Privacy Policy

I Privacy Statement

We are happy to welcome you on our website. We respect your privacy. Data protection and data security of our website’s users are very important to us. In this Privacy Statement, we aim to provide information on the extent in which the data of our website’s users is collected as well as on the purposes that we use said data for, and your related rights.

II Controller

borisgloger consulting GmbH
Westhafenplatz 1
60327 Frankfurt
Germany
Registration court: Amtsgericht Frankfurt
Registration number: HRB119415

III Data Protection Officer

V-Formation GmbH
Oliver Meyer-van-Raay (data protection officer, lawyer, specialist in IT law)
Stephanienstrasse 18
76133 Karlsruh
Germany
Telephone: +49 721 / 17029034
E-mail: om@v-formation.gmbh

IV Data Processing

IV.1 Use of Google Analytics
a. Nature and Purpose of Processing

This website uses Google Analytics, a web analytics service of Google Building Gordon House, 4 Barrow Street, Dublin, D04 E5W5, Ireland. Google Analytics uses so-called “cookies”, i.e., text files that are stored on your computer and enable an analysis of your use of this website. As a rule, the information on your website use that is generated by a cookie is transmitted to a Google server in the US and stored there. Due to the activation of IP anonymization on these websites, your IP address is shortened by Google within European Union member states or other states party to the Agreement on the European Economic Area before being transmitted to Google’s US servers. Only in exceptional cases will the full IP address be transmitted to a Google server in the US and shortened there. Google will use this information on behalf of this website’s provider in order to analyze your website use, compile reports on website activity, and provide other services relating to the use of this website and the Internet to the website provider. The IP address transmitted from your browser as part of the Google Analytics service will not be associated with other data by Google. The purposes of data processing are the analysis of the website use and the compilation of reports on website activities. Based on the website and Internet use, other related services are to be provided.

b. Legal Basis for Processing

Processing of the data provided is performed based on the user’s consent (Art. 6(1)(a) GDPR).

c. Categories of Data

• IP address (shortened/anonymized)

d. Recipients

• Employees of the IT and marketing departments of borisgloger consulting GmbH
• Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

e. Storage Periods

Data will only be processed in this context if the relevant consent has been given. They will then be deleted unless legal obligations to retain the data exist. If you wish to contact us for an issue relating to this, please use the contact data provided at the beginning of this Privacy Statement.

f. Legal/Contractual Requirement

Provision of your personal data shall be effected voluntarily, solely based on your consent. In case you restrict access, this might result in a restriction of the website’s functions.

g. Transfer to Third Countries

In exceptional cases, Google will process your data in the US.

h. Withdrawal of Consent

You can withdraw your consent to store your personal data at any time with future effect. You can inform us about the withdrawal of your consent at any time, using the contact data provided at the beginning of this Privacy Statement.
You can prevent the storage of cookies by activating the appropriate settings in your browser software; however, we point out that in that case you might not be able to fully use all of this website’s functions. Furthermore, you can prevent the collection of data generated by the cookie and relating to your website use (including your IP address) by Google and processing of such data by Google, by downloading and installing the browser plugin available under the following link: ”Google Analytics Opt-out Browser Add-on”.

i. Automated Decision-making and Profiling

The Google Analytics tracking tool supports us in evaluating the behavior of this website’s users and in analyzing their interests. To this end, we create pseudonymous user profiles.

IV.1.a Google Tag Manager
a. Nature and Purpose of Processing

Use of Google Tag Manager: Google Tag Manager is a solution that allows marketers to manage website tags via an interface. The Tag Manager tool itself (which implements the tags) is a domain that does not use cookies and does not collect personal data. The tool triggers the activation of other tags that might collect data. Google Tag Manager does not access these data. In case of a deactivation at the domain or cookie level, such a deactivation is valid for all tracking tags implemented with Google Tag Manager: http://www.google.de/tagmanager/use-policy.html.

b. Legal Basis for Processing

Processing of the data provided is performed based on the user’s consent (Art. 6(1)(a) GDPR).

c. Categories of Data

IP address (anonymized)

d. Recipients

The data’s recipients are internal employees of the marketing department and Google as processor. We have concluded the relevant data processing agreement with Google to that end.

