Privacy Policy

1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data is evaluated without reference to your person to understand how our website is used.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

We analyse the use of our website with Matomo. Matomo runs on our own server, sets no cookies, does not read any information from your device and shortens your IP address before it is stored. The analysis does not allow any conclusions about your person, and no data is passed on to third parties. Details can be found under “5. Web analytics”.

Some pages embed videos from YouTube or Vimeo. What is transmitted in the process is described under “7. Plug-ins and tools”.

2. Hosting

External Hosting

This website is hosted by an external service provider (host). Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

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

Our host will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

We are using the following host:

ecruiting solutions consulting
Dipl.-Psych. Ralph Köbler
Burggasse 100/7
A-1070 Vienna, Austria

Our host operates this website on servers of Server4You GmbH, Hessen-Homburg-Platz 1, 63452 Hanau, Germany, which acts as a sub-processor in this respect.

Execution of a contract data processing agreement

In order to guarantee processing in compliance with data protection regulations, we have concluded an order processing contract with our host.

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

European Association for The Wholeness Work e.V. (EATWW e.V.)
c/o Ulrich Bührle
Hasenbergsteige 23
70197 Stuttgart
Germany

E-mail: info@wholenesswork.eu
Represented by the board, see legal notice.

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage duration

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

Information on data transfer to non-EU countries

Some of the services listed under “7. Plug-ins and tools” are based in the USA or may transfer data there. For the USA there is an adequacy decision of the EU Commission (EU-U.S. Data Privacy Framework). Where a provider is certified under it, the transfer is based on this decision; otherwise it is based on the standard contractual clauses of the EU Commission.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

• In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
• If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
• If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
• If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

4. Recording of data on this website

Cookies

Our website does not set any cookies for analysis or advertising purposes. A cookie is only set in the password-protected areas for members, coaches and trainers: after you enter the password, a session cookie stores that you are logged in. It is deleted when you close your browser. This cookie is technically necessary for the access you have requested (Section 25(2) no. 2 TDDDG, Art. 6(1)(b) and (f) GDPR).

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

• The type and version of browser used
• The used operating system
• Referrer URL
• The hostname of the accessing computer
• The time of the server inquiry
• The IP address

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact form

If you write to us via the contact form, we send your details (name, e-mail address, message) by e-mail to the association’s mailboxes and send you a confirmation to the address you provided. The mailboxes are operated by Heinlein Hosting GmbH (mailbox.org), Berlin. We use the data exclusively to handle your inquiry and any follow-up questions and do not share it without your consent.

The processing is based on Art. 6(1)(b) GDPR if your inquiry is related to a contract or membership, and otherwise on our legitimate interest in answering inquiries (Art. 6(1)(f) GDPR). If you also select the newsletter in the form, section “6. Newsletter” applies.

The data remains with us until you ask us to delete it or the purpose of storage no longer applies, e.g. after your inquiry has been dealt with. Statutory retention periods remain unaffected.

Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

Registration for the webinar recording

If you register for the recording of our free webinar, we process your first and last name, your e-mail address and the language you have chosen. You will receive an e-mail with the link to the recording and, over the following days, up to three further e-mails about the content of the webinar and about our seminars. For sending these e-mails we store your data with our newsletter service provider Brevo (see “6. Newsletter”).

The legal basis is your consent, which you give by submitting the form (Art. 6(1)(a) GDPR). You can revoke it at any time via the unsubscribe link in every e-mail or by e-mail to us.

Membership application

If you apply for membership via our website, we transfer the data entered in the form to the association’s membership administration, which runs on the same server, and notify the board by e-mail. We process the data to review and carry out the membership, including the billing of membership fees (Art. 6(1)(b) GDPR). After the membership ends we delete it, unless statutory retention periods apply.

Registration for seminars

Registration for our seminars takes place via our registration system at register.wholenesswork.eu. We process the details from the registration form, in particular name, address, e-mail address, booked seminar parts, language, payment method and, where applicable, your VAT identification number, in order to organise your participation, issue invoices and allocate incoming payments (Art. 6(1)(b) GDPR). We retain invoice data in accordance with tax and commercial law requirements (Art. 6(1)(c) GDPR). For online payment see “8. Payment service providers”.

