PRIVACY POLICY
We are very delighted that you have shown interest
in our enterprise. Data protection is of a
particularly high priority for the management of
the Sondermann Consulting & Coaching. The use of
the Internet pages of the Sondermann Consulting &
Coaching is possible without any indication of
personal data; however, if a data subject wants to
use special enterprise services via our website,
processing of personal data could become
necessary. If the processing of personal data is
necessary and there is no statutory basis for such
processing, we generally obtain consent from the
data subject.
The processing of personal data, such as the name,
address, e-mail address, or telephone number of a data
subject shall always be in line with the General Data
Protection Regulation (GDPR), and in accordance with
the country-specific data protection regulations
applicable to the Sondermann Consulting & Coaching. By
means of this data protection declaration, our
enterprise would like to inform the general public of
the nature, scope, and purpose of the personal data we
collect, use and process. Furthermore, data subjects
are informed, by means of this data protection
declaration, of the rights to which they are entitled.
As the controller, the Sondermann Consulting &
Coaching has implemented numerous technical and
organizational measures to ensure the most complete
protection of personal data processed through this
website. However, Internet-based data transmissions
may in principle have security gaps, so absolute
protection may not be guaranteed. For this reason,
every data subject is free to transfer personal data
to us via alternative means, e.g. by telephone.
1. Definitions
The data protection declaration of the Sondermann
Consulting & Coaching is based on the terms used by
the European legislator for the adoption of the
General Data Protection Regulation (GDPR). Our data
protection declaration should be legible and
understandable for the general public, as well as our
customers and business partners. To ensure this, we
would like to first explain the terminology used.
In this data protection declaration, we use, inter
alia, the following terms:
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a) Personal data
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.
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b) Data subject
Data subject is any identified or identifiable
natural person, whose personal data is processed
by the controller responsible for the processing.
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c) Processing
Processing is 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, organisation,
structuring, storage, adaptation or alteration,
retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making
available, alignment or combination, restriction,
erasure or destruction.
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d) Restriction of processing
Restriction of processing is the marking of stored
personal data with the aim of limiting their
processing in the future.
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e) Profiling
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 analyse or
predict aspects concerning that natural person's
performance at work, economic situation, health,
personal preferences, interests, reliability,
behaviour, location or movements.
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f) Pseudonymisation
Pseudonymisation is 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
organisational measures to ensure that the
personal data are not attributed to an identified
or identifiable natural person.
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g) Controller or controller responsible for
the processing
Controller or controller responsible for the
processing is 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.
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h) Processor
Processor is a natural or legal person, public
authority, agency or other body which processes
personal data on behalf of the controller.
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i) Recipient
Recipient is 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.
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j) Third party
Third party is 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 authorised to process personal
data.
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k) Consent
Consent of the data subject is any freely given,
specific, informed and unambiguous indication of
the data subject's wishes by which he or she, by a
statement or by a clear affirmative action,
signifies agreement to the processing of personal
data relating to him or her.
2. Name and Address of the controller
Controller for the purposes of the General Data
Protection Regulation (GDPR), other data protection
laws applicable in Member states of the European Union
and other provisions related to data protection is:
Sondermann Consulting & Coaching
Römerstr. 26
63843 Niedernberg
Germany
Phone: +49 (0) 6021 991965
Email: info@sococo.eu
Website: www.sococo.eu
3. Collection of general data and information
The website of the Sondermann Consulting & Coaching
collects a series of general data and information when
a data subject or automated system calls up the
website. This general data and information are stored
in the server log files. Collected may be (1) the
browser types and versions used, (2) the operating
system used by the accessing system, (3) the website
from which an accessing system reaches our website
(so-called referrers), (4) the sub-websites, (5) the
date and time of access to the Internet site, (6) an
Internet protocol address (IP address), (7) the
Internet service provider of the accessing system, and
(8) any other similar data and information that may be
used in the event of attacks on our information
technology systems.
When using these general data and information, the
Sondermann Consulting & Coaching does not draw any
conclusions about the data subject. Rather, this
information is needed to (1) deliver the content of
our website correctly, (2) optimize the content of our
website as well as its advertisement, (3) ensure the
long-term viability of our information technology
systems and website technology, and (4) provide law
enforcement authorities with the information necessary
for criminal prosecution in case of a cyber-attack.
