Geneviève Retzlaff
Oskar-Coester-Weg 5
81479 München
Germany

T. +49 (0) 89 750 77 897

M. +49 (0) 163 777 4096

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Data privacy statement

In the following data privacy statement, you will obtain a detailed overview on the processing of your personal data when visiting our website www.grow-better-together.com.

1. Contact details of the parties responsible and the data protection officer

1.1. Name and address of the person responsible

The person responsible pursuant to the EU General Data Protection Regulation (GDPR) and other national Data Protection Acts of the member states as well as other data protection regulations is Geneviève Retzlaff.

Geneviève Retzlaff

Oskar-Coester-Weg 5

81479 München

genevieve@grow-better-together.com
 

2. General information on the collection of personal data

2.1. Principle

This data protection applies to all clients and people interested, employees as well as other contractual partners and all other natural persons that visit our website and make use of the services and benefits.

2.2. Principles on the extent of processing personal data

We share the philosophy laid down in the General Data Protection Regulation (GDPR) and the Federal Data Protection Act, that restricts the collection and processing of personal data (“data”) as much as possible. Therefore, we only process personal data, as long as it is required and as far as it is clearly defined, which is going to be shown to you in the following (principles on data avoidance and data economy). Data processing is only admissible as long as it can be based on a sufficient legal basis or your consent (principle of legality).

2.3. General information on the legal basis for the processing of personal data

2.3.1. General legal basis

The processing of personal data is prohibited in principle and only exceptionally admissible. The admissibility of data processing can only occur when the processing of data can be based on a suitable legal basis. In conclusion, the following can be considered as such:

  • As long as we sought the consent of the person affected for the processing operation of personal data, article 6 para. 1 a GDPR serves as the legal basis.

  • Article 6 para. 1 b GDPR serves as the legal basis for processing personal data, that is required for fulfilling a contract, of which the contractual partner is the person affected. This is also true for processing operations that are required for the execution of pre-contractual actions.

  • As far as the processing of personal data is required for fulfilling the legal obligation, which we are subject to, article 6 para. 1 c GDPR serves as the legal basis.

  • In case vital interest of the person affected or any other natural person require the processing of personal data, article 6 para. 1 d GDPR serves as the legal basis.

  • As long as the processing is required for performing a task, that is in the public interest or in the exercise of official authority, that was transferred to us, article 6 para. 1 e GDPR is the legal basis for processing.

  • If the processing is required for protecting a justified interest of our company or a third party and these interests, fundamental rights and freedoms of the person affected do not outweigh the first mentioned interest, article 6 para. 1 f GDPR serves as the legal basis for processing.

2.3.2. Special legal basis when processing special categories of personal data pursuant to article 9 GDPR

The processing of personal data from which the racial and ethical origin, political opinion, religious or philosophical beliefs or the trade union membership emerge, as well as the processing of genetic data, biometric data for clear identification of a natural person, health data or data on sex live or sexual orientation of a natural person is forbidden.

Exceptionally the processing of these special categories of personal data can be permitted by us, as long as there is a suitable legal basis for it. As such, the following can be considered in particular:

  • As far as the person affected has explicitly agreed to the processing of the special categories of special data for one or several purposes defined, this is the legal basis of the processing (art. 9 para. 2 a GDPR). This does not apply if pursuant to Union law or the law of the member states the prohibition on processing the special categories of personal data cannot be lifted.

  • In case the person affected published data obviously, article 9 para. 2 e GDPR is the legal basis for the processing.

  • As long as the processing of data for assertion, execution or defence of claims is required, the processing according to article 9 para. 2 f GDPR is admissible.

  • The processing of data is admissible, as long as it is on the basis of the Union law or the law of a member state that is in an appropriate relation to the pursued objective, maintains the essence of the right to data protection and prescribes appropriate and specific actions for protecting fundamental rights and interests of the person affected that is required due to a significant public interest, cf. art. 9 para. 2 g GDPR.

2.4. Objection and revocation against the processing of your data

If you have given a consent for processing your data, you can revoke this at any time. Such a revocation influences the admissibility of the processing of your personal data, after you have informed us about it.

As long as we base the processing of your personal data on the balance of interests, you can revoke the processing. This is the case, in particular, when processing is not required for fulfilling a contract with you, which is shown by us respectively with the subsequent description of the functions. When executing such a revocation, we ask for stating reasons, as to why we should not process your personal data. In case of your justified objection, we will examine the situation and will either stop processing the data and/or adapt it or show you our compelling legitimate grounds, on the basis of which we will continue the processing. It goes without saying that you can object to the processing of your personal data for purposes of advertising and data analysis at any time.

2.5. Data deletion and storage period

Your personal data will be deleted or blocked, as soon as the purpose for storage no longer applies; blocking means in this context any kind of cancellation of the data related to your person (e.g. for statistical purposes). Furthermore, storage can occur when it was prescribed by the European or national lawmaker in regulations, laws or other rules, which we are subject to. Blocking or deleting data also occurs, when a storage period expires due to the mentioned standards, unless, there is a need to continue storing the data for concluding a contract or fulfilling a contract.

 

3. Data protection when using the contact form

On our website, we offer every visitor the possibility to get in touch via a contact form by stating personal data.
The following data are submitted by you compulsorily in the context of getting in touch via the contact form:

  • IP address

  • Date and time of your message

  • Name

  • Email address

  • Subject

  • Message

Furthermore, you can make the following statements voluntarily:

  • Information in a data attachment

Whether and to what extent you will submit further personal data in the data attachment to us and we will process them, cannot be controlled by us initially. If not required, however, we ask not to submit any personal details in a data attachment to us.

3.1. Purposes of data processing

The processing of your data serves the processing and reply to your enquiry. Stating your email address is required in order to get in touch with you.  Stating your name serves the personalisation of your enquiry and/or the reply as well as the internal allocation in our company.

3.2. Legal basis of data processing

The legal basis for the processing of the data is art. 6 para. 1 p. 1 a GDPR provided your consent is present. If the request serves the fulfilment of the contract, of which you are the contractual party or the execution of the pre-contractual actions, the additional legal basis for processing data is art. 6 para. 1 p. 1 b GDPR. In order to carry out an allocation of your enquiry in our company, the maintenance of our justified interest serves as another legal basis, art. 6 para. 1 f GDPR; hereby, our justified interests result from the described purposes, we assume, however, that your interests do not outweigh ours.

3.3. Duration of storage; possibility of objection and removal

The data is deleted as soon as it is no longer needed for fulfilling the purpose the data was collected for. This is particularly the case when your enquiry was processed conclusively and possibly responded to.
If getting in contact already serves the execution of the contract, of which you are a contractual partner or the execution of a pre-contractual action, then the data is deleted when they are no longer required for the execution of the contract.
There can be a necessity to save personal data beyond that in order to meet the contractual and legal obligations and maintain our justified interest.
As long as the processing of your data is based on a consent you have the possibility to revoke the consent. By clicking on the respective check box (opt in) before sending your entered data to us you agree to the processing of your data pursuant to this data privacy statement. If, in addition, the data is required for fulfilling a contract or for executing pre-contractual actions, an early deletion of data is only possible, provided there are no contractual or legal obligations for deletion present.

4. Transfer of your data to third parties

As far as not presented in a deviating way previously, we do not forward any personal data to companies, organisations or people outside our company, except in the following circumstances:

4.1. With your consent

We promise not to share your date, however, in some cases also beyond that, we forward personal data to companies, organisations and people outside our company, provided we have your consent for it (art. 6 para. 1 p. 1 a possibly in connection with art. 9 para. 2 a GDPR).

4.2. Processing by others

We make personal data available to the other companies that are our third party business partners, other trustworthy companies and people that process them on our behalf. This takes place on the basis of our instructions and according to our data protection statement as well as other suitable confidentiality and security actions.

4.4. For legal reasons

We will forward personal data to companies, organisations or people outside our company, when we can assume in good faith that the access of this data or its use, retention or disclosure is required reasonably, in order to particularly adhere to current laws, regulations or legal procedures or to comply with an enforceable administrative order; the legal basis is art. 6 para. 1 p. 1 c possibly in connection with art. 9 para. 2 b GDPR.

5. Rights

If personal data is processed about you, you are the affected person for the purpose of GDPR and you have the following rights against us and the party responsible.
You can contact any party responsible mentioned in item 1.1 for executing your rights.

5.1. Right to information

You can request a confirmation from the party responsible on as to whether personal data affecting you is processed by us. If such a processing is the case, you can request access to the following information from the party responsible:

  • the purposes for which the personal data is being processed;

  • the category of personal data which is being processed;

  • the recipient and/or the categories of the recipients; who were given the personal data affecting you or are going to be given.

  • the planned storage period of the personal data affecting you or if no concrete statement is possible about it, the criterion for determining the storage period;

  • the existence of a right to correct or delete the personal data affecting you, a right to restrict the processing by the party responsible or a right to object against this processing;

  • the existence of a right to complain at a supervisory authority;

  • all information available on the origin of the data, if the personal data is not collected with the person affected;

  • the existence of an automated decision-making including profiling pursuant to art. 22 para. 1 and 4 GDPR and – at least in this case – meaningful information on the logic involved as well as the dimension and the pursued implication of such processing for the person affected.

You have the right to obtain information whether personal data affecting you is sent to a third country or an international organisation. In this context you can request via the suitable guarantees according to art. 46 GDPR to be informed about the transfer in this context.

5.2. Right of adjustment

You have the right of adjustment and/or completion towards the party responsible provided the personal data processed affecting you is incorrect or incomplete. The party responsible has to carry out the adjustment immediately.

5.3. Right of restricting the processing

Under the following requirements you can request the restriction of the processing of personal data affecting you:

  • if you dispute the correctness of the personal data affecting you for a certain period of time, that enables the party responsible to examine the correctness of the personal data;

  • the processing is unlawful and you reject the deletion of personal data and instead request for a restriction of the use of the personal data;

  • the party responsible no longer requires the personal data for the purpose of processing, however, you need them for the assertion, execution or defence of legal claims or

  • if you appealed the processing pursuant to art. 21 para. 1 GDPR and it is not certain yet whether the justified reasons of the party responsible outweigh your reasons.

