Status: October 2022
I appreciate your interest in my consulting and examination services. I take data protection seriously and it has a particularly high priority for me. The use of my websites is possible without any indication of personal data. Only if a visitor of my website wants to use one of the services offered by me, processing of personal data could become necessary. If the processing of your personal data is necessary and there is no legal basis for such processing, I generally obtain the consent of the data subject.
I provide technical means (e-mail form, online diary) and have taken measures here to ensure the highest possible level of protection for personal data processed through my website. However, Internet-based data transmissions generally have security gaps, so that I cannot guarantee absolute protection. For this reason, however, you are free to transmit personal data to me also by alternative means, for example by telephone.
My data protection declaration is based on the terms used by the European legislator for the adoption of the DS-GVO.
2. name and address of the responsible person
3. general data and information when visiting my website
My website collects a series of general data and information with each call-up of the website by a data subject. These general data and information is stored in the server’s log files. The following data may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of an access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and informations that serve to avert danger in the event of attacks on our information technology systems.
3.1 Purpose of processing and legal basis
When using these general data and informations, I do not draw any conclusions about the data subject. Rather, these informations are needed to (1) correctly deliver the content of my website, (2) optimize the content of my website, and (3) ensure the long-term functionality of my information technology systems and the technology of our website. These collected personal data and informations are evaluated exclusively by me in order to increase data protection and data security. The personal data of the server log files are stored separately from any personal data provided by a data subject.
The legal basis for the temporary storage of personal data and log files is Art. 6 para. 1 lit. f DS-GVO for the protection of my interests…
3.2 Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
In the case of storage of data in log files, this is the case after one month at the latest. Storage beyond this is possible in anonymized form. In this case, the IP addresses are deleted or alienated, so that an assignment of the calling client is no longer possible.
If the personal data is required for the prosecution of a criminal offense, it will be deleted after expiration of the proceedings in compliance with the statutory retention periods.
3.3 Need to provide
The provision of the data is neither legally nor contractually required. However, the collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website.
Failure to provide personal data may result in disadvantages for you. For example, this could result in you not being able to receive or use our services (e.g. access to the website may not be possible). However, unless otherwise stated, you will not suffer any legal disadvantages from not providing it.
4. Subscription to our press releases and newsletter
On my website, possibly in the future, users will be given the opportunity to subscribe to a newsletter. Which personal data is transmitted to the responsible person when ordering press releases and newsletters can be seen from the input mask used for this purpose. As a rule, only the name, the e-mail address, additionally the IP address and the time of registration are collected.
4.1 Purpose of processing and legal basis
The personal data collected in the context of a registration for the newsletter dispatch are used exclusively for the dispatch of my newsletter. My future newsletters may contain so-called tracking pixels. A tracking pixel is a thumbnail graphic that is embedded in my emails to provide a log file record and log file analysis. This allows a statistical analysis.
All personal data collected in my newsletters containing tracking pixels are stored and evaluated exclusively by me in order to optimize newsletter delivery and to improve to adapt the content of future newsletter content to the interests of the respective data subject. This personal data will not be passed on to third parties. The legal basis for the processing of data in the context of the provision of my newsletter is, with your consent, Art. 6 para. 1 lit. a) GDPR.
4.2 Duration of storage and unsubscription
I process your data until your subscription to the newsletter is cancelled. There is a link for this in every e-mail.
4.3 Need for provision
The provision of personal data is neither legally nor contractually required. You can cancel the subscription at any time.
5. Contact possibility
Such personal data transmitted to me on a voluntary basis by a data subject will be stored for the purpose of processing or contacting the data subject. The legal basis for the processing of data transmitted in the course of sending an e-mail or using the contact form is Art. 6 para. 1 lit. f GDPR. If the contact aims at the conclusion of a contract or is directed at an existing contract, the legal basis for the processing is Art. 6 para. 1 lit. b GDPR. This personal data is not passed on to third parties.
5.2 Duration of storage
If I no longer need your data to process your request, your personal data will be deleted. This is usually the case at with the end of the conversation with you, unless I am obliged to keep them longer to comply with my legal obligations.
5.3 Need for provision
The provision of personal data is neither legally nor contractually required. If you do not provide your data, I cannot (continue) the conversation with you.
