Privacy Policy
We are very pleased about your interest in our company. Data protection is a particularly high priority for the management of the MASTERING ACADEMY. The use of the Internet pages of the MASTERING ACADEMY is possible without any indication of personal data. However, if a data subject wants to use special services of our enterprise via our website, processing of personal data could become necessary. If processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the country-specific data protection regulations applicable to the MASTERING ACADEMY. By means of this data protection declaration, our enterprise would like to inform the public about the type, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this data protection declaration.
As the controller, the MASTERING ACADEMY has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions can always be vulnerable to security risks, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.
1. Definitions
The data protection declaration of the MASTERING ACADEMY is based on the terms used by the European Directive and Ordinance when issuing the Data Protection Regulation (GDPR). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.
We use the following terms, among others, in this Privacy Policy:
a) personal data
Personal data is 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
b) person concerned
Data subject is any identified or identifiable natural person whose personal data are processed by the controller.
c) Processing
Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
e) Profiling
Profiling is any type of automated processing of personal data that consists of 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 job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
f) Pseudonymization
Pseudonymization is 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 separate and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Controller or person responsible for processing
The controller or person responsible for processing is 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. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for under Union or Member State law.
h) Processor
Processor means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the Controller.
i) Recipient
A recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigation mandate under Union or Member State law shall not be considered as recipients.
j) Third
Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.
k) Consent
Consent shall mean any freely given indication of the data subject’s wishes for the specific case in an informed and unambiguous manner in the form of a statement or any other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.
2. Name and address of the controller
The responsible party within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:
MASTERING ACADEMY GmbH
Friedemann Tischmeyer
Grossmannstrasse 213
20539 Hamburg
Germany
Tel.: +49 160 5874347
E-mail: [email protected]
Website: www.mastering-academy.com
3. SSL or TLS encryption
For security reasons and to protect the transmission of confidential content, this site uses for example, orders or inquiries that you send to us as the site operator use SSL or TLS encryption. You can recognize an encrypted connection by the fact that the browser’s address bar is filled with “http://” changes to “https://” and by the lock icon in your browser bar. When SSL or TLS encryption is enabled, the data that you transmit to us cannot be be read by third parties.
4. Cookies
The internet pages of the MASTERING ACADEMY use cookies. Cookies are text files that are stored on a computer system via an Internet browser.
Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters by which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the visited Internet pages and servers to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific internet browser can be recognized and identified via the unique cookie ID.
Through the use of cookies, the MASTERING ACADEMY can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized in the sense of the user. Cookies allow us, as already mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter his or her access data each time he or she visits the website, because this is handled by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online store. The online store uses a cookie to remember the items that a customer has placed in the virtual shopping cart.
The data subject can prevent the setting of cookies by our website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing.
The legal bases for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of the personal data is not yet contractually required and is also not necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
5. Collection of general data and information
The website of the MASTERING ACADEMY collects a series of general data and information with each call-up of the website by a data subject or automated system. This general data and information is stored in the log files of the server. The following data may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.
When using these general data and information, the MASTERING ACADEMY does not draw any conclusions about the data subject. Rather, this information is needed (1) to deliver the content of our website correctly, (2) to optimize the content of our website and the advertising for it, (3) to ensure the long-term functionality of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Therefore, the MASTERING ACADEMY analyzes anonymously collected data and information on one hand, and on the other hand, with the aim of increasing the data protection and data security of our enterprise, to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.
6. Registration on our website
The data subject has the opportunity to register on the website of the controller by providing personal data. Which personal data is transmitted to the controller in the process is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be transferred to one or more processors, for example a parcel service provider, who will also use the personal data exclusively for an internal use attributable to the controller.
By registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) of the data subject, the date and the time of registration are also stored. The storage of this data takes place against the background that only in this way can the misuse of our services be prevented and, if necessary, this data makes it possible to clarify committed crimes. In this respect, the storage of this data is necessary for the protection of the data controller. As a matter of principle, this data is not passed on to third parties unless there is a legal obligation to pass it on or the passing on serves the purpose of criminal prosecution.
The registration of the data subject by voluntarily providing personal data serves the purpose of the controller to offer the data subject content or services which, due to the nature of the matter, can only be offered to registered users. Registered persons are free to modify the personal data provided during registration at any time or to have it completely deleted from the data stock of the controller.
