Introduction
With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also briefly referred to as “data”) we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”).
The terms used are not gender-specific.
As of: August 25, 2020
Table of Contents
Controller
Coaching Team Munich
Julian Holch
Edelweißstrasse 8a
82194 Gröbenzell
Email address: jh[at]coachingteammuenchen.de
Overview of Processing Activities
The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects.
Types of Data Processed
Categories of Data Subjects
Purposes of Processing
Relevant Legal Bases
Below, we share the legal bases of the General Data Protection Regulation (GDPR) on which we process personal data. Please note that in addition to the GDPR regulations, national data protection requirements in your or our country of residence and establishment may apply. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.
National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains special provisions regarding the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated individual decision-making, including profiling. Furthermore, it regulates data processing for employment purposes (§ 26 BDSG), particularly with regard to the establishment, performance, or termination of employment relationships and the consent of employees. In addition, state data protection laws of the individual federal states may apply.
Security Measures
In accordance with legal requirements, taking into account the state of the art, implementation costs, and the nature, scope, context, and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, ensuring availability, and their separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the erasure of data, and responses to data breaches. We also consider the protection of personal data already during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default.
SSL encryption (https): To protect your data transmitted via our online offering, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in your browser’s address bar.
Use of Cookies
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie primarily serves to store information about a user during or after their visit within an online offering. Stored information may include, for example, language settings on a website, login status, a shopping cart, or the point at which a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g., when user information is stored based on pseudonymous online identifiers, also referred to as “user IDs”).
The following cookie types and functions are distinguished:
Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the given consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g., in the economic operation of our online offering and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.
Storage duration: Unless we provide you with explicit information on the storage duration of permanent cookies (e.g., within the scope of a so-called cookie opt-in), please assume that the storage duration can be up to two years.
General notes on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke given consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection via your browser settings, e.g., by deactivating the use of cookies (although this may limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you may receive further objection information within the scope of the details provided for the service providers and cookies used.
Provision of the Online Offering and Web Hosting
To provide our online offering securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.
The data processed in the context of providing the hosting offering may include all information relating to the users of our online offering that arises during use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and generally IP addresses and the requesting provider.
Server log files can be used for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilization and stability.
Blogs and Publication Media
We use blogs or similar means of online communication and publication (hereinafter “publication medium”). The data of readers is processed for the purposes of the publication medium only insofar as it is necessary for its presentation and communication between authors and readers or for security reasons. For other matters, we refer to the information on the processing of visitors to our publication medium within these data protection notices.
Services and Service Providers Used:
Contacting Us
When you contact us (e.g., via contact form, email, telephone, or social media), the information of the inquiring persons is processed insofar as this is necessary to answer the contact inquiries and any requested measures.
The contact inquiries within the framework of contractual or pre-contractual relationships are answered for the fulfillment of our contractual obligations or to answer (pre-)contractual inquiries, and otherwise on the basis of legitimate interests in answering the inquiries.
Music and Podcasts
We use hosting and analysis services from service providers to offer our audio content for listening or download and to obtain statistical information on the retrieval of audio content.
Services and Service Providers Used:
Cloud Services
We use software services accessible via the internet and executed on the servers of their providers (so-called “cloud services,” also referred to as “Software as a Service”) for the following purposes: document storage and management, calendar management, email dispatch, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of websites, forms or other content and information, as well as chats and participation in audio and video conferences.
In this context, personal data may be processed and stored on the providers’ servers, insofar as they are part of communication processes with us or are otherwise processed by us, as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on processes, contracts, other procedures, and their content. The providers of cloud services also process usage data and metadata, which they use for security purposes and service optimization.
If we provide forms or other documents and content for other users or publicly accessible websites using cloud services, the providers may store cookies on the users’ devices for web analysis purposes or to remember user settings (e.g., in the case of media control).
Notes on legal bases: If we ask for consent to use cloud services, the legal basis for processing is consent. Furthermore, their use may be part of our (pre-)contractual services if the use of cloud services has been agreed upon in this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e., interest in efficient and secure administrative and collaboration processes).
Services and Service Providers Used:
Newsletters and Electronic Notifications
We send newsletters, emails, and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or a legal permission. If the content of a newsletter is specifically described during registration, it is decisive for the users’ consent. Otherwise, our newsletters contain information about our services and us.
To subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name for personalized addressing in the newsletter, or other information if it is necessary for the purposes of the newsletter.
Double opt-in procedure: Registration for our newsletter generally takes place in a so-called double opt-in procedure. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with other people’s email addresses. Newsletter registrations are logged to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the shipping service provider are also logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them, in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is simultaneously confirmed. In the case of obligations for permanent compliance with objections, we reserve the right to store the email address solely for this purpose in a blocking list (so-called “blacklist”).
The logging of the registration procedure is carried out on the basis of our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider with the dispatch of emails, this is done on the basis of our legitimate interests in an efficient and secure dispatch system.
Notes on legal bases: The dispatch of newsletters is based on the consent of the recipients or, if consent is not required, on the basis of our legitimate interests in direct marketing, provided and insofar as this is legally permitted, e.g., in the case of existing customer advertising. Insofar as we commission a service provider with the dispatch of emails, this is done on the basis of our legitimate interests. The registration procedure is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law.
Content: Information about us, our services, promotions, and offers.
Analysis and performance measurement: The newsletters contain a so-called “web beacon,” i.e., a pixel-sized file that is retrieved from our server, or, if we use a dispatch service provider, from their server, when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, are initially collected.
This information is used for the technical improvement of our newsletter based on technical data or target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider, to observe individual users. The evaluations serve us rather to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the performance measurement are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of users.
A separate revocation of the performance measurement is unfortunately not possible; in this case, the entire newsletter subscription must be canceled or objected to.
Services and Service Providers Used:
Online Marketing
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “content”) based on the potential interests of users, as well as measuring their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which information relevant for the display of the aforementioned content is stored about the user. This information may include, for example, viewed content, visited websites, used online networks, but also communication partners and technical information, such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) are stored within the online marketing procedure, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is generally stored in cookies or by similar procedures. These cookies can later generally also be read out on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing procedure provider.
In exceptional cases, clear data can be assigned to the profiles. This is the case, for example, if users are members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned information. We ask you to note that users may enter into additional agreements with the providers, e.g., by giving consent during registration.
We generally only receive access to aggregated information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, please assume that cookies used are stored for a period of two years.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Services and Service Providers Used:
Presences on Social Networks (Social Media)
We maintain online presences within social networks and process user data in this context to communicate with active users there or to offer information about us.
We point out that user data may be processed outside the European Union. This may result in risks for users, for example, because the enforcement of user rights could be made more difficult.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on user behavior and resulting interests. These usage profiles can then be used to display advertisements within and outside the networks that presumably correspond to the users’ interests. For these purposes, cookies are generally stored on the users’ computers, in which the users’ usage behavior and interests are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective processing forms and the objection options (opt-out), we refer to the privacy policies and information of the operators of the respective networks.
Also, in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can directly take appropriate measures and provide information. Should you still need help, you can contact us.
Services and service providers used:
Plugins and embedded features and content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, or social media buttons and posts (hereinafter collectively referred to as “content”).
Integration always requires that the third-party providers of this content process users’ IP addresses, as they would otherwise be unable to send the content to their browsers without the IP address. The IP address is therefore required to display this content or these functions. We endeavour to use only content whose respective providers use the IP address solely to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on users’ devices and may include, among other things, technical information about the browser and operating system, referring websites, time of visit, and other details about the use of our online offering, as well as be combined with such information from other sources.
Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e., interest in efficient, cost-effective, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Services and service providers used:
Changes and updates to the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an action on your part (e.g., consent) or other individual notification.
If we provide addresses and contact information of companies and organisations in this privacy policy, please note that addresses may change over time and we ask you to verify the information before contacting them.
Definitions
In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily to aid understanding. The terms are listed alphabetically.
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