Privacy

1. Privacy at a glance

General information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on data protection, please refer to our privacy policy set out below this text.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator’s contact details in the section “Information about the controller” in this privacy policy.

How do we collect your data?

On the one hand, your data is collected when you provide it to us – for example, when you fill in the contact form.

On the other hand, accessing the site generates technical data that every transmission on the internet entails, for example browser, operating system and time of access. This happens automatically as soon as you open a page; without it, the site could not be delivered.

What do we use your data for?

We use the data you provide to us yourself exclusively to deal with your request. The technical data generated when the site is accessed serves to deliver the site and to prevent misuse. Your behaviour on this website is not analysed, and no user profiles are created.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipients and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can withdraw this consent at any time with effect for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time about this and any other questions on the subject of data protection.

2. Hosting

We host the content of our website with the following provider:

External hosting

This website is hosted by an external service provider (host). The personal data collected on this website is stored on the host’s servers. This may include, in particular, IP addresses, contact requests, metadata and communication data, contact details, names, website access data and other data generated via a website.

The host is used for the purpose of fulfilling contracts with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR).

Our host will only process your data to the extent necessary to fulfil its service obligations and will follow our instructions with regard to this data.

We use the following host:

OVH Hosting Limited
Unit 12 The Courtyard Building, Carmanhall Road
Sandyford, Dublin 18
Ireland

The company belongs to OVH Groupe SA, 2 rue Kellermann, 59100 Roubaix, France. Our server is located in the OVHcloud data centre in Beauharnois, Canada. For Canada, the European Commission has found that an adequate level of data protection exists there (Decision 2002/2/EC, continuing in force under Art. 45(9) GDPR); we base the transfer on this adequacy decision.

Data processing agreement

We have concluded a data processing agreement for the use of the above-mentioned service. This is a contract required by data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General information and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

Please note that data transmission over the internet (e.g. when communicating by email) may have security gaps. Complete protection of data against access by third parties is not possible.

Information about the controller

The controller responsible for data processing on this website is:

Win-win Consult LTD
86A Triq Leli Falzon
Naxxar, NXR 2609, Malta

Phone: +49 177 69 60 650
Email: info@win-win-consult.de

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, email addresses or similar).

Storage period

Unless a more specific storage period has been stated in this privacy policy, your personal data will remain with us until the purpose for which it was processed no longer applies. If you make a justified request for deletion or withdraw your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons cease to apply.

General information on the legal bases for data processing on this website

If your data is required to fulfil a contract or to carry out pre-contractual measures, we process it on the basis of Art. 6(1)(b) GDPR. If the processing is necessary to fulfil a legal obligation, it is based on Art. 6(1)(c) GDPR. In all other cases, we base the processing on our legitimate interest under Art. 6(1)(f) GDPR. Which basis applies in each individual case is stated in the section on the process concerned.

We do not obtain consent on this website. It is not the legal basis for any of the processes described here, and nothing is stored on your device for which consent would be required under § 25 TDDDG.

Transfers to third countries

Our server is located in Canada. For Canada, the European Commission has found an adequate level of data protection (Decision 2002/2/EC, continuing in force under Art. 45(9) GDPR); we base the transfer on this decision. Further details can be found in the section “Hosting”. Access to the site does not pass through any other intermediary, and the backups do not leave our host’s data centres.

When you book an appointment via Zoho Bookings, companies of the Zoho group may also access the data from outside the European Economic Area. The basis for this is set out in the section on appointment booking.

Right to object to data collection in special cases (Art. 21 GDPR)

If we process data on the basis of Art. 6(1)(f) GDPR, you have the right to object to this processing at any time on grounds relating to your particular situation. The legal basis that applies to a process is stated in the relevant section of this privacy policy.

If you object, we will no longer process the personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims (objection under Art. 21(1) GDPR).

We do not send advertising. An objection to direct marketing under Art. 21(2) GDPR therefore has nothing to apply to; should we ever start doing so, we would inform you separately beforehand.