Cookies may be necessary for our website to function properly. By setting cookies, I can, for example, determine that you have logged into in to my website
Before you can visit my website at all, I ask you for your consent, so that the setting of cookies in accordance with Art. 6 para. 1 lit. a) GDPR is justified. The cookies that I absolutely need to provide the website, I use on the basis of legitimate interest under Art. 6 para. 1 lit. f) GDPR.
I use the data collected by cookies for as long as they are required for the respective stated purpose.
The data subject can prevent the setting of cookies by my website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of my website may be fully usable.
8. google custom search engine
Within my website, the “Google custom search” (Google Custom Search Engine “Google CSE”) of Google Inc. (“Google”), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA as a central search service. The embedded search service allows a full-text search for content on my website. Access to this search function is possible via a search box embedded in the header of each website.
For the information of the users of the website, a Google icon is displayed in the search box.
8.1 Activating the search
By entering a search term in the search box and then pressing the enter key or the search icon (magnifying glass symbol), the user activates the search function and the search results page is called up, which loads the corresponding search results from Google by means of a plugin provided by Google. In the process, data is transferred to the tracing service.
Google states that, in principle, the following information (including personal data) may be processed, among others:
Log data (in particular the IP address);
Unique application numbers;
Cookies and similar technologies.
If you are logged into your Google account, Google may add the processed information to your account depending on your account settings and treat it as personal data, see in particular https://www.google.de/policies/privacy/partners/.
Google states the following about this, among other things:
I may link personal data from one service with information and personal data from other Google services. By doing so, I make it easier for you to share content with friends and acquaintances. Depending on your account settings, your activities on other websites and apps may be linked to your personal data to improve Google’s services and ads served by Google.” (https://www.google.com/intl/de/policies/privacy/index.html)
For information about Google’s privacy settings, see:
8.2 Search result page
The plugin developed and provided by Google (Google Custom Search Engine “Google CSE”) is integrated into the search results page by the responsible party as a software module “as-is” (unchanged). The plugin enables automated communication (data exchange) between the called search results page and the Google service when the search results page is called. The use of the search function provided by Google involves a dynamic transfer of data by the service provider Google to the search results page.
8.3 Transfer of data to Google
Data is only transferred to Google as soon as the user activates the search box, starts a full-text search and thereby calls up the search results page. By using the search function within the search results page, user data is also transmitted to Google at the same time.
8.4 Legal basis: Consent to data transmission by using Google search
Before using the full text search and the associated call of the search results page, you will be asked for your consent to the processing by me and Google and the transfer of data to the Google service in accordance with Art. 6 para. 1 lit. a) DS-GVO asked. This includes, for example, the search terms you entered and the IP address of the computer you are using.
If you are logged in to Google at the same time, the Google service is able to assign the information directly to your user profile. You should log out to avoid collection of profile information about you.
It cannot be ruled out that Google also transmits the information to a server in a third country. As can be seen from Google’s Privacy Shield certification (available at https://www.privacyshield.gov/list under the search term “Google”), Google has committed to comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework on the collection, use and retention of personal data from the member states of the EU and Switzerland, respectively. Google, including Google LLC and its wholly owned subsidiaries in the U.S., has declared by certification that it complies with the Privacy Shield Principles. For more information, visit https://www.google.de/policies/privacy/frameworks/.
9. information on social media (Facebook, Twitter and Instagram)
9.1.1 Social media links on my website
When you visit my website, no personal data is initially passed on to the operators of the social media platforms. On my website you will only find passive links to Facebook, Instagram or Twitter. They are neither disabled social media buttons nor active plug-ins. Therefore, personal data is only transmitted to the operators of the social media platforms when you actively click on the links and are thus redirected to the social media website itself.
My website contains a link to the social network Facebook of Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA, operated within the EU by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (collectively “Facebook”). When you click on the link, you will be redirected to the Facebook website. In doing so, Facebook obtains knowledge of the IP address assigned to you as well as the information that the user of this IP address has accessed the corresponding page you visited. If you are logged into Facebook, Facebook can assign the visit to your Facebook account. If you interact with the plugins, for example by clicking the “Like” button or posting a comment, the corresponding information is transmitted directly from your browser to Facebook and stored there.
