1. Data protection at a glance

I. General information

This privacy policy explains how we collect and handle your personal data (in accordance with the EU GDPR) when we

– assist you in finding a project,
– maintain a relationship with you after we have found a role for you,
– provide a service to you or you provide a service to us,
– use your data to ask for your assistance in relation to one of our candidates or
– when you visit our website.

This Privacy Policy applies to the personal data of visitors to our website, candidates, customers, suppliers and other persons with whom we may contact to learn more about our candidates.

You can find detailed information on the subject of data protection in our data protection declaration listed below this text.

We ask our partner companies as well as freelance trainers and consultants to consent to the collection, storage and use of their data (if necessary for their company).

Important: This privacy policy may be changed from time to time. Please use this page to inform yourself, as we will post any changes here.

II. Note on the responsible body

The person responsible for data processing on this website is

Phone: +49 5221 996453
E-mail: butler@cleohpatra.com

Responsible party is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, e-mail addresses, etc.).

III. Third-party analysis tools and tools

When you visit our website, your surfing behaviour can be statistically evaluated. This is mainly done with cookies and with so-called analysis programs. The analysis of your surfing behaviour is usually anonymous; the surfing behaviour cannot be traced back to you. You can object to this analysis or prevent it by not using certain tools. For details, please refer to our privacy policy under the heading „Third party modules and analysis tools“.

You can contradict this analysis. We will inform you about the possibilities of objection in this privacy policy.

2. Website in general

I. Data processing for specific purposes

Whenever content of the website is accessed, data is temporarily stored there via so-called log files, which may allow identification. The following data is collected in this process:

– Date and time of retrieval

– IP address of the calling computer

– Host name of the accessing computer

– Website from which the website was accessed

– Websites accessed via the website

– Visited page on our website

– data volume transferred

– Message whether the retrieval was successful

– Information about the type of browser and the version used

– operating system

The temporary storage of the data is necessary for the course of a website visit in order to enable the delivery of the website. Further storage of the log files takes place in order to ensure the functionality of the website and the security of the information technology systems.

II. Legal basis of this data processing

The legal basis for the storage and processing is the protection of our interests according to Art. 6 para. 1 lit. f DS-GVO.

III. Other recipients of the personal data

The website of Cleohpatra UG is hosted by the DigitalOcean. The DigitalOcean receives the above data for this purpose as a processor. A transfer of data to a third country according to the requirements of the DS-GVO does not take place.

A corresponding AV (order data processing) was concluded with the service provider. Further information on the subject of data protection can be found on the DigitalOcean website.

IV. Storage period of the data

The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the provision of the website, this is the case when the respective session has ended. The log files are kept directly and exclusively accessible to administrators for up to 24 hours. After that, they are only indirectly available via the reconstruction of backup tapes and are finally deleted after four weeks.

3. Newsletter

I. Scope of application

This data protection notice indicates the scope of data use for the newsletter in accordance with the EU Data Protection Regulation and the Federal Data Protection Act, as well as the Telemedia Act on the nature, scope and purpose of the collection and use of personal data by the website operator MailChimp.

The website operator takes your privacy very seriously and treats your personal data confidentially and in accordance with the statutory provisions.

Privacy Policy: https://mailchimp.com/legal/privacy/

Please bear in mind that data transmission on the Internet can always be subject to security vulnerabilities. Full protection against access by third parties is not possible.

We send newsletters, e-mails and other electronic notifications (hereinafter „newsletter“) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of a personal address in the newsletter, or further details if these are required for the purposes of the newsletter.

II. Double opt-in procedure

The registration for our newsletter is always carried out in a so-called double opt-in process. This means that you will receive an e-mail after registration in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other email addresses. The registrations to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

III. Measurement of open and click-through rates:

The newsletters contain a so-called „web beacon“, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from their server. Within the scope of this retrieval, technical information, such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.

This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and what content is accessed via the links.