Right to lodge a complaint with the competent supervisory authority

The controller is based in Malta. The competent authority is therefore the Maltese data protection supervisory authority:

Office of the Information and Data Protection Commissioner
Floor 2, Airways House, Triq il-Kbira
Tas-Sliema SLM 1549, Malta
Phone: +356 2328 7100
Website: idpc.org.mt

Irrespective of this, under Art. 77 GDPR you have the right to lodge a complaint with the supervisory authority of the Member State in which you habitually reside, in which you work or in which the alleged infringement took place. In Germany, this is the data protection supervisory authority of the respective federal state. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent that it is technically feasible.

Information, deletion and correction

Within the framework of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, where applicable, a right to correction or deletion of this data. You can contact us at any time about this and any other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us about this at any time. The right to restriction of processing exists in the following cases:

• If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
• If the processing of your personal data was or is unlawful, you can request the restriction of data processing instead of deletion.
• If we no longer need your personal data but you need it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of its deletion.
• If you have lodged an objection under Art. 21(1) GDPR, your interests and ours must be weighed against each other. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the establishment, exercise or defence of legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

SSL/TLS encryption

For security reasons and to protect the transmission of confidential content, such as the requests you send to us, this site uses SSL/TLS encryption. You can recognise an encrypted connection by the browser’s address bar changing from “http://” to “https://” and by the lock symbol in your browser bar.

As long as encryption is active, the data you transmit to us cannot be read by third parties.

Objection to advertising emails

We hereby object to the use of contact data published as part of our legal notice obligation for sending unsolicited advertising and information material. The operators of these pages expressly reserve the right to take legal action in the event of unsolicited advertising information being sent, for example through spam emails.

No automated decision-making

We do not make decisions based solely on automated processing which produce legal effects concerning you or similarly significantly affect you. Profiling within the meaning of Art. 4(4) GDPR does not take place.

4. Data collection on this website

Log data when the site is accessed

Every request for a web page involves technical data without which a response cannot be delivered. This is the IP address of your device, the requested address, the time and volume of the transmission and the information your browser sends about itself, such as type, version and operating system. This data is generated at our host.

If you submit the contact form, your IP address is additionally used to limit the number of submissions per connection. For this purpose it is held in memory for up to one hour and is not stored together with your request.

The legal basis is our legitimate interest in technically error-free delivery and in preventing misuse (Art. 6(1)(f) GDPR). This data is not merged with other data sources, not analysed to recognise individual persons, and is deleted as soon as it is no longer required for the stated purposes. What our own server records of it and for how long is set out in the following section.

Access log

Our web server records every request to this website in an access log. We need it to find errors and, after an attack, to be able to trace the route it took.

For each request, the following is stored: time and duration, the requested address including the information after a question mark, request method and protocol, the request headers – i.e. what your browser sends about itself, such as browser identification, previously visited page and preferred language –, details of the connection and its encryption, as well as the status code, size and headers of the response. What you submit via the contact form is not included in the log.

The IP address from which a request originates is stored in shortened form: for IPv4 to the first 24 bits – 203.0.113.47 becomes 203.0.113.0 –, for IPv6 to the first 48 bits.

The log is written continuously to a file. When it reaches 10 MB, it is closed and a new one is started. Closed files are deleted 30 days later, and no more than 14 of them are kept. An entry therefore remains stored until its file is full, and after that for a maximum of another 30 days.

Requests by email or phone

If you contact us by email or phone, your request including all resulting personal data will be stored and processed by us for the purpose of dealing with your request. We do not pass this data on without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR if your request is related to the performance of a contract or is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the requests addressed to us (Art. 6(1)(f) GDPR).

The data you send us will remain with us until you ask us to delete it or the purpose for storing it no longer applies, for instance once your request has been dealt with. Mandatory statutory retention periods remain unaffected.

