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1) Introduction and contact details of the controller


1.1 We are pleased that you are visiting our website and thank you for your interest. In the following, 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 responsible for data processing on this website within the meaning of the General Data Protection
Regulation (GDPR) is Cristina Lorena González de Palmer, Cristina Palmer Coaching, Training, Assessment, Am
Vogelrain 2, 61169 Friedberg (Hessen), Germany, Tel.: 017653570046, Email: info@cpalmer.de. The controller
responsible for 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 visiting our website


2.1 When you use our website for information purposes only, meaning if you do not register or otherwise provide us
with information, we only collect the data that your browser transmits to the page server (so-called “server log files”).
When you access our website, we collect the following data, which is technically necessary for us to display the website
to you:

  • Our visited website

  • Date and time at the time of access

  • Amount of data sent in bytes

  • Source/reference from which you reached the page

  • Browser used

  • Operating system used

  • IP address used (if applicable: in anonymized form)

Processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data is not shared or otherwise used. However, we reserve the right to subsequently review server log files if there are concrete indications of unlawful use.

2.2 For security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries sent to the controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the character string “https://” and the lock symbol in your browser bar.

3) Hosting & Content Delivery Network

 

3.1 Wix
For the hosting of our website and the presentation of the page content, we use the system of the following provider:
Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo, Israel
Data is also transferred to: Wix Inc., 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA
All data collected on our website is processed on the provider’s servers.
We have concluded a data processing agreement with the provider that ensures the protection of the data of our site
visitors and prohibits unauthorized disclosure to third parties.
For data transfers to the provider’s location, an adequate level of data protection is ensured by an adequacy decision of
the European Commission.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance
with the European level of data protection on the basis of an adequacy decision of the European Commission.

 

3.2 Google Cloud CDN

We use a content delivery network from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St,
Dublin, D04 E5W5, Ireland
This service enables us to deliver large media files such as graphics, page content or scripts more quickly via a
network of regionally distributed servers. Processing is carried out to safeguard our legitimate interest in improving the
stability and functionality of our website in accordance with Art. 6 para. 1 lit. f GDPR.
Data may also be transferred to: Google LLC, USA
We have concluded a data processing agreement with the provider that ensures the protection of the data of our site
visitors and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance
with the European level of data protection on the basis of an adequacy decision of the European Commission.

 

3.3 IONOS
We use a content delivery network from the following provider: 1&1 IONOS Internet SE, Elgendorfer Str. 57, 56410
Montabaur, Germany
This service enables us to deliver large media files such as graphics, page content or scripts more quickly via a
network of regionally distributed servers. Processing is carried out to safeguard our legitimate interest in improving the
stability and functionality of our website in accordance with Art. 6 para. 1 lit. f GDPR.
We have concluded a data processing agreement with the provider that ensures the protection of the data of our site
visitors and prohibits unauthorized disclosure to third parties.


3.4 Wix (wixstatic)
We use a content delivery network from the following provider: Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo,
Israel
Data may also be transferred to:

  • Wix Inc., 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA

  • Fastly Inc., 475 Brannan St. #300, San Francisco, CA 94107, USA

  • Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

  • Amazon Web Services, Inc., 410 Terry Avenue North, Seattle, WA 98109, USA

This service enables us to deliver large media files such as graphics, page content or scripts more quickly via a
network of regionally distributed servers. Processing is carried out to safeguard our legitimate interest in improving the
stability and functionality of our website in accordance with Art. 6 para. 1 lit. f GDPR. We have concluded a data
processing agreement with the provider that ensures the protection of the data of our site visitors and prohibits
unauthorized disclosure to third parties.


For data transfers to the provider’s location, an adequate level of data protection is ensured by an adequacy decision of
the European Commission.


For data transfers to the USA, the data recipients have joined the EU-US Data Privacy Framework, which ensures
compliance with the European level of data protection on the basis of an adequacy decision of the European
Commission.

 

4) Cookies


To make visiting our website attractive and to enable the use of certain functions, we use cookies, i.e. small text files
that are stored on your end device. Some of these cookies are automatically deleted after the browser is closed (so-
called “session cookies”), while others remain on your end device for longer and enable the storage of page settings
(so-called “persistent cookies”). In the latter case, you can find the storage duration in the overview of your web
browser’s cookie settings.


If personal data is also processed by individual cookies used by us, the processing is carried out in accordance with
Art. 6 para. 1 lit. b GDPR either for the performance of the contract, in accordance with Art. 6 para. 1 lit. a GDPR in the
case of consent given, or in accordance with Art. 6 para. 1 lit. 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 site visit.


