Privacy Policy for Training Programs

We hereby inform you in accordance with the requirements of Articles 13 and 14 of the General Data Protection Regulation (GDPR) about the processing of personal data collected about you as well as your related data protection rights. To ensure that you are fully informed about the processing of your personal data, please take note of the following information.

Controller

Kanzlei Kunke Rechtsanwälte PartG mbB
Scheibenstr. 38 40479 Düsseldorf
Tel.: +49 (0) 211/436912202 info@kanzlei-kunke.de

Provision of the Webseite

For the provision of our website, we use the services of the following service provider:

IONOS SE Elgendorfer Str. 57 56410 Montabaur

When you visit our website, we process your IP address and information transmitted by your browser during the connection, such as the user agent (which contains information about your browser) or the display languages preferred by your browser. We store this information together with the time of your request and the requested pages in log files in order to verify the correct functioning and security of this website.

The legal basis for processing this personal data is Article 6(1)(f) GDPR, our legitimate interest in providing our web presence. The log files are automatically overwritten after 7 days.

Contacting us

When you send us a message, we process your first and last name, your email address, and your message to us. If you write to us for the purpose of contract initiation, then we process your personal data on the basis of Article 6(1)(b) GDPR. If your message is not necessary for the performance of pre-contractual measures, we process your personal data on the basis of Article 6(1)(f) GDPR. Our legitimate interest lies in reading and responding to messages sent to us for contact purposes.

We process your message only until the completion of processing. If a contract has resulted from your message, we are legally obligated to retain your message for 6 years.

Exam

We offer the opportunity to test your knowledge and earn a certificate by partaking in our online exam. If we sent you an invite to an exam, your employer transmitted your first name, last name and email address to us so that we may send you the invite. This data is only stored locally and exclusively for the purpose of sending you the invite and the certificate. We also process the following additional personal data (Exam Data):

  • UUID-token
  • Session token
  • Timestamps for start and completion of exam
  • Answers to the exam questions
  • IP-address in use when taking the exam

The Exam Data is stored on our webserver. After the exam, we transfer your personal data to process it locally. Only then will it be combined with your registration data for creating and sending the certificate to you. We also review the logs for irregularities. Your employer may receive an overview of the participant's results including yours, if they request it.

The legal basis for this processing is Article 6(1)(f) GDPR. We have a legitimate interest in offering the online exams as a service to your employer. After the logs have been reviewed and the certificates sent out, we store your personal data for an additional 60 days in case your employer has questions regarding the exam or wants you to retake a failed exam.

Insofar as we have not already provided more specific information on the following topics, the following processing principles apply in addition:

Disclosure of personal data and recipient categories

We only disclose personal data internally and to third parties, in addition to the cases explicitly mentioned in this privacy policy, when this is necessary for the stated purposes or legally required.

Categories of recipients: Our own service providers (e.g. communication service providers, IT service providers, auditors, tax advisors or judicial authorities), social security institutions and tax administration.

Transfer to third countries

We – or our processors – generally only process personal data in countries within the EU or the European Economic Area that are subject to the scope of the GDPR. In exceptional cases, personal data is transferred to other countries (so-called "third countries") if an adequate level of data protection is guaranteed according to Article 44 GDPR, such as:

  • if a so-called "adequacy decision" by the European Commission exists,
  • through the use of "EU Standard Contractual Clauses" or
  • through other suitable safeguards to ensure an adequate level of data protection according to Article 46 GDPR.

For example, a transfer to a third country can take place according to Article 49(1)(a) GDPR if you have explicitly consented to the data transfer after being informed about the possible risks of such data transfers that exist for you in the absence of an adequacy decision and without suitable guarantees.

Storage duration and deletion of personal data

As soon as we achieve the pursued purpose of the data processing, we delete your personal data.

In addition, we only store data if legal exceptions and obligations exist, such as according to Article 17(3) GDPR. This is particularly significant in connection with the fulfillment of legal retention obligations (Article 17(3)(b) GDPR) and with the establishment, exercise or defense of legal claims (Article 17(3)(e) GDPR). Sector-specific regulations are observed.

Legal provisions for storage arise in particular from the retention periods of the Commercial Code (HGB) or the Tax Code (AO). According to these, the retention period is between 6 and 10 years after completion of the transaction.

Data subject rights

When we process personal data about you, you generally and where applicable have the rights listed below. If you wish to exercise any of these rights, you can contact us at any time using the contact details provided.

  • Right to access according to Article 15 GDPR

    You have the right that we provide you with information about your personal data processed by us at any time free of charge.

  • Right to rectification according to Article 16 GDPR

    You have the right to demand that inaccurate personal data concerning you be rectified without delay or that such data be completed.

  • Right to erasure according to Article 17 GDPR

    You have the right that we carry out deletion of personal data concerning you without delay.

  • Right to restriction of processing according to Article 18 GDPR

    You have the right to request a restriction of the processing of your personal data at any time.

  • Right to data portability according to Article 20 GDPR

    You have the right that we provide the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format.

  • Right to object according to Article 21 GDPR

    You have the right to object to processing in various situations (processing based on the legal basis according to Article 6(1)(e) or (f) GDPR, profiling or direct marketing).

  • Right to lodge a complaint

    You have the right to lodge a complaint with a supervisory authority of your choice regarding the processing.