5. Services on this website

Contact form

If you fill in the contact form, your details – first name, last name, phone number, email address and your message – will be stored by us for the purpose of processing the request and in case of follow-up questions. Your request is also forwarded by our server to our own email address so that it is not overlooked, and in the same way you receive a confirmation of receipt at the address you provided.

Only your email address is required, because without it we cannot reply. You can leave all other fields empty; the request will still be accepted.

The processing is based on Art. 6(1)(b) GDPR if your request is related to the performance of a contract or is necessary to carry out pre-contractual measures. In all other cases, it is based on our legitimate interest in the effective handling of the requests addressed to us (Art. 6(1)(f) GDPR).

For each request, we record when it is to be deleted: three months after receipt. We delete it by then at the latest. We delete it earlier as soon as you ask us to or the purpose no longer applies. Mandatory statutory retention periods remain unaffected.

To protect against automated submissions, we use measures that do not involve passing data on to third parties: an additional field that is invisible to you, a measurement of the time taken to fill in the form, and a limit on submissions per connection. You do not have to solve a puzzle for this.

Appointment booking via Zoho Bookings

You do not book appointments on this website, but on a booking page of the Zoho Bookings service, to which the appointment buttons on this website lead. As long as you do not click on any of these links, no connection is established with Zoho and no data is transmitted there.

On the booking page, you enter the details required for the appointment – usually name, email address, phone number and the selected time. Zoho processes them on our behalf in order to schedule the appointment and to notify you about it. Zoho’s privacy policy, which is linked there, also applies to processing on the booking page.

The contracting party is Zoho Corporation B.V., Beneluxlaan 4B, 3527 HT Utrecht, Netherlands. A data processing agreement under Art. 28 GDPR is in place with it. The booking data is stored in Zoho data centres within the European Economic Area. Companies of the Zoho group and their subcontractors may also access the data from outside the European Economic Area in the course of providing the service; Zoho has undertaken to ensure a transfer mechanism permissible under the GDPR for this. You can obtain a copy of the safeguards from us on request.

The legal basis is Art. 6(1)(b) GDPR, as the processing is carried out to take pre-contractual steps at your request. The general section above applies to the storage period: the booking data will be deleted as soon as it is no longer required for carrying out and following up the appointment, unless statutory retention obligations prevent this.

Sending emails

The forwarding of your request to our mailbox and the confirmation of receipt to you are sent by our own server directly to the receiving mailbox. No other delivery service is involved. Your email address and the content of the respective message are transmitted – to your email provider and to ours.

The legal basis is Art. 6(1)(b) GDPR insofar as your request is related to a contract or pre-contractual measures, and otherwise our legitimate interest in reliable delivery (Art. 6(1)(f) GDPR).

Data backup

Our server is fully backed up once a day so that it can be restored following an outage or an attack. A backup contains everything stored on the server, including enquiries received via the contact form, such as your name, telephone number, email address and the text you have written.

Our hosting provider is responsible for the backups. They are stored on separate systems in the same data centre in Canada where our server is located; they do not leave our hosting provider’s data centres.

The legal basis is our legitimate interest in ensuring the recoverability of our data (Article 6(1)(f) of the GDPR). Each backup is retained for seven days and then automatically deleted. If we delete a data record, it will only be removed from backups that have already been created once those backups expire.

Translation

The English versions of our editorial texts are prepared by machine translation using the DeepL service of DeepL SE, Maarweg 165, 50825 Cologne, Germany. Only the texts of this website are transmitted. No personal data of visitors is transmitted to DeepL.

Translation takes place before publication, not during your visit. No connection to DeepL is established when you visit the website.

Fonts

The fonts on this website are stored on our own server and loaded from there. No connection to third-party servers is established, and no data is transmitted to third parties.

No cookies

This website does not set any cookies. Nor does it store anything on your device or read anything from it in any other way. That is why you do not see a consent banner: there is nothing for which consent would need to be obtained.

No audience measurement

This website does not include any program for measuring reach or usage. There is no analysis of which pages you visit, where you came from or how long you stay. No user profiles are created and no data is transmitted to third parties for this purpose.