You can set your browser so that you are informed about the setting of cookies and can decide individually on their
acceptance or can exclude the acceptance of cookies for specific cases or in general.


Please note that if cookies are not accepted, the functionality of our website may be restricted.

5) Contacting us
When contacting us (e.g. via contact form or email), personal data is collected. Which data is collected in the case of
using 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 contacting you and the associated technical administration.


The legal basis for processing this data is our legitimate interest in responding to your request in accordance with Art. 6
para. 1 lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6
para. 1 lit. b GDPR. Your data will be deleted after final processing of your inquiry. This is the case if it can be inferred
from the circumstances that the matter in question has been conclusively clarified and provided that there are no
statutory retention obligations to the contrary.

6) Use of customer data for direct advertising

 

Subscription to our email newsletter
If you subscribe to our email newsletter, we will regularly send you information about our offers. The only mandatory
information required for sending the newsletter is your email address. The provision of further data is voluntary and is
used to address you personally. For sending the newsletter, we use the so-called double opt-in procedure. This means
that we will only send you an email newsletter once you have expressly confirmed that you consent to receiving the
newsletter. We will then send you a confirmation email asking you to confirm by clicking on a corresponding link that
you wish to receive the newsletter in the future.

By activating the confirmation link, you grant us your consent to use your personal data in accordance with Art. 6 para.
1 lit. a GDPR. When registering for the newsletter, we store your IP address entered by the Internet Service Provider
(ISP) as well as the date and time of registration in order to be able to trace possible misuse of your email address at a
later time. The data collected by us when registering for the newsletter is used exclusively for advertising purposes by
means 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 controller named at the beginning. After you unsubscribe,
your email address will be deleted immediately from our newsletter distribution list unless you have expressly
consented to further use of your data or we reserve the right to use data beyond this, which is permitted by law and
about which we inform you in this declaration.

7) Web analytics services

 

Wix Analytics
This website uses the web analytics service of the following provider: Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel
Aviv-Yafo, Israel


With the help of cookies and/or comparable technologies (tracking pixels, web beacons, algorithms for reading end
device and browser information), the service collects and stores pseudonymized 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 behavior on our website and to create pseudonymized usage profiles. Among other things, this enables the
evaluation of movement patterns (so-called heatmaps), which show the duration of page visits as well as interactions
with page contents (e.g. text entries, scrolling, clicks and mouse-overs). Pseudonymization generally excludes direct
personal reference. No merging with clear data about your person collected in another way takes place.
All processing described above, in particular the reading or storage of information on the end device used, is only
carried out if you have given us your express consent in accordance with Art. 6 para. 1 lit. 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 a data processing agreement with the provider that ensures the protection of the data of our site
visitors and prohibits unauthorized disclosure to third parties.


For data transfers to the provider’s location, an adequate level of data protection is ensured by an adequacy decision of
the European Commission.

8) Page functionalities

 

8.1 Google Web Fonts
This page uses so-called web fonts from the following provider for the uniform display of fonts: Google Ireland Limited,
Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland


When a page is accessed, your browser loads the required web fonts into your browser cache in order to display texts
and fonts correctly and establishes a direct connection to the provider’s servers. Certain browser information, including
your IP address, is transmitted to the provider.


Data may also be transferred to: Google LLC, USA
The processing of personal data in the course of establishing contact with the font provider is only carried out if you
have given us your express consent in accordance with Art. 6 para. 1 lit. 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 from your computer will be used.


For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance
with the European level of data protection on the basis of an adequacy decision of the European Commission.
Further information on Google’s privacy policy can be found here: https://business.safety.google/intl/de/privacy/

 

8.2 Microsoft Teams
We use this provider to conduct online meetings, video conferences and/or webinars: Microsoft Corporation, One
Microsoft Way, Redmond, WA 98052-6399 USA


The provider processes different data, whereby the scope of the processed data depends on which data you provide
before or during participation in an online meeting, video conference or webinar. Your data is processed as a
communication participant and stored on the provider’s servers. This may include in particular your registration data
(name, email address, telephone number (optional) and password) and session data (topic, participant IP address,
device information, description (optional)).


In addition, image and sound contributions of participants as well as voice inputs in chats may be processed.
For the processing of personal data that is required for the performance of a contract with you (this also applies to
processing operations necessary for carrying out pre-contractual measures), Art. 6 para. 1 lit. b GDPR serves as the
legal basis. Insofar as you have given us consent to process your data, the processing takes place on the basis of Art.
6 para. 1 lit. a GDPR. Consent given can be revoked at any time with effect for the future.