5. Web analytics

Matomo

We use the open-source tool Matomo to analyse the use of our website statistically, for example which pages are visited and how visitors find us. Matomo runs on our own server (see “2. Hosting”); the data does not leave this server and is not passed on to third parties.

Matomo is configured so that it sets no cookies and does not read any information from your device beyond what is transmitted anyway with every page request. Your IP address is shortened by two bytes before it is stored (e.g. 192.168.xxx.xxx), so that it can no longer be attributed to you. Consent under Section 25 TDDDG is therefore not required.

The legal basis is our legitimate interest in designing and developing our website in line with demand (Art. 6(1)(f) GDPR). The raw data is deleted after 13 months at the latest.

You can object to the analysis by activating the “Do Not Track” setting in your browser; Matomo will then not record your visits. Alternatively, an informal e-mail to us is sufficient.

6. Newsletter

Newsletter data

If you would like to receive our newsletter, we need your e-mail address and your name. Subscription uses the double opt-in procedure: you receive an e-mail with a confirmation link and are only added to the mailing list once you have clicked it. The time of subscription and confirmation is stored as proof.

The processing is based on your consent (Art. 6(1)(a) GDPR). You can revoke it at any time, for example via the unsubscribe link in every newsletter. The lawfulness of data processing operations already carried out remains unaffected by the revocation. After you unsubscribe, we delete your data from the mailing list; your e-mail address may remain on a block list so that you do not receive any further newsletters.

Brevo

We use Brevo to send the newsletter and the e-mails relating to the webinar recording. The provider is Sendinblue SAS (Brevo), 106 boulevard Haussmann, 75008 Paris, France. Your data is stored on servers in the European Union. Brevo evaluates whether an e-mail was opened and which links in it were clicked; this helps us to improve the content. A data processing agreement is in place with Brevo. More information: https://www.brevo.com/legal/privacypolicy/.

7. Plug-ins and tools

Fonts

The fonts used on this website are stored locally on our server. No connection to servers of Google or other font providers is established when you visit the pages.

YouTube

Some pages embed videos from the YouTube platform. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. We use the privacy-enhanced mode (youtube-nocookie.com). Nevertheless, when a page with a video is loaded, a connection to YouTube’s servers is established, during which in particular your IP address and the page visited are transmitted. Only when you play the video can YouTube collect further data and set cookies. If you are logged in to YouTube, YouTube can link your browsing behaviour to your profile; you can prevent this by logging out beforehand.

The legal basis is our legitimate interest in an appealing presentation of our content (Art. 6(1)(f) GDPR). More information: https://policies.google.com/privacy?hl=en.

Vimeo

The webinar recording and videos in the members’ areas are embedded via Vimeo. The provider is Vimeo.com, Inc., New York, USA. The webinar recording is only loaded when you click on it. We embed Vimeo with the “Do Not Track” setting, so that Vimeo does not set any tracking cookies; however, when you play a video, your IP address and technical information are transmitted to Vimeo.

The legal basis is our legitimate interest in providing our videos (Art. 6(1)(f) GDPR). More information: https://vimeo.com/privacy.

8. Payment service providers

PayPal

You can pay the membership fee on our website via PayPal. The provider is PayPal (Europe) S.à r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg. When you click a PayPal button, you are redirected to PayPal; PayPal processes the data required for the payment under its own responsibility. We receive confirmation of the payment from PayPal with name, e-mail address and amount in order to allocate it to your membership. More information: https://www.paypal.com/de/legalhub/privacy-full.

Stripe

For the online payment of seminar fees in the registration system we use Stripe. The provider is Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland. Stripe processes the payment data (e.g. card details) under its own responsibility; we only receive confirmation and the amount of the payment. More information: https://stripe.com/privacy.

The legal basis for payment processing is Art. 6(1)(b) GDPR.

Data transfer upon closing of contracts for services and digital content

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with the financial institution tasked with the processing of payments.

Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur.

The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions.