Privacy Policy

Data Protection Information

With this privacy policy, we would like to inform you about how we process personal data and explain your rights. We are aware of the importance that the processing of personal data has for you as a user and therefore comply with all relevant legal requirements. Protecting your privacy is of the utmost importance to us. Your personal data is processed by us in compliance with the General Data Protection Regulation and the applicable state-level data protection regulations.

Name and contact details of the controller and their representative

Struss & Claussen Personal Development

Moorfuhrtweg 15
22301 Hamburg
Phone: 040 - 688 79 49 70
Email: kontakt@strussundclaussen.de

Authorized managing directors: Ragnhild Struss and Johann Claussen

Contact details of the Data Protection Officer:

Ayda Pirmohammadi, M.A. Philosophy
Consultant for Knowledge Management and Digitalization
Struss & Claussen Personal Development
Moorfuhrtweg 15
22301 Hamburg
Phone: 040 - 688 79 49 70
Email: pirmohammadi@strussundclaussen.de

Definitions:

This privacy policy uses the terminology of the General Data Protection Regulation (GDPR).

"Personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

"Restriction of processing" means the marking of stored personal data with the aim of limiting their processing in the future.

"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

"Pseudonymization" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

"Filing system" means any structured set of personal data which is accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis;

"Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

"Processor" means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

"Recipient" means a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

"Third party" means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

"Consent" means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

Processing operations

We collect and process the following personal data about you:

Contact and address information, provided you have submitted your contact details to us or registered on our site,
Data you have provided to us during consulting, training, or coaching sessions, or that we record from you,
Data you have provided to us during telephone consultations,
Online identifiers (e.g., your IP address, browser type and version, the operating system used, the referrer URL, the IP address, the file name, access status, the amount of data transferred, and the date and time of the server request).

Processing purposes

We process your data for the following purposes:

to fulfill your request for contact,
to update our offerings for you,
for contract fulfillment,
to develop a strategy tailored to you as part of our consulting services,
for advertising purposes,
to send the email newsletter, provided you have subscribed to it,
for quality assurance and
for our statistics.

Legal basis for data processing

Your data is processed on the basis of the following legal grounds:

your consent pursuant to Art. 6 (1) (a) GDPR,
for the performance of a contract with you pursuant to Art. 6 (1) (b) GDPR,
for the fulfillment of legal obligations pursuant to Art. 6 (1) (c) GDPR or
based on a legitimate interest pursuant to Art. 6 (1) (f) GDPR.

Legitimate interests

Insofar as we base the processing of your personal data on legitimate interests within the meaning of Art. 6 (1) (f) GDPR, such interests are

improving our services,
protection against misuse and
maintaining our statistics.

Data sources

We receive data from you (including via the devices you use). If we do not collect personal data directly from you, we will also inform you of the source of the personal data and, where applicable, whether it originates from publicly accessible sources.

Recipients or categories of recipients of personal data

When processing your data, we work with the following service providers who have access to your data:

twentyreasons business solutions GmbH
Gallup CliftonStrengths Assessment
LINC GmbH
Mailchimp
Thinkific
Chatbase

Data is transferred to third countries outside the European Union. This takes place on the basis of legally provided contractual provisions intended to ensure adequate protection of your data, which you can view upon request.

Storage duration

We only store your personal data for as long as is necessary to achieve the purpose of the processing or as required by a legal retention period.
We store your data,

if you have consented to the processing, for no longer than until you withdraw your consent,
if we require the data for the performance of a contract, for no longer than the contractual relationship with you exists or legal retention periods apply,
if we use the data on the basis of a legitimate interest, for no longer than your interest in deletion or anonymization outweighs our interest.

Your rights

You have the right—in some cases subject to certain conditions—to:

to request information about the processing of your data free of charge, as well as to receive a copy of your personal data. You may request information regarding, among other things, the purposes of the processing, the categories of personal data being processed, the recipients of the data (if disclosure occurs), and the duration of storage or the criteria for determining that duration;
to rectify your data. Should your personal data be incomplete, you have the right to complete the data, taking into account the purposes of the processing;
to have your data deleted or blocked. Reasons for a claim to deletion/blocking may include, among others, the withdrawal of consent upon which the processing is based, the data subject objecting to the processing, or the personal data having been processed unlawfully;
to have the processing restricted;
to object to the processing of your data;
to withdraw your consent to the processing of your data for the future, and
to lodge a complaint with the competent supervisory authority regarding unlawful data processing.

Requirement or obligation to provide data

Unless expressly stated otherwise at the time of collection, the provision of data is not required or mandatory. Such an obligation may arise from legal requirements or contractual provisions.