The controller shall provide any data subject at any time, upon request, with information about what personal data is stored about the data subject. Furthermore, the controller shall correct or delete personal data at the request or indication of the data subject, provided that this does not conflict with any statutory retention obligations. The entire staff of the controller shall be available to the data subject as contact persons in this context.
7. Commercial and business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data for the fulfillment of our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as the entrepreneurial organization. Within the framework of applicable law, we only disclose the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the contractual partners (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We inform the contractual partners which data are required for the above-mentioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.
Customer account:
Contractual partners can create an account within our online offer (e.g. customer or user account, in short “customer account”). If registration of a customer account is required, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and prevent any misuse of the customer account.
If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of customers to back up their data when the customer account is terminated.
Economic analysis and market research:
For business reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offering.
The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users together with their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take the privacy of the users into consideration and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).
8. Subscription to our newsletter
Newsletter data
If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.
Sendinblue
This website uses Sendinblue to send newsletters. The provider is Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany.
Sendinblue is a service with which, among other things, the sending of newsletters can be organized and analyzed. The data you enter for the purpose of receiving the newsletter is stored on Sendinblue’s servers in Germany.
If you do not want Sendinblue to analyze your data, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in each newsletter message.
Data analysis by Sendinblue
With the help of Sendinblue, it is possible for us to analyze our newsletter campaigns. For example, we can see whether a newsletter message was opened and which links, if any, were clicked. In this way, we can determine, among other things, which links were clicked on particularly often.
Sendinblue also allows us to subdivide (“cluster”) newsletter recipients based on various categories. In doing so, the newsletter recipients can be subdivided according to the selection of the desired newsletters. In this way, the newsletters can be better adapted to the respective target groups.
Legal basis
The processing of the data entered in the newsletter registration form is based exclusively on your consent (§ 6 para. 1 lit. b KDG). You can revoke your consent to the storage of the data, the e-mail address and their use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.
Storage period
The data you provide us with for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data that has been stored by us for other purposes remains unaffected by this.
After you have unsubscribed from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements for sending newsletters (legitimate interest within the meaning of § 6 para. 1 lit. g KDG). The storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.
For more details, please refer to Sendinblue’s privacy policy at: https://de.sendinblue.com/datenschutz-uebersicht/?rtype=n2go.
Conclusion of a contract for order processing
We have concluded a contract with Sendinblue in which we oblige Sendinblue to protect our customers’ data and not to pass it on to third parties.
9. Contact possibility via the website
Based on statutory provisions, the website of the MASTERING ACADEMY contains data that enable a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or by using a contact form, the personal data transmitted by the data subject will be stored automatically. Such personal data transmitted on a voluntary basis by a data subject to the controller will be stored for the purpose of processing or contacting the data subject. No disclosure of this personal data to third parties will take place.
10. Request by e-mail, telephone or fax
If you contact us by e-mail, telephone or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of processing your request. We will not pass on this data without your consent.
The processing of this data is based on Art. 6 (1) lit. b GDPR, if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of requests addressed to us (Art. 6 para. 1 lit. f GDPR) or on your
The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (e.g. after processing your request has been completed). Mandatory legal provisions – in particular legal retention periods – remain unaffected.
11. Use of the appointment system via Calendly
You have the option to sign up for a callback on our website. We use the online calendar “Calendly” to request and select an appointment. “Calendly” is a service provided by Calendly, LLC, 3423 Piedmont Road NE, Atlanta, GA 30305-1754, United States.
When you press the Callback Arrange button, you will be automatically connected to our appointment account at Calendly. After choosing your appointment, confirming it and entering your contact details and concerns, you will receive an email from Calendly confirming your appointment. You can view more information about Calendly and data protection at Calendly here: https://calendly.com/pages/privacy
The information you provide in the Calendly form, including the data you enter there, will be stored by us for the purpose of processing your inquiry and in case of follow-up questions. This data remains with us until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (e.g. appointment made). Mandatory legal provisions – in particular retention periods – remain unaffected.
12. Comment function in the blog on the website
The MASTERING ACADEMY provides users with the possibility to leave individual comments on individual blog contributions on a blog, which is on the website of the controller. A blog is a portal maintained on a website, usually publicly viewable, in which one or more persons, called bloggers or web bloggers, can post articles or write down thoughts in so-called blogposts. The blogposts can usually be commented on by third parties.