My Instagram account is operated by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland (“Facebook”). The link used on my website is marked with the Instagram logo in the form of an “Instagram camera”. You can find me at @flugmedberlin.
Your browser only establishes a direct connection to Facebook’s servers when you click on the link. By visiting my Instagram channel, Facebook receives the information that your browser has accessed the corresponding page of my website, even if you do not have an Instagram profile or are not currently logged in to Instagram. This information (including your IP address) is transmitted from your browser directly to a Facebook server in Ireland and the USA and stored there.
I will only process data to the above-mentioned and limited extent (see section 12.1.2).
Not only Facebook Ireland Limited, but also Facebook Inc. in the USA processes your personal data. Through certification under the EU-US Privacy Shield (“EU-US Privacy Shield”)https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active, Facebook Inc. guarantees that EU data protection requirements are also complied with when processing data in the USA.10. Links to other websites11. Processors and third parties
10. links to other websites
For ease of use and information purposes, my website contains links to other websites Such websites are operated independently of us. Where we provide links to websites of other organizations, this privacy statement does not apply to the processing of personal data by those organizations. Linked sites have their own privacy policies or statements; I encourage you to review them carefully when visiting linked sites, as I am not responsible for the content of such sites, nor for any use or privacy practices of such sites.
11. processors and third parties
I will only share your personal data with service providers and other third parties in accordance with applicable data protection laws.
I may disclose personal information to those service providers I engage and require them to perform services on my behalf. This concerns in particular the processing of your personal data during website maintenance. In doing so, I observe the strict applicable national and European data protection regulations. For the operation of my website I have used an IT service provider. This service provider is subject to my instructions and is subject to strict contractual restrictions regarding the processing of personal data. Accordingly, processing is only permitted to the extent necessary to perform the services on our behalf or to comply with legal requirements. It is specified in advance by me exactly what rights and obligations my service provider should have with regard to personal data.
In addition, I pass on your personal data,
- if they are required to do so by law or court order,
- To law enforcement or other governmental agencies; or
- When they believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
In addition, should the controller or its assets be sold, transferred or otherwise restructured, in whole or in part, I reserve the right to transfer data relating to you that is held by me. Following such disposal or transfer, if you have any questions about the processing of such data, you may contact the entity to which I transferred your personal data.
12. routine deletion and blocking of personal data
I process and store personal data of the data subject only for the period necessary to achieve the purpose of storage or where provided for by the European legislator or other legislator in laws or regulations to which the controller is subject.
If the purpose of storage no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
The deadlines can be found separately for each data processing operation in the respective section.
13. rights of the data subject
13.1 The rights of data subjects regarding personal data
If personal data is processed by me, you are a data subject within the meaning of the GDPR and you have the right to exercise data subject rights. You have the following rights vis-à-vis me regarding the processing by me of personal data concerning you:
- Right to revoke the declaration of consent under data protection law (Art. 7 (3) DS-GVO)
- Right to information (Art. 15 DS-GVO);
- Right to rectification (Art. 16 DS-GVO);
- Right to erasure (“right to be forgotten”) (Art. 17 DS-GVO);
- Right to restriction of processing (Art. 18 DS-GVO);
- Right to data portability (Art. 20 DS-GVO);
- Right to object to processing (21 GDPR); and
- Right to complain to a supervisory authority (Art. 13 para. 2 lit. d) DS-GVO).
13.2 Below you will find more information about your rights:
13.2.1 Right to revoke the declaration of consent under data protection law
13.2.2 Right to confirmation
You have a right to request confirmation from the controller as to whether personal data in question are being processed.
13.2.3 Right to information
You have a right to receive free information about the personal data stored about you and a copy of the personal data from the person responsible at any time. Furthermore, the European legislator has granted you access to the following information:
the processing purposes
the categories of personal data that are processed
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations
if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
the existence of a right to obtain the rectification or erasure of personal data concerning him or her, or the restriction of processing by the controller, or a right to object to such processing
the existence of a right of appeal to a supervisory authority
if the personal data are not collected from the data subject: All available information about the origin of the data
the existence of automated decision making including profiling pursuant to Art. 22 para. 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
Furthermore, the data subject has a right to information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.