Further information on data protection

Contact form

The contact form on our website is an easy way to get in touch with us quickly. To enable us to contact you, some fields are marked as mandatory. By filling out the fields and clicking "Send," you agree that your data will be transmitted to us via email along with your message. The data is not stored on the web server.

Email newsletter

When you sign up for our newsletter, we use the data required for this purpose or provided separately by you to send you our email newsletter on a regular basis. Data processing is based on your consent (Art. 6(1)(a) GDPR). We use this data exclusively for sending the requested information and do not pass it on to third parties. You can unsubscribe from the newsletter at any time by sending a message to the contact address provided above or by using the unsubscribe link provided in the newsletter.

Newsletters are sent via Mailchimp, which also stores email addresses and other information used for sending and analyzing the newsletters.

Mailchimp

This website uses the services of Mailchimp to send newsletters. The provider is The Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

Mailchimp is a service used to organize and analyze the distribution of newsletters, among other things. If you enter data for the purpose of subscribing to our newsletter (e.g., your email address), it will be stored on Mailchimp's servers in the USA.

Mailchimp is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the USA designed to ensure compliance with European data protection standards in the USA.

Mailchimp allows us to analyze our newsletter campaigns. When you open an email sent via Mailchimp, a file contained in the email (a web beacon) connects to Mailchimp's servers in the USA. This makes it possible to determine whether a newsletter message has been opened and which links, if any, have been clicked. Technical information is also collected (e.g., time of access, IP address, browser type, and operating system). This information cannot be assigned to the specific newsletter recipient. It is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to the interests of the recipients.

If you do not want your data to be analyzed by Mailchimp, you must unsubscribe from the newsletter. We provide a link for this purpose in every newsletter message. You can also unsubscribe from the newsletter directly on our website.

Data processing is based on your consent (Art. 6(1)(a) GDPR). You can revoke this consent at any time by unsubscribing from the newsletter. The legality of data processing operations already carried out remains unaffected by the revocation.

The data you provide for the purpose of subscribing to our newsletter will be stored by us until you unsubscribe. Once you unsubscribe, the data will be deleted from both our servers and Mailchimp's servers. Data stored for other purposes (e.g., email addresses for the member area) remains unaffected by this.

For more details, please refer to Mailchimp's privacy policy at: https://mailchimp.com/legal/terms/.

We have entered into a data processing agreement with Mailchimp, in which we obligate Mailchimp to protect our customers' data and not to pass it on to third parties. This agreement can be viewed at the following link: https://mailchimp.com/legal/forms/data-processing-agreement/sample-agreement/.

Data security

We have implemented extensive technical and organizational measures to protect your data against potential risks, such as unauthorized access, unauthorized disclosure, alteration, or distribution, as well as loss, destruction, or misuse.

To protect your personal data during transmission from unauthorized access by third parties, we secure data transfers using SSL encryption where necessary. This is a standardized encryption method for online services, particularly for the web.

Log files

The provider of these pages automatically collects and stores information in server log files, which your browser automatically transmits to us. This includes: browser type and version, operating system used, referrer URL, hostname of the accessing computer, time of the server request, and IP address.

This data will not be combined with other data sources.

The basis for data processing is Art. 6 (1) (f) GDPR, which permits the processing of data for the fulfillment of a contract or pre-contractual measures.

Cookiebot

We use the consent management service Cookiebot, provided by Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (Cybot). This allows us to obtain and manage the consent of website users for data processing. Processing is necessary to fulfill a legal obligation (Art. 7 (1) GDPR) to which we are subject (Art. 6 (1) sentence 1 (c) GDPR). For this purpose, the following data is processed using cookies:

Your IP address (the last three digits are set to '0'). Date and time of consent. Browser information. URL from which the consent was sent. An anonymous, random, and encrypted key. Your end-user consent status as proof of consent.

The key and consent status are stored in the browser for 12 months using the “CookieConsent” cookie. This ensures your cookie preference is retained for subsequent page requests. The key allows your consent to be verified and tracked.

If you activate the “Bulk Consent” service function to enable consent for multiple websites through a single end-user consent, the service additionally stores a separate, random, unique ID with your consent. If all the following criteria are met, this key is stored in encrypted form in the third-party “CookieConsentBulkTicket” cookie in your browser: You activate the bulk consent function in the service configuration. You allow third-party cookies via browser settings. You have deactivated “Do Not Track” via browser settings. You accept all or at least certain types of cookies when giving consent.

The functionality of the website is not guaranteed without this processing.

Cybot is the recipient of your personal data and acts as a data processor for us.

