Privacy Policy – Breakthrough Leadership App

1. Introduction

This website is operated by: atrain GmbH. It is very important to us to handle the data of our website visitors with confidence and to protect them in the best possible way. For this reason, we make every effort to comply with the requirements of the GDPR. In the following, we explain how we process your data on our website. To do this, we use the clearest and most transparent language possible so that you really understand what happens with your data.

2. General information

2.1 Processing of personal data and other terms
Data protection applies to the processing of personal data. Personal means all data with which you can be personally identified. This is, for example, the IP address of the device (PC, laptop, smartphone, etc.) in front of which you are currently sitting. Such data is processed when ‘something happens to it’. Here, for example, the IP is transmitted from the browser to our provider and stored there automatically. This is then a processing (according to Art. 4 No. 2 GDPR) of personal data (according to Art. 4 No. 1 GDPR).
These and other legal definitions can be found in Art. 4 GDPR.

2.2 Applicable regulations/laws – GDPR, BDSG and TTDSG
The scope of data protection is regulated by laws. In this case, these are the GDPR (General Data Protection Regulation) as a European regulation and the BDSG (Federal Data Protection Act) as a national law. In addition, the TTDSG supplements the provisions from the GDPR as far as the use of cookies is concerned.

2.3 The person in charge
The person responsible for data processing on this website is the controller within the meaning of the GDPR. This is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

You can reach the person in charge at:
atrain GmbH
Unterer Kaulberg 3
96049 Bamberg
datasecurity@atrain.com

2.4 Data Protection Officer
We have appointed a data protection officer for our company.

Andreas Hein
ITs Hein GmbH
Kulmbacher Str. 27b
95460 Bad Berneck
Phone: 0951/3020680
E-mail: datasecurity@atrain.com

2.5 This is how data is basically processed on this website
We have already established, there are data (e.g. IP address) that are collected
automatically. This data is mainly required for the technical provision of the homepage. Insofar as we use personal data or collect other data, we will inform you of this or ask for your consent. personal data you share with us knowingly. Detailed information on this can be found below.

2.6 Your Right
The GDPR provides you with comprehensive rights. These are, for example, the free information about the origin, recipient and purpose of your stored personal data. In addition, you can request the correction, blocking or deletion of this data or complain to the competent data protection supervisory authority. You can revoke any consent you have given at any time.
You can find out in detail what these rights are and how to exercise them in the last section of this Privacy Policy.

2.7 Data protection – Our view
Data protection is more than just a chore for us! Personal data is of great value and careful handling of this data should be a matter of course in our digitalized world. In addition, you as a website visitor should be able to decide for yourself what “happens” to your data, when and by whom. We therefore undertake to comply with all legal provisions, collect only the data that is necessary for us and, of course, treat it confidentially.

2.8 Disclosure and deletion
The transfer and deletion of data are also important and sensitive topics. Therefore, we would like to briefly inform you in advance about our general approach to this.
A transfer of data only takes place on the basis of a legal basis and only if this is unavoidable. This may be the case in particular if it is a so-called Data Processor and a Data Processing Agreement has been concluded in accordance with Art. 28 GDPR.
We delete your data when the purpose and the legal basis for processing cease to apply and the deletion does not conflict with any other legal obligations. A ‘good’ overview of this is also provided by Art. 17 GDPR.
For all further information, please refer to this Privacy Policy and contact the responsible person if you have any specific questions.

2.9 Hosting
This website is hosted externally. The personal data collected on this website is stored on the hoster’s servers. This includes the automatically collected and stored log files (see below for more details), as well as all other data provided by the website visitors.
External hosting is used for the purpose of secure, fast and reliable provision of our website and in this context serves the fulfillment of contracts with our potential and existing customers.
The legal basis for the processing is Art. 6 (1) lit. a, b and f GDPR, as well as Section 25 (1) TTDSG, insofar as consent includes the storage of cookies or access to information in the terminal device of the website visitor or user as defined by the TTDSG.
Our hoster only processes data that is necessary for the fulfillment of its service obligation and acts as our Data Processor, which means that it is subject to our instructions. We have concluded a corresponding Data Processing Agreement with our hoster.
We use the following hoster:
Microsoft Azure
https://azure.microsoft.com/de-de/

2.10 Legal basis
The processing of personal data always requires a legal basis. The GDPR provides for the following possibilities in Art. 6 (1) Sentence 1:
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 whichthe person in chargesubject to;
d) the processing is necessary in order 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 inthe person in charge was transferred;
f) processing is necessary for the purposes of safeguarding the legitimate interests ofof the responsible person(s) orof a/an third party necessary, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data override this, in particular where the data subject is a child.
In the following sections, we will provide you with the specific legal basis for the respective processing.