e. Storage Periods

Data will only be processed in this context if the relevant consent has been given. They will then be deleted unless legal obligations to retain the data exist. If you wish to contact us for an issue relating to this, please use the contact data provided at the beginning of this Privacy Statement.

f. Legal/Contractual Requirement

Provision of your personal data shall be effected voluntarily, solely based on your consent. In case you restrict access, this might result in a restriction of the website’s functions.

g. Transfer to Third Countries

In exceptional cases, Google will process your data in the US.

h. Withdrawal of Consent

You can withdraw your consent to store your personal data at any time with future effect. You can inform us about the withdrawal of your consent at any time, using the contact data provided at the beginning of this Privacy Statement.
You can prevent the storage of cookies by activating the appropriate settings in your browser software; however, we point out that in that case you might not be able to fully use all of this website’s functions.

i. Profiling

The Google Tag Manager tool enables the evaluation of behavior of this website’s users and an analysis of their interests.

V Google Fonts
a. Nature and Purpose of Processing

We use “Google Web Fonts” (1600 Amphitheatre Parkway, Mountain View, CA 94043, US) for the display of fonts, in order to display our content in a correct and appealing way in different browsers. You can find the Privacy Policy of the library’s operator, Google, here: https://www.google.com/policies/privacy/. The access of script libraries or font libraries automatically establishes a connection to the library’s operator. In that case, it is theoretically conceivable—but unclear whether and, if so, to what purposes—the operator, in this case Google, collects data. You can find more information on Google Web Fonts at https://developers.google.com/fonts/faq and in Google’s Privacy Policy: https://www.google.com/policies/privacy/.

b. Legal Basis for Processing

The legal basis of the integration of Google Webfonts and the related data transfer to Google consists in your consent (Art. 6(1)(a) GDPR).

c. Categories of Data

IP address (anonymized)

d. Recipients

The data’s recipients are internal employees of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, and Google as processor.

e. Storage Periods

Data will only be processed in this context if the relevant consent has been given. They will then be deleted unless legal obligations to retain the data exist. If you wish to contact us for an issue relating to this, please use the contact data provided at the beginning of this Privacy Statement.

f. Legal/Contractual Requirement

The provision of personal data is neither required legally, nor contractually. However, the correct display of content is not possible without standard fonts.

g. Transfer to Third Countries

In exceptional cases, Google will process your data in the US.

h. Withdrawal of Consent

The programming language JavaScript is regularly used for the display of content. You can therefore object to the processing of your data by disabling JavaScript in your browser or by installing a JavaScript blocker. Please be aware that this might result in a restriction of the website’s functions. You can withdraw your consent to store your personal data at any time with future effect. You can inform us about the withdrawal of your consent at any time, using the contact data provided at the beginning of this Privacy Statement.

i. Automated Decision-making and Profiling

As a responsible company, we forego automated decision-making and profiling for this data processing.

VI DoubleClick
a. Nature and Purpose of Processing

We use the online advertising service Google “DoubleClick”.
This service serves the purpose of placing advertisements in the Google advertising network (e.g., in search results, in videos, on websites, etc.). DoubleClick features the display of advertisements in real time, based on supposed interests of the user. This allows us a more targeted display of advertisements for and within our online offer, in order to present users only with advertisements that potentially meet their interests. Those cases in which a user is shown, e.g., advertisements for products that they were interested in on other online-offer sites, are referred to as “remarketing”. For that purpose, Google executes a Google code when our website, and other websites on which the Google advertising network is activated, are accessed. As a consequence, so-called (re)marketing tags (invisible graphics or code, also called “web beacons”) are integrated into the website. They serve to store an individual cookie (i.e., a small file) on the user’s device (similar technologies can be used instead of cookies). This file records the websites accessed by the user, the content they are interested in, and the offers they clicked, as well as technical information on their browser and operating system, referring websites, time of access, and other information on their use of the online offers.

Furthermore, it records the user’s IP address, which will be shortened within European Union member states or other states party to the Agreement on the European Economic Area; only in exceptional cases will the full IP address be transmitted to a Google server in the US and shortened there. Google may associate the information mentioned above with information from other sources. If the user subsequently accesses other websites, they can be shown advertisements matching their supposed interests based on their user profile.

The user data are processed in a pseudonymous manner within the Google advertising network. This means that Google does not store and process the users’ names or e-mail addresses, for example, but processes relevant data on a cookie-related basis as part of pseudonymous user profiles. As a consequence, from Google’s point of view, the advertisements are not managed and displayed for a specifically identified person, but for the cookie owner, independent of who the cookie owner is. This does not apply if a user explicitly allowed Google to process data without pseudonymization.

b. Legal Basis for Processing

Processing of the data provided is performed based on the user’s consent (Art. 6(1)(a) GDPR).

c. Categories of Data

IP address (anonymized)

d. Recipients

The recipients are internal employees of the marketing department and Google as processor.

e. Storage Periods

After discontinuation of the purpose and cessation of our use of Google DoubleClick, the data collected in connection with it will be deleted.

f. Legal/Contractual Requirement

Provision of your personal data shall be effected voluntarily, solely based on your consent. Without provision of your personal data, we cannot provide access to the content and services we offer.

g. Transfer to Third Countries

Processing is not effected outside of the European Union (EU) or the European Economic Area (EEA).

h. Withdrawal of Consent

Find more information on data use by Google, settings options, and possibilities of withdrawal, in Google’s Privacy Policy (https://policies.google.com/technologies/ads) and in the settings for the display of Google advertisements (https://adssettings.google.com/authenticated). You can withdraw your consent to store your personal data at any time with future effect. You can inform us about the withdrawal of your consent at any time, using the contact data provided at the beginning of this Privacy Statement.

i. Automated Decision-making and Profiling

As a responsible company, we forego automated decision-making and profiling for this data processing.

VII YouTube
a. Nature and Purpose of Processing

We have embedded YouTube videos into some of our websites. The relevant plugin operator is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, US. If you access a site with the YouTube plugin, a connection to YouTube’s servers is established. As a consequence, YouTube is informed of the websites that you access. If you are logged into your YouTube account, YouTube will be able to attribute your surfing behavior to you personally. You can avoid that by first logging out of your YouTube account. When a YouTube video is started, the provider uses cookies that collect information on user behavior. Find further information on the purpose and extent of data collection and data processing by YouTube, as well as further information on your rights and setting options to protect your privacy in the provider’s Privacy Policy (https://policies.google.com/privacy).

b. Legal Basis for Processing

The legal basis for the integration of YouTube and the related data transfer to Google consists in your consent (Art. 6(1)(a) GDPR).

c. Categories of Data

Check the specific data categories and find information on processing at www.google.de/intl/en/policies/privacy/.

d. Recipients

The data recipient is YouTube as the provider of the services.

e. Storage Periods

Those who disabled the storage of cookies for the Google ad program will not have to expect such cookies when watching YouTube videos. However, YouTube also stores non-personal usage information in other cookies. To prevent this, you have to block the storage of cookies in your browser. Find more information on privacy with YouTube in the provider’s Privacy Policy: https://www.google.de/intl/en/policies/privacy/

f. Legal/Contractual Requirement

Provision of your personal data shall be effected voluntarily, solely based on your consent. In case you restrict access, this might result in a restriction of the website’s functions.

g. Transfer to Third Countries

Google processes your data in the US.

h. Withdrawal of Consent

You can withdraw your consent to store your personal data at any time with future effect. You can inform us about the withdrawal of your consent at any time, using the contact data provided at the beginning of this Privacy Statement.

i. Automated Decision-making and Profiling

As a responsible company, we forego automated decision-making and profiling for this data processing.

VII.1 Newsletter, Case Studies & Whitepaper
a. Nature and Purpose of Processing

Your data will be used for the sole purpose of sending you the newsletter you subscribed to, or whitepapers or case studies, via e-mail. The indication of your name serves the purpose of addressing you personally in the e-mails and to potentially identify you in case you want to exercise your rights as a data subject. Providing your e-mail address is sufficient to receive the e-mails. When subscribing to our newsletter, the data you indicated are used solely for this purpose. It is also possible that subscribers receive information about issues relating to the service or subscription (e.g., changes to the newsletter offer or technical issues) via e-mail. We need a valid e-mail address for an effective subscription. In order to verify that a subscription was indeed effected by the owner of an e-mail address, we use a “double opt-in” process. To that end, we log the newsletter subscription, the dispatch of a confirmation e-mail, and the receipt of the reply requested in the latter. No further data are collected. The data are used exclusively for the dispatch of newsletters and are not passed on to third parties.