If a data subject leaves a comment on the blog published on this website, in addition to the comments left by the data subject, information on the time of comment entry and the user name (pseudonym) chosen by the data subject will be stored and published. Furthermore, the IP address assigned by the Internet service provider (ISP) of the person concerned is also logged. This storage of the IP address is done for security reasons and in case the data subject violates the rights of third parties by posting a comment or posts illegal content. The storage of this personal data is therefore in the controller’s own interest, so that the controller could exculpate itself if necessary in the event of an infringement. There is no disclosure of this collected personal data to third parties, unless such disclosure is required by law or serves the legal defense of the controller.
13. Subscription to comments on the blog on the website
The comments made in the blog of MASTERING ACADEMY can generally be subscribed to by third parties. In particular, there is the possibility that a commentator subscribes to the comments following his comment on a particular blog post.
If a data subject chooses the option to subscribe to comments, the controller sends an automatic confirmation e-mail to verify in the double opt-in procedure whether the owner of the specified e-mail address has really chosen this option. The option to subscribe to comments can be terminated at any time.
14. Routine deletion and blocking of personal data
The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or where provided for by the European Directive and Regulation or other legislator in laws or regulations to which the controller is subject.
If the purpose of storage no longer applies or if a storage period prescribed by the European Directive and Regulation or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
15. Rights of the data subject
a) Right to confirmation
Every data subject shall have the right, granted by the European Directive and the Regulation, to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right, he or she may, at any time, contact any employee of the controller.
b) Right to information
Any person concerned by the processing of personal data has the right granted by the European Directive and Regulation to obtain at any time from the controller, free of charge, information about the personal data stored about him or her and a copy of that information. Furthermore, the European Directive and Regulation has granted the data subject access to the following information:
- the processing purposes
- the categories of personal data that are processed
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations
- if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
- the existence of a right to obtain the rectification or erasure of personal data concerning them or to obtain the restriction of processing by the controller or a right to object to such processing
- the existence of a right of appeal to a supervisory authority
- if the personal data are not collected from the data subject: All available information about the origin of the data
- the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and – at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject
Furthermore, the data subject shall have the right to obtain information as to whether personal data have been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.
If a data subject wishes to exercise this right of access, he or she may, at any time, contact an employee of the controller.
c) Right to rectification
Any person affected by the processing of personal data has the right granted by the European Directive and Regulation to request the immediate rectification of inaccurate personal data concerning him or her. Furthermore, the data subject has the right to request the completion of incomplete personal data – also by means of a supplementary declaration – taking into account the purposes of the processing.
If a data subject wishes to exercise this right to rectify, he or she may, at any time, contact any employee of the controller.
d) Right to erasure (right to be forgotten)
Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain from the controller the erasure without delay of personal data concerning him or her, where one of the following reasons applies and insofar as the processing is not necessary:
The personal data were collected or otherwise processed for purposes for which they are no longer necessary.
The data subject revokes the consent on which the processing was based pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR and there is no other legal basis for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
The personal data have been processed unlawfully.
The deletion of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
The personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to arrange for the deletion of personal data stored by the MASTERING ACADEMY, he or she may, at any time, contact any employee of the controller. The employee of the MASTERING ACADEMY will arrange for the erasure request to be complied with immediately.
If the personal data was made public by the MASTERING ACADEMY and our company is responsible pursuant to Art. 17 Para. 1 GDPR, the MASTERING ACADEMY shall implement reasonable measures, including technical measures, to compensate other data controllers for processing the personal data published, taking into account the available technology and the cost of implementation, in order to inform the data subject that he or she has requested from those other data controllers to erase all links to the personal data or copies or replications of the personal data, unless the processing is necessary. The employee of the MASTERING ACADEMY will arrange the necessary in individual cases.
e) Right to restriction of processing
Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain from the controller the restriction of processing if one of the following conditions is met:
The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful, the data subject objects to the erasure of the personal data and requests instead the restriction of the use of the personal data.
The controller no longer needs the personal data for the purposes of processing, but the data subject needs it for the assertion, exercise or defense of legal claims.
