The Savvy Center in Nordbayern

Privacy Policy

Status: December 29, 2024

Table of Contents

Person responsible

The Savvy Center- Nina Gassner und Joshua Burke Betreiber GbR
Engweg 1
97535 Wasserlosen

Authorized representatives: Nina Gassner and Joshua Burke

E-mail address: info@thesavvycenter.de

Imprint: https://www.thesavvycenter.de/en/imprint/

Overview of processing

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

Types of data processed

  • Inventory data.
  • Contact data.
  • Content data.
  • Usage data.
  • Meta, communication and process data.
  • Protocol data.

Categories of persons affected

  • Communication partners.
  • Users.

Purposes of processing

  • Communication.
  • Organizational and administrative procedures.
  • Feedback.
  • Provision of our online offer and user-friendliness.
  • Information technology Infrastructure.
  • Public relations.

Relevant legal bases

Relevant legal bases under the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 Para. 1 Clause 1 lit. a) GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 lit. b) GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR) – The processing is necessary to safeguard the legitimate interests of the controller or a third party, provided that the interests, fundamental rights and freedoms of the data subject which require the protection of personal data are not overridden. prevail.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the law to protect against misuse of personal data in data processing (Federal Data Protection Act – BDSG). The BDSG contains in particular special regulations on the right to information, the right to erasure, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission and automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Note on the validity of the GDPR and the Swiss DSG: This data protection notice serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that the terms of the GDPR are used due to the broader spatial application and comprehensibility. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “personal data requiring particular protection” used in the Swiss DSG, the terms “processing” of “personal data” as well as “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined according to the Swiss DSG within the scope of the validity of the Swiss DSG.

Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transmission, securing the availability and separation of the data. Furthermore, we have set up procedures that ensure the exercise of the rights of those affected, the deletion of data and reactions to threats to the data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Securing online connections using TLS/SSL encryption technology (HTTPS): In order to protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the advanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator for users that their data is being transmitted securely and encrypted.

Transmission of personal data

As part of our processing of personal data, it may happen that this is transmitted to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

International data transfers

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 as part of the use of third-party services or the disclosure or transmission of data to other persons, bodies or companies, this will only be done in accordance with the legal requirements. If the data protection level in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the data protection level is otherwise secured, in particular through standard contractual clauses (Art. 46 Para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transmission (Art. 49 Para. 1 GDPR). Otherwise, we will inform you of the basis for third-country transfers from the individual providers from the third country, with the adequacy decisions taking priority. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de. As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA as part of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). In the privacy policy we will inform you which service providers we use are certified under the Data Privacy Framework.

General information on data storage and deletion

We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consent is revoked or there are no further legal bases for the processing. This applies to cases in which the original processing purpose no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require the data to be stored or archived for a longer period.

In particular, data that must be stored for commercial or tax law reasons or whose storage is necessary for legal proceedings or to protect the rights of other natural or legal persons must be archived accordingly.

Our data protection notices contain additional information on the storage and deletion of data that applies specifically to certain processing procedures.

If there are several details on the storage period or deletion periods for a date, the longest period always applies.

If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships within the framework of which data is stored, the event that triggers the deadline is the time at which the termination or other termination of the legal relationship takes effect.

Data that is no longer stored for the originally intended purpose but due to legal requirements or other reasons, is only processed by us for the reasons that justify its storage.

Further information on processing procedures, methods and services:

  • Storage and deletion of data: The following general deadlines apply to storage and archiving under German law:
    • 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets as well as the work instructions and other organizational documents, accounting documents and invoices required for their understanding (Section 147 Para. 3 i. in conjunction with paragraph 1 no. 1, 4 and 4a AO, Section 14b paragraph 1 UStG, Section 257 paragraph 1 no. 1 and 4, paragraph 4 HGB).
    • 6 years – Other business documents: received commercial or business letters, reproductions of sent commercial or business letters, other documents, insofar as they are relevant for taxation, e.g. B. Hourly wage slips, operating accounting sheets, calculation documents, price labels, but also payroll documents, insofar as they are not already booking documents and cash register slips (Section 147 Paragraph 3 in conjunction with Paragraph 1 Nos. 2, 3, 5 AO, Section 257 Paragraph 1 Nos. 2 and 3, Paragraph 4 HGB).
    • 3 years – Data that is required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries based on previous business experience and usual industry practices are stored for the duration of the regular statutory limitation period of three years (Sections 195, 199 BGB).

Rights of the data subjects

Rights of the data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right of object: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed in order to conduct direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct advertising.
  • Right of withdrawal of consent: You have the right to withdraw consent given at any time.
  • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the statutory requirements.
  • Right to rectification: In accordance with the statutory requirements, you have the right to request that the data concerning you be completed or that incorrect data concerning you be rectified.
  • Right to erasure and restriction of processing: In accordance with the statutory requirements, you have the right to request that data concerning you be erased immediately or, alternatively, to request that the processing of the data be restricted in accordance with the statutory requirements.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us. have, in accordance with the legal requirements, in a structured, common and machine-readable format or to request that they be transmitted to another responsible party.
  • Complaint to the 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, place of work or place of the alleged infringement, if you believe that the processing of personal data concerning you violates the provisions of the GDPR.