Therefore, the Sondermann Consulting & Coaching
analyzes anonymously collected data and information
statistically, with the aim of increasing the data
protection and data security of our enterprise, and to
ensure an optimal level of protection for the personal
data we process. The anonymous data of the server log
files are stored separately from all personal data
provided by a data subject.
4. Routine erasure and blocking of personal data
The data controller shall process and store the
personal data of the data subject only for the period
necessary to achieve the purpose of storage, or as far
as this is granted by the European legislator or other
legislators in laws or regulations to which the
controller is subject to.
If the storage purpose is not applicable, or if a
storage period prescribed by the European legislator
or another competent legislator expires, the personal
data are routinely blocked or erased in accordance
with legal requirements.
5. Rights of the data subject
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a) Right of confirmation
Each data subject shall have the right granted by
the European legislator to obtain from the
controller the confirmation as to whether or not
personal data concerning him or her are being
processed. If a data subject wishes to avail
himself of this right of confirmation, he or she
may, at any time, contact any employee of the
controller.
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b) Right of access
Each data subject shall have the right granted by
the European legislator to obtain from the
controller free information about his or her
personal data stored at any time and a copy of
this information. Furthermore, the European
directives and regulations grant the data subject
access to the following information:
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the purposes of the processing;
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the categories of personal data concerned;
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the recipients or categories of recipients to
whom the personal data have been or will be
disclosed, in particular recipients in third
countries or international organisations;
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where possible, the envisaged period for which
the personal data will be stored, or, if not
possible, the criteria used to determine that
period;
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the existence of the right to request from the
controller rectification or erasure of
personal data, or restriction of processing of
personal data concerning the data subject, or
to object to such processing;
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the existence of the right to lodge a
complaint with a supervisory authority;
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where the personal data are not collected from
the data subject, any available information as
to their source;
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the existence of automated decision-making,
including profiling, referred to in Article
22(1) and (4) of the GDPR and, at least in
those cases, meaningful information about the
logic involved, as well as the significance
and envisaged consequences of such processing
for the data subject.
Furthermore, the data subject shall have a right
to obtain information as to whether personal data
are transferred to a third country or to an
international organisation. Where this is the
case, the data subject shall have the right to be
informed of the appropriate safeguards relating to
the transfer.
If a data subject wishes to avail himself of this
right of access, he or she may, at any time,
contact any employee of the controller.
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c) Right to rectification
Each data subject shall have the right granted by
the European legislator to obtain from the
controller without undue delay the rectification
of inaccurate personal data concerning him or her.
Taking into account the purposes of the
processing, the data subject shall have the right
to have incomplete personal data completed,
including by means of providing a supplementary
statement.
If a data subject wishes to exercise this right to
rectification, he or she may, at any time, contact
any employee of the controller.
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d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by
the European legislator to obtain from the
controller the erasure of personal data concerning
him or her without undue delay, and the controller
shall have the obligation to erase personal data
without undue delay where one of the following
grounds applies, as long as the processing is not
necessary:
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The personal data are no longer necessary in
relation to the purposes for which they were
collected or otherwise processed.
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The data subject withdraws consent to which
the processing is based according to point (a)
of Article 6(1) of the GDPR, or point (a) of
Article 9(2) of the GDPR, and where there is
no other legal ground for the processing.
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The data subject objects to the processing
pursuant to Article 21(1) of the GDPR and
there are no overriding legitimate grounds for
the processing, or the data subject objects to
the processing pursuant to Article 21(2) of
the GDPR.
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The personal data have been unlawfully
processed.
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The personal data must be erased for
compliance with a legal obligation in Union or
Member State law to which the controller is
subject.
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The personal data have been collected in
relation to the offer of information society
services referred to in Article 8(1) of the
GDPR.
If one of the aforementioned reasons applies, and
a data subject wishes to request the erasure of
personal data stored by the Sondermann Consulting
& Coaching, he or she may, at any time, contact
any employee of the controller. An employee of
Sondermann Consulting & Coaching shall promptly
ensure that the erasure request is complied with
immediately.