The data subject has objected to the processing pursuant to Article 21(1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of personal data stored by the MASTERING ACADEMY, he or she may, at any time, contact any employee of the controller. The employee of the MASTERING ACADEMY will arrange the restriction of the processing.
f) Right to data portability
Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to receive the personal data concerning him or her, which have been provided by the data subject to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit such data to another controller without hindrance from the controller to whom the personal data have been provided, provided that the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, when exercising the right to data portability pursuant to Article 20(1) of the GDPR, the data subject has the right to obtain that the personal data be transferred directly from one controller to another controller where technically feasible and provided that this does not adversely affect the rights and freedoms of other individuals.
In order to assert the right to data portability, the data subject may at any time contact any employee of the MASTERING ACADEMY.
g) Right of objection
Any person affected by the processing of personal data has the right granted by the European Directive and Regulation to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her carried out on the basis of Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.
The MASTERING ACADEMY shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the assertion, exercise or defence of legal claims.
If the MASTERING ACADEMY processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data processed for such marketing.
This also applies to profiling, insofar as it is related to such direct marketing. If the data subject objects to the MASTERING ACADEMY to the processing for direct marketing purposes, the MASTERING ACADEMY will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her which is carried out by the MASTERING ACADEMY for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may directly contact any employee of the MASTERING ACADEMY or another employee. The data subject is also free to exercise his/her right to object by means of automated procedures using technical specifications in connection with the use of information society services, notwithstanding Directive 2002/58/EC.
h) Automated decisions in individual cases including profiling
Any data subject concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is permitted by Union or Member State law to which the controller is subject and that law contains suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is made with the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the data controller, or (2) it is made with the data subject’s explicit consent, the MASTERING ACADEMY shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, which include at least the right to obtain the data subject’s involvement on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated decisions, he or she may, at any time, contact any employee of the controller.
i) Right to revoke consent under data protection law
Every person affected by the processing of personal data has the right granted by the European Directive and Regulation to withdraw consent to the processing of personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the controller.
16. Data protection during applications and the application process
The controller collects and processes the personal data of applicants for the purpose of handling the application procedure. The processing may also take place electronically. This is the case, in particular, when an applicant submits relevant application documents to the controller by electronic means, for example, by e-mail or via a web form located on the website. If the controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller conflict with such deletion. Other legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).
17. Data protection provisions about the application and use of Facebook
The controller has integrated components of the company Facebook on this website. Facebook is a social network.
A social network is a social meeting place operated on the Internet, an online community that generally enables users to communicate and interact with each other in virtual space. A social network can serve as a platform for sharing opinions and experiences or enables the Internet community to provide personal or company-related information. Facebook allows users of the social network to create private profiles, upload photos and network via friend requests, among other things.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a data subject lives outside the USA or Canada, the controller of personal data is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
By each call of one of the individual pages of this website, which is operated by the controller and on which a Facebook component (Facebook plug-in) has been integrated, the internet browser on the information technology system of the data subject is automatically caused by the respective Facebook component to download a representation of the corresponding Facebook component from Facebook. A complete overview of all Facebook plug-ins can be found at https://developers.facebook.com/docs/plugins/?locale=de_DE. Within the scope of this technical procedure, Facebook receives knowledge of which specific subpage of our website is visited by the data subject.
If the data subject is logged in to Facebook at the same time, Facebook recognizes which specific subpage of our website the data subject is visiting each time the data subject calls up our website and for the entire duration of the respective stay on our website. This information is collected by the Facebook component and assigned by Facebook to the respective Facebook account of the data subject. If the data subject activates one of the Facebook buttons integrated on our website, for example the “Like” button, or if the data subject makes a comment, Facebook assigns this information to the personal Facebook user account of the data subject and stores this personal data.
Facebook always receives information via the Facebook component that the data subject has visited our website if the data subject is logged into Facebook at the same time as calling up our website; this takes place regardless of whether the data subject clicks on the Facebook component or not. If the data subject does not want this information to be transmitted to Facebook, he or she can prevent the transmission by logging out of his or her Facebook account before accessing our website.
The data policy published by Facebook, which is available at https://de-de.facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. It also explains which setting options Facebook offers to protect the privacy of the data subject. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by the data subject to suppress data transmission to Facebook.
Facebook Pixel
The controller has integrated Facebook Pixel on this website. Conversion measurement the visitor action pixel of Facebook, Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”).
This allows the behavior of page visitors to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This allows the effectiveness of the Facebook ads to be evaluated for statistical and market research purposes and future advertising measures to be optimized.
