Privacy Policy
1) Information on the Collection of Personal Data and Contact Details of the Controller
1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.
1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Marie-Pascale Gafinen, Rosenhofstraße 7, 20357 Hamburg, Germany, Phone.: +4915226869025, e-mail: kontakt@gafinen.com. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
2) Data Collection When You Visit Our Website
2.1 When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:
- Our visited website
- Date and time at the moment of access
- Amount of data sent in bytes
- Source/reference from which you came to the page
- Browser used
- Operating system used
- IP address used (if applicable: in anonymized form)
Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.
2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.
3) Cookies
In order to make your visit to our website more attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. In some cases, these cookies are automatically deleted again after the browser is closed (so-called "session cookies"), in other cases, these cookies remain on your end device for longer and allow page settings to be saved (so-called "persistent cookies"). In the latter case, you can find the duration of the storage in the overview of the cookie settings of your web browser.
If personal data is also processed by individual cookies set by us, the processing is carried out either in accordance with Art. 6 (1) point b GDPR for the performance of the contract, in accordance with Art. 6 (1) point a GDPR in the case of consent given or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.
You can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.
Please note that the functionality of our website may be limited if cookies are not accepted.
4) Contacting Us
4.1 Calendly
For the provision of an online appointment booking function, we use the services of the following provider: Calendly, LLC, BB&T Tower, 271 17th St NW, Atlanta, GA 30363, USA
For the purpose of making an appointment, your first name, surname and e-mail address (and telephone number, if a telephone appointment is requested) are collected in accordance with Art. 6 (1) point b GDPR and transferred to the provider in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in effective customer management and efficient appointment management and stored there for the purpose of organising the appointments.
After the appointment has been held or after the agreed appointment period has expired, your data will be deleted by the provider.
We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
4.2 When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration.
The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.
5) Commentary Function
Within the scope of the commentary function on this website, in addition to your comment, information on the time of writing the comment and the name of the commentator you have chosen is stored and published on the website. Furthermore, your IP address is logged and stored. This IP address is stored for security reasons in case the person concerned violates the rights of third parties or posts illegal content by submitting a comment. We need your e-mail address to contact you if a third party should object to your published content as unlawful. The legal basis for the storage of your data is Art. 6 (1) point b and f GDPR. We reserve the right to delete comments if they are objected to as unlawful by third parties.
6) Use of Client Data for Direct Advertising
6.1 Subscribe to our e-mail newsletter
If you register for our e-mail newsletter, we will regularly send you information about our offers. The only mandatory data for sending the newsletter is your e-mail address. The provision of further data is voluntary and will be used to address you personally. We use the so-called double opt-in procedure for sending the newsletter. This means that we will only send you an e-mail newsletter once you have expressly confirmed that you consent to receiving newsletters. We will then send you a confirmation e-mail asking you to confirm that you wish to receive the newsletter in future by clicking on an appropriate link.
By activating the confirmation link, you give us your consent for the use of your personal data pursuant to Art. 6 (1) point a GPPR. When you register for the newsletter, we store your IP address entered by your Internet service provider (ISP) as well as the date and time of registration for the purpose of tracing any possible misuse of your e-mail address at a later date. The data collected by us when you register for the newsletter is used exclusively for the promotional purposes by way of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the responsible person named at the beginning. After unsubscribing, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data, or we reserve the right to a more extensive use your data which is permitted by law and about which we inform you in this declaration.
6.2 MailChimp
Our e-mail newsletters are sent via this provider: The Rocket Science Group, LLC d/b/a MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA
On the basis of our legitimate interest in effective and user-friendly newsletter marketing, we pass on the data you provided when registering for the newsletter to this provider in accordance with Art. 6 (1) point f GDPR so that they can send the newsletter on our behalf.
Subject to your express consent pursuant to Art. 6 (1) point a GDPR, the provider also carries out a statistical analysis of the success of newsletter campaigns by means of web beacons or tracking pixels in the emails sent, which can measure opening rates and specific interactions with the newsletter content. In the process, end device information (e.g. time of page view, IP address, browser type and operating system) is also collected and analysed, but not combined with other data records.
You can revoke your consent to newsletter tracking at any time with effect for the future.
We have concluded an order processing agreement with the provider, which safeguards the data of our website visitors and prohibits a transfer to third parties.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
7) Web Analysis Services
Jetpack
This website uses the web analytics service provided by the following provider: Automattic Inc., 60 29th Street #343, San Francisco, CA 94110-4929, USA
Using cookies and/or comparable technologies (tracking pixels, web beacons, algorithms for reading end device and browser information), the service collects and stores pseudonymised visitor data, including information on the end device used such as the IP address and browser information, in order to evaluate it for statistical analyses of user behaviour on our website and to create pseudonymised user profiles. Among other things, this enables the analysis of movement patterns (so-called heat maps), which show the duration of page visits and interactions with page content (e.g. text entries, scrolling, clicks and mouse-overs). Pseudonymisation generally excludes the possibility of direct personal reference. Your personal data will not be combined with data collected in any other way.
