Privacy policy

Name and contact of the responsible person according to article 4 para. 7 GDPR

SPM-2000 Schulung Promotion Management GbR,
represented by the managing director Dr. Torsten W. Roth

Gohliser Street 7
04105 Leipzig

Fon +49 (0) 341 – 33 384 00
Fax +49 (0) 341 – 33 384 01
Mail group(at)spm2000.com

Data Protection Officer

Francesca Schrader
Gohliser Street 7, 04105 Leipzig
francesca.schrader(at)spm2000.de

Security and protection of your personal data

We consider it our primary responsibility to maintain the confidentiality of the personal information you provide to us and to protect it from unauthorized access. Therefore, we use extreme care and state-of-the-art security standards to ensure maximum protection of your personal data.

As a company under private law, we are subject to the provisions of the European General Data Protection Regulation (DSGVO) and the regulations of the German Federal Data Protection Act (BDSG). We have taken technical and organizational measures to ensure that the regulations on data protection are observed both by us and by our external service providers.

Definitions

The legislator requires that personal data be processed in a lawful manner, in good faith and in a way that is comprehensible to the data subject (“lawfulness, processing in good faith, transparency”). To ensure this, we inform you about the individual legal definitions, which are also used in this privacy policy:

1. personal data

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “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.

2. processing

“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

3. restriction of processing

“Restriction of processing” means the marking of stored personal data with the aim of limiting their future processing.

4. profiling

“Profiling” means any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

5. pseudonymization

“Pseudonymization” means the processing of personal data in such a way 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 organizational measures which ensure that the personal data cannot be attributed to an identified or identifiable natural person.

6. file system

“File system” means any structured collection of personal data accessible according to specified criteria, whether such collection is maintained on a centralized, decentralized, or functional or geographic basis.

7. responsible person

“controller” means a 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 designation may be provided for by Union or Member State law.

8. order processor

“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the Controller.

9. receiver

“Recipient” means a natural or legal person, public authority, agency or other body to whom Personal Data is disclosed, whether or not a third party. However, authorities that may receive personal data in the context of a specific investigation mandate under Union or Member State law shall not be considered as recipients; the processing of such data by the aforementioned authorities shall be carried out in accordance with the applicable data protection rules, in line with the purposes of the processing.

10. third

“Third party” means a natural or legal person, public authority, agency or other body, other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.

11. consent

Consent” of the data subject means any freely given specific, informed and unambiguous indication of his or her wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

Lawfulness of processing

The processing of personal data is only lawful if there is a legal basis for the processing. The legal basis for the processing may be Article 6 para. 1 lit. a – f GDPR shall be in particular:

• a. The data subject has given his/her consent to the processing of personal data concerning him/her for one or more specific purposes;
• b. the processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the data subject’s request;
• c. processing is necessary for compliance with a legal obligation to which the controller is subject;
• d. the processing is necessary to protect the vital interests of the data subject or another natural person;
• e. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• f. processing is necessary for the purposes of the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child.

Information about the collection of personal data

(1) In the following, we inform about the collection of personal data when using our website. Personal data are e.g. name, address, e-mail addresses, user behavior.

(2) If you contact us by e-mail or via a contact form, the data you provide (your e-mail address, name and telephone number, if applicable) will be stored by us in order to answer your questions. We delete the data accruing in this context after storage is no longer necessary, or processing is restricted if there are legal obligations to retain data.

Collection of personal data when visiting our website

In the case of merely informational use of the website, i.e. if you do not register or otherwise transmit information to us, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure stability and security (legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO):

• IP address
• Date and time of the request
• Time zone difference from Greenwich Mean Time (GMT)
• Content of the request (concrete page)
• Access status/HTTP status code
• Data volume transferred in each case
• Website from which the request comes
• Browser
• Operating system and its interface
• Language and version of the browser software

Other functions and offers of our website

(1) In addition to the purely informational use of our website, we offer various services that you can use if you are interested. For this purpose, you will usually have to provide additional personal data that we use to provide the respective service and to which the aforementioned data processing principles apply.

(2) In some cases, we use external service providers to process your data. They have been carefully selected and commissioned by us, are bound by our instructions and are regularly inspected.

(3) Furthermore, we may pass on your personal data to third parties if promotional participations, competitions, contract conclusions or similar services are offered by us together with partners. You will receive more detailed information on this when you provide your personal data or below in the description of the offer.