Processing takes place within the European Union. Further information on objection and removal options regarding Cybot can be found at: https://www.cookiebot.com/de/privacy-policy/

Your personal data will be deleted continuously after 12 months or immediately after the termination of the contract between us and Cybot.

Please note our general information on the deletion and deactivation of cookies above.

Cookies

This website uses cookies. A cookie is a text file with an identification number that is transmitted to the user's computer along with other requested data when using the website and is stored there. The file is kept there for later access and is used to authenticate the user. Since cookies are only simple files and not executable programs, they pose no threat to the computer. Depending on the user's internet browser settings, cookies are accepted automatically. However, this setting can be changed, and the storage of cookies can be deactivated or set so that the user is notified as soon as a cookie is set. If cookie usage is deactivated, some functions of the website may not be available or may only be available to a limited extent. You can prevent the setting of cookies by our website at any time by adjusting the settings of the internet browser used, thereby permanently objecting to the setting of cookies. Cookies that are already active can be deleted at any time via an internet browser or other software programs. We may work with advertising partners who help us make our website more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). If we work with the aforementioned advertising partners, you will be informed individually and separately about the use of such cookies and the scope of the information collected in each case in the following paragraphs.

Cookie Overview

Chatbase

When you activate the chat function on our website, additional personal data is processed. Data categories processed: technical connection data of the server access (IP address, date, time, requested page, browser information), information about your inquiry, and contact details such as name or email address. Purpose of processing: analysis of user behavior, support for website visitors with technical or content-related questions, and optimization of content. The legal basis for processing: your consent pursuant to Art. 6 (1) (a) GDPR. Data is transmitted to the independent controller CHATBASE.CO INC, 4700 Keele Street, 215 Bergeron Centre of Engineering Excellence, Toronto, ON, M3J 1P3, Canada (https://www.chatbase.co/). The legal basis for the data transfer to CHATBASE.CO INC is your consent pursuant to Art. 6 (1) (a) GDPR. This may also involve the transfer of personal data to a country outside the European Union. The transfer of data to Canada takes place based on Art. 45 GDPR in conjunction with the adequacy decision C(2001) 4539 of the European Commission. The privacy policy of CHATBASE.CO INC: https://www.chatbase.co/privacy.

Google Analytics

We use the Google Analytics service provided by Google Inc. This service enables an analysis of the use of our websites and uses cookies for this purpose. For this purpose, the information generated by the cookie, such as your anonymized IP address, is transmitted to a Google Inc. server in the USA on our behalf, where it is stored and evaluated. Google Analytics on this website has been extended with the code “gat._anonymizeIp();” to ensure anonymized collection of IP addresses. The anonymization of your IP address is generally carried out by Google Inc. by truncating your IP address within the European Union or other contracting states of the European Economic Area (EEA). In exceptional cases, your IP address will be transmitted to a Google Inc. server in the USA and anonymized there. The IP address transmitted in this process will not be merged with other data from Google Inc. As part of the Google Analytics advertising function, remarketing and reports on performance based on demographic characteristics and interests are used. The purpose of these procedures is to align advertising measures more closely with the interests of the respective users using information about user behavior. As part of remarketing, personalized advertising can be displayed on other websites based on the user's browsing behavior on this website. The advertisements may contain products that the user has previously viewed on the website. If you have consented to Google linking your web and app browser history to your Google account and using information from your Google account to personalize ads, Google will use this data for cross-device remarketing. You can object to the collection of your data by Google Analytics at any time. The following options are available for this purpose: Most browsers accept cookies automatically. However, you can prevent the use of cookies by adjusting your browser settings; in this case, however, you may not be able to use all the functions of the website. You must adjust the settings separately for each browser you use.

You can also prevent the collection and processing of this data by Google Inc. by downloading and installing the browser add-on available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de

Alternatively, or when using browsers on mobile devices, please click the following link:

Google Analytics Opt-Out Cookie

Your current setting: The opt-out cookie is not set

An opt-out cookie will be placed on your device for our websites, effective for the browser you are currently using. If you delete your cookies in this browser, you will need to click this link again. Further information on terms of use and data protection can be found at http://www.google.com/analytics/terms/de.html or https://policies.google.com/?hl=de.

Google Fonts

We use Google Fonts, a service provided by Google Inc. ("Google"): www.google.com/fonts#AboutPlace:about. These web fonts are integrated by a server call, usually to a Google server in the USA. This transmits information to the server about which of our web pages you have visited. The IP address of the browser used by the visitor's device is also stored by Google. Further information can be found in Google's privacy policy, which you can access here: www.google.com/policies/privacy/.

