Information in accordance with § 5 TMG

Operator and contact:

Dr. Wolfgang Walter
Executive Consulting
Cecilienallee 6-7
40474 Düsseldorf
Germany

Telephone +49 211 49844894
info(at)wolfgang-walter.com

Liability note:
We assume no liability for the content of external links despite careful review of their content. The operators of the linked pages carry the sole responsibility for their content.

Copyright:
All rights reserved. Duplication, extracts, copies or reproduction using electronic systems is only permitted with the permission of Dr. Wolfgang Walter.

Privacy Policy

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offering and its related websites, functions and content, as well as external online contributions such as our Social Media Profile (collectively referred to as the "online offering"). With regard to the terminology used, e.g. "processing" or "responsible entity", we refer you to such definitions in Article 4 of the General Data Protection Regulation (GDPR).

Types of processed data:
- Inventory data (e.g. names, postal addresses) - Contact data (e.g. email addresses, telephone numbers) - Content data (e.g. text entries, photographs, videos) - Usage data (e.g. websites visited, interest in content, access times) - Meta-/communications data (e.g. device information, IP addresses).

Categories of persons concerned
Visitors and users of the online offering (in the following, persons concerned are also referred to collectively as 'users').

Purpose of processing
- Provision of the online offering, its functions and content - Response to contact enquiries, communication with users - Security measures - Coverage measurement / Marketing

Terminology
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "person concerned"), whereby a natural person can be considered as being directly or indirectly identifiable, in particular by means of being assignable to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special features that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

"Processing" means any process performed with or without the aid of automated procedures, or any such process associated with personal data. The term goes a long way and includes virtually every form of data handling.

"Pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be assigned to a specific person concerned without the provision of additional information, provided that such additional information is stored separately and is subject to technical and organisational measures which ensure that the personal data is not assigned to an identified or identifiable natural person.

"Profiling" means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects of that natural person relating to job performance, economic situation, health, personal preferences, interests, reliability, behaviour, whereabouts or change of location.

"Responsible instance" means the natural or legal person, public authority, agency or other body that decides, alone or jointly with others, 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 responsible instance.

Relevant legal basis
In accordance with Art. 13 GDPR, we hereby inform you about the legal basis of our data processing. The following applies if the legal basis is not specified in the Privacy Policy: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR; the legal basis for processing the fulfilment of performance for our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b GDPR; the legal basis for processing the fulfilment of our legal obligations is Art. 6 (1) lit. c GDPR, and the legal basis for processing the protection of our legitimate interests is Article 6 (1) lit. f GDPR. In the event that vital interests of the person concerned or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR forms the legal basis.

Security measures
Taking into account technical state-of-the-art, implementation costs and the nature, scope, circumstances and purposes of processing, as well as the varying likelihood and height of risk to the rights and freedoms of natural persons, we apply appropriate technical and organisational measures in accordance with Art. 32 GDPR to ensure a level of protection commensurate with the risk.

In particular, measures include ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the relevant access method, input, disclosure, availability and separation. We have also set up procedures to assure data subject rights, data deletion and reaction to data vulnerability. Furthermore, we pay attention to the protection of personal data during the development stage as well as the selection of hardware, software and procedures in line with the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR).

Collaboration with contract processors and third parties
If, in the context of processing, we disclose data to other persons and companies (contract processors or third parties) and transmit this data to them or otherwise allow access to the data, this will only be done on the basis of granting a legal permission (e.g. if transmission of the data to third parties, such as payment service providers, is required pursuant to Art. 6 (1) (b) GDPR in order to fulfil the contract), or if you have given your consent, or if it is based on a legal obligation or on our legitimate interests (e.g. the use of agents, web hosters, etc.).
If we commission third parties to process data on the basis of a "processing contract", this takes place on the basis of Art. 28 GDPR.

Transmission 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 takes place in connection with the use of third-party services, or disclosing or transmitting data to third parties, this will only take place if it is for the purpose of fulfilling our (pre-) contractual obligations, on the basis of your consent, on the basis of a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we either process or have the data processed in a third country only if the special conditions pursuant to Art. 44 et seq. GDPR apply. This means that the processing takes place for example on the basis of specific guarantees, such as the officially recognised level of data protection applying to the EU (e.g. for the US through the Privacy Shield), or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").

Rights of persons concerned
In accordance with Art. 15 GDPR, you have the right to ask for confirmation as to whether specific data is being processed, and to ask for information about this data as well as for additional information and a copy of the data.
In accordance with Art. 16 GDPR, you have the right to demand completion of the data or correction of incorrect data concerning your person.
In accordance with Art. 17 GDPR, you have the right to demand the immediate deletion of relevant data or, alternatively in accordance with Art. 18 GDPR, to demand a restriction on the processing of the data.
In accordance with Art. 20 GDPR, you have the right to demand that the data relating to you, which you have provided to us, be made available, and to request its transmission to other responsible instances.
In accordance with Art. 77 GDPR, you have the right to file a complaint with the responsible supervisory authority.

Right of withdrawal
In accordance with. Art. 7 para. 3 GDPR, you have the right to withdraw previously granted consent with effect for the future.

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

Deletion of data
The data processed by us will be either deleted or limited in terms of processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in the context of this Privacy Policy, the data stored by us will be deleted as soon as it is no longer required for its specific purpose and given that the deletion does not conflict with any statutory storage requirements. Insofar as the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies for example for data that is required to be retained for commercial or tax reasons.

In line with German legal requirements, the storage takes place in particular for 10 years in accordance with §§ 147 Abs. 1 AO, 257 Abs. 1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, booking vouchers, trading books, relevant documents for taxation, etc.) and 6 years in accordance with § 257 (1) no. 2 and 3, para. 4 HGB (commercial letters).

In line with legal requirements in Austria, the storage takes place in particular for 7 years in accordance with § 132 paragraph 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, income and expense statement, etc.), for 22 years in connection with real estate and for 10 years in the case of documents relating to electronically transmitted services, telecommunications, broadcasting and television services provided to non-commercial entities in EU member states and for which the Mini-One-Stop-Shop (MOSS) applies.

Therapeutic services and coaching
In order to provide them with our contractual or pre-contractual services, we process the data of our clients and interested parties as well as other purchasers or contractual partners (collectively referred to as "clients") in accordance with Art. 6 para. 1 lit. b) GDPR. The data processed and the nature, scope, purpose and necessity of this processing are determined by the underlying contractual relationship. The processed data essentially includes clients' regular and master data (e.g. name, address, etc.) as well as contact data (e.g. email address, telephone, etc.), the contract data (e.g. services used, fees, names of contact persons, etc.) and payment details (e.g. bank details, payment history, etc.).

As part of our services, we can also process special data categories in accordance with Art. 9 para. 1 GDPR, in particular information regarding clients' health, where applicable related to their sexual life or sexual orientation, ethnic origin or religious or ideological convictions. If necessary, we obtain the client's express consent in accordance with Art. 6 para. 1 lit. a., Art. 7, Art. 9 para. 2 lit. a. GDPR, but otherwise process the special data categories required for health care purposes on the basis of Art. 9 (2) (h). GDPR, § 22 Abs. 1 Nr. 1 b. Federal Data Protection Act.

If contractually or legally required, we disclose or transmit client information in the course of communication with other professionals or third parties required or typically involved in the performance of these contracts, such as billing agencies or comparable service providers, provided that this is in line with the provision of our services in accordance with Art. Art. 6 para. 1 lit b. GDPR, or if accordance with Art. 6 para. 1 lit c. GDPR is legally prescribed, or serves the legitimate interests of our clients in the context of efficient and cost-effective health care in accordance with Art. 6 para. 1 lit. F. GDPR, or is required in accordance with Art. 6 (1) lit. d. GDPR in order to protect the vital interests of clients or other natural persons, or in the context of consent in accordance with. Art. 6 para. 1 lit. a., Art. 7 GDPR.

The data is deleted if it is no longer required for the fulfilment of contractual or legal care-related duties and the handling of any warranty and similar obligations, whereby the necessity of retaining the data is reviewed every three years; in any case, statutory storage obligations apply.

Contact enquiries
When contacting us (for example by contact form, email, telephone or via social media), the user information that applies to the contact enquiry is processed in accordance with. Art. 6 para. 1 lit. b) GDPR. User information can be stored in a Customer Relationship Management System ("CRM System") or in a comparable enquiry organisation.

We delete the requests if they are no longer required. We check the requirement status every two years; furthermore, the legal archiving obligations apply.

Hosting and e-mailing The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security and the technical maintenance services we use to operate this online service.

In this context we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data as well as meta and communication data relating to this online offer's customers, interested parties and visitors on the basis of our legitimate interest in the efficient and secure provision of this online offer pursuant to Art. 6 para. 1 lit. f GDPR in combination with Art. 28 GDPR (conclusion of processing contract).

Collection of access data and logfiles
Based on our legitimate interests in the context of Art. 6 para. 1 lit. f. GDPR, we, or our hosting provider, collect data during every instance of access to the server on which this service is located (so-called server log files). The access data includes the designation of the retrieved web page, the file, the date and time of retrieval, the amount of data transmitted, the notification of successful retrieval, the browser type and version, the user's operating system, the referrer URL (i.e. the previously visited page), the IP address and the requesting provider.

Logfile information is stored for security purposes (for example to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data requiring further retention for evidential purposes is exempted from deletion until final clarification of the incident has taken place.

Integration of third-party services and content
Based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering according to Art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to integrate their content and services, such as videos or fonts (hereafter referred to as "content").

This always presupposes that the third-party providers of this content recognise the user's IP address, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavour to only use such content for which the IP address is used solely by the respective providers to deliver the content. Third parties 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 evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referral web pages, visit time, and other information regarding the use of our online offer, but can also be connected with such information from other sources.

Photography:
José-Luis Martinez

Website:
SEM Webdesign, Düsseldorf

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