Where the controller has made personal data public
and is obliged pursuant to Article 17(1) to erase
the personal data, the controller, taking account
of available technology and the cost of
implementation, shall take reasonable steps,
including technical measures, to inform other
controllers processing the personal data that the
data subject has requested erasure by such
controllers of any links to, or copy or
replication of, those personal data, as far as
processing is not required. An employees of the
Sondermann Consulting & Coaching will arrange the
necessary measures in individual cases.
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e) Right of restriction of processing
Each data subject shall have the right granted by
the European legislator to obtain from the
controller restriction of processing where one of
the following applies:
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The accuracy of the personal data is contested
by the data subject, for a period enabling the
controller to verify the accuracy of the
personal data.
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The processing is unlawful and the data
subject opposes the erasure of the personal
data and requests instead the restriction of
their use instead.
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The controller no longer needs the personal
data for the purposes of the processing, but
they are required by the data subject for the
establishment, exercise or defence of legal
claims.
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The data subject has objected to processing
pursuant to Article 21(1) of the GDPR pending
the verification whether the legitimate
grounds of the controller override those of
the data subject.
If one of the aforementioned conditions is met,
and a data subject wishes to request the
restriction of the processing of personal data
stored by the Sondermann Consulting & Coaching, he
or she may at any time contact any employee of the
controller. The employee of the Sondermann
Consulting & Coaching will arrange the restriction
of the processing.
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f) Right to data portability
Each data subject shall have the right granted by
the European legislator, to receive the personal
data concerning him or her, which was provided to
a controller, in a structured, commonly used and
machine-readable format. He or she shall have the
right to transmit those data to another controller
without hindrance from the controller to which the
personal data have been provided, as long as the
processing is based on consent pursuant to point
(a) of Article 6(1) of the GDPR or point (a) of
Article 9(2) of the GDPR, or on a contract
pursuant to point (b) of Article 6(1) of the GDPR,
and the processing is carried out by automated
means, as long as the processing is not necessary
for the performance of a task carried out in the
public interest or in the exercise of official
authority vested in the controller.
Furthermore, in exercising his or her right to
data portability pursuant to Article 20(1) of the
GDPR, the data subject shall have the right to
have personal data transmitted directly from one
controller to another, where technically feasible
and when doing so does not adversely affect the
rights and freedoms of others.
In order to assert the right to data portability,
the data subject may at any time contact any
employee of the Sondermann Consulting & Coaching.
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g) Right to object
Each data subject shall have the right granted by
the European legislator to object, on grounds
relating to his or her particular situation, at
any time, to processing of personal data
concerning him or her, which is based on point (e)
or (f) of Article 6(1) of the GDPR. This also
applies to profiling based on these provisions.
The Sondermann Consulting & Coaching shall no
longer process the personal data in the event of
the objection, unless we can demonstrate
compelling legitimate grounds for the processing
which override the interests, rights and freedoms
of the data subject, or for the establishment,
exercise or defence of legal claims.
If the Sondermann Consulting & Coaching processes
personal data for direct marketing purposes, the
data subject shall have the right to object at any
time to processing of personal data concerning him
or her for such marketing. This applies to
profiling to the extent that it is related to such
direct marketing. If the data subject objects to
the Sondermann Consulting & Coaching to the
processing for direct marketing purposes, the
Sondermann Consulting & Coaching will no longer
process the personal data for these purposes.
In addition, the data subject has the right, on
grounds relating to his or her particular
situation, to object to processing of personal
data concerning him or her by the Sondermann
Consulting & Coaching for scientific or historical
research purposes, or for statistical purposes
pursuant to Article 89(1) of the GDPR, unless the
processing is necessary for the performance of a
task carried out for reasons of public interest.
In order to exercise the right to object, the data
subject may contact any employee of the Sondermann
Consulting & Coaching. In addition, the data
subject is free in the context of the use of
information society services, and notwithstanding
Directive 2002/58/EC, to use his or her right to
object by automated means using technical
specifications.