Google Maps

We use Google Maps (API) from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) on our website. Google Maps is a web service used to display interactive maps and visualize geographical information. Using this service allows us to show you our location and makes it easier for you to find us. As soon as you access the subpages where the Google Maps map is embedded, information about your use of our website (such as your IP address) is transmitted to Google servers in the USA and stored there. This occurs regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged into Google, your data will be directly associated with your account. If you do not wish for your data to be associated with your Google profile, you must log out before activating the button. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them. Such evaluation is carried out in particular in accordance with Art. 6 (1) (f) GDPR based on Google's legitimate interests in displaying personalized advertising, market research, and/or tailoring its website to needs. You have the right to object to the creation of these user profiles, and you must contact Google to exercise this right. Detailed information on data protection in connection with the use of Google Maps can be found on Google's website (“Google Privacy Policy”): http://www.google.de/intl/de/policies/privacy/.

Facebook using the "Shariff" function

Plugins from the social network Facebook, provided by Facebook Inc., 1 Hacker Way, Menlo Park, California 94025, USA, are integrated into our pages. You can recognize the Facebook plugins by the Facebook logo or the "Like" button on our site. An overview of the Facebook plugins can be found here: http://developers.facebook.com/docs/plugins/. We use the privacy-friendly "Shariff" button. Shariff replaces the standard "Share" button, meaning your data is not automatically transmitted to Facebook every time you visit the page. This only happens when you click the button. Please note that as the provider of the site, we have no knowledge of the content of the transmitted data or its use by Facebook. Further information on this can be found in Facebook's privacy policy at http://de-de.facebook.com/policy.php.

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create user profiles, store cookies, or perform independent analyses. It is used solely for the management and deployment of the tools integrated through it. However, the Google Tag Manager does collect your IP address, which may also be transmitted to Google's parent company in the United States. The use of the Google Tag Manager is based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and management of various tools on their website. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) (a) GDPR and Section 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's device (e.g., device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.

Google Ads

The website operator uses Google Ads. Google Ads is an online advertising program from Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. Google Ads allows us to display advertisements in the Google search engine or on third-party websites when the user enters specific search terms on Google (keyword targeting). Furthermore, targeted advertisements can be displayed based on user data available to Google (e.g., location data and interests) (audience targeting). As the website operator, we can evaluate this data quantitatively by analyzing, for example, which search terms led to the display of our ads and how many ads resulted in corresponding clicks. The use of this service is based on your consent in accordance with Art. 6 (1) (a) GDPR and Section 25 (1) TTDSG. Consent can be revoked at any time. Data transfer to the USA is based on the EU Commission's standard contractual clauses. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.

Google Conversion Tracking

This website uses Google Conversion Tracking. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. With the help of Google Conversion Tracking, Google and we can determine whether a user has performed certain actions. For example, we can evaluate which buttons on our website are clicked most frequently and which products are viewed or purchased most often. This information is used to create conversion statistics. We learn the total number of users who clicked on our ads and what actions they took. We do not receive information that would allow us to personally identify the user. Google itself uses cookies or comparable recognition technologies for identification. The use of this service is based on your consent in accordance with Art. 6 (1) (a) GDPR and Section 25 (1) TTDSG. Consent can be revoked at any time. More information on Google Conversion Tracking can be found in Google's privacy policy: https://policies.google.com/privacy?hl=de.

YouTube

We use providers such as YouTube to embed videos. YouTube is operated by YouTube LLC, headquartered at 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is represented by Google Inc., located at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When you visit pages on our website that feature a plugin—such as our media library—a connection to the YouTube servers is established, and the plugin is displayed. This transmits information to the YouTube server about which of our pages you have visited. If you are logged into YouTube as a member, YouTube associates this information with your personal user account. When using the plugin, such as clicking the start button on a video, this information is also associated with your user account. You can prevent this association by logging out of your YouTube account and any other accounts belonging to YouTube LLC and Google Inc. before using our website and by deleting the corresponding cookies from these companies. Further information on data processing and privacy by YouTube (Google) can be found at www.google.de/intl/de/policies/privacy/.

FontAwesome

We use the FontAwesome web font on our website. When you visit our site, your browser loads the required web fonts into your browser cache to display text and fonts correctly. To do this, your browser must connect to the FontAwesome servers. This informs FontAwesome that our website has been accessed via your IP address. If your browser does not support web fonts, a standard font from your computer will be used. Further information on FontAwesome web fonts can be found in the FontAwesome privacy policy: https://www.fontawesome.com/privacy.