In order to further optimise our newsletter, our service provider evaluates the data on user behaviour and processes the information as personalised newsletter tracking.

IV. Recipients of your personal data

The newsletter is sent by the dispatch service provider MailChimp, a dispatch platform of The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA.

Information about the privacy policy of the shipping service provider can be found at MailChimp.

V. Data collected

The service providers collect data when registering for the newsletter. The data collected will be used exclusively for sending the newsletter and will not be transmitted to third parties.

Surveyed:

• Name, first name
• Email address

VI. Legal basis of the processing of these data

The legal basis for the temporary storage of the data is § 3 para. 1 DSG NRW i. V. m. Art. 6 para. 1 lit. e and para. 3, Art. 57 para. 1 DS-GVO.

VII. Handling of personal data

The website operator collects, uses and discloses your personal data only if this is permitted by law or if you consent to the collection of such data.

Personal data is any information that can be used to identify you personally and that can be traced back to you – i.e. your name and e-mail address.

VIII. Handling of contact data

If you contact the website operator using the contact options offered, your details will be stored so that they can be used to process and respond to your enquiry. This data will not be passed on to third parties without your consent.

IX. Rights of the user: information, correction and deletion

As a user, you can request information free of charge about what personal data has been stored about you. Provided that your request does not conflict with a legal obligation to store data (e.g. data retention), you have the right to have incorrect data corrected and to have your personal data blocked or deleted.

4. Use of the contact forms

I. Scope of application

The Cleohpatra UG collects certain personal data when visiting our website and using the offers to contact us, for which we require consent. This takes place, for example, when a message is written to us via one of our forms, a seminar is booked or an application is made via our portal.

II. Declaration of consent

By using our available forms, you consent to us collecting the personal data provided and processing it as described in this privacy policy. This consent can be revoked at any time with effect for the future by making a corresponding declaration to us. However, we would like to point out that it is no longer possible to use our service without your consent.

For a revocation, please use the contact path of Cleohpatra UG, which is listed under point 1.II. With the revocation the name, e-mail and postal address is to be indicated, so that we can assign the request exactly.

III. Purpose and legal basis of the processing of personal data

We process personal data that is required for the justification, implementation or processing of our range of services on the legal basis of Art. 6 Para. 1 lit. b DSGVO.

Insofar as we have been given consent to process personal data for specific purposes, we process on the basis of consent in accordance with Art. 6 (1) lit. a DSGVO.

Insofar as we use external service providers within the framework of commissioned data processing, the processing is carried out on the legal basis of Art. 28 DSGVO.

The personal data is collected, processed and used by us exclusively for the following purposes.

• For contacting and related correspondence on the basis of consent
• To process a request based on consent
• For the realization of a booking of a seminar on the basis of your consent and/or a contract
• To process an application on the basis of a legitimate interest and/ or consent
• To the newsletter dispatch on the basis of the consent

IV. Personal data collected and processed

We collect and process your personal data only if they are provided to us voluntarily, e.g. by filling out our forms or sending e-mails.

An exception are requests to external trainers, whose data we receive from official information files or from project managers.

In the context of the available forms or messages, this is first of all the following data:

Data of interested parties and inquiring person

• salutation*
• full name*
• complete address*
• Company name*
• E-mail address*
• complete telephone number*
• the agreement to the privacy policy*
• Message*
• the consent*

Data from seminar bookings

• salutation*
• full name*
• complete address*
• Company name*
• E-mail address*
• complete telephone number*
• the agreement to the privacy policy*
• Message*
• the consent*

Data from applications via the website

• Name
• First name
• Address
• Curriculum vitae/ proof of qualifications
• Email
• Phone number

5 General notes and mandatory information

I. Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the legal data protection regulations and this data protection declaration.

When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission on the Internet (e.g. communication by e-mail) can have security gaps. A complete protection of data against access by third parties is not possible.

II. Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke any consent already given at any time. For this purpose, an informal notification by e-mail to us is sufficient. The legality of the data processing carried out up to the time of revocation remains unaffected by the revocation.