If the processing of the personal data affecting you was restricted, this data can only be processed -let alone saved- with your consent or for the assertion, execution or defence of legal claims or for protecting the rights of another natural or legal person or for reasons of an important public interest of the Union or a member state. If the restriction of the processing was restricted according to the above-mentioned requirements, you will be informed by the party responsible before the restriction is revoked.

5.4. Right of deletion

5.4.1. Obligation of deletion

You can request from the party responsible that the personal data affecting you has to be deleted immediately and the party responsible is obliged to delete the data immediately as long as one of the following reasons apply:

  • The personal data affecting you is no longer needed for the purpose for which it was collected or was processed in any other way.

  • You revoke your consent on which the processing is based on pursuant to art. 6 para. 1 a or art. 9 para. 2 a GDPR and another legal basis for processing is missing.

  • You appeal against the processing pursuant to art. 21 para. 1 GDPR and there are no primary justified reasons for the processing or you appeal against the processing pursuant to art. 21 para. 2 GDPR.

  • The personal data affecting you was unlawfully processed.

  • The deletion of the personal data is required for fulfilling a legal obligation according to Union law or the right of a member state of which the party responsible is subject to.

  • The personal data affecting you was collected in connection with services of the information society offered pursuant to art. 8 para. 1 GDPR.

5.4.2. Information to third parties

If the party responsible has published the personal data affecting you and is obliged to delete it pursuant to art. 17 para. 1 GDPR, they have to take suitable actions by considering the technologies available and costs of implementation, also of technical nature, in order to inform the parties responsible for the data processing that they have requested the deletion of all links to personal data or of copies or replications of this personal data.

5.4.3. Exceptions

The right of deletion does not exist provided the processing is necessary

  • for executing the rights of freedom of opinion and information;

  • for fulfilling a legal obligation, that is required and subject to the processing pursuant to the law of the Union or the member states of which the party responsible is subject to or for performing a task that is in the public interest or results from the exercise of official authority, that was given to the party responsible;

  • for reasons of public interest in the area of public health pursuant to art. 9 para. 2 h and i as well as art. 9 para. 3 GDPR;

  • for archive purposes in the public interest, scientific or historic research purposes or for statistical purposes pursuant to art. 89 para. 1 GDPR, provided the law mentioned in section a) makes the realisation of the objectives of this processing impossible or influences them significantly or

  • for assertion, execution or defence of legal claims.

5.5. Right to information

If you have you asserted the right to adjustment, deletion or restriction of processing against the party responsible, they are obliged to disclose all recipients who they have given personal data affecting you, inform you about this adjustment or deletion of the data or restriction of the processing unless this proves to be impossible or is linked to an excessive effort.

You are entitled to be informed about these recipients.

5.6. Right of data portability

You have the right to receive the personal data affecting you, which you have provided to the party responsible in a structured, usual and machine-readable format. In addition, you have the right to make the personal data available to another party responsible without the hindrance of the party, which you provided the personal data, provided

  • the processing is based on a consent pursuant to art. 6 para. 1 a GDPR or art. 9 para. 2 a GDPR or an agreement pursuant to art. 6 para. 1 b GDPR and

  • the processing takes place by automated methods.

In addition to executing this right, you have the right to have personal data affecting you being transferred from one party responsible to another party responsible, provided this is technically possible. Hereby, freedoms and rights of other people are not allowed to be restricted. The right of data portability does not apply to the processing of personal data that is required for performing a task that is in the public interest or results from the exercise of official authority that was given to the party responsible.

5.7. Right of objection

At any time, you have the right, for reasons occurring due to your special situation, to object against the processing of the personal data affecting you, that occurs due to art. 6 para. 1 e or f GDPR; this also applies for profiling based on these regulations.  The party responsible no longer processes the personal data affecting you, unless they can prove mandatory legitimate reasons for the processing that outweigh your interests, rights and freedoms or the processing serves the assertion, execution or defence of legal claims. If the personal data affecting you are processed to carry out direct advertisement you have the right to appeal against the processing of the personal data affecting you for the purpose of such advertisement; this also applies to profiling, provided it is in connection with such direct advertisement.  If you appeal against the processing for purposes of direct advertising, personal data affecting you will no longer be used for these purposes. You have the possibility, in connection with the use of services of the information society -irrespective of directive 2002/58/EG- to execute your right of objection by means of automated methods for which technical specifications are used.

5.8. Right of objection of the data protection statement

You have the right to revoke your data protection statement at any time. By revoking your consent, the legality of the processing from the consent to the revocation is not affected.

5.9. Right to complain at a supervisory authority

Irrespective of another administrative or legal remedy, you have the right to complain with a supervisory authority, in particular, in the member state of your residence, your workplace or the place of the alleged infringement which you believe violates the GDPR in terms of processing of the personal data affecting you. The supervisory authority, where the complaints was submitted, informs the about the status and the results of the complaint including the possibility of a judicial remedy according to art. 78 GDPR.