FontAwesome is integrated via a CDN (Content Delivery Network). When a website loads, every file contained on the page generates an HTTP request (a server request). Modern browsers can process between two and four requests in parallel, which inevitably creates a queue. The longer the queue, the slower the website loads. However, the request limit is per domain. If media content is offloaded to additional domains, the page can be loaded from different sources and will build up faster.

TYPEFORM

We use the "TYPEFORM" service on our websites, provided by TYPEFORM S.L., located at Carrer Bac de Roda, 163, 08018 Barcelona (Spain). TYPEFORM collects data to analyze and transmit user behavior on our site to us. Your consent is required for TYPEFORM S.L. to collect and process the specified data for the stated purposes. If you do not wish to consent to the described collection and processing of your data by TYPEFORM S.L., you will not be able to submit your request via the online form. Detailed information on data collection and processing by TYPEFORM S.L. can be found at https://admin.typeform.com/to/dwk6gt.

Spotify

We use the Spotify widget from Spotify AB, Regeringsgatan 19, 111 53 Stockholm, Sweden, to provide our audio content for listening and downloading, and to obtain statistical information regarding its usage. Usage data (such as information about the websites you visit, your interest in content, and access times) and meta/communication data (such as device information, IP address, and pseudonymous cookie IDs) are collected and processed to measure the reach of content through access statistics, identify returning visitors, evaluate website visitor interactions, and create user profiles for advertising purposes. Further information can be found in Spotify's privacy policy, which you can access here: https://www.spotify.com/de/legal/privacy-policy/.

Calendly

You have the option to schedule appointments with us via our website. We use the "Calendly" tool for appointment booking. The provider is Calendly LLC, 271 17th St NW, 10th Floor, Atlanta, Georgia 30363, USA (hereinafter "Calendly").

To book an appointment, please enter the requested information and your preferred date into the provided form. The data entered will be used for scheduling, conducting, and, if necessary, following up on the appointment. Appointment data is stored for us on Calendly servers; you can view their privacy policy here: https://calendly.com/de/pages/privacy.

The data you provide will be retained by us until you request its deletion, revoke your consent for storage, or the purpose for data storage no longer applies. Mandatory legal provisions—particularly retention periods—remain unaffected.

The legal basis for data processing is Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in making appointment scheduling as straightforward as possible for interested parties and customers. If consent has been requested, Art. 6 (1) (a) GDPR is the legal basis for data processing; consent can be revoked at any time.

Data transfer to the USA is based on the EU Commission's standard contractual clauses. Details can be found here: https://calendly.com/pages/dpa.

Hosting via Vercel

We use Vercel, a cloud deployment platform, for our test portal. The service provider is the American company Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789.

Vercel processes your data in the USA, among other locations. Please note that, according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This may involve various risks regarding the legality and security of data processing.

As a basis for data processing by recipients based in third countries (outside the European Union, Iceland, Liechtenstein, and Norway, particularly in the USA) or for data transfers to such countries, we use what are known as standard contractual clauses (Art. 46 (2) and (3) GDPR). Standard contractual clauses (SCCs) are templates provided by the EU Commission designed to ensure that your data complies with European data protection standards even when transferred to and stored in third countries (such as the USA). Through these clauses, Vercel commits to maintaining the European level of data protection when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision by the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=en

The Data Processing Addendum, which complies with the standard contractual clauses, can be found at https://vercel.com/legal/dpa.

You can learn more about the data processed through the use of Vercel in their privacy policy at https://vercel.com/legal/privacy-notice.

Supabase

We use Supabase as a backend service for our website. Supabase is an open-source service provided by Supabase, Inc., 970 Toa Payoh North #07-04, Singapore 318992.

Our database is hosted in the EU (Frankfurt, Germany). When using our website, the following data may be processed in the Supabase database:

Contact inquiries via the contact form
Admin user accounts (for association staff only)

Data processing is carried out on the basis of Art. 6 (1) (b) GDPR (performance of a contract) or Art. 6 (1) (f) GDPR (legitimate interest in operating the website).

You can find further information in Supabase's privacy policy: https://supabase.com/privacy

Data processing

We have entered into a data processing agreement (DPA) with the provider mentioned above. This is a contract required by data protection law that ensures the provider processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

Use of services for the online coaching course

We use the following services to conduct our online coaching course:

Zoom

As part of our online coaching course, we use the video transmission tool Zoom, a service of Zoom Video Communications, Inc., 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA (hereinafter "Zoom"). We use Zoom to conduct live sessions, coaching, and peer group work via video transmission.