III. Right of appeal to the competent supervisory authority

In the event of violations of data protection law, the person concerned has a right of appeal to the competent supervisory authority. The competent supervisory authority in matters of data protection law is the State Data Protection Commissioner of the federal state in which our company is based. A list of the data protection officers and their contact details can be found at the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

IV. Right to data portability

You have the right to have data, which we process automatically on the basis of your consent or in fulfilment of a contract, handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another responsible party, this will only take place to the extent that it is technically feasible.

V. SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from „http://“ to „https://“ and by the lock symbol in your browser line.

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

VI. Information, blocking, deletion

Within the framework of the applicable legal provisions, you have the right to obtain information free of charge at any time about your stored personal data, its origin and recipients and the purpose of the data processing and, if applicable, a right to correct, block or delete this data. For this purpose, as well as for further questions regarding personal data, you can contact us at any time at the address given in the imprint.

VII. Objection to advertising e-mails

We hereby object to the use of contact data published within the scope of the imprint obligation to send advertising and information material not expressly requested. The operators of this website expressly reserve the right to take legal action in the event that unsolicited advertising information is sent, for example by spam e-mails.

6. Data collection & processing in our business processes

I. Data of our customers and suppliers

We collect data from and about our customers and suppliers only to the minimum extent necessary to enable a functioning business relationship. This includes the contact data of the company as well as contact data of individual contact persons within the company organisation (e.g. names, telephone numbers and e-mail addresses), as well as bank data in order to be able to make payments.

We may also store other information that someone in the customer or supplier organization has voluntarily provided to us.

We assume that all these activities fall within the scope of our legitimate interests as business partners.

II. Data of our trainers and consultants

Training, process visualization and project management made to measure is our motto – to realize it, we have to collect and process relevant data about our trainers and consultants (permanent and freelance). These are:

• Personal data: name, date of birth / age, contact details, emergency contacts, company loyalty, origin/initial contact, contact history, availability, preferences and conditions
• Skills & abilities: Categorization trainer/consultant, language skills, branch/industry experience, SAP skills (duration, modules, applications, technologies), authoring tools, TOBA membership/certification
• Profile data: Links to XING and LinkedIn profiles, CVs as they are provided to us by people themselves (usually via email)

III. Collection & use of personal data

We collect personal data in three ways:

• Notification by the business partners themselves
• From other sources, especially social networks and partner companies
• Automatic registration on this website

We may share your personal information with the following categories of persons in many ways and for many purposes, as appropriate and in accordance with local laws and regulations:

• Individuals and organizations who, in order to work with us, have information associated with the reference or application, such as current, past or prospective employees, trainers and selection boards, and employment and recruitment agencies
• tax, audit or other authorities, if we believe in good faith that we are required by law or other regulation to disclose such information (e.g., in the event of litigation or government requests)
• Providers of externally contracted IT services and storage providers, if a corresponding processing agreement (or comparable security) exists
• In the case of candidates: potential clients and other external partners

Please note that this list is not universal and can be changed

We will take all reasonable and appropriate (technical as well as organizational) measures to protect the personal information stored by us from misuse, loss or unauthorized access.

7. Data collection on our website

I. Cookies

The Internet pages partly use so-called cookies. Cookies do not damage your computer and do not contain viruses. Cookies serve to make our offer more user-friendly, effective and safer. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called „session cookies“. They are automatically deleted at the end of your visit. Other cookies remain stored on your terminal device until you delete them. These cookies enable us to recognize your browser the next time you visit us.

You can set your browser to inform you about the setting of cookies and to allow cookies only in individual cases, to exclude the acceptance of cookies for certain cases or in general and to activate the automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of this website may be limited.