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h) Automated individual decision-making,
including profiling
Each data subject shall have the right granted by
the European legislator not to be subject to a
decision based solely on automated processing,
including profiling, which produces legal effects
concerning him or her, or similarly significantly
affects him or her, as long as the decision (1) is
not is necessary for entering into, or the
performance of, a contract between the data
subject and a data controller, or (2) is not
authorised by Union or Member State law to which
the controller is subject and which also lays down
suitable measures to safeguard the data subject's
rights and freedoms and legitimate interests, or
(3) is not based on the data subject's explicit
consent.
If the decision (1) is necessary for entering
into, or the performance of, a contract between
the data subject and a data controller, or (2) it
is based on the data subject's explicit consent,
the Sondermann Consulting & Coaching shall
implement suitable measures to safeguard the data
subject's rights and freedoms and legitimate
interests, at least the right to obtain human
intervention on the part of the controller, to
express his or her point of view and contest the
decision.
If the data subject wishes to exercise the rights
concerning automated individual decision-making,
he or she may, at any time, contact any employee
of the Sondermann Consulting & Coaching.
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i) Right to withdraw data protection consent
Each data subject shall have the right granted by
the European legislator to withdraw his or her
consent to processing of his or her personal data
at any time.
If the data subject wishes to exercise the right
to withdraw the consent, he or she may, at any
time, contact any employee of the Sondermann
Consulting & Coaching.
6. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for
processing operations for which we obtain consent for
a specific processing purpose. If the processing of
personal data is necessary for the performance of a
contract to which the data subject is party, as is the
case, for example, when processing operations are
necessary for the supply of goods or to provide any
other service, the processing is based on Article 6(1)
lit. b GDPR. The same applies to such processing
operations which are necessary for carrying out
pre-contractual measures, for example in the case of
inquiries concerning our products or services. Is our
company subject to a legal obligation by which
processing of personal data is required, such as for
the fulfillment of tax obligations, the processing is
based on Art. 6(1) lit. c GDPR. In rare cases, the
processing of personal data may be necessary to
protect the vital interests of the data subject or of
another natural person. This would be the case, for
example, if a visitor were injured in our company and
his name, age, health insurance data or other vital
information would have to be passed on to a doctor,
hospital or other third party. Then the processing
would be based on Art. 6(1) lit. d GDPR. Finally,
processing operations could be based on Article 6(1)
lit. f GDPR. This legal basis is used for processing
operations which are not covered by any of the
abovementioned legal grounds, if processing is
necessary for the purposes of the legitimate interests
pursued by our company 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. Such
processing operations are particularly permissible
because they have been specifically mentioned by the
European legislator. He considered that a legitimate
interest could be assumed if the data subject is a
client of the controller (Recital 47 Sentence 2 GDPR).
7. The legitimate interests pursued by the
controller or by a third party
Where the processing of personal data is based on
Article 6(1) lit. f GDPR our legitimate interest is to
carry out our business in favor of the well-being of
all our employees and the shareholders.
8. Period for which the personal data will be
stored
The criteria used to determine the period of storage
of personal data is the respective statutory retention
period. After expiration of that period, the
corresponding data is routinely deleted, as long as it
is no longer necessary for the fulfillment of the
contract or the initiation of a contract.
9. Provision of personal data as statutory or
contractual requirement; Requirement necessary to
enter into a contract; Obligation of the data
subject to provide the personal data; possible
consequences of failure to provide such data
We clarify that the provision of personal data is
partly required by law (e.g. tax regulations) or can
also result from contractual provisions (e.g.
information on the contractual partner). Sometimes it
may be necessary to conclude a contract that the data
subject provides us with personal data, which must
subsequently be processed by us. The data subject is,
for example, obliged to provide us with personal data
when our company signs a contract with him or her. The
non-provision of the personal data would have the
consequence that the contract with the data subject
could not be concluded. Before personal data is
provided by the data subject, the data subject must
contact any employee. The employee clarifies to the
data subject whether the provision of the personal
data is required by law or contract or is necessary
for the conclusion of the contract, whether there is
an obligation to provide the personal data and the
consequences of non-provision of the personal data.
10. Existence of automated decision-making
As a responsible company, we do not use automatic
decision-making or profiling.
This Privacy Policy has been generated by the Privacy
Policy Generator of the German
Association for Data Protection that
was developed in cooperation withPrivacy
Lawyers from WILDE BEUGER SOLMECKE,
Cologne.
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