Data privacy statement
Rosenberg Society for Holistic Health and Education gGmbH
Forsthausstr. 6, 63633 Birstein, Germany
Commercial Register No.: HRB 12226 Hanau
Managing Directors: Mark and Kerstin Rosenberg
Telephone number: +49 (0) 6054-9131-0
Types of processed data:
• Personal and contact details
• Content data
• Contract data
• Usage data
• Meta / Communication date
Processing of special categories of data (Article 9 (1) GDPR):
No special categories of data are processed.
Categories of data subjects:
• Interested persons
• Visitors and users of the online offer
Purpose of processing:
• Providing the online offer, its contents and functions
• Provision of contractual services, service and customer care
• Answering contact requests and communicating with users
• Marketing, advertising and market research
• Safety measures
1. Relevant legal bases
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as legal basis.
3. Safety measures
3.1. We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk. Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection by technology design and by privacy-friendly default settings taken into account (Article 25 GDPR).
3.2. One of the security measures is the encrypted transfer of data between your browser and our server.
4. Cooperation with contract processors and third parties
4.1. If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, as to payment service providers, in accordance with article 6 paragraph 1 letter b GDPR is necessary for the fulfillment of the contract), you have consented to a legal obligation or on the basis of our legitimate interests (e.g. within the Rosenberg Group, the use of agents, webhosters, etc).
4.2. If we commission third parties to process data on the basis of a so-called "processing contract", this is done on the basis of Art. 28 GDPR.
5. Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. GDPR. I.e. the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.gg for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
6. Rights of the persons concerned
6.1. You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.
6.2. According to Art. 16 GDPR the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
6.3. In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.
6.4. You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible.
6.5. According to Art. 77 GDPR the right to file a complaint with the competent supervisory authority.
You have the right to grant consent in accordance with Art. 7 para. 3 GDPR with effect for the future.
8. Right to object
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.
9. Cookies and right to oppose direct mail
10. Deletion of data
10.2. According to legal requirements, the storage takes place in particular for 6 years in accordance with Art. 257 para. 1 HGB (trading books, inventories, opening balance sheets, annual accounts, trade letters, accounting documents, etc.) and for 10 years in accordance with Art. 147 para. 1 AO (books, records, management reports , accounting documents, commercial and business letters, documents relevant to taxation, etc.).
11.1. On our website we offer users the opportunity to register for an event by providing personal information. In this regard, we process inventory data (e.g., names and addresses and contact information of users), contract data (e.g., services used, names of contacts) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 para. 1 lit b. GDPR. The entries marked as mandatory in online forms are required for the conclusion of the contract. The data are stored electronically in the customer database of the Rosenberg Group. Processing within the group takes place on the legal basis of Recital 48 (1) GDPR.
11.2. As part of the registration and re-registration and use of our online services, we store the IP address and the time of the respective user action. The storage takes place on the basis of both our legitimate interests and the interests of users against protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c GDPR.
11.3. We process usage data (e.g., the visited web pages of our online offering, interest in our products) and content data (e.g., submissions in the contact form or user profile) for advertising purposes in a user profile to send our customers postal and email information about similar services.
11.4. The deletion takes place after expiration of legal warranty and comparable obligations, the necessity of the storage of the data is checked every five years; in the case of legal archiving obligations, the deletion takes place after its expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); Information in the customer account remains stored until its deletion.
12. Contacting us
12.1. When contacting us (via contact form or e-mail), the information provided by the user are processed in order to handle the contact request in accordance with Art. 6 para. 1 lit. b) GDPR.
12.2. The details of the users can be stored in the customer database of the Rosenberg Group. Processing within the group takes place on the legal basis of Recital 48 (1) GDPR.
12.3. We delete the inquiries, if they are no longer required. We check the requirement every five years. In the case of legal archiving obligations, the deletion takes place after its expiry (end of commercial law (6 years) and tax law (10 years) retention obligation).
13. Collection of access data and logfiles
13.1. Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR, we collect data on every access to the server on which this service is located (so-called server log files). The access data include name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
13.2. Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of seven days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.
14. Online presence in social media
14.1. Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR, we maintain online presence within social networks and platforms in order to communicate with the active customers, prospects and users and to inform them about our services. When calling the respective networks and platforms, the terms and conditions and the data processing guidelines apply to their respective operators.