All processing described above, in particular the reading or saving of information on the end device used, is only carried out if you have given us your express consent in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the "cookie consent tool" provided on the website.
We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
8) Site functionalities
8.1 Instagram plugins
Plugins of the social network of the following provider are used on our website: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Instagram)
These plugins allow direct interaction with content on the social network.
In order to increase the protection of your data when visiting our website, the plugins are initially deactivated and integrated into the page by means of a so-called "2-click" or "Shariff" solution. This integration ensures that when you access a page of our website that contains such plugins, no connection is yet established with the servers of the provider.
Your browser only establishes a direct connection to the servers of the provider when you activate the plugins and thereby give your consent to the data transfer in accordance with Art. 6 (1) point a GDPR. In this process, regardless of whether you log into an existing user profile, a certain amount of information about your end device used (including your IP address), your browser and your page history is transferred to the provider and may be further processed there.
If you are logged into an existing user profile on the provider's social network, information about interactions carried out via the plugins will also be published there and displayed to your contacts.
You can revoke your consent at any time by deactivating the activated plugin by clicking on it again. However, the revocation has no influence on the data that has already been transferred to the provider.
Data can also be transferred to: Meta Platforms Inc., USA
We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorised disclosure to third parties.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
8.2 Google Web Fonts
This site uses so-called web fonts from the following provider to display fonts in a uniform manner: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Data is also transferred to: Google LLC, USA
When you call up a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly and establishes a direct connection to the provider's servers. In this process, certain browser information, including your IP address, is transmitted to the provider.
The processing of personal data while establishing the connection with the provider of the fonts is only carried out if you have given us your express consent to do so in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service via the "cookie consent tool" provided on the website. If your browser does not support web fonts, a standard font will be used by your computer.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
Further information on Google's privacy standards can be found here: https://business.safety.google
8.3 Google reCAPTCHA
On this website, we use the CAPTCHA service of the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
Data may also be transmitted to: Google LLC, USA. For the visual design of the CAPTCHA window, the provider uses "Google Fonts", i.e., fonts loaded from the Internet by Google. No further information is processed except that mentioned above, which is already transmitted to Google via the functionality of ReCaptcha.
The service checks whether an input is made by a natural person or abusively by machine and automated processing with the aim of blocking spam, DDoS attacks and similar automated malicious attacks. To ensure whether an action is performed by a human being and not by an automated bot, the provider collects the IP address of the end device used, the recognition data of the browser, the operating system type and the date and duration of the visit and transmits these data to the provider's servers to be evaluated.
This process is based on our legitimate interest in determining individual responsibility when using the Internet and in preventing abuse and spam in accordance with Art. 6 Para. 1 lit. f GDPR.
We have concluded an order processing contract with the provider, ensuring the protection of our site visitors' data and prohibiting unauthorized disclosure to third parties.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
Further information on Google's privacy standards can be found here: https://business.safety.google
8.4 Zoom
We use this provider to conduct online meetings, video conferences and/or webinars: Zoom Video Communications Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA
The provider processes different data, whereby the scope of the processed data depends on the data you provide before or during the participation in an online meeting, video conference or webinar. Your data as a communication participant is processed and stored on servers of the provider. This may include, in particular, your registration data (name, e-mail address, telephone number (optional) and password) and session data (topic, participant IP address, device information, description (optional)). In addition, participants' image and sound contributions as well as voice input in chats may be processed.
For the processing of personal data that is necessary for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures), Art. 6 (1) point b GDPR serves as the legal basis. If you have given us your consent to process your data, the processing is based on Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future.
In addition, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest pursuant to Art. 6 (1) point f GDPR in the effective conduct of the online meeting, webinar or video conference.
We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.
For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.
9) Tools and Miscellaneous
This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "cookie consent tool" is displayed to users in the form of an interactive user interface when they access the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box. Through the use of the tool, all cookies/services requiring consent are only loaded if the respective user provides the corresponding consent by ticking the corresponding box. This ensures that such cookies are only set on the respective end device of the user if consent has been granted.
The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed.
If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.
Further legal basis for the processing is Art. 6 (1) point c GDPR. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.
Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.
10) Rights of the Data Subject
10.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:
- Right of access by the data subject pursuant to Art. 15 GDPR;
- Right to rectification pursuant to Art. 16 GDPR;
- Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR;
- Right to restriction of processing pursuant to Art. 18 GDPR;
- Right to be informed pursuant to Art. 19 GDPR;
- Right to data portability pursuant to Art. 20 GDPR;
- Right to withdraw a given consent pursuant to Art. 7 (3) GDPR;
- Right to lodge a complaint pursuant to Art. 77 GDPR.
10.2 RIGHT TO OBJECT
IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.
11) Duration of Storage of Personal Data
The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and - if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).
If personal data is processed on the basis of an express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.
If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.
When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.
If personal data is processed for the purpose of direct marketing on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.
Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.