. e-mail, phone numbers)
- content data (e.g. text input, photographs, videos)
- usage data (e.g. websites visited, interest in content, access times)
- meta / communication data (e.g. device information, IP addresses)
Categories of Persons Affected
Visitors and users of the online offer (hereinafter we refer to the affected persons as “users”).
Purpose of Processing
- Providing the online offer, its features and content
- Answering contact requests and communicating with users
- Safety measures
- Audience measurement / marketing
Terms Used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term includes virtually every handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data are not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal to analyze or predict preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.
“Responsible person” means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.
“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Relevant Legal Bases
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as legal basis.
Security Measures
Subject to Art. 32 GDPR, we shall take appropriate technical measures, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing and the different likelihood and severity of the risk to the rights and freedoms of individuals and organizational measures to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR).
Collaboration with Processors and Third Parties
If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfill the contract), you have consented to a legal obligation or based on our legitimate interests (e.g. the use of agents, webhosters, etc.).
If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
Transfers to Third Countries
If we process data in a third country (ie outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 ff. GDPR. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
Rights of Data Subjects
You have the right to ask for confirmation as to whether relevant data are being processed and for information about this data as well as for further information and a copy of the data according to Art. 15 GDPR.
In accordance with Art. 16 GDPR you have the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with Art. 17 GDPR, they have the right to demand that the relevant data be deleted without delay, or, alternatively, to require a restriction on the processing of the data in accordance with Art. 18 GDPR.
You have the right to demand that the data relating to you provided to us be obtained in accordance with Art. 20 GDPR and to request their transmission to other persons responsible.
In accordance with Art. 77 GDPR you have the right to file a complaint with the competent supervisory authority.
Right of Revocation
You have the right to revoke granted consent in accordance with Art. 7 (3) GDPR with effect for the future.
Right of Objection
You may at any time object to the future processing of your data in accordance with Art. 21 GDPR. The objection may in particular be made against processing for direct marketing purposes.
Cookies and Right to Object in Direct Mail
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or a login status are saved. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, this is called “first-party cookies”).
We can use temporary and permanent cookies and clarify this in the context of our privacy policy.
If users do not want cookies stored on their computer, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general contradiction to the use of cookies used for online marketing purposes can be found in a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ be explained. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all features of this online offer may be used.
Deletion of Data
The data processed by us are deleted or restricted in their processing in accordance with Art. 17 and 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legitimate purposes, its processing will be restricted. That The data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.
According to legal requirements in Germany, the storage takes place in particular for 10 years according to sections 147 Abs. 1 AO, 257 Abs. 1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting documents, trading books, relevant for taxation Documents, etc.) and 6 years in accordance with section 257 (1) no. 2 and 3, para. 4 HGB (commercial letters).
According to legal regulations in Austria the storage takes place especially for 7 years according to section 132 para. 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate and for 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is used.
Agency Services
We process our clients’ data as part of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, campaign / process / handling implementation, server administration, data analysis / consulting services, and training services.
Here we process stock data (e.g. customer master data, such as names or addresses), contact data (e.g.e-mail, telephone numbers), content data (e.g. text inputs, photographs, videos), contract data (e.g. subject matter, term), payment data (bank account, payment history), usage and metadata (e.g. in the context of the evaluation and success measurement of marketing measures). In principle, we do not process special categories of personal data, unless these are components of a commissioned processing. Those affected include our customers, prospects and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contract services, billing and our customer service. The legal basis of the processing results from Art. 6 para. 1 lit. b GDPR (contractual benefits), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that are necessary for the establishment and performance of the contractual services and indicate the necessity of their information. Disclosure to external parties will only be made if required by an order. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as with the legal requirements of order processing pursuant to Art. 28 GDPR and process the data for no other purpose than the order.
We delete the data after expiry of legal warranty and comparable obligations. The necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiry (6 years, pursuant to section 257 (1) HGB, 10 years, in accordance with section 147 (1) AO). If data have been disclosed to us in the context of an order by the client, we delete the data according to the specifications of the order, in principle after the end of the order.
Therapeutic Services and Coaching
We process the data of our clients and interested parties and other clients or contractual partners (uniformly referred to as “clients”) in accordance with Art. 6 para. 1 lit. b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the underlying contractual relationship. The processed data basically include stock and master data of the clients (e.g. name, address, etc.), as well as the contact data (e.g., e-mail address, telephone, etc.), the contract data (e.g., services used, Fees, names of contact persons, etc.) and payment details (e.g. bank details, payment history, etc.).