The collected data is anonymous for us as the operator of this website, we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, according to the Facebook data usage policy. This allows Facebook to enable the placement of advertisements on Facebook pages as well as outside of Facebook. This use of the data cannot be influenced by us as the site operator.
The use of Facebook Pixel is based on Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in effective advertising measures including social media.
You can find more information about protecting your privacy in Facebook’s privacy policy: https://de-de.facebook.com/about/privacy/.
You can also disable the Custom Audiences remarketing feature in the Ad Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must be logged in to Facebook.
If you do not have a Facebook account, you can disable usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website: http://www.youronlinechoices.com/de/praferenzmanagement/.
18. Data protection provisions about the use and application of Google Fonts
The controller has integrated Google Fonts on this website and embeds the fonts (“Google Fonts”) of the provider Google, whereby the user’s data is used solely for the purpose of displaying the fonts in the user’s browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display, as well as taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://fonts.google.com/; privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
19. Data protection provisions about the application and use of Google Maps
The controller has integrated Google Maps on this website and embeds the maps of the service “Google Maps” of the provider Google. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed in the context of the settings of their mobile devices); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://cloud.google.com/maps-platform; data protection declaration: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; opt-out option: opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertising: https://adssettings.google.com/authenticated.
20. Data protection provisions about the application and use of ReCaptcha
The controller has integrated the “ReCaptcha” function on this website for the detection of bots, e.g. when entering data in online forms. The users’ behavioral data (e.g. mouse movements or queries) are evaluated in order to distinguish humans from bots. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://www.google.com/recaptcha/; Privacy policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https://adssettings.google.com/authenticated.
21. Data protection provisions about the application and use of Google Analytics (with anonymization function)
The controller has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, compilation and analysis of data about the behavior of visitors to websites. A web analysis service collects, among other things, data on which website a data subject came to a website from (so-called referrers), which subpages of the website were accessed or how often and for how long a subpage was viewed. A web analysis is predominantly used for the optimization of a website and for the cost-benefit analysis of internet advertising.
The operating company of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. By means of this addition, the IP address of the Internet connection of the data subject is shortened and anonymized by Google if access to our Internet pages takes place from a member state of the European Union or from another state party to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the flow of visitors to our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us showing the activities on our website, and to provide other services related to the use of our website.
Google Analytics sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyze the use of our website. By each call of one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component has been integrated, the internet browser on the information technology system of the data subject is automatically caused by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to track the origin of visitors and clicks and subsequently enable commission calculations.
By means of the cookie, personal information, for example the access time, the location from which an access originated and the frequency of visits to our website by the data subject, is stored. Each time the data subject visits our website, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical procedure to third parties.
The data subject can prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.
Furthermore, the data subject has the option to object to the collection of data generated by Google Analytics and related to the use of this website as well as to the processing of this data by Google and to prevent such processing. For this purpose, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout. This browser add-on tells Google Analytics via JavaScript that no data and information about visits to Internet pages may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection. If the data subject’s information technology system is deleted, formatted or reinstalled at a later point in time, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within the data subject’s sphere of control, it is possible to reinstall or reactivate the browser add-on.
Further information and the applicable Google privacy policy can be found at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html.
Google Analytics is explained in more detail under this link https://www.google.com/intl/de_de/analytics/.
22. Data protection provisions about the application and use of Google Remarketing
On this website, the controller has integrated Google Remarketing services. Google Remarketing is a feature of Google Ads, which allows an enterprise to display advertising to Internet users who have previously resided on the enterprise’s Internet site. The integration of Google Remarketing therefore allows an enterprise to create user-based advertising and thus shows relevant advertisements to interested Internet users.
The operating company of the Google Remarketing services is the Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google Remarketing is the insertion of interest-relevant advertising. Google Remarketing allows us to display ads on the Google network or on other websites, which are based on individual needs and matched to the interests of Internet users.
Google Remarketing sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google enables a recognition of the visitor of our website if he calls up consecutive web pages, which are also a member of the Google advertising network. With each call-up to an Internet site on which the service has been integrated by Google Remarketing, the web browser of the data subject identifies automatically with Google. During the course of this technical procedure, Google receives personal information, such as the IP address or the surfing behaviour of the user, which Google uses, inter alia, for the insertion of interest relevant advertising.