15. Cookies & reach measurement
15.1. Cookies are information transmitted from our web server or third-party web servers to users' web browsers and stored there for later retrieval. Cookies can be small files or other types of information storage.
15.2. We use "session cookies" that are only stored for the duration of the current visit to our online presence (for example, to remember your language preference and thus enable the use of our online offer at all). In a session cookie, a randomly generated unique identification number is stored, a so-called session ID. In addition, a cookie contains information about its origin and the retention period. These cookies can not save any other data. Session cookies will be deleted if you have finished using our online offer and you have e.g. logged out or closed the browser.
15.4. If users do not want cookies stored on their computer, they will have to disable the option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
16. Google Analytics
16.2. Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
16.3. Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
16.4. We use Google Analytics to show advertisements within Google and its affiliate advertising services, only to those users who have taken an interest in our online offering or who have certain characteristics (e.g. interests in specific topics or products visited by them) Web pages) that we submit to Google (so-called "remarketing" or "Google Analytics audiences"). With Remarketing Audiences, we also want to make sure that our ads are in line with the potential interest of users and are not annoying.
16.5. We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
16.6. The IP address submitted by the user's browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly. Users may also prevent the collection of the data generated by the cookie and related to their use of the online offer as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: tools.google.com/dlpage/gaoptout?hl=en.
16.7. For more information about Google's data usage, hiring and opt-out options, please visit Google's websites: google.com/intl/en/policies/privacy/partners ("How Google uses data when you use our partners' sites or apps"), policies.google.com/technologies/ads ("Use of data in advertising"), adssettings.google.com/authenticated ("Control the information Google uses to show you ads").
16.8. Incidentally, the personal data will be anonymized or deleted after a lapse of 14 months.
17. Google Re/marketing services
17.1. On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR) we use the marketing and remarketing services ("Google Marketing Services "), of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, ("Google").
17.2. Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
17.3. Google Marketing Services allows us to better target ads to and on our website so that we only present ads to users that potentially represent their interests. If e.g. a user gets to see ads for products he has been interested in on other websites this called remarketing. For these purposes, when our website or other website working with Google Marketing Services are visited, a code will be executed by Google and so-called (re)marketing tags (invisible graphics or code, also called "Web Beacons") will be incorporated into the website. With their help, the user is provided with an individual cookie, i. e. a small file is saved on its device (instead of cookies, comparable technologies can also be used). The cookies can be set by different domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file is noted which web pages the user visited, what content he is interested in and which offers he has clicked, as well as technical information about the browser and operating system, referring web pages, visit time and other information on the use of the online offer. The IP address of the users is also recorded, whereby in the context of Google Analytics we announce that the IP address is shortened within member states of the European Union or other parties to the Agreement on the European Economic Area and only in exceptional cases is transmitted to a Google server in the US and shortened there. The IP address will not be merged with data of the user within other offers from Google. The above information may also be linked by Google with similar information from other sources. If the user then visits other websites, ads tailored to his interests can be displayed.
17.4. The data of the users are pseudonimized in the context of the Google marketing services. I.e. Google stores and processes e.g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users through Google Marketing Services is transmitted to Google and stored on Google's servers in the United States.
17.5. Among the Google marketing services we use is among others the online advertising program "Google AdWords". In the case of Google AdWords, each advertiser receives a different "conversion cookie". Cookies can not be tracked through AdWords advertisers' websites. The information collected through the cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Advertisers will see the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users.
17.6. In addition, we may use the "Google Tag Manager" to integrate and manage the Google Analytics and Marketing Services on our website.
17.8. If you wish to opt-out of interest-based advertising through Google Marketing Services, you can take advantage of Google's recruitment and opt-out options: adssettings.google.com/authenticated.
18. Integration of services and content of third parties
18.1. Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to integrate their content and services, such as videos or fonts (collectively referred to as "content"). This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include, but is not limited to, technical information about the browser and operating system, referring websites, visit time, and other information regarding the use of our online offer.
18.2. The following presentation provides an overview of third-party providers as well as their contents and links to their data protection statements, which contain further information on the processing of data and, for already mentioned here, contradictory possibilities (so-called opt-out) contain: