Privacy Policy

This data protection declaration explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as ‘data’) within our online offer and the associated websites, functions and content, as well as external online presences, such as our social media profiles. (hereinafter collectively referred to as ‘online offer’). With regard to the terms used, such as ‘processing’ or ‘controller’, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Controller

Tistel – civil crisis consulting & tactical trainings UG (haftungsbeschränkt)
Lausitzer Straße 10
10999 Berlin

Board:
Anna-Lea Göhl
Jannik Best

Types of data processed

• Inventory data (e.g. names, addresses).
• Contact details (e.g. email addresses, telephone numbers).
• Content data (e.g. text entries, photographs, videos).
• Usage data (e.g. websites visited, interest in content, access times).
• Meta/communication data (e.g. device information, IP addresses).
• Account data (e.g. IBAN / BIC)

Categories of data subjects

Visitors and users of the online offering (hereinafter, we will refer to the data subjects collectively as ‘users’).

Purpose of the processing

• Provision of the online offer, its functions and content.
• Responding to contact requests and communicating with users.
• Security measures.
• Range measurement/marketing.

Terminology used

‘Personal data’ means any information relating to an identified or identifiable natural person (hereinafter referred to as ‘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 location data, an online identifier (e.g. a cookie) or one or more special features that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

‘Processing’ means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.

The term ‘controller’ refers to 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.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you of the legal basis for our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing to fulfil our services and carry out contractual measures and respond to enquiries is Art. 6 para. 1 (b) GDPR, the legal basis for processing to fulfil our legal obligations is Article 6(1)(c) GDPR, and the legal basis for processing to safeguard our legitimate interests is Article 6(1)(f) GDPR. In the event that the vital interests of the data subject or of another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

Cooperation with processors and third parties

If we disclose data to other persons and companies (processors or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary for the fulfilment of the contract in accordance with Art. 6 para. 1 lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.

The transfer of personal data to a third country or an international organisation only takes place under the conditions described in this section. A third country is a country outside the European Economic Area (EEA) in which the GDPR does not apply directly. A third country is considered unsafe if the EU Commission has not issued an adequacy decision for this country in accordance with Art. 45 para. 1 GDPR, which confirms that there is adequate protection for personal data in the country.

The USA is a so-called unsafe third country. This means that the level of data protection in the USA cannot be compared with that in the EU. If personal data is transferred to the USA, there is a risk that US authorities may gain access to the data on the basis of the PRISM and UPSTREAM surveillance programmes based on Section 702 of the FISA (Foreign Intelligence Surveillance Act), as well as on the basis of Executive Order 12333 or Presidential Police Directive 28. EU citizens have no effective legal defence against this access in the USA or the EU.

In this privacy policy, we inform you when and how we transfer personal data to the USA or other insecure third countries.

If we process data in a third country or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this is only done to fulfil 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 authorisations, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to the EU (e.g. for the USA through the “EU-US Data Privacy Framework”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).

Rights of the data subjects

(1) Right of access pursuant to Art. 15 of the General Data Protection Regulation

You can request information about whether personal data has been processed. If this is the case, you will receive information about the personal data processed and, if applicable, further information in accordance with Art. 15 of the General Data Protection Regulation.

(2) Right to rectification in accordance with Art. 16 of the General Data Protection Regulation

You can request that any inaccurate personal data concerning you be corrected without delay. This may also include the completion of incomplete personal data.

(3) Right to erasure under Art. 17 of the General Data Protection Regulation (‘right to be forgotten’)

You may request that personal data concerning you be deleted immediately if the conditions of Art. 17 GDPR are met.

(4) Right to restriction of processing in accordance with Art. 18 of the General Data Protection Regulation

You have the right to request the restriction of the processing of data concerning you if the conditions of Art. 18 GDPR are met.

(5) Right to data portability in accordance with Art. 20 of the General Data Protection Regulation

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 transmit this data to another controller, provided that the legal requirements are met.

(6) Right to object pursuant to Art. 21 of the General Data Protection Regulation

For reasons arising from your particular situation, you may object at any time to the processing of personal data concerning you that is carried out on the basis of Article 6(1)(e) or (f) of the General Data Protection Regulation.

(7) Right to withdraw consent

You have the right to withdraw your consent to the processing of personal data at any time.

(8) Right of appeal

If you are of the opinion that we have not complied with data protection regulations when processing your data, you can lodge a complaint with a data protection supervisory authority

Berlin Commissioner for Data Protection and Freedom of Information
Alt-Moabit 59-61
10555 Berlin
Entrance: Alt-Moabit 60

Tel.: +49 30 13889-0
Fax: +49 30 2155050
E-mail: mailbox[at]datenschutz-berlin.de

Cookies and the right to object to direct marketing

Cookies are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or ‘session cookies’ or ‘transient cookies’, are cookies that are deleted after a user leaves an online offer and closes their browser. In such a cookie, for example, the contents of a shopping basket in an online shop or a login status can be stored. Cookies that remain stored even after the browser is closed are referred to as ‘permanent’ or ‘persistent’. For example, the login status can be stored if users visit the site after several days. Similarly, the interests of users can be stored in such a cookie, which are used for reach measurement or marketing purposes. Third-party cookies are cookies that are offered by providers other than the person responsible for the online offer (otherwise, if it is only their cookies, they are referred to as ‘first-party cookies’).

We may use temporary and permanent cookies and explain this in our data protection declaration.

If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in their browser’s system settings. Stored cookies can be deleted in the browser’s system settings. Excluding cookies may lead to functional restrictions of this online offer.

A general objection to the use of cookies for online marketing purposes can be declared for a variety of services, especially in the case of tracking, via the US site https://www.youronlinechoices.com. Furthermore, cookies can be disabled by changing the settings in your browser. Please note that this may prevent you from using all the functions of this website.

Deletion of data

The data we process will be deleted or restricted in its processing in accordance with Articles 17 and 18 of the GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.

In accordance with the legal requirements in Germany, data is stored for 6 years in particular in accordance with § 257 para. 1 HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).

According to the legal requirements in Austria, the storage period is 7 years in particular in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, list of income and expenses, etc.), 22 years in connection with real estate and for 10 years for documents relating to electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

Business-related processing

We also process

• contract data (e.g. subject matter of the contract, term, customer category, sustaining membership).
• Payment data (e.g. bank details, payment history)
  from our customers, interested parties and business partners for the purpose of providing contractual services (e.g. sponsorship memberships), service and customer care, marketing, advertising and market research.

Hosting

The hosting services we use are used to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use to operate this online offer.

In doing so, we or our hosting providers process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in the efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f DSGVO i.V.m. Art. 28 DSGVO (conclusion of a contract processing agreement).

Collection of access data and log files

We, or our hosting provider, collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, the file, the date and time of access, the amount of data transferred, the notification of successful retrieval, the browser type and version, the user’s operating system, the referrer URL (the previously visited page), the IP address and the requesting provider.

For security reasons (e.g. to investigate cases of abuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data that must be retained for evidentiary purposes is exempt from deletion until the respective incident has been definitively resolved.

Administration, financial accounting, office organisation, contact management

We process data as part of administrative tasks and the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process as part of the provision of our contractual services. The processing is based on Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. The processing affects customers, interested parties, business partners and website visitors. The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information provided for these processing activities.

In doing so, we disclose or transfer data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, we store information on suppliers, organisers and other business partners, e.g. for the purpose of contacting them at a later date, on the basis of our business interests. We generally store this data, which is mostly company-related, permanently.

Contact

When you contact us (e.g. via contact form, e-mail, telephone or social media), the user’s information is processed in accordance with Art. 6 para. 1 lit. b) GDPR in order to process the contact request and its handling. The user’s information may be stored in a customer relationship management system (‘CRM system’) or comparable enquiry organisation.

We delete the requests if they are no longer required. We review the necessity every two years; Furthermore, the legal archiving obligations apply.

Comment subscriptions

Subsequent comments can be subscribed to by users with their consent in accordance with Art. 6 para. 1 lit. a GDPR. Users will receive a confirmation email to verify that they are the owner of the email address entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will contain information on how to unsubscribe.

Online presence in social media

We maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users who are active there and to be able to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.

Unless otherwise stated in our data protection declaration, we process the data of users who communicate with us within social networks and platforms, e.g. by posting comments on our online presences or sending us messages.

Integration of third-party services and content

We use content or service offers from third-party providers within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f GDPR). This is done in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as ‘content’).

Data processing by third-party providers

The integration of this content always requires that the third-party providers recognise the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavour to only use content whose providers only use the IP address to deliver the content.

In addition, third-party providers may use so-called pixel tags (invisible graphics, also known as ‘web beacons’) for statistical or marketing purposes. These pixel tags can be used to analyse information such as the number of visitors to the pages of this website. The pseudonymised information may be stored in cookies on the user’s device and contain technical information about the browser and operating system, referring websites, visiting times and other details about the use of our online offering.

YouTube

We integrate the videos of the platform ‘YouTube’ of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Privacy policy: Google Privacy
Opt-Out: Google Ads Settings

Google Fonts

We integrate the fonts (‘Google Fonts’) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Privacy Policy: Google Privacy
Opt-Out: Google Ads Settings
Google LLC is certified under the EU-U.S. Data Privacy Framework and thus guarantees compliance with European data protection law (see Participant Search).
For more information about the pixels we use and how you can withdraw your consent, please read our Cookie Policy.