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Privacy Policy

Introduction

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online services"). The terms used are not gender-specific.

The controllers within the meaning of data protection laws, in particular the EU General Data Protection Regulation (GDPR), are:

Fenriz Training Center GmbH

Overview of processing activities

The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. names, addresses).

  • Content data (e.g., entries in online forms).

  • Contact details (e.g. email, phone numbers).

  • Metadata/communication data (e.g., device information, IP addresses).

  • Usage data (e.g. websites visited, interest in content, access times).

Categories of affected persons

  • Communication partner.

  • Users (e.g., website visitors, users of online services).

Purposes of processing

  • Provision of our online services and user-friendliness.

  • Contact requests and communication.

Relevant legal bases

Below you will find an overview of the GDPR legal bases on which we process personal data. Please note that in addition to the GDPR regulations, national data protection regulations may apply in your or our country of residence or establishment. If more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.

  • Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.

  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Security measures

In accordance with legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the varying likelihood and severity of the threat to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.

Transfer of personal data

As part of our processing of personal data, it may be necessary to transfer or disclose data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, IT service providers or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies, this will only be done in accordance with legal requirements.

Subject to explicit consent or where transfer is required by contract or law, we only process or have data processed in third countries with a recognized level of data protection, contractual obligations through so-called standard contractual clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Articles 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

Cookies are text files containing data from visited websites or domains, stored by a browser on the user's computer. A cookie primarily serves to store information about a user during or after their visit to an online service. Stored information can include, for example, language settings on a website, login status, items in a shopping cart, or the point at which a video was paused. We also include other technologies that perform the same functions as cookies in the term "cookies" (e.g., when user data is stored using pseudonymous online identifiers, also known as "user IDs").

The following cookie types and functions are distinguished:

  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves an online service and closes their browser.

  • Persistent cookies: Persistent cookies remain stored even after the browser is closed. This allows, for example, login status to be saved or preferred content to be displayed directly when the user revisits a website. Similarly, user interests, which are used for audience measurement or marketing purposes, can be stored in such a cookie.

  • First-party cookies: First-party cookies are set by us.

  • Third-party cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.

  • Necessary (also: essential or absolutely required) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user input, or for security reasons).

  • Statistics, marketing, and personalization cookies: Cookies are also typically used for audience measurement and when a user's interests or behavior (e.g., viewing specific content, using certain functions, etc.) on individual websites are stored in a user profile. Such profiles are used to show users content that matches their potential interests. This process is also known as "tracking," i.e., monitoring users' potential interests. If we use cookies or tracking technologies, we will inform you separately in our privacy policy or when obtaining your consent.

Information on the legal basis: The legal basis for processing your personal data using cookies depends on whether we ask for your consent. If so, and you consent to the use of cookies, the legal basis for processing your data is your explicit consent. Otherwise, data processed using cookies is processed based on our legitimate interests (e.g., in the efficient operation and improvement of our online services) or, if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: Unless we provide you with explicit information on the storage period of persistent cookies (e.g., as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether processing is based on consent or legal permission, you have the right to revoke any consent you have given or to object to the processing of your data by cookie technologies at any time (collectively referred to as "opt-out"). You can initially declare your objection via your browser settings, e.g., by disabling the use of cookies (although this may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via a variety of services, especially in the case of tracking, through the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ . You can also find further information on how to object in the details provided about the service providers and cookies used.

Processing of cookie data based on consent: We use a cookie consent management process to obtain, manage, and revoke user consent for the use of cookies and the processing activities and providers mentioned within the cookie consent management process. The consent declaration is stored to avoid having to request it again and to be able to demonstrate consent in accordance with legal requirements. Storage can be server-side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) to assign the consent to a user or their device. Subject to individual information regarding the providers of cookie management services, the following applies: The storage period for consent can be up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information on the scope of the consent (e.g., which categories of cookies and/or service providers), and the browser, operating system, and device used.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Affected persons: Users (e.g., website visitors, users of online services).

  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Provision of the online service and web hosting

To ensure the secure and efficient provision of our online services, we utilize the services of one or more web hosting providers, from whose servers (or servers they manage) the online services can be accessed. For these purposes, we may utilize infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.

The data processed in connection with providing our hosting services may include all information relating to users of our online services that is generated during use and communication. This regularly includes the IP address, which is necessary to deliver the content of online services to browsers, and all entries made within our online services or on websites.

Collection of access data and log files: We (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and, typically, IP addresses and the requesting provider.

Server log files can be used for security purposes, e.g., to avoid overloading the servers (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server utilization and stability.

  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Affected persons: Users (e.g., website visitors, users of online services).

  • Purposes of processing: Provision of our online service and user-friendliness.

  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Contact

When you contact us (e.g. via contact form, email, telephone or social media), the information provided by the requesting persons will be processed to the extent necessary to answer the contact requests and any requested measures.

Responding to contact requests within the framework of contractual or pre-contractual relationships is done to fulfill our contractual obligations or to answer (pre-)contractual inquiries, and otherwise on the basis of our legitimate interests in answering the inquiries.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms).

  • Affected persons: Communication partners.

  • Purposes of processing: Contact requests and communication.

  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consents allowing its processing are revoked or other permissions cease to apply (e.g., if the purpose of processing this data no longer exists or it is no longer necessary for that purpose).

Unless the data is deleted because it is required for other legally permissible purposes, its processing will be restricted to those purposes. This means the data will be blocked and not processed for any other purpose. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person.

Our privacy policy may also contain further information on the storage and deletion of data, which takes precedence for the respective processing activities.

Changes and updates to the privacy policy

We ask that you regularly review the content of our privacy policy. We will update the privacy policy as soon as changes to our data processing activities make this necessary. We will inform you if any changes require action on your part (e.g., consent) or any other individual notification.

If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting them.

Rights of data subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

  • Right of withdrawal for consents: You have the right to withdraw any consent you have given at any time.

  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed, and to access this data as well as further information and a copy of the data in accordance with legal requirements.

  • Right to rectification: In accordance with legal requirements, you have the right to request the completion of your personal data or the correction of inaccurate personal data concerning you.

  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.

  • Right to data portability: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, or to request its transmission to another controller, in accordance with the legal requirements.

  • Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, however, are intended primarily to aid understanding. The terms are listed alphabetically.

  • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "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 (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

  • Controller: The term "controller" refers to 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.

  • Processing: "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. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission, or erasure.

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