Provision of the online offer and web hosting

We process user data in order to be able to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

  • Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, people involved); protocol data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. textual or visual messages and contributions as well as information relating to them, such as information on authorship or time of creation).
  • Persons affected: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).).
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing procedures, procedures and services:

  • Provision of online offering on rented storage space: To provide our online offering, we use storage space, computing capacity and software that we rent from a corresponding server provider (also called a “web host”) or obtain from another source; Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).
  • E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information relating to the e-mail sending (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purposes of detecting SPAM. Please note that e-mails are generally not sent encrypted over the Internet. E-mails are usually encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We cannot therefore accept any responsibility for the transmission path of the e-mails between the sender and the receipt on our server; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
  • STRATO: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: STRATO AG, Pascalstraße 10,10587 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.strato.de; Privacy policy: https://www.strato.de/datenschutz/. Contract processing: Provided by the service provider.

Use of cookies

The term “cookies” refers to functions that store information on users’ end devices and read it from them. Cookies can also be used for various purposes, such as for the purposes of the functionality, security and convenience of online services and the creation of analyses of visitor flows. We use cookies in accordance with legal regulations. To do so, we obtain the user’s consent in advance if necessary. If consent is not necessary, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online service. Consent can be revoked at any time. We provide clear information about the scope of this and which cookies are used.

Notes on the legal basis for data protection: Whether we process personal data using cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), they should assume that these are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with legal requirements, including by means of the privacy settings of their browser.

  • Types of data processed: Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Persons affected: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR). Consent (Art. 6 Para. 1 S. 1 lit. a) GDPR).

Further information on processing processes, procedures and services:

  • Processing of cookie data based on consent: We use a consent management solution in which users’ consent is obtained for the use of cookies or for the procedures and providers named in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users’ end devices. As part of this procedure, users’ consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers named in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are saved in order to avoid further queries and to be able to provide proof of consent in accordance with legal requirements. The data is stored on the server and/or in a cookie (so-called opt-in cookie) or using comparable technologies in order to be able to assign the consent to a specific user or their device. Unless specific information is available about the providers of consent management services, the following general information applies: The consent is stored for a period of up to two years. A pseudonymous user identifier is created, which is stored together with the time of the consent, information on the scope of the consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, the system and the device used; Legal basis: Consent (Art. 6 Para. 1 Clause 1 Letter a) GDPR).

Contact and inquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the details of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.

  • Types of data processed: Inventory data (e.g. full name, home address, contact information, customer number, etc.); Contact data (e.g. postal and e-mail addresses or telephone numbers); Content data (e.g. textual or visual messages and contributions as well as information relating to them, such as details of authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, persons involved).
  • Data subjects: communication partners.
  • Purposes of processing: communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR).

Further information on processing processes, procedures and services:

  • Contact form: When you contact us via our contact form, by e-mail or other communication channels, we process the personal data sent to us to answer and process the respective request. This usually includes information such as name, contact information and, if applicable, other information that is communicated to us and is necessary for appropriate processing. We use this data exclusively for the stated purpose of contact and communication; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 Para. 1 Clause 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 lit. f) GDPR).

Presences in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for users because it could, for example, make it more difficult to enforce user rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The latter may in turn be used to place advertisements within and outside the networks that presumably correspond to the interests of users. Cookies are therefore usually stored on users’ computers in which the user behavior and interests of users are stored. In addition, data can also be stored in the user profiles regardless of the devices used by the users (especially if they are members of the respective platforms and are logged in there).

For a detailed description of the respective processing methods and the objection options (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as information relating to them, such as details of authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Communication; Feedback (e.g. collecting feedback via online form). Public relations.
  • Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 Clause 1 Letter f) GDPR).

Further information on processing procedures, procedures and services:

  • Instagram: Social network, enables sharing photos and videos, commenting on and favorite posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third country transfers: Data Privacy Framework (DPF).
  • Facebook pages: Profiles within the social network Facebook – Together with Meta Platforms Ireland Limited, we are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices users use (e.g. IP addresses, operating system, browser type, language preferences, cookie data; see “Device Information” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, so-called “Page Insights”, to page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular the right to information, deletion, objection and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint responsibility is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of data to the parent company Meta Platforms, Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basic basis for third country transfers: Data Privacy Framework (DPF).

Plug-ins and embedded functions and content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or city maps (hereinafter referred to uniformly as “content”).

The integration always requires that the third-party providers of this content process the IP address of the users, since without an IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known 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 can also be stored in cookies on the user’s device and can contain, among other things, technical information about the browser and operating system, referring websites, the time of the visit and other information about the use of our online service, but can also be linked to such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Types of data processed: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, people involved).
  • Affected persons: users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness.
  • Storage and deletion: deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods can be stored on users’ devices for a period of two years.).
  • Legal basis: consent (Art. 6 Para. 1 S. 1 lit. a) GDPR). Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Further information on processing procedures, methods and services:

  • Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use to display or make our online offering more user-friendly). The respective providers collect the user’s IP address and can process this for the purposes of transmitting the software to the user’s browser, for security purposes and to evaluate and optimize their offering. – We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use to display or make our online offering more user-friendly). The respective providers collect the IP address of the user and can process this for the purposes of transmitting the software to the user’s browser as well as for security purposes and to evaluate and optimize their offer; Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).

Changes and updates

We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or 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 please check the information before contacting us.

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