Privacy policy
1. Person responsible
Felicia Mundhenke
Brend'amourstr. 48
40545 Düsseldorf
Phone: 0211 845 6761
E-Mail: hello(at)consalio.com
Website: www.consalio.com
2. Types of data processed:
- Inventory data (e.g., names, addresses).
- Contact details (e.g., e-mail, 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).
3. Categories of affected personsn
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as “users”).
4. Purpose of the processing
- Provision of the online offer, its functions and content.
- Answering contact requests and communicating with users.
- Security measures.
- Reach measurement/marketing.
5. Terminology used
„Personal data“ means any information relating to an identified or identifiable natural person (hereinafter ”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 identification number, location data, an online identifier (e.g. a cookie) 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 operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data.
“Pseudonymization” 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 organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
The “controller” is 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.
6. Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not stated in the privacy policy, 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 for the performance of our services and implementation of contractual measures as well as responding to inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
7. Sicherheitsmaßnahmen
We take appropriate technical and organizational measures 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, to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, deletion of data and response to threats to data. Furthermore, we take the protection of personal data into account as early as the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).
8. 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 performance of the contract pursuant to Art. 6 para. 1 lit. b GDPR), you have given your consent, 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 with the processing of data on the basis of a so-called "order processing contract" , this is done on the basis of Art. 28 GDPR.
9. Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done 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 if the special requirements of Art. 44 et seq. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
10. Rights of the data subjects
You have the right to request confirmation as to whether the data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
You have accordingly. Art. 16 GDPR, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with Art. 18 GDPR.
You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request that it be transferred to other data controllers.
In accordance with Art. 77 GDPR, you also have the right to lodge a complaint with the competent supervisory authority.
11. Right of withdrawal
You have the right to withdraw your consent in accordance with Art. 7 (3) GDPR with effect for the future
12. Right of objection
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. In particular, you may object to processing for direct marketing purposes.
13. Contact us
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user's details will be used to process the contact request and its handling in accordance with Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other inquiries) GDPR. The user's details may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.
We delete the requests if they are no longer required. We review the necessity every two years; the statutory archiving obligations also apply.
14. Cookies and right to object to direct advertising
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 service and closes their browser. The content of a shopping cart in an online store or a login status, for example, can be stored in such a cookie. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be saved if the user visits the website after several days. The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only the controller's cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and provide information about this in our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website https://www.aboutads.info/choices/ or the EU website https://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that you may then not be able to use all the functions of this website.
15. Deletion of data
The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, 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 retained for commercial or tax law reasons.
According to legal requirements in Germany, the retention period is 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).
According to legal requirements in Austria, the retention period is 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), 22 years in connection with real estate and 10 years for documents in connection with 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.
16. Hosting and E-Mail-dispatch
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services that we use for the purpose of operating this online offering.
We, or our hosting provider, 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 GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract). Art. 28 GDPR (conclusion of order processing contract).
17. Collection of access data and log files
We, or our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. GDPR, we collect data 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, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for a certain period of time for security reasons (e.g. to clarify acts of abuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
18. Integration of third-party services and content
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third-party providers within our online offer. GDPR), we use content or service offers from third-party providers to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third-party providers of this content are aware of 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 endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offer, as well as being linked to such information from other sources.
19. Formspark
We use Formspark, operated by Trampoline Software SRL based in Belgium, to process form data, especially when contacting us.
Personal data is collected when you contact us.
Date and time of access, browser type/version, IP address, operating system used, first name, surname e-mail address
We process the data in accordance with point 13.
20. Calendly
We also use the online booking system Calendly. The service provider is the American company Calendly Inc, 115 E. Main St., Ste A1B, Buford, GA 30518, USA.
Calendly also processes your data in the USA, among other places. Calendly is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data of EU citizens to the USA. You can find more information on this at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.
Calendly also uses so-called standard contractual clauses (= Art. 46 (2) and (3) GDPR). Standard Contractual Clauses (SCCs) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to third countries (such as the USA) and stored there. Through the EU-US Data Privacy Framework and the Standard Contractual Clauses, Calendly undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de
You can find more information on the standard contractual clauses at Calendly in the data processing conditions at https://calendly.com/dpa
We hope we have been able to provide you with the most important information about Calendly's data processing. You can find out more about the data that is processed through the use of Calendly in the privacy policy on https://calendly.com/privacy?tid=331751622791
21. Cloudflare
To ensure the security of our website and to increase the speed of delivery, we use the content delivery network of Cloudflare, Inc, 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare protects Internet websites from malicious activities such as Distributed Denial of Service attacks, malicious bots and other harmful intruders. Cloudflare provides a Content Delivery Network (CDN) and website protection features (Web Application Firewall). The communication between your browser and our server takes place via the Cloudflare infrastructure and is analyzed there for attack patterns in order to ward off these attacks.
The logging of IP addresses by Cloudflare has been deactivated. Data processing is carried out by specific configuration on servers located in EU countries.
The legal basis for this processing is Section 3 BDSG (processing for the performance of a task for which we are responsible or in the exercise of official authority vested in us: Protection of our website and ensuring fast transmission of content).
Please note: Cloudflare is a company based in the USA. Cloudflare relies on so-called standard contractual clauses for the transmission to ensure that the processing of personal data is subject to a level of security that corresponds to that of the GDPR. You can access Cloudflare's standard contractual clauses here: https://www.cloudflare.com/de-de/cloudflare-customer-dpa/.
Cloudflare also processes your data in the USA, among other places. Cloudflare is an active participant in the EU-US Data Privacy Framework, which regulates the correct and secure transfer of personal data from EU citizens to the USA. You can find more information on this at https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en.
Cloudflare states that it generally does not have access to customer content. In addition, Cloudflare states that it has not provided any government with a feed of customer content passing through the Cloudflare network for many years. In the event that Cloudflare is requested to do so, Cloudflare has also committed to exhausting all legal remedies to protect the data after illegal or unconstitutional requests, in Cloudflare's judgment.
Further information on data protection at Cloudflare can be found here: https://www.cloudflare.com/de-de/gdpr/introduction/.