(4) If our service providers or partners are located in a country outside the European Economic Area (EEA), we will inform you about the consequences of this circumstance in the description of the offer.

Newsletter

(1) With your consent, you can subscribe to our newsletter, with which we inform you about our current interesting offers. The advertised goods and services are named in the consent form.

(2) For the registration to our newsletter we use the so-called double opt-in procedure. This means that after your registration, we will send you an e-mail to the e-mail address you provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month. In addition, we store your IP addresses and times of registration and confirmation. The purpose of the procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.

(3) The only mandatory information for sending the newsletter is your e-mail address. The provision of further, separately marked data is voluntary and will be used to address you personally. After your confirmation, we store your e-mail address for the purpose of sending you the newsletter. The legal basis is Art. 6 para. 1 p. 1 lit. a GDPR.

(4) You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You can declare the revocation by clicking on the link provided in every newsletter e-mail, by e-mail to group@spm2000.de or by sending a message to the contact details given in the imprint.

(5) We would like to point out that we evaluate your user behavior when sending the newsletter. For this evaluation, the emails sent contain so-called web beacons or tracking pixels, which are single-pixel image files stored on our website. For the evaluations, we link the above data and the web beacons with your e-mail address and an individual ID. The data is collected exclusively pseudonymously, i.e. the IDs are not linked to your other personal data, and direct personal reference is excluded. You can object to this tracking at any time by clicking on the separate link provided in each email or by informing us via another contact channel. The information is stored for as long as you are subscribed to the newsletter. After unsubscribing, we store the data purely statistically and anonymously.

(6) We use an external service provider to send newsletters. A separate order data processing agreement has been concluded with the service provider to ensure the protection of your personal data. We are currently working with the following service provider:

CleverReach
CleverReach GmbH & Co KG
Mühlenstr. 43
26180 Rastede
Tel.: +49 (0) 4402 97390-00
E-mail: info@cleverreach.com

In the process, the following data is transmitted to CleverReach:

• Name
• E-mail address
• IP address

For more information, please refer to CleverReach’s privacy policy, which is available at https://www.cleverreach.com/de/datenschutz/.

Children

Our offer is basically aimed at adults. Persons under the age of 18 should not submit any personal data to us without the consent of their parents or legal guardians.

Rights of the data subject

(1) Revocation of consent

If the processing of personal data is based on a granted consent, you have the right to revoke the consent at any time. The revocation of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

To exercise the right of withdrawal, you can contact us at any time.

(2) Right to confirmation

You have the right to request confirmation from the controller as to whether we are processing personal data relating to you. You can request confirmation at any time using the contact details above.

(3) Right to information

If personal data is processed, you can request information about this personal data and about the following information at any time:

• a. the purposes of processing;
• b. the categories of personal data that are processed;
• c. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations;
• d. if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration;
• e. the existence of a right to rectification or erasure of personal data concerning you or to restriction of processing by the controller or a right to object to such processing;
• f. the existence of a right of appeal to a supervisory authority;
• g. if the personal data are not collected from the data subject, any available information on the origin of the data;
• h. the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

If personal data is transferred to a third country or to an international organization, you have the right to be informed about the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer. We will provide a copy of the personal data that is the subject of the processing. For any additional copies you request person, we may charge a reasonable fee based on administrative costs. If you make the request electronically, the information must be provided in a common electronic format, unless it specifies otherwise. The right to receive a copy under paragraph 3 shall not affect the rights and freedoms of other persons.

(4) Right to rectification

You have the right to request that we correct any inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data – also by means of a supplementary declaration.

(5) Right to erasure (“right to be forgotten”)

You have the right to request the controller to delete personal data concerning you without undue delay, and we are obliged to delete personal data without undue delay, if one of the following reasons applies:

• a. The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
• b. The data subject revokes the consent on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR and there is no other legal basis for the processing.
• c. 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.
• d. The personal data have been processed unlawfully.
• e. The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
• f. The personal data has been collected in relation to information society services offered in accordance with Article 8(1) of the GDPR.

If the controller has disclosed the personal data to the public and is obliged to erase it pursuant to paragraph 1, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that a data subject has requested that they erase all links to or copies or replications of such personal data.

The right to erasure (“right to be forgotten”) does not exist insofar as the processing is necessary:

• to exercise the right to freedom of expression and information;
• for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• for reasons of public interest in the field of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the GDPR;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, insofar as the right referred to in paragraph 1 is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
• for the assertion, exercise or defense of legal claims.