Processed data includes user details (e.g., first name, last name, email address), meeting metadata (e.g., topic, participant IP addresses, device/hardware information), and recordings (MP4 file of all video, audio, and presentation recordings, M4A file of all audio recordings, text file of the online meeting chat).
Data processing is carried out for the fulfillment of the contract based on Art. 6 (1) (b) GDPR.

As part of the service, data is transferred to the USA. The processing of "operational data" in the USA and the processing of personal data in support cases are based on the EU Commission's standard contractual clauses.

You can find the Zoom privacy policy here: https://explore.zoom.us/de/privacy/

Stripe

We use Stripe for payment processing, a service of Stripe Payments Europe, Ltd., The One Building, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland (hereinafter "Stripe"). Stripe allows us to offer fast and secure payment processing.

Processed data includes inventory data (e.g., names, addresses), payment data (e.g., bank details, invoices, payment history), contract data (e.g., subject matter of the contract, duration, customer category), and meta/communication data (e.g., device information, IP addresses).

Data processing is carried out for the fulfillment of the contract based on Art. 6 (1) (b) GDPR.

As part of the service, data is transferred to the USA. The transfer is based on the EU Commission's standard contractual clauses.

You can find the Stripe privacy policy here: https://stripe.com/de/privacy

Thinkific

For hosting our online coaching course, we use Thinkific, a service provided by Thinkific Labs Inc., #400 – 369 Terminal Ave, Vancouver, British Columbia, V6A 4C4, Canada (hereinafter "Thinkific"). Thinkific enables us to provide a user-friendly course environment. Furthermore, the service serves as a sales interface for distributing the course.

Processed data includes user data (e.g., first name, last name, email address), meta/communication data (e.g., device information, IP addresses), usage data (e.g., interactions with website elements, access times, course progress), and payment data (e.g., bank details, invoices, billing address, payment history). We have access to this data at all times and can remove it.

Data processing is carried out for the fulfillment of the contract based on Art. 6 (1) (b) GDPR and due to our legitimate interest under Art. 6 (1) (f) GDPR in being able to offer a digital, smooth, and convenient course experience.

As part of the service, data is transferred to the USA. The transfer is based on the EU Commission's standard contractual clauses.

You can find the Thinkific privacy policy here: https://www.thinkific.com/privacy-policy/

PayPal

We use PayPal as an additional payment service provider, a service of PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). PayPal allows us to offer fast and secure payment processing.

For the purpose of payment processing, the data collected during the payment process, including inventory data (e.g., name, email address, telephone number), payment data (payment amount, product name), and meta/communication data (e.g., IP address), is transmitted to PayPal.

PayPal may transmit the collected data to credit agencies for the purpose of identity and credit checks, for example, when paying by direct debit or invoice. You can find more information here: https://www.paypal.com/de/webapps/mpp/ua/creditref

Data processing serves the purpose of contract fulfillment on the basis of Art. 6(1)(b) GDPR. The use of PayPal also serves our legitimate interest under Art. 6(1)(f) GDPR in offering fast and secure payment processing and protecting ourselves against fraud.

As part of this service, data is transferred to the USA. The transfer is based on the EU Commission's standard contractual clauses. Further details can be found here: https://www.paypal.com/de/webapps/mpp/gdpr-readiness-requirements

You can find PayPal's privacy policy here: https://www.paypal.com/en/webapps/mpp/ua/privacy-full

Gallup CliftonStrengths Assessment

As part of our online coaching course, our participants take part in the CliftonStrengths Assessment, a talent assessment program by Gallup, Inc., 901 F Street, NW, Washington D.C., 20004, USA (hereinafter "Gallup"). The test offers participants the opportunity to receive personality reports on their own talent focus areas and strengths. To do this, the participant answers the test questions, which are then evaluated by Gallup to generate the report.

To participate in the CliftonStrengths Assessment, each course participant receives an access code from us, which they can enter on the Gallup website. The course participant will then be prompted to set up a user account with Gallup.

Participation in the CliftonStrengths Assessment is voluntary. We only provide the access codes separately via email, which the participant can use to register on the Gallup website. If the course participant registers for the program, carries it out, and completes it, we can view the results on Gallup, among other things, but not the participants' specific answers to individual questions within the program. This data processing serves the purpose of contract fulfillment on the basis of Art. 6(1)(b) GDPR.

When registering for and participating in the CliftonStrengths Assessment, Gallup collects personal data such as inventory data (e.g., name, email address, telephone number), test data (e.g., participant responses), and meta/communication data (e.g., IP address), which are transferred to the USA.

You can find Gallup's privacy policy here: https://www.gallup.com/privacy

Mailchimp

As part of our online coaching course, we use Mailchimp for internal course email communication. Mailchimp is a service provided by The Rocket Science Group LLC, 675 Ponce de Leon Ave NE, Suite 50000, Atlanta, GA 30308, USA; parent company: Intuit Inc., 2700 Coast Ave, Mountain View, CA 94043, USA. The service helps us manage communication with our course participants.

For the purpose of sending emails, inventory data (e.g., email address, name) is processed, among other things.

Data is processed for the performance of a contract on the basis of Art. 6(1)(b) GDPR and our legitimate interest under Art. 6(1)(f) GDPR in being able to operate email communication with our course participants simply and efficiently via a central application, e.g., for sending course-related information.

As part of this service, data is transferred to the USA. Data processing is based on the EU Commission's standard contractual clauses. You can find details here: https://mailchimp.com/de/help/mailchimp-european-data-transfers/

We have entered into a data processing agreement with Mailchimp, in which we commit Mailchimp to protecting our customers' data and not passing it on to third parties. This contract can be viewed at the following link: https://mailchimp.com/de/legal/data-processing-addendum/

You can find Mailchimp's privacy policy here: https://www.intuit.com/privacy/statement/

Clarity

We use Clarity on our website, an analysis tool provided by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, to better understand our users' experiences and optimize our website. Clarity's technology helps us gain a better understanding of our users' experiences, such as how much time they spend on which pages, how far they scroll, and which links or areas are clicked most frequently. Clarity uses cookies and other technologies to collect information about user behavior and the devices used. Personal data is processed for this purpose, in particular the device's IP address (which is recorded and stored exclusively in anonymized form). In addition, screen size, device type, information about the browser used, and location (region only) are recorded. Clarity stores this information in a pseudonymized user profile; the storage period is one year. This is done on the basis of your consent, which you can withdraw at any time. The information is not used by Clarity or by us to identify individual users, nor is it combined with other data about individual users. You can find more information in Microsoft's privacy policy at https://privacy.microsoft.com/de-de/privacystatement.

We reserve the right to amend this privacy policy at any time with future effect.

Privacy Policy

Data protection information

With this privacy policy, we would like to inform you about how we process personal data and explain your rights. We are aware of the importance that the processing of personal data has for you as a user and we comply with all relevant legal requirements accordingly. Protecting your privacy is of the utmost importance to us. Your personal data is processed by us in compliance with the General Data Protection Regulation and national data protection laws.

Name and contact details of the controller and their representative

Struss & Claussen Personal Development

Moorfuhrtweg 15
22301 Hamburg
Phone: 040 - 688 79 49 70
Email: kontakt@strussundclaussen.de
Authorized Managing Directors: Ragnhild Struss and Johann Claussen
Contact details of the Data Protection Officer:
Ayda Pirmohammadi, M.A. Philosophy
Consultant for Knowledge Management and Digitalization
Struss & Claussen Personal Development
Moorfuhrtweg 15
22301 Hamburg
Phone: 040 - 688 79 49 70
Email: pirmohammadi@strussundclaussen.de

Definitions

This privacy policy uses the terminology of the General Data Protection Regulation (GDPR).

“Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Restriction of processing” means the marking of stored personal data with the aim of limiting their processing in the future.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“Filing system” means any structured set of personal data which is accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis;

“Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

“Processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

“Recipient” means a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

“Third party” means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

“Consent” means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

Processing operations

We collect and process the following personal data about you:

Processing purposes

We process your data for the following purposes:

Legal basis for data processing

Your data is processed on the basis of the following legal grounds:

Legitimate interests

Where we base the processing of your personal data on legitimate interests within the meaning of Art. 6 (1) (f) GDPR, such interests are

Data sources

Recipients or categories of recipients of personal data

We work with the following service providers who have access to your data during the processing process:

Storage duration

We only store your personal data for as long as is necessary to achieve the purpose of the processing or as required by statutory retention periods.

We store your data,

Your rights

You have the right – in some cases subject to certain conditions –

Requirement or obligation to provide data

Unless expressly stated at the time of collection, the provision of data is not required or mandatory. Such an obligation may arise from legal requirements or contractual provisions.

Data protection, confidentiality, and regulation

Protecting your data and your privacy is our top priority. Against the backdrop of the European General Data Protection Regulation (GDPR) and the new EU AI Act, which specifically requires transparency and responsible AI use, we design our use of AI to be deliberately considerate and risk-aware. For you, this means:

In doing so, we align ourselves with international guidelines for the responsible and ethical use of AI in professional services: transparency, traceability, protection of confidentiality, and meaningful human oversight.

Further information on data protection

Contact form

The contact form on our website is a simple way to get in touch with us quickly. To enable us to contact you, some fields are marked as mandatory. By filling out these fields and selecting "Send," you agree that your data will be transmitted to us via email along with your message. This data is not stored on the web server.

Email newsletter

When you subscribe to our newsletter, we use the data required for this purpose or provided by you separately to send you our email newsletter on a regular basis. Data processing is based on your consent (Art. 6(1)(a) GDPR). We use this data exclusively for sending the requested information and do not pass it on to third parties. You may unsubscribe from the newsletter at any time by sending a message to the contact address provided above or by using the unsubscribe link included in the newsletter.

Newsletters are sent via "Mailchimp," which also stores email addresses and other information regarding the distribution and analysis of the newsletters.

MailChimp

This website uses the services of MailChimp to send newsletters. The provider is The Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

MailChimp is a service used to organize and analyze the distribution of newsletters, among other things. When you enter data for the purpose of subscribing to our newsletter (e.g., your email address), it is stored on MailChimp's servers in the USA.

MailChimp is certified under the EU-US Privacy Shield. The Privacy Shield is an agreement between the European Union (EU) and the USA designed to ensure compliance with European data protection standards in the United States.

We use MailChimp to analyze our newsletter campaigns. When you open an email sent via MailChimp, a file contained within the email (known as a web beacon) connects to MailChimp's servers in the USA. This allows us to determine whether a newsletter message has been opened and which links, if any, were clicked. Technical information is also collected (e.g., time of access, IP address, browser type, and operating system). This information cannot be attributed to the individual newsletter recipient. It is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better tailor future newsletters to the interests of the recipients.

If you do not want your data analyzed by MailChimp, you must unsubscribe from the newsletter. We provide a link for this purpose in every newsletter message. You can also unsubscribe from the newsletter directly on our website.

Data processing is based on your consent (Art. 6(1)(a) GDPR). You can revoke this consent at any time by unsubscribing from the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.

The data you provide for the purpose of subscribing to our newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted from both our servers and MailChimp's servers after you unsubscribe. Data stored by us for other purposes (e.g., email addresses for the member area) remains unaffected by this.

For more details, please refer to MailChimp's privacy policy at: https://mailchimp.com/legal/terms/.

We have entered into a data processing agreement with MailChimp, in which we obligate MailChimp to protect our customers' data and not to pass it on to third parties. This contract can be viewed at the following link: https://mailchimp.com/legal/forms/data-processing-agreement/sample-agreement/.

Data security

We have implemented extensive technical and organizational measures to secure your data against potential risks, such as unauthorized access, unauthorized disclosure, alteration, or distribution, as well as loss, destruction, or misuse.

To protect your personal data from unauthorized access by third parties during transmission, we secure data transfers using SSL encryption where necessary. This is a standardized encryption method for online services, particularly for the web.

Log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. This includes: browser type and version, operating system used, referrer URL, hostname of the accessing computer, time of the server request, and IP address.

This data is not merged with other data sources.

The basis for data processing is Art. 6(1)(f) GDPR, which permits the processing of data for the fulfillment of a contract or pre-contractual measures.

Cookiebot

We use the consent management service Cookiebot, provided by Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (Cybot). This allows us to obtain and manage website user consent for data processing. Processing is required to fulfill a legal obligation (Art. 7(1) GDPR) to which we are subject (Art. 6(1) sentence 1(c) GDPR). For this purpose, the following data is processed using cookies:

Your IP address (the last three digits are set to '0'). Date and time of consent. Browser information. URL from which the consent was sent. An anonymous, random, and encrypted key. Your end-user consent status as proof of consent.

The key and consent status are stored in the browser for 12 months using the "CookieConsent" cookie. This ensures your cookie preference is retained for subsequent page requests. The key allows your consent to be verified and tracked.

If you activate the "Bulk Consent" service feature to enable consent for multiple websites via a single end-user consent, the service additionally stores a separate, random, unique ID with your consent. If all of the following criteria are met, this key is stored in encrypted form in the third-party cookie "CookieConsentBulkTicket" in your browser: You activate the bulk consent feature in the service configuration. You allow third-party cookies via browser settings. You have disabled "Do Not Track" in your browser settings. You accept all or at least certain types of cookies when providing consent.

The functionality of the website cannot be guaranteed without this processing.

Cybot is the recipient of your personal data and acts as a data processor on our behalf.

Processing takes place within the European Union. Further information on how to object to or remove data held by Cybot can be found at: https://www.cookiebot.com/de/privacy-policy/.

Your personal data will be deleted on an ongoing basis after 12 months or immediately upon termination of the contract between us and Cybot.