b. Legal Basis for Processing

We regularly send you our newsletter and/or comparable information via e-mail, to the e-mail address you indicated, based on your explicit consent given via a double opt-in process (Art. 6(1)(a) GDPR, Art. 7 GDPR in conjunction with Art. 107(2) Telecommunications Act / TKG, Telekommunikationsgesetz).

c. Categories of Data

• E-mail address
• Surname
• First name

d. Recipients

• Employees of the marketing department
• Service providers for the dispatch of the newsletter, the whitepaper, or the case studies

e. Storage Periods

Data will only be processed in this context for as long as the relevant consent has not been withdrawn. Subsequently, they will be deleted.

f. Legal/Contractual Requirement

Provision of your personal data shall be effected voluntarily, solely based on your consent. Without your consent, we will unfortunately not be able to send you our newsletter.
To prevent an abuse of your e-mail address, subscription to the newsletter is effected via double opt-in process; i.e., after subscription, you receive an e-mail asking you to confirm your subscription. We log the newsletter subscription in order to be able to account for the subscription process according to legal requirements and, if necessary, prevent or resolve an abuse of your personal data. Logging of our subscription procedure, therefore, is effected based on our legitimate interests pursuant to Art. 6(1)(f) GDPR.

g. Transfer to Third Countries

Dispatch is provided by the e-mail marketing service MailChimp, a newsletter dispatch platform of the US provider Rocket Science Group LLC. You can find the e-mail marketing service’s privacy policy at: https://mailchimp.com/legal/privacy/. We use the e-mail marketing service based on our legitimate interests pursuant to Art. 6(1)(f) GDPR as well as a data processing agreement.

h. Withdrawal of Consent

You can withdraw your consent to receive our newsletter at any time, particularly by unsubscribing from our newsletter. You can exercise this right by using the unsubscribe link at the end of every newsletter. If you subscribed to our newsletter only, we will delete your personal data following your unsubscription.

i. Automated Decision-making and Profiling

As a responsible company, we forego automated decision-making and profiling for this data processing.

VII.2 Account for the training platform and booking of training sessions

You can log into the training platform from our website or directly book training sessions online. It is not necessary to have a training platform account and/or be logged into it to book training sessions. We particularly use the training platform to provide you with the relevant certificates after you have completed a training. As a rule, you receive your individual access data for the training platform during or after a training that you booked. We use the data processed in the context of the training platform based on Art. 6(1)(b),(f) GDPR in order to create a profile for you, identify you at each log-in, and be able to provide the services offered in the section of our website reserved for registered users to you. We delete this data as soon as the purpose for collection no longer applies, and particularly if you delete your account with us and there is no other legal basis for a longer storage period.

If you want to register for a training on our website, the relevant contract can only be concluded if you indicate the personal data required for the completion of your booking.

Categories of Data:

•Form of address, first name, and last name
•Address and e-mail address
•Company name and invoicing address

Recipients of Data:

• Training department
• Marketing department

Further information, e.g., date of birth, telephone number, etc., are optional/voluntary. We process the data you indicated in order to complete your booking and provide the training you booked. The data are therefore processed for the purpose of performing a contract based on Art. 6(1)(b) GDPR. We might furthermore process the contact data you indicated when booking a training in order to inform you about other training offers or other services from our portfolio that might be of interest to you, based on the bookings you made up to this point. In that respect, data processing is effected based on our legitimate interests pursuant to Art. 6(1)(f) GDPR to maintain and expand our client relationships. You can withdraw your consent to the use of your contact data for that purpose at any time as stated below. Your personal data shall only be passed on to third parties if this is required for the performance of the contract or if you consented to the disclosure in advance.