As part of our services, we can also special categories of data acc. Art. 9 para. 1 GDPR, in particular information on the health of clients, possibly with reference to their sexual life or sexual orientation, ethnic origin or religious or ideological convictions. For this we get, if necessary, gem. Art. 6 para. 1 lit. a., Art. 7, Art. 9 para. 2 lit. a. GDPR expressly consent the clients and process the special categories of data otherwise for health care purposes on the basis of Art. 9 (2) (h). GDPR, section 22 para. 1 no. 1 b. Federal Data Protection Act (Germany).
If required or required by law to perform the contract, we disclose or disclose client information in the context of communication with other professionals, those required or typically required to perform the contract, such as, but not limited to, third parties. Billing agencies or comparable service providers, provided that this is in line with the provision of our services in accordance with Art. Art. 6 para. 1 lit b. GDPR serves, legally gem. Art. 6 para. 1 lit c. GDPR is required by our interests or those of clients in an efficient and cost-effective health care as legitimate interest. Art. 6 para. 1 lit. F. GDPR serves or gem. Art. 6 (1) lit. d. GDPR is necessary. to protect the vital interests of clients or any other natural person, or in the context of consent in accordance with. Art. 6 para. 1 lit. a., Art. 7 GDPR.
The data is deleted if the data for the fulfillment of contractual or legal duties of care and handling of any warranty and similar obligations is no longer required, with the necessity of preserving the data every three years is checked; otherwise the statutory storage obligations apply.
Contractual Services
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. GDPR to provide them with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g. names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g. services used, contract contents, contractual communication, names of contact persons) and payment data (e.g.bank details, payment history).
In principle, we do not process special categories of personal data, unless they are part of a contracted or contractual processing.
We process data which are necessary for the establishment and fulfillment of the contractual services and point out the necessity of their indication, if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if required by a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as the legal requirements.
As part of the use of our online services, we can save the IP address and the time of each user action. The storage is based on our legitimate interests, as well as the interests of the user in the protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is to pursue our claims according to Art. 6 para. 1 lit. f. GDPR required or there is a legal obligation according to Art. 6 para. 1 lit. c. The data will be deleted if the data is no longer required for the fulfillment of contractual or statutory duties of care and for the handling of any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; otherwise the statutory storage obligations apply.
Google Analytics
Based on our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offer as defined in Art. 6 (1) f., GDPR) Google Analytics uses a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users are usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to its use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
For more information about Google’s data usage, hiring and disparaging options, please read Google’s Privacy Policy (https://policies.google.com/technologies/ads) and Google’s Ads Ads Settings (https://adssettings.google.com/authenticated).
The personal data of users will be deleted or anonymized after 14 months.
Targeting with Google Analytics
We use Google Analytics to display advertisements displayed within Google and its affiliate advertising services, only those users who have shown an interest in our online offering or who have certain characteristics (e.g. interests in specific topics or products visited by them) that we submit to Google (so-called “remarketing” or “Google Analytics audiences”). With Remarketing Audiences, we also want to make sure that our ads meet the potential interest of users.
Google AdWords and Conversion Measurement
We use the services of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online service within the meaning of Art. 6 (1) (f) GDPR) , USA, (“Google”).Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use Google’s online AdWords marketing tool “AdWords” to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a suspected interest in the ads. This allows us to more specifically display ads for and within our online offering so that we only present ads to users that potentially match their interests. If, e.g., a user are shown ads for products he’s been looking for on other online offers this is called remarketing. For these purposes, upon access to our and other websites where Google Advertising Network is active, Google will immediately execute a Google code and become so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) incorporated into the website. With their help, the user is provided with an individual cookie, i.e. a small file is saved (instead of cookies, comparable technologies can also be used).In this file is noted which websites the user visited, for what content he is interested and what offers the user has clicked, as well as technical information about the browser and operating system, referring websites, visit time and other information on the use of the online offer.
Furthermore, we receive an individual “conversion cookie”. The information obtained through the cookie is used by Google to generate conversion statistics for us. However, we only hear the anonymous total number of users who clicked on our ad and were redirected to a conversion tracking tag page. However, we do not receive any information that personally identifies users.
The data of the users are pseudonym-processed within the Google advertising network. I.e. Google stores and processes e.g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the United States.
For more information about Google’s data usage, hiring and opt-out options, please refer to Google’s Privacy Policy (https://policies.google.com/technologies/ads) as well as in the settings for the display of advertising impressions by Google (https://adssettings.google.com/authenticated).