Elena Popretinskaya
Coach and Consultant
Zauberwaldstr. 7
81825 Munich
Germany
e-mail: hello@lenathecoach.com
"Personal data" means any information relating to an identified or identifiable individual (hereinafter the "data subject"); an identifiable individual 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.
"Processing" means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.
"Pseudonymisation" means 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 individual.
"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, 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.
"Controller" means 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.
"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the privacy policy is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR. In the case that vital interests of the data subject or another individual require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as legal basis.
We implement appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as controlling their access, input, disclosure, ensuring availability and separation. We have also set up procedures to ensure the exercise of data subject rights, data deletion and reaction to data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR).
If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit data to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfill the contract), on the basis of your consent that you have provided, to fulfill a legal obligation or based on our legitimate interests (e.g. the use of agents, web hosting companies, etc.).
If we commission third parties to process data on the basis of a so-called "data processing agreement", this is done on the basis of Art. 28 GDPR.
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. of GDPR. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.
You have the right accordingly Art. 16 GDPR to demand the completion or the correction of the data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.
You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transfer to other controllers.
You have according to Art. 77 GDPR the right to file a complaint with the competent supervisory authority.
You have the right to withdraw the consent given with effect for the future according to Art. 7 Abs. 3 GDPR.
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.
The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 of GDPR. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements. In case the data will not be deleted because it is required for other and legitimate purposes, its processing will be restricted meaning the data will be blocked and will not be processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.
According to legal requirements in Germany, the storage takes place in particular for 10 years according to § 147 Abs. 1 AO, § 257 Abs. 1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting documents, trading books, relevant for taxation documents, etc.) and 6 years in accordance with § 257 (1) no. 2 and 3, para. 4 HGB (commercial letters).
When the user contacts us (for example, by contact form, e-mail, telephone or via social media), the information of the user is processed for working on the contact request and its execution in accordance with Art. 6 para. 1 lit. b) GDPR. User information can be stored in our Customer Relationship Management System ("CRM System") or comparable request organization.
We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, the statutory archiving obligations apply.