DATA PROTECTION

As of May 25, 2018

This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within my online offer and the websites, functions and content connected to it, as well as external online presences, such as my social media profile (hereinafter collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "responsible", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Responsible

Anja Steiner
Bernstrasse 15

3045 Meikirch
Switzerland

Email: contact@anjasteiner.com

Imprint: https://www.anjasteiner.com/impressum-disclaimer

Types of data processed:

- Inventory data (e.g., names, addresses), according to the contact form on this homepage
- Contact details (e.g., email, telephone numbers), according to the contact form on this homepage
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g. websites visited, interest in content, access times).
- Meta / communication data (e.g., device information, IP addresses).

 

Categories of data subjects

Visitors and users of the online offer (in the following I refer to the data subjects collectively as "users").

 

Purpose of processing

- Providing the online offer, its functions and content.
- Answering contact inquiries and communicating with users.
- Safety measures.
- Range measurement / marketing

 

Terms used

"Personal data" is all information that relates to an identified or identifiable natural person (hereinafter "data subject"); An identifiable person is a natural person who can be identified directly or indirectly, in particular by assigning an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.

“Processing” is any process carried out with or without the help of automated processes or any such series of processes in connection with personal data. The term goes far and covers practically every handling of data.

"Pseudonymization" means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data cannot be assigned to an identified or identifiable natural person.

“Profiling” means any type of automated processing of personal data, which consists in the fact that this personal data is used to evaluate certain personal aspects related to a natural person, in particular aspects relating to work performance, economic situation, health, personal Analyze or predict the preferences, interests, reliability, behavior, location or change of location of this natural person.

The “person responsible” is the natural or legal person, public authority, agency or other body that alone or together with others decides on the purposes and means of processing personal data.

"Processor" means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the person responsible.

 

Relevant legal bases

In accordance with Art. 13 GDPR, we will inform you of the legal basis for our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and implementation of contractual measures as well as answering inquiries is Art. 6 Para. 1 lit. b GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 Para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 Para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

 

Safety measures

In accordance with Art. 32 GDPR, we take into account appropriate technical considerations, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of processing, as well as the different probability and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling the physical access to the data, as well as the access, input, transfer, securing availability and its separation. Furthermore, we have set up procedures that guarantee the exercise of data subject rights, deletion of data and reaction to data threats. We also take the protection of personal data into account when developing or selecting hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).

 

Cooperation with processors and third parties

If we disclose data to other people and companies (processors or third parties) as part of our processing, transmit them to them or otherwise give them access to the data, this will only be done on the basis of legal permission (e.g. if the data is transmitted to third parties, as to payment service providers, in accordance with Art. 6 Para. 1 b GDPR for the fulfillment of the contract), you have consented, a legal obligation provides for this or based on our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 GDPR.

 

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done as part of the use of third-party services or disclosure or transmission of data to third parties, this will only take place if it happens to fulfill our (pre) contractual obligations, based on your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 ff. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").

 

Rights of the data subjects

You have the right to request confirmation as to whether the data in question are being processed and for information about this data and for further information and a copy of the data in accordance with Art. 15 GDPR.

You have accordingly. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with Art. 17 GDPR, you have the right to request that the data in question be deleted immediately, or alternatively, in accordance with Art. 18 GDPR, to request that the processing of the data be restricted.

You have the right to request that the data concerning you, which you have provided to us, be received in accordance with Art. 20 GDPR and to be transmitted to other responsible persons.

You have also gem. Art. 77 GDPR the right to lodge a complaint with the responsible supervisory authority.

 

Right of withdrawal

You have the right to give consent in accordance with Revoke Art. 7 Para. 3 GDPR with effect for the future

 

Right to object

You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection can be made in particular against processing for direct marketing purposes.

 

Cookies and right to object to direct mail

"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit within an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie can be used, for example, to store the contents of a shopping cart in an online shop or a login status. "Permanent" or "persistent" are cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. Such a cookie can also be used to store the interests of users who are used for range measurement or marketing purposes. A “third party cookie” refers to cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only their cookies, we speak of “first party cookies”).

We can use temporary and permanent cookies and clarify this in the context of our data protection declaration.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be found on a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ be explained. Furthermore, cookies can be saved by switching them off in the browser settings. Please note that not all functions of this online offer can then be used.

 

Deletion of data

The data processed by me is deleted in accordance with Art. 17 and 18 GDPR or its processing is restricted. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no statutory retention requirements to prevent deletion. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.

According to legal requirements in Germany, storage is carried out in particular for 10 years in accordance with §§ 147 Paragraph 1 AO, 257 Paragraph 1 No. 1 and 4, Paragraph 4 HGB (books, records, management reports, booking vouchers, trading books, more relevant for taxation Documents, etc.) and 6 years according to § 257 Paragraph 1 No. 2 and 3, Paragraph 4 HGB (commercial letters).

According to legal requirements in Austria, storage is carried out in particular for 7 years in accordance with section 132 (1) BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.) for 22 years in connection with land and for 10 years for documents in connection with electronically provided services, telecommunication, radio and television services, which are provided to non-entrepreneurs in EU member states and for which the mini-one-stop shop (MOSS) is used.

 

Business related processing

We also process
- Contract data (e.g., object of contract, term, customer category).
- Payment data (e.g. bank details, payment history)
from my customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

 

Therapeutic services and coaching

I process the data of my clients and prospects and other clients or contractual partners (uniformly referred to as "clients") in accordance with Art. 6 Para. 1 lit. b) GDPR, to provide you with my contractual or pre-contractual services. The data processed here, the type, scope, purpose and necessity of their processing are determined by the underlying contractual relationship. The processed data basically includes client's inventory and master data (e.g., name, address, etc.), as well as the contact details (e.g., email address, telephone, etc.), the contract data (e.g., services used, Fees, names of contact persons, etc.) and payment data (e.g., bank details, payment history, etc.).

As part of my services, we can also special categories of data acc. Process Art. 9 Para. 1 GDPR, in particular information on the health of clients, possibly with reference to their sexual life or sexual orientation, ethnic origin or religious or ideological convictions. For this, we collect, if necessary, according to Art. 6 para. 1 lit. a., Art. 7, Art. 9 Para. 2 lit. a. GDPR with the express consent of the clients and otherwise process the special categories of data for purposes of health care on the basis of Art. 9 Para. 2 lit. GDPR, § 22 Paragraph 1 No. 1 b. BDSG.

If required for the fulfillment of the contract or legally required, we disclose or transmit the data of the clients in the context of communication with other specialists, necessary for the fulfillment of the contract or typically third parties involved, such as billing agencies or comparable service providers, if this corresponds to the provision of our services in accordance with. Art. 6 para. 1 lit b. GDPR serves, legally according to Art. 6 para. 1 lit c. GDPR is mandatory, our interests or those of the clients in an efficient and inexpensive health care as a legitimate interest acc. Art. 6 para. 1 lit f. GDPR serves or acc. Art. 6 para. 1 lit d. GDPR is necessary. to protect the vital interests of clients or another natural person or within the scope of a consent in accordance with Art. 6 para. 1 lit. a., Art. 7 GDPR.

The data will be deleted when the data is no longer required to fulfill contractual or statutory care obligations and to deal with any warranty and comparable obligations, the necessity of storing the data being checked every three years; otherwise the statutory retention requirements apply.

 

Contractual benefits

I process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners (uniformly referred to as "contractual partner") in accordance with Art. 6 Para. 1 lit. b. GDPR, to provide you with my contractual or pre-contractual services. The data processed here, the type, scope, purpose and necessity of their processing are determined by the underlying contractual relationship.

The processed data includes the master data of my contractual partners (e.g., names and addresses), contact details (e.g. email addresses and telephone numbers) as well as contract data (e.g., services used, contract content, contractual communication, names of contact persons) and payment data (e.g., Bank details, payment history).

We generally do not process special categories of personal data, unless they are part of commissioned or contractual processing.

I process data which are necessary for the establishment and fulfillment of the contractual services and point out the necessity of their specification, if this is not evident for the contractual partners. Disclosure to external persons or companies only takes place if it is required under a contract. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client and the legal requirements.

As part of the use of my online services, we can save the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests, as well as the interests of the users in protecting against misuse and other unauthorized use. As a matter of principle, this data will not be passed on to third parties unless it is used to pursue our claims in accordance with. Art. 6 para. 1 lit. f. GDPR required or there is a legal obligation to do so in accordance with. Art. 6 para. 1 lit. c. GDPR.

The data will be deleted if the data is no longer required to fulfill contractual or statutory care obligations and to deal with any warranty and comparable obligations, the necessity of storing the data being checked every three years; otherwise the statutory retention requirements apply.

 

External payment service providers

I use external payment service providers whose platforms users and I can use to make payment transactions (e.g., each with a link to the data protection declaration, Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/ legal / data protection terms and conditions /), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https: / /www.americanexpress.com/de/content/privacy-policy-statement.html)

In the context of fulfilling contracts, I use the payment service providers on the basis of Art. 6 Para. 1 lit. b. GDPR. For the rest, I use external payment service providers based on our legitimate interests in accordance with. Art. 6 para. 1 lit. f. GDPR in order to offer our users effective and secure payment options.

The data processed by the payment service providers include inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, sums and recipient-related information. The information is required to complete the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. The data may be transmitted by the payment service provider to credit reporting agencies. The purpose of this transmission is to verify identity and creditworthiness. We refer to the terms and conditions and data protection information of the payment service providers.

The terms and conditions and the data protection notices of the respective payment service providers apply to the payment transactions, which can be called up on the respective websites or transaction applications. We also refer to these for further information and assertion of cancellation, information and other data subject rights.

 

Administration, financial accounting, office organization, contact management

I process data in the context of administrative tasks as well as the organization of my company, financial accounting and compliance with legal obligations, such as archiving. In doing so, I process the same data that we process as part of the provision of our contractual services. The processing bases are Art. 6 Para. 1 lit. c. GDPR, Art. 6 Para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and my interest in processing lies in administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

I disclose or transmit data to the financial administration, consultants, such as tax advisors or auditors, as well as other fee agencies and payment service providers.

Furthermore, based on our business interests, we store information about suppliers, organizers and other business partners, e.g. for the purpose of contacting you later. We generally store this mostly company-related data permanently.

 

Comments and posts

If users leave comments or other contributions, their IP addresses can be based on our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. GDPR can be stored for 7 days. This is done for our security, if someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, I can be prosecuted for the comment or contribution and am therefore interested in the identity of the author.

Furthermore, I reserve the right, based on my legitimate interests. Art. 6 para. 1 lit. f. GDPR to process user information for spam detection.

On the same legal basis, I reserve the right to store users' IP addresses for the duration of surveys and to use cookies to avoid multiple votes.

The data given in the comments and posts will be saved permanently by me until the user objects.

 

contact

When contacting me (e.g. via contact form, e-mail, telephone or via social media), the information provided by the user for processing the contact request and processing it in accordance with Art. 6 para. 1 lit. b) GDPR processed. The information provided by the users can be stored in a customer relationship management system ("CRM system") or a comparable request organization.

I delete the requests if they are no longer necessary. I check the necessity every two years; The statutory archiving obligations also apply.

 

Hosting and emailing

The hosting services I use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services that I use for the purpose of operating this online offer.

In doing so, I, or my hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data from customers, interested parties and visitors to this online offer based on my legitimate interest in the efficient and secure provision of this online offer in accordance with. Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of an order processing contract).

 

Collection of access data and log files

I, or my hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR data about every access to the server on which this service is located (so-called server log files). The access data include the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider .

For security reasons (e.g. to investigate misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further storage is required for evidence purposes are excluded from deletion until the respective incident has been finally clarified.

 

Facebook pixels, custom audiences and Facebook conversion

Due to our legitimate interests in analysis, optimization and economic operation of my online offer and for these purposes, the so-called "Facebook pixel" of the social network Facebook, which is provided by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025 , USA, or if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland is operated ("Facebook").

Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

With the help of the Facebook pixel, Facebook is able to determine the visitors of my online offer as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel in order to only display the Facebook ads we have placed to those Facebook users who have shown an interest in my online offer or who have certain characteristics (e.g. interests in certain topics or products based on the visited Websites determined) that we transmit to Facebook (so-called "custom audiences"). With the help of the Facebook pixel, I would also like to ensure that my Facebook ads correspond to the potential interest of the users and are not annoying. With the help of the Facebook pixel, we can also understand the effectiveness of Facebook advertisements for statistical and market research purposes by seeing whether users were forwarded to our website after clicking on a Facebook advertisement (so-called "conversion").

Facebook processes the data in accordance with Facebook's data usage guidelines. Accordingly, general information on the display of Facebook ads in the data usage guidelines of Facebook: https://www.facebook.com/policy.php. Special information and details about the Facebook pixel and how it works can be found in the help section of Facebook: https://www.facebook.com/business/help/651294705016616.

You can object to the recording by the Facebook pixel and the use of your data to display Facebook ads. To set which types of advertisements are displayed to you on Facebook, you can call up the page set up by Facebook and follow the instructions on the settings for usage-based advertising there: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, ie they are applied to all devices, such as desktop computers or mobile devices.

You can also use cookies for range measurement and advertising purposes via the deactivation page of the network advertising initiative (http://optout.networkadvertising.org/) and also the US website (http://www.aboutads.info/ choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

 

Online presence in social media

I maintain online presences within social networks and platforms in order to communicate with the customers, interested parties and users active there and to be able to inform them about my services there. When calling up the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.

Unless otherwise stated in my privacy policy, I process the data of users provided that they communicate with us within social networks and platforms, e.g. write posts on my online presence or send me messages.

 

Integration of services and content from third parties

On the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Article 6 (1) (f) GDPR), I use content or service offers from third-party providers within my online offer in order to understand their content and Integrate services such as videos or fonts (hereinafter referred to as “content”).

This always presupposes that the third-party providers of this content perceive the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required to display this content. I only endeavor to use content whose providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information on the use of our online offer, as well as being linked to such information from other sources.

 

Youtube

I am integrating the videos of the “YouTube” platform from Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data protection declaration: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

 

Google Maps

I am including the maps of the “Google Maps” service provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. The processed data can include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually as part of the settings of their mobile devices). The data can be processed in the USA. Data protection declaration: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

 

Use of Facebook social plugins

On the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of my online offer within the meaning of Article 6 (1) (f) GDPR), I use social plugins ("plugins") from the social network facebook.com, which operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland ("Facebook"). The plugins can represent interaction elements or content (eg videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white "f" on blue tile, the terms "Like", "Like" or a "thumbs up" sign ) or are marked with the addition "Facebook Social Plugin". The list and the appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

When a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection to the Facebook servers. The content of the plug-in is transmitted from Facebook directly to the user's device, which integrates it into the online offer. User profiles of the users can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore informs the users according to our level of knowledge.

By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offer. If the user is logged into Facebook, Facebook can assign the visit to their Facebook account. If users interact with the plugins, for example by pressing the Like button or leaving a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save his IP address. According to Facebook, only an anonymized IP address is saved in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as the related rights and setting options for protecting the privacy of users can be found in Facebook's data protection information: https://www.facebook.com/about/privacy/ .

If a user is a Facebook member and does not want Facebook to collect data about them via this online offer and link it to their member data stored on Facebook, they must log out of Facebook before using our online offer and delete their cookies. Further settings and contradictions regarding the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US website http://www.aboutads.info / choices / or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, ie they are applied to all devices, such as desktop computers or mobile devices.

 

Instagram

Functions and content of the Instagram service offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA can be integrated into my online offer. This can include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Instagram. If the users are members of the Instagram platform, Instagram can assign the access to the above content and functions to the user profiles there. Instagram's privacy policy: http://instagram.com/about/legal/privacy/.

 

Modified by Anja Steiner

Created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke