This data protection declaration informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the websites, functions and content associated with it as well as external online presences, such as our social media profiles (hereinafter jointly referred to as "online offer"). With regard to the terms used, such as "personal data" or their "processing", we refer to the definitions in Article 4 of the General Data Protection Regulation (DSGVO).
Rosenberg Society for Holistic Health and Education gGmbH
Commercial register: HRB 12226 Hanau
Managing Director: Mark and Kerstin Rosenberg
Types of data processed:
- Inventory data
- Contact data
- Content data
- Contract data
- Payment data
- Usage data
- Meta-/Communication data
Processing of special categories of data (Art. 9 (1) DSGVO): No special categories of data are processed.
Categories of data subjects processed:
- Interested parties
- Visitors and users of the online offer
Purpose of processing:
- Provision of the online offer, its contents and functions.
- Provision of contractual services, service and customer care
- Answering contact requests and communication with users
- Marketing, advertising and market research
- Security measures
1. relevant legal basis
We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
3. Security measures
We take appropriate technical and organizational measures in accordance with Article 32 of the GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order 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 physical access to the data, as well as access to, input, disclosure, ensuring availability and segregation of the data. We also have procedures in place to ensure the exercise of data subject rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Article 25 of the GDPR).
The security measures include in particular the encrypted transmission of data between your browser and our server.
4. cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (order processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract pursuant to Art. 6 para. 1 lit. b DSGVO), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. within the Rosenberg Group of Companies, when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called "order processing agreement", this is done on the basis of Art. 28 DSGVO.
5. 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 happens in the context of the use of third-party services or disclosure, or transfer of data to third parties, this will only happen if it is done for the fulfilment of our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or allow data to be processed in a third country if the special requirements of Art. 44 et seq. DSGVO are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA by the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
6. rights of the data subjects
You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with Art. 15 DSGVO.
You have according to. 6.2. You have the right, in accordance with Art. 16 of the GDPR, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
In accordance with Art. 17 DSGVO, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with Art. 18 DSGVO, to demand restriction of the processing of the data.
You have the right to request that the data concerning you that you have provided to us be received in accordance with Article 20 of the GDPR and to request that it be transferred to other data controllers.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.
7. right of revocation
You have the right to revoke any consent you have given in accordance with Art. 7 (3) DSGVO with effect for the future.
8. right of objection
You may object to the future processing of data relating to you in accordance with Art. 21 DSGVO at any time. The objection can be made in particular against the processing for purposes of direct advertising.
9 Cookies and right to object to direct advertising
10. deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 DSGVO. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
In accordance with legal requirements, data is stored in particular for 6 years in accordance with § 257 para. 1 HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).
11. registration and prospectus requests
On our website we offer users the possibility to register for an educational offer or to request information by providing personal data. In this context, we process inventory data (e.g. names and addresses as well as contact data of users), contract data (e.g. services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 para. 1 lit b. DSGVO. The entries marked as mandatory in online forms are required for the conclusion of the contract or for the sending of information material. The data is stored electronically in the customer database of the Rosenberg group of companies. The processing within the group of companies takes place on the legal basis of recital 48 sentence 1 DSGVO.
Insofar as customers register for training, they receive access to a protected area, the so-called student login. Access requires the entry of the email address in conjunction with a password. The training documents that can be viewed via the student login are not personal. User accounts are not public and cannot be indexed by search engines. When users have completed or terminated their education, their data with regard to the user account will be deleted.
Within the scope of registration and renewed registrations as well as the use of our online services, we store the IP address and the time of the respective user action. The storage is based on both our legitimate interests and the interests of users in protection against abuse and other unauthorized use. In principle, this data is not passed on to third parties unless it is necessary for the pursuit of our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c DSGVO.
We process usage data (e.g. the websites visited on our online offer, interest in our products) and content data (e.g. entries in the contact form or user profile) for advertising purposes in a user profile in order to send our customers information on similar services by post and email.
The deletion takes place after the expiry of legal warranty and comparable obligations, the necessity of the storage of the data is reviewed every five years; in the case of legal archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation); information in the customer account remains until its deletion.
When contacting us (via contact form or e-mail), the user's details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) DSGVO.
12.2 The user's details may be stored in the customer database of the Rosenberg group of companies. The processing within the group of companies takes place on the legal basis of recital 48 sentence 1 DSGVO.
We delete the requests if they are no longer necessary. We review the necessity every five years. In the case of legal archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation).
13.Collection of access data and log files
We collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO, we collect data about every access to the server on which this service is located (so-called server log files). The access data includes 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.
Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for a maximum of seven days and then deleted. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the final clarification of the respective incident.
14. Online presence in social media
We maintain online presences on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO, we maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
15 Cookies & Reach Measurement
Cookies are pieces of information that are transmitted from our web server or third-party web servers to users' web browsers and stored there for later retrieval. Cookies may be small files or other types of information storage.
We use "session cookies", which are only stored for the duration of the current visit to our online presence (e.g. to store your login status or language setting and thus enable the use of our online offer at all). In a session cookie, a randomly generated unique identification number is stored, a so-called session ID. In addition, a cookie contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and log out or close the browser, for example.
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.
16 Google Analytics
Google is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European data protection law(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous user profiles of the users can be created from the processed data.
We use Google Analytics to display the ads placed within advertising services of Google and its partners only to those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited), which we transmit to Google (so-called "Remarketing Audiences" or "Google Analytics Audiences"). With the help of Remarketing Audiences, we also want to ensure that our ads correspond to the potential interest of the users and do not have a harassing effect.
We only use Google Analytics with IP anonymisation enabled. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
For more information about Google's use of data, settings and opt-out options, please visit Google's websites: https://www.google.com/intl/de/policies/privacy/partners("Google's use of data when you use our partners' websites or apps"),https://policies.google.com/technologies/ads("Use of data for advertising purposes"),https://adssettings.google.com/authenticated (" Manage theinformation Google uses to serve you ads").
Otherwise, the personal data will be anonymized or deleted after a period of 14 months.
17. Google Re/Marketing Services
We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the marketing and remarketing services (in short "Google marketing services") of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google").
Google is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European data protection law(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google's marketing services allow us to display advertisements for and on our website in a more targeted manner in order to present users only with ads that potentially match their interests. For example, if a user is shown ads for products he or she has been interested in on other websites, this is referred to as "remarketing". For these purposes, when our website and other websites on which Google marketing services are active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as "web beacons") are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (comparable technologies can also be used instead of cookies). Cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, which content he is interested in and which offers he has clicked on, as well as technical information on the browser and operating system, referring websites, time of visit and other information on the use of the online offer. The IP address of the user is also recorded, whereby we inform Google Analytics that the IP address is shortened within member states of the European Union or in other contracting states of the Agreement on the European Economic Area and only in exceptional cases is transferred in full to a Google server in the USA and shortened there. The IP address will not be merged with data of the user within other offers of Google. The aforementioned information may also be combined by Google with such information from other sources. If the user subsequently visits other websites, he can be shown ads tailored to his interests.
User data is processed pseudonymously as part of Google's marketing services. This means that Google does not store and process, for example, the name or email address of the user, but processes the relevant data in a cookie-related manner within pseudonymous user profiles. I.e. from Google's perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymisation. The information collected by Google marketing services about users is transmitted to Google and stored on Google's servers in the USA.
The Google marketing services we use include, among others, the online advertising program "Google AdWords". In the case of Google AdWords, each AdWords customer receives a different "conversion cookie". Cookies can therefore not be tracked through the websites of AdWords customers. The information obtained with the help of the cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. The AdWords customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that personally identifies users.
Furthermore, we may use the "Google Tag Manager" to integrate and manage Google analytics and marketing services on our website.
If you wish to object to interest-based advertising by Google marketing services, you can use the settings and opt-out options provided by Google: https://adssettings.google.com/authenticated.
18 Facebook Social Plugins
We use on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) social plugins ("plugins") of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are recognisable by one of the Facebook logos (white "f" on a blue tile, the terms "Like", "Like" or a "thumbs up" sign) or are marked with the addition "Facebook Social Plugin". The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance 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 with Facebook's servers. The content of the plugin is transmitted by Facebook directly to the user's device and integrated into the online offer by the latter. In the process, user profiles 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 inform the users according to our state of knowledge.
By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged into Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from their device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will learn and store his or her IP address. According to Facebook, only an anonymized IP address is stored in Germany.
If a user is a Facebook member and does not want Facebook to collect data about him/her via this online offer and link it to his/her membership data stored with Facebook, he/she must log out of Facebook and delete his/her cookies before using our online offer. Further settings and objections to 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 site www.aboutads.info/choices/or the EU sitehttp://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
19. Amazon affiliate program
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter "newsletter") only with the consent of the recipient or a legal permission. If the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our products, offers, promotions and our group of companies.
Double-Opt-In and logging: The registration for our newsletter takes place in a so-called double-opt-in procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Changes to your data stored with the shipping service provider are also logged.
Furthermore, according to its own information, the shipping service provider may use this data in pseudonymous form, i.e. without assigning it to a user, to optimise or improve its own services, e.g. to technically optimise the dispatch and presentation of the newsletters or for statistical purposes to determine which countries the recipients come from. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass it on to third parties.
Registration data: To sign up for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to enter a name for the purpose of a personal address in the newsletter.
Performance measurement - The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from the server of the dispatch service provider when the newsletter is opened. Within the scope of this retrieval, technical information, such as information on the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The dispatch of the newsletter and the measurement of success are carried out on the basis of the consent of the recipients in accordance with Art. 6 Para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 Para. 2 No. 3 UWG or on the basis of the legal permission in accordance with § 7 Para. 3 UWG.
The logging of the registration process takes place on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO and serves as proof of consent to receive the newsletter.
20.10. Cancellation/revocation - Newsletter recipients can cancel receipt of our newsletter at any time, i.e. revoke their consent. You will find a link to cancel the newsletter at the end of each newsletter. At the same time, their consent to the performance measurement will expire. A separate cancellation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled. With the cancellation of the newsletter, the personal data will be deleted, unless their retention is legally required or justified, in which case their processing will be limited only to these exceptional purposes. In particular, we may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them for the purposes of sending newsletters, in order to be able to prove consent previously given. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
21. integration of services and contents of third parties
We use within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer in the sense of Art. 6 para. 1 lit. f. DSGVO) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as "content"). This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may 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 may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in part already mentioned here, options for objection (so-called opt-out):