The cookie is used to store personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to the interest-based advertising by Google. For this purpose, the data subject must call up the link to www.google.de/settings/ads and make the desired settings on each Internet browser used by the data subject.
Further information and the actual data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
23. Data protection provisions about the application and use of Google-Ads
On this website, the controller has integrated Google Ads. Google Ads is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google Ads allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.
The operating company of Google Ads is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google Ads is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.
If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.
The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs.
The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
24. Data protection provisions about the application and use of Instagram
The controller has integrated components of the service Instagram on this website. Instagram is a service that qualifies as an audiovisual platform and allows users to share photos and videos and also to redistribute such data on other social networks.
The operating company of the Instagram services is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.
By each call of one of the individual pages of this website, which is operated by the controller and on which an Instagram component (Insta button) has been integrated, the internet browser on the information technology system of the data subject is automatically caused by the respective Instagram component to download a representation of the corresponding component from Instagram. Within the scope of this technical procedure, Instagram receives knowledge about which specific subpage of our website is visited by the data subject.
If the data subject is logged in to Instagram at the same time, Instagram recognizes which specific subpage the data subject is visiting each time the data subject calls up our website and for the entire duration of the respective stay on our website. This information is collected by the Instagram component and assigned by Instagram to the respective Instagram account of the data subject. If the data subject activates one of the Instagram buttons integrated on our website, the data and information thus transmitted will be assigned to the personal Instagram user account of the data subject and stored and processed by Instagram.
Instagram always receives information via the Instagram component that the data subject has visited our website if the data subject is simultaneously logged into Instagram at the time of calling up our website; this takes place regardless of whether the data subject clicks on the Instagram component or not. If the data subject does not want this information to be transmitted to Instagram, he or she can prevent the transmission by logging out of his or her Instagram account before accessing our website.
Further information and the applicable privacy policy of Instagram can be found at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.
25. Data protection provisions about the application and use of YouTube
The controller has integrated YouTube components on this website. YouTube is an Internet video portal that allows video publishers to post video clips free of charge and other users to view, rate and comment on them, also free of charge. YouTube allows the publication of all types of videos, which is why complete film and television programs, but also music videos, trailers or videos made by users themselves can be accessed via the Internet portal.
The operating company of YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
By each call of one of the individual pages of this website, which is operated by the controller and on which a YouTube component (YouTube video) has been integrated, the internet browser on the information technology system of the data subject is automatically caused by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. Further information on YouTube can be found at https://www.youtube.com/yt/about/de/. Within the scope of this technical procedure, YouTube and Google receive knowledge of which specific subpage of our website is visited by the data subject.
If the data subject is logged into YouTube at the same time, YouTube recognizes which specific sub-page of our website the data subject is visiting when a sub-page containing a YouTube video is called up. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.
YouTube and Google always receive information via the YouTube component that the data subject has visited our website if the data subject is logged into YouTube at the same time as calling up our website; this takes place regardless of whether the data subject clicks on a YouTube video or not. If the data subject does not want this information to be transmitted to YouTube and Google, he or she can prevent the transmission by logging out of his or her YouTube account before accessing our website.
The privacy policy published by YouTube, which is available at https://www.google.de/intl/de/policies/privacy/, provides information about the collection, processing and use of personal data by YouTube and Google.
26. Data protection provisions about the application and use of Vimeo
The controller has integrated components of Vimeo on this website. The provider is Vimeo Inc, 555 West 18th Street, New York, New York 10011, USA. When you visit one of our pages equipped with a Vimeo video, a connection to the servers of Vimeo is established. In the process, the Vimeo server is informed which of our pages you have visited. In addition, Vimeo obtains your IP address. This also applies if you are not logged in to Vimeo or do not have an account with Vimeo. The information collected by Vimeo is transmitted to the Vimeo server in the USA.
When you are logged into your Vimeo account, you enable Vimeo to associate your browsing behavior directly with your
personal profile. You can prevent this by logging out of your Vimeo account. Vimeo uses cookies or comparable recognition technologies (e.g. device fingerprinting) to recognize website visitors. The use of Vimeo is in the interest of an appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. Insofar as a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission and, according to Vimeo, on “legitimate business interests”. Details can be found here: https://vimeo.com/privacy.
For more information on the handling of user data, please see Vimeo’s privacy policy at: https://vimeo.com/privacy.