VIII Contact form
a. Nature and Purpose of Processing

The data you indicated will be stored for the purpose of individual communication with you. This requires the indication of a valid e-mail address and your name, which serve the attribution of and subsequent reply to your request. Indication of any further data is optional.

b. Legal Basis for Processing

Processing of the data provided via the contact form is performed based on our legitimate interest (Art. 6(1)(f) GDPR). We provide the contact form with the aim of making it easy for you to contact us. The data you indicated are stored for the purpose of processing your request and possible subsequent requests. Should you contact us with the aim of getting an offer, processing of the data entered into the contact form is effected for the performance of pre-contractual measures (Art. 6(1)(b) GDPR).

c. Categories of Data

• E-mail address
• First name
• Surname

d. Recipients

• Employees of the IT and marketing departments
• Employees of the sales department
• Service provider for newsletter dispatch

e. Storage Periods

The data you indicated will be processed by us in order to process and complete your contact request pursuant to Art. 6(1)(b) GDPR and might, in this context, also be passed on to affiliated companies or third parties. This data might also be stored in our Customer Relationship Management (CRM) system. We will delete the data you provided as soon as the purpose for collection no longer applies and no other legal basis becomes effective (e.g., further data processing is or becomes necessary to perform a concluded contract). If and for as long as legal retention periods exist, we shall only delete the data after expiry of the relevant periods.

f. Legal/Contractual Requirement

Provision of your personal data is effected voluntarily. However, we will only be able to process your request if you provide your name, your e-mail address, and the reason for your request.

g. Transfer to Third Countries

Processing is not effected outside of the European Union (EU) or the European Economic Area (EEA).

h. Withdrawal of Consent

You can withdraw your consent to store your personal data at any time with future effect. You can inform us about the withdrawal of your consent at any time, using the contact data provided at the beginning of this Privacy Statement.

i. Automated Decision-making and Profiling

As a responsible company, we forego automated decision-making and profiling for this data processing.

IX Data Security

The personal data of each individual in a contractual, pre-contractual, or other relationship with our company, is to be specifically protected. It is our aim to maintain a high privacy standard. To this end, we are committed to the continuous development of our data protection and security policies. We therefore undertake to protect your privacy and keep your personal data confidential. To prevent manipulation, loss, or abuse of your data stored by us, we implement exhaustive technical and organizational safeguards that are regularly reviewed and kept up-to-date with technological advances. These safeguards include, among others, the use of recognized encryption methods (SSL or TLS). However, we point to the fact that due to the Internet’s structure, it is conceivable that privacy rules and the above-mentioned safeguards might not be followed by other individuals or institutions outside of our area of responsibility. Particularly data transmitted in an unencrypted manner—e.g., via e-mail—can be read by third parties. We have no technical means of influence on that. It lies within the scope of responsibility of the user to use encryption or other methods to protect data provided by them against abuse.

X Rights of data subjects

As a data subject, i.e., a person whose data is processed, you have numerous rights. More specifically, these are:
•Right of access: You are entitled to access the data concerning you that are stored by us.
•Rights to rectification and erasure: You are entitled to request that we rectify wrong data and erase your data.
•Restriction of processing: You are entitled to request that we restrict the processing of your data.
•Data portability: Should you have provided data to us based on a contract or a consent, you are entitled to request to receive the data provided by you in a structured, commonly used, and machine-readable format or request us to transmit the data to another controller.
If we process your data based on legitimate interests (Art. 6(1)(f) GDPR) or for the purpose of performing a public duty (Art. 6(1)(e) GDPR), you can object to the processing of your personal data based on reasons relating to your particular situation. Furthermore, you are entitled to object to any kind of data processing for the purpose of direct marketing.
•Withdrawal of consent: If you have given us consent to process your data, you can withdraw your consent at any time with future effect. The lawfulness of your data’s processing until the time of withdrawal shall remain unaffected by this.
•Right to lodge a complaint with a supervisory authority: In case you believe that processing your data is in violation of any applicable legislation, you are furthermore entitled to lodge a complaint with the competent supervisory authority. To that end, you can contact either the data protection authority competent for your place of residence or your country, or the data protection authority competent for our business location.
You are entitled to the above-mentioned rights only on condition that the applicable legal requirements have been met; this also applies if this is not mentioned explicitly in the above description. For questions on the processing of your personal data, on your rights as a data subject, and on a potentially given consent, you can contact us free of charge. To exercise all of the above-mentioned rights, please contact operations@borisgloger.com or send a letter to the address indicated above. When doing so, please make sure that we are able to uniquely identify you.

XI Our Right to Change this Privacy Statement

As legislative amendments or changes to our company’s processes might require amendments to this Privacy Statement, we would like to ask you to regularly read the latest applicable version of our Privacy Statement. We therefore reserve the right to make amendments to this Privacy Statement, in compliance with data protection provisions, at any time.