This right of access may be restricted to the extent that it is likely to render impossible or seriously impair the achievement of the research or statistical purposes and the restriction is necessary for the fulfillment of the research or statistical purposes.
13.2.4 Right to rectification
You have a right to request that inaccurate personal data concerning you be corrected without delay. Furthermore, you have the right, taking into account the purposes of the processing, to request the completion of incomplete personal data – also by means of a supplementary declaration.
13.2.5 Right to erasure (right to be forgotten)
You have the right to obtain from the controller the erasure without delay of personal data concerning you, where one of the following grounds applies and insofar as the processing is not necessary:
The personal data were collected or otherwise processed for purposes for which they are no longer necessary.
The data subject revokes the consent on which the processing is based pursuant to Art. 6 para. 1 lit. a DS-GVO or Art. 9 para. 2 lit. a DS-GVO and there is no other legal basis for the processing.
The data subject shall, pursuant to Art. 21 para. 1 DS-GVO, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (1) DS-GVO. 2 DS-GVO to object to the processing.
The personal data have been processed unlawfully.
The deletion of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
The personal data was collected in relation to information society services offered pursuant to Art. 8 para. 1 DS-GVO collected.
If one of the above reasons applies and you want to arrange the deletion of personal data stored by me, you can contact me at any time. I will comply with the deletion request immediately.
The right to erasure does not exist insofar as the processing is necessary to
to exercise the right to freedom of expression and information;
for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;
for archiving purposes in the public interest, scientific or historical research purposes, or for statistical purposes in accordance with. Art. 89 par. 1 GDPR, insofar as the right referred to in Section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
for the assertion, exercise or defense of legal claims.
13.2.6 Right to restriction of processing
You have the right to request the controller to restrict processing if one of the following conditions is met:
The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful, the data subject objects to the erasure of the personal data and requests instead the restriction of the use of the personal data.
The controller no longer needs the personal data for the purposes of processing, but the data subject needs it for the assertion, exercise or defense of legal claims.
The data subject has objected to the processing pursuant to. Art. 21 par. 1 DS-GVO and it is not yet clear whether the legitimate grounds of the controller outweigh those of the data subject.
Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of their storage, only with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
Your right to restrict processing may be limited to the extent that it is likely to render impossible or seriously impede the achievement of the research or statistical purposes and the restriction is necessary for the fulfillment of the research or statistical purposes.
13.2.7 Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right to be informed about these recipients by the data controller.
13.2.8 Right to data portability
You have the right to receive the personal data concerning you, which has been provided by the data subject to a controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent pursuant to Art. 6 para. 1 letter a DS-GVO or Art. 9 para. 2 letter a DS-GVO or on a contract pursuant to Art. 6 para. 1(b) of the GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, when exercising his or her right to data portability pursuant to Art. 20 para. 1 DS-GVO the right to obtain that the personal data be transferred directly from one controller to another controller, insofar as this is technically feasible and insofar as this does not adversely affect the rights and freedoms of other persons.
The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
13.2.9 Right of objection
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 lit. e) or f) DS-GVO is carried out. This also applies to profiling based on these provisions.
I shall no longer process the personal data in the event of the objection, unless I can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the assertion, exercise or defense of legal claims.
To exercise the right to object, the data subject may contact me directly in person. You are also free, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.
Your right to object may be limited to the extent that it is likely to render impossible or seriously impair the realization of the research or statistical purposes and the limitation is necessary for the fulfillment of the research or statistical purposes.
13.2.10 Automated decisions in individual cases including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, provided that the decision is
is not necessary for the conclusion or performance of a contract between you and the responsible person, or
is permitted by Union or Member State legislation to which the controller is subject and that legislation contains appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, or
is done with your express consent.
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 DS-GVO, unless Art. 9 para. 2 lit. a) or g) DS-GVO applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.
Is the decision
necessary for the conclusion or performance of a contract between the data subject and the controller, or
it takes place with the express consent of the data subject,
I take appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, which include at least the right to obtain the intervention of a person responsible, to express his or her point of view and to contest the decision.
13.2.11 Right of complaint to a data protection supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 of the GDPR.