(6) Right to restriction of processing

You have the right to request us to restrict the processing of your personal data if one of the following conditions is met:

• a. 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,
• b. the processing is unlawful and the data subject refuses the erasure of the personal data and instead requests the restriction of the use of the personal data;
• c. the controller no longer needs the personal data for the purposes of processing, but the data subject needs them for the assertion, exercise or defense of legal claims; or
• d. the data subject has objected to the processing pursuant to Article 21(1) of the GDPR, as long as it has not yet been determined whether the legitimate grounds of the controller override those of the data subject.

Where processing has been restricted in accordance with the above conditions, such personal data shall – apart from being stored – only be processed with the consent of the data subject or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or a Member State.

In order to exercise the right to restrict the processing, the data subject may contact us at any time using the contact details provided above.

(7) 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, and you have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that:

• a. the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b) DSGVO and
• b. the processing is carried out with the help of automated procedures.

When exercising the right to data portability pursuant to paragraph 1, you have the right to obtain that the personal data be transferred directly from one controller to another controller, to the extent that this is technically feasible. The exercise of the right to data portability does not affect the right to erasure (“right to be forgotten”). This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

(8) Right of objection

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. The controller shall no longer process the personal data unless it 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 defense of legal claims.

If personal data are processed for the purpose of direct marketing, you have the right to object at any time to processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is associated with such direct marketing. If you object to processing for direct marketing purposes, the personal data will no longer be processed for these purposes.

In connection with the use of information society services, notwithstanding Directive 2002/58/EC, you may exercise your right to object by means of automated procedures using technical specifications.

You have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1), unless the processing is necessary for the performance of a task carried out in the public interest.

You can exercise the right to object at any time by contacting the respective person responsible.

(9) Automated decisions in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision:

• a. is necessary for the conclusion or performance of a contract between the data subject and the controller,
• b. is permitted by Union or Member State legislation to which the controller is subject and that legislation contains appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject; or
• c. with the express consent of the data subject.

The controller shall take reasonable steps to safeguard the rights and freedoms as well as the legitimate interests of the data subject, which shall include, at least, the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.

The data subject may exercise this right at any time by contacting the respective data controller.

(10) Right to complain to a supervisory authority

They shall also have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular in the Member State of their residence, place of work or the place of the alleged infringement, if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

(11) Right to effective judicial remedy

Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to Article 77 GDPR, you shall have the right to an effective judicial remedy if it considers that your rights under this Regulation have been infringed as a result of the processing of your personal data not in compliance with this Regulation.

Use of Matomo (formerly Piwik)

(1) This website uses the web analytics service Matomo to analyze and regularly improve the use of our website. The statistics obtained enable us to improve our offer and make it more interesting for you as a user. The legal basis for the use of Matomo is Art. 6 para. 1 p. 1 lit. f GDPR.

(2) Cookies are stored on your computer for this evaluation. The information collected in this way is stored by the responsible party exclusively on its server in [Deutschland]. You can set the evaluation by deleting existing cookies and preventing cookies from being stored. If you prevent the storage of cookies, we point out that you may not be able to use this website in full. Preventing the storage of cookies is possible through the setting in your browser. Preventing the use of Matomo is possible by unchecking the following box to enable the opt-out plug-in:

Opt-out complete; your visits to this website will not be recorded by the Web Analytics tool. Note that if you clear your cookies, delete the opt-out cookie, or if you change computers or Web browsers, you will need to perform the opt-out procedure again.

You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.

You are not opted out. Uncheck this box to opt-out. You are currently opted out. Check this box to opt-in.

The tracking opt-out feature requires cookies to be enabled.

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(3) This website uses Matomo with the extension “AnonymizeIP”. This means that IP addresses are processed in abbreviated form, thus excluding the possibility of direct personal references. The IP address transmitted by your browser via Matomo is not merged with other data collected by us.

(4) The Matomo program is an open source project. You can obtain information from the third-party provider on data protection at https://matomo.org/privacy-policy/.

Processor

We use external service providers (order processors), e.g. for sending newsletters, maintaining our website or hosting. A separate order data processing agreement has been concluded with the service provider to ensure the protection of your personal data.

We cooperate with the following service providers:

IKONUM Brand and Web Agency, Bautzner Straße 6, 01099 Dresden, Germany
UnixOS GbR, Schänkberg 8, 06179 Angersdorf
CleverReach GmbH & Co KG, Mühlenstr. 43, 26180 Rastede