Otherwise, the legal basis for data processing when conducting online meetings, video conferences or webinars is our
legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR in the effective conduct of the online meeting, webinar or video
conference.


We have concluded a data processing agreement with the provider that ensures the protection of the data of our site
visitors and prohibits unauthorized disclosure to third parties.


For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance
with the European level of data protection on the basis of an adequacy decision of the European Commission.

9) Tools and miscellaneous

 

Cookie consent tool
This website uses a so-called “cookie consent tool” to obtain effective user consent for cookies and cookie-based
applications requiring consent. The “cookie consent tool” is displayed to users when the page is accessed in the form of
an interactive user interface on which consent for certain cookies and/or cookie-based applications can be granted by
ticking boxes. Through the use of the tool, all cookies/services requiring consent are only loaded if the respective user
grants corresponding consent by ticking boxes. This ensures that such cookies are only set on the respective user’s
end device if consent has been granted.


The tool sets technically necessary cookies to store your cookie preferences. Personal user data is generally not
processed in this context.


If, in individual cases, personal data (such as the IP address) is nevertheless processed for the purpose of storing,
assigning or logging cookie settings, this is carried out in accordance with Art. 6 para. 1 lit. 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.


Another legal basis for processing is also Art. 6 para. 1 lit. c GDPR. As the controller, we are subject to the legal
obligation to make the use of technically unnecessary cookies dependent on the respective user’s consent.
Where required, we have concluded a data processing agreement with the provider that ensures the protection of the
data of our site visitors and prohibits unauthorized disclosure to third parties.


Further information about 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 Applicable data protection law grants you the following data subject rights (rights of access and intervention) vis-à-

vis the controller with regard to the processing of your personal data, whereby reference is made to the stated legal
basis for the respective exercise requirements:

  • Right of access pursuant to Art. 15 GDPR;

  • Right to rectification pursuant to Art. 16 GDPR;

  • Right to erasure 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 revoke consent granted pursuant to Art. 7 para. 3 GDPR;

  • Right to lodge a complaint pursuant to Art. 77 GDPR.

 

10.2 RIGHT TO OBJECT
IF WE PROCESS YOUR PERSONAL DATA WITHIN THE FRAMEWORK OF A BALANCING OF INTERESTS ON
THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME
TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON GROUNDS RELATING TO YOUR PARTICULAR
SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED.
FURTHER PROCESSING REMAINS RESERVED, HOWEVER, IF WE CAN PROVE COMPELLING LEGITIMATE
GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND
FREEDOMS, OR IF THE PROCESSING SERVES THE ASSERTION, EXERCISE OR DEFENCE OF LEGAL CLAIMS.
IF YOUR PERSONAL DATA IS PROCESSED BY US FOR THE PURPOSE OF DIRECT ADVERTISING, YOU HAVE
THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR
THE PURPOSE OF SUCH ADVERTISING. YOU CAN 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 measured on the basis of the respective legal basis, the processing
purpose and – where applicable – additionally on the basis of the respective statutory retention period (e.g. retention
periods under commercial and tax law).


When processing personal data on the basis of express consent in accordance with Art. 6 para. 1 lit. a GDPR, the data
concerned is stored until you revoke your consent.


If statutory retention periods exist for data processed within the framework of legal or quasi-legal obligations on the
basis of Art. 6 para. 1 lit. b GDPR, this data is routinely deleted after expiry of the retention periods, provided that it is
no longer required for contract fulfilment or contract initiation and/or we no longer have a legitimate interest in further
storage.


When processing personal data on the basis of Art. 6 para. 1 lit. f GDPR, this data is stored until you exercise your right
to object pursuant to Art. 21 para. 1 GDPR, unless we can demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise or
defence of legal claims.


When processing personal data for the purpose of direct advertising on the basis of Art. 6 para. 1 lit. f GDPR, this data
is stored until you exercise your right to object pursuant to Art. 21 para. 2 GDPR.


Unless otherwise stated in the other information in this declaration regarding specific processing situations, stored
personal data is otherwise deleted when it is no longer necessary for the purposes for which it was collected or
otherwise processed.

Copyright notice: This privacy policy was created by the specialist lawyers of IT-Recht Kanzlei and is protected by
copyright (https://www.it-recht-kanzlei.de)

Privacy Policy

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