27. Data protection provisions about the application and use of Tiktok Pixel.
The controller has integrated components of TikTok on this website. We use the TikTok Pixel on our website. The TikTok Pixel is a TikTok advertiser tool provided by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland, and TikTok Information Technologies UK Limited, WeWork, 125 Kingsway, London, WC2B 6NH, United Kingdom (collectively “TikTok”). The TikTok Pixel is a JavaScript code snippet that allows us to understand and track visitors’ activity on our website. To do this, the Tiktok Pixel collects and processes information about visitors to our website or the devices they use. The data collected through the TikTok Pixel is used for targeting our ads and improving ad delivery and personalized advertising. For this purpose, the data collected on our website by means of the TikTok Pixel is transmitted to TikTok. In part, this data is information stored in the terminal device you are using. In addition, cookies are also used via the TikTok Pixel, via which information is stored on your end device used. Such storage of information by the TikTok Pixel or access to information already stored in your terminal device will only occur with your consent.
For more information about how TikTok processes personal data, including the legal basis on which TikTok relies and how you can exercise your rights against TikTok, please see TikTok’s privacy policy at https://www.tiktok.com/legal/privacy-policy.
28. Data protection provisions about the application and use of CloudFlare Content Delivery Network.
The data controller has integrated components of the company Cloudflare Inc. on this website. Provider is CloudFlare, Inc. 665 3rd St. #200, San Francisco, CA 94107, USA. CloudFlare offers a worldwide distributed content delivery network with DNS. Technically, the information transfer between your browser and our website is routed through the CloudFlare network. CloudFlare is thus able to analyse the data traffic between users and our website, for example to recognise and ward off attacks on our services.
In addition, CloudFlare may store cookies on your computer for optimisation and analysis purposes. This serves to protect our prevailing legitimate interests in an optimal marketing of our services in accordance with article 6 paragraph 1 sentence 1 letter b GDPR.
We have concluded a corresponding agreement with Cloudflare on the basis of the GDPR Cloudflare is a certified participant of the EU-US Privacy Shield Framework. Cloudflare has committed itself to handle all personal data contained in the Member States of the European Union (EU) in accordance with the Privacy Shield Framework and its applicable principles. For more information about the Privacy Shield Framework, please see the Privacy Shield List of the US Department of Commerce at https://www.privacyshield.gov. Cloudflare collects statistical data about visits to this website. Access data includes: Name of the accessed website, 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.
Cloudflare uses the protocol data for statistical evaluations for the purpose of operation, security and optimisation of the offer.Here you will find information about the data collected there and about security & privacy at CloudFlare.
29. Data protection provisions about the application and use of HubSpot CRM.
The data controller has integrated components of the company HubSpot on this website.
Our registration and contact service allows visitors to our website to learn more about our company, download content, and provide their contact information and other demographic information. This information is stored on servers operated by our software partner HubSpot.
It may be used by us to contact visitors to our website and to determine which of our company’s services are of interest to them. All information we collect is subject to this privacy policy. We use all information collected solely to optimize our marketing. HubSpot is a software company based in the USA with a branch office in Ireland.
Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500. HubSpot is subject to TRUSTe ‘s Privacy Seal and the U.S. – EU Safe Harbor Framework and the U.S. – Swiss Safe Harbor Framework.
30. Data protection provisions about the application and use of Hotjar.
The data controller has integrated components of the company Hotjar on this website in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.
For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.
31. Legal basis of the processing
Article 6 I lit. a GDPR serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Article 6 I lit. b GDPR. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services.
If our company is subject to a legal obligation by which a processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result his or her name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d GDPR.
Finally, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47 sentence 2 GDPR).
32. Legitimate interests in the processing pursued by the controller or a third party
If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the performance of our business activities for the benefit of the well-being of all our employees and our shareholders.
33. Duration for which the personal data are stored
The criterion for the duration of storage of personal data is the respective statutory retention period. After expiry of the period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfillment or initiation of the contract.
34. Legal or contractual requirements to provide the personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision
We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Sometimes, in order to conclude a contract, it may be necessary for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data by the data subject, the data subject must contact one of our employees. Our employee will explain to the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what the consequences of not providing the personal data would be.
35. Existence of automated decision making
As a responsible company, we do not use automatic decision-making or profiling.