3. What happens on our website

By visiting our website, we process personal data from you. To protect this data as best as possible against unauthorized access by third parties, we use SSL or TLS encryption. You can recognize this encrypted connection by the fact that a https:// or a lock symbol is displayed in the address bar of your browser.
In the following, you will learn what data is collected when you visit our website, for what purpose this is done and on what legal basis.

3.1 Data collection when calling up the website
By calling up the website, information is automatically stored in so-called server log files. This is the following information:
• Browser type and version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server request
• IP address
This data is temporarily required in order to be able to display our website to you permanently and without problems. In particular, this data thus serves the following purposes:
• System security of the website
• System stability of the website
• Website troubleshooting
• Connecting to the website
• Website presentation
The data processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR and is based on our legitimate interest in the processing of this data, in particular the interest in the functionality of the website as well as its security.
If possible, this data is stored pseudonymously and deleted after the respective purpose has been achieved.
Insofar as the server log files allow the identification of the person concerned, the data is stored for a maximum period of 14 days. An exception exists if a security-relevant event occurs. In this case, the server log files are stored until the elimination and final clarification of the security-relevant event.
For the rest, a consolidation with other data does not take place.

3.2 Cookies
3.2.1 General
This website uses so-called cookies. This is a data record, information that is stored in the browser of your terminal device and is related to our website. By setting cookies, the navigation of the website in particular can be made easier for the visitor.

3.2.2 Reject cookies
The setting of cookies can be prevented by adjusting the settings of your browser. Here you can find the corresponding links to frequently used browsers:
Mozilla Firefox: https://support.mozilla.org/de/kb/cookies-und-website-daten-in- firefox-loschen?redirectslug=Cookies+1%C3%B6schen&redirectlocale=en
Google Chrome: https://support.google.com/chrome/answer/95647? co=GENIE.Platform%3DDesktop&hl=de
Microsoft Edge: https://support.microsoft.com/de-de/windows/l%C3%B6schen- und-verwalten-von-cookies-168dab11-0753-043d-7c16-ede5947fc64d
Safari: https://support.apple.com/de-de/guide/mdm/mdmf7d5714d4/web and https://support.apple.com/de-de/guide/safari/sfri11471/mac As far as you use another browser, it is recommended to enter the name of your browser and ‘Delete and manage cookies’ into a search engine and follow the official link to your
browser.
Alternatively, you can also manage your cookie settings at www.aboutads.info/choices/ or www.youronlinechoices.com. However, we must inform you that comprehensive blocking/deletion of cookies may lead to impairments in the use of the website.

3.2.3 Technically necessary cookies
We use technically necessary cookies on this website to ensure that our website functions without errors and in accordance with applicable laws. They help to make the website user-friendly. Some functions of our website cannot be displayed without the use of cookies.
The legal basis for this is, depending on the individual case, Art. 6 para. 1 lit. b, c and/or f GDPR.

3.2.4 Technically unnecessary cookies
In addition, we also use cookies on our website that are not technically necessary. These cookies are used, among other things, to analyze the surfing behavior of the website visitor or to offer website functions that are, however, not technically necessary.
The legal basis for this is your consent pursuant to Art. 6 para. 1 lit. a GDPR. Technically unnecessary cookies are only set with your consent, which you can revoke at any time in the cookie consent tool.

3.3 Data processing through user input
3.3.1 Own data collection
We offer the following (service) on our website: Questionnaire data. For this purpose, we collect the following data:
Name
E-mail address
Questionnaire results
The legal basis for this data processing is Art. 6 para. 1 lit. b GDPR.
The data will be deleted as soon as the respective purpose ceases to apply and it is possible in accordance with the legal requirements.

3.3.2 Contact
a) E-mail
If you contact us by e-mail, we process your e-mail address and, if applicable, other data contained in the e-mail. These are stored on the mail server and partly on the respective end devices. Depending on the request, the legal basis for this is regularly Art. 6 para. 1 lit. f GDPR or Art. 6 para. 1 lit. b GDPR. The data will be deleted as soon as the respective purpose ceases to apply and it is possible according to the legal requirements.

3.3.3 Questionnaires/forms
a) Breakthrough Leadership App
https://bla.atrain.com/

3.4 Mailing service
3.4.1 SendGrid
We use SendGrid as a mailing service. This service is offered by Twilio Inc, 889 Winslow St, Redwood City, California 94063, USA.
This is a service for e-mail delivery.
SendGrid can be used to analyze interactions.
The processing is either based on consent according to Art. 6 para. 1 lit. a GDPR, as far as we use the mailing service to contact our leads. The consent can be revoked at any time.
When sending e-mails for the specific purpose of initiating a contract or in an existing contractual relationship, the legal basis for the processing is Art. 6 (1) lit. b GDPR, as the services used serve customer management and the fulfillment of our contractual performance.
The data will be deleted at the end of the contract between us and SendGrid. In the case of data transfer to the USA, the standard contractual clauses (SCC) of the EU Commission apply.
More details:
https://sendgrid.com/resource/general-data-protection-regulation-2/.

4. This is also important

Finally, we would like to inform you in detail about your rights and how you will be informed about changes in data protection requirements.
4.1 Your Rights in detail
4.1.1 Right to information according to Art. 15 GDPR
You can request information about whether personal data about you is being processed. If this is the case, you can request further information on the type and manner of processing. A detailed list can be found in Art. 15 (1) lit. a to h GDPR

4.1.2 Right to rectification according to Art. 16 GDPR
This right includes the correction of inaccurate data and the completion of incomplete personal data.

4.1.3 Right to information according to Art. 17 GDPR
This so-called ‘right to be forgotten’ gives you the right, under certain conditions, to request the deletion of personal data by the controller. This is generally the case if the purpose of the data processing has ceased to exist, if consent has been revoked or if the initial processing took place without a legal basis. A detailed list of reasons can be found in Art. 17 (1) a to f GDPR. Furthermore, this “right to be forgotten” corresponds with the obligation of the controller under Art. 17 (2) GDPR to take appropriate measures to bring about a general erasure of the data.

4.2 Right to restriction of processing according to Art. 18 GDPR
This right is subject to the conditions set out in Art. 18(1)(a) to (d).
4.2.1 Right to data portability according to Art. 20 GDPR
Here, the basic right to receive one’s own data in a common form and to transfer it to another data controller is regulated. However, this only applies to data processed on the basis of consent or a contract pursuant to Art. 20 (1) (a) and (b) and to the extent that this is technically feasible.
4.2.2 Right of objection according to Art. 21 GDPR
In principle, you can object to the processing of your personal data. This applies in particular if your interest in objecting outweighs the legitimate interest of the controller in the processing and if the processing relates to direct marketing and or profiling.

4.2.3 Right to “decision in individual cases” according to Art. 22 GDPR
In principle, 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. However, this right is also subject to limitations and supplements in Art. 22 (2) and (4) GDPR.

4.2.4 Other rights
The GDPR includes comprehensive rights to inform third parties whether or how you have asserted rights under Art. 16, 17, 18 GDPR. This, however, only insofar as this is also possible or feasible with a reasonable effort. We would like to take this opportunity to once again inform you of your right to withdraw your consent in accordance with Article 7 (3) of the GDPR. However, this does not affect the lawfulness of the processing carried out up to that point. In addition, we would also like to inform you about your rights according to §§ 32 ff. BDSG, which, however, are largely congruent with the rights just described.

4.2.5 Right of appeal according to Art. 77 GDPR
You also have the right to complain to a data protection supervisory authority if you consider that any processing of personal data concerning you is in breach of this Regulation.

4.2 Right to restriction of processing according to Art. 18 GDPR This right is subject to the conditions set out in Art. 18(1)(a) to (d).
4.2.1 Right to data portability according to Art. 20 GDPR Here, the basic right to receive one’s own data in a common form and to transfer it to another data controller is regulated. However, this only applies to data processed on the basis of consent or a contract pursuant to Art. 20 (1) (a) and (b) and to the extent that this is technically feasible.
4.2.2 Right of objection according to Art. 21 GDPR In principle, you can object to the processing of your personal data. This applies in particular if your interest in objecting outweighs the legitimate interest of the controller in the processing and if the processing relates to direct marketing and or profiling.
4.2.3 Right to “decision in individual cases” according to Art. 22 GDPR
In principle, 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. However, this right is also subject to limitations and supplements in Art. 22 (2) and (4) GDPR.
4.2.4 Other rights
The GDPR includes comprehensive rights to inform third parties whether or how you have asserted rights under Art. 16, 17, 18 GDPR. This, however, only insofar as this is also possible or feasible with a reasonable effort. We would like to take this opportunity to once again inform you of your right to withdraw your consent in accordance with Article 7 (3) of the GDPR. However, this does not affect the lawfulness of the processing carried out up to that point. In addition, we would also like to inform you about your rights according to §§ 32 ff. BDSG, which, however, are largely congruent with the rights just described.
4.2.5 Right of appeal according to Art. 77 GDPR
You also have the right to complain to a data protection supervisory authority if you consider that any processing of personal data concerning you is in breach of this Regulation.

5. What if tomorrow the GDPR is abolished or other changes take place?

The current status of this Privacy Policy is 07.11.2023. As soon as we change this Policy, we will inform you of this on our website.