Cookies, which are necessary for the electronic communication process or for the provision of certain functions you require (e.g. shopping basket function), are stored on the basis of Art. 6 Para. 1 lit. f DSGVO. The website operator has a legitimate interest in the storage of cookies for the technically error-free and optimised provision of his services. Insofar as other cookies (e.g. cookies for analysing your surfing behaviour) are stored, these are treated separately in this data protection declaration.

Required

Necessary cookies are strictly required for the proper functioning of the website. These cookies ensure basic functionalities and security features of the website, anonymised.

Cookie	Duration	Description
_wpfuuid	11 years	This cookie is used by the WPForms WordPress plugin. The cookie is used to allow the paid version of the plugin to connect entries from the same user, and is used for some additional features such as the Form Abandonment addon
cookielawinfo-checbox-analytics	11 months	This cookie is set by the GDPR Cookie Consent Plugin. The cookie is used to store the user’s consent for the cookies in the „Analytics“ category.
cookielawinfo-checbox-functional	11 months	The cookie is set by the GDPR cookie consent to store user consent for the cookies in the „Functional“ category.
cookielawinfo-checbox-others	11 months	This cookie is set by the GDPR Cookie Consent plugin. The cookie is used to store user consent for the cookies in the „Other“ category.
cookielawinfo-checkbox-advertisement	1 year	The cookie is set by the GDPR cookie consent to record the user’s consent for the cookies of the category „Advertising“.
cookielawinfo-checkbox-necessary	11 months	This cookie is set by the GDPR Cookie Consent plugin. The cookie is used to store the user’s consent for the cookies in the „Necessary“ category.
cookielawinfo-checkbox-performance	11 months	This cookie is set by the GDPR Cookie Consent plugin. The cookie is used to store the user’s consent for the cookies in the „Performance“ category.
viewed_cookie_policy	11 months	The cookie is set by the GDPR cookie consent plugin and is used to store whether or not the user has consented to the use of cookies. It does not store any personal data.

Functional

Functional cookies help us to perform certain functions such as sharing the content of the website on social media platforms, collecting feedback and other third party functions.

Performance

Performance cookies are used by us to analyse key performance indices of the website. The information is intended to provide a better user experience for visitors.

Analysis

Analytical cookies are used to analyse the user behaviour of visitors to our website. These cookies help provide information about the number of visitors, bounce rates, data sources, etc.

Cookie	Duration	Description
_ga	2 years	This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session and campaign data and to track website usage for the website analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.

View

Advertising cookies are used to provide visitors with appropriate advertising and marketing campaigns. These cookies document visitors‘ usage behaviour on our website and collect the necessary information to offer tailored advertising.

Other

Other uncategorised cookies are those that have not yet been assigned to a specific category but are to be used for our purposes.

Cookie	Duration	Description
_ga_KXX323DK5Q	2 years	No description

COOKIE	DESCRIPTION
Required
cookielawinfo-checkbox-advertisement	The cookie is set by the GDPR cookie consent to record the user’s consent for the cookies of the category „Advertising“.
_wpfuuid	This cookie is used by the WPForms WordPress plugin. The cookie is used to allow the paid version of the plugin to connect entries from the same user, and is used for some additional features such as the Form Abandonment addon
cookielawinfo-checkbox-necessary	This cookie is set by the GDPR Cookie Consent plugin. The cookie is used to store the user’s consent for the cookies in the „Necessary“ category.
cookielawinfo-checbox-functional	The cookie is set by the GDPR cookie consent to store user consent for the cookies in the „Functional“ category.
cookielawinfo-checkbox-performance	This cookie is set by the GDPR Cookie Consent plugin. The cookie is used to store the user’s consent for the cookies in the „Performance“ category.
cookielawinfo-checbox-analytics	This cookie is set by the GDPR Cookie Consent Plugin. The cookie is used to store the user’s consent for the cookies in the „Analytics“ category.
cookielawinfo-checbox-others	This cookie is set by the GDPR Cookie Consent plugin. The cookie is used to store user consent for the cookies in the „Other“ category.
viewed_cookie_policy	The cookie is set by the GDPR cookie consent plugin and is used to store whether or not the user has consented to the use of cookies. It does not store any personal data.
Analysis
_ga	This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session and campaign data and to track website usage for the website analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.
Other
_ga_KXX323DK5Q	No description

II. Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

• 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 not merged with other data sources.

The basis for data processing is Art. 6 para. 1 letter b DSGVO, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.

III. Processing of data (customer and contract data)

We collect, process and use personal data only to the extent that they are necessary for the establishment, content or modification of the legal relationship (inventory data). This is done on the basis of Art. 6 para. 1 lit. b DSGVO, which permits the processing of data for the fulfilment of a contract or pre-contractual measures. We collect, process and use personal data on the use of our Internet pages (usage data) only to the extent necessary to enable or charge the user for the use of the service.

The collected customer data will be deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.

IV. Data transmission upon conclusion of the contract for online shops, traders and dispatch of goods

We only transfer personal data to third parties if this is necessary for the execution of the contract, for example to the companies entrusted with the delivery of the goods or the credit institution commissioned with the handling of payments. A further transmission of the data does not take place or only if you have expressly agreed to the transmission. Your data will not be passed on to third parties without your express consent, for example for advertising purposes.

The basis for data processing is Art. 6 para. 1 letter b DSGVO, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.

V. Data transmission upon conclusion of a contract for services and digital content

We only transfer personal data to third parties if this is necessary for the execution of the contract, for example to the credit institution commissioned with the payment processing.

A further transmission of the data does not take place or only if you have expressly agreed to the transmission. Your data will not be passed on to third parties without your express consent, for example for advertising purposes.

The basis for data processing is Art. 6 para. 1 letter b DSGVO, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.

8. Analysis tools and advertising

I. Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses so-called „cookies“. These are text files which are stored on your computer and which enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there.

The storage of Google Analytics cookies is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in the analysis of user behaviour in order to optimise both his website and his advertising.

II. IP Anonymisation

We have activated the IP anonymization function on this website. This means that your IP address will be truncated by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area before it is transmitted to the USA. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide further services to the website operator in connection with the use of the website and the Internet. The IP address transmitted by your browser within the scope of Google Analytics is not combined with other data from Google.

III. Browser plugin

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

IV. Objection to data collection

You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie is set to prevent the collection of your information on future visits to this site: Disable Google Analytics.

More information on how Google Analytics handles user data can be found in the Google privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

V. Commissioned data processing

We have concluded a contract with Google for commissioned data processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

VI. Google reCAPTCHA

We use „Google reCAPTCHA“ (hereinafter „reCAPTCHA“) on our websites. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA („Google“).

The purpose of reCAPTCHA is to check whether the data input on our websites (e.g. in a contact form) is done by a human being or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of the website visitor on the basis of various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For analysis purposes, reCAPTCHA evaluates various information (e.g. IP address, time spent on the website or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The reCAPTCHA analyses run completely in the background. Website visitors are not notified that an analysis is taking place.

Data processing is carried out on the basis of Art. 6 para. 1 letter f DSGVO. The website operator has a legitimate interest in protecting his web offers from abusive automated spying and from SPAM.

For more information about Google reCAPTCHA and Google’s privacy policy, please see the following links: https://www.google.com/intl/de/policies/privacy/ and https://www.google.com/recaptcha/intro/android.html.

9. Plugins and tools

I. Google Web Fonts

This site uses so-called web fonts, which are provided by Google, for the uniform display of fonts. When you call up a page, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly.

For this purpose, the browser you use must connect to Google’s servers. This enables Google to know that our website has been accessed via your IP address. The use of Google Web Fonts is in the interest of a uniform and attractive presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO.

If your browser does not support web fonts, a default font is used by your computer.

For more information about Google Web Fonts, please visit https://developers.google.com/fonts/faq and Google’s privacy policy: https://www.google.com/policies/privacy/.

II. Google Maps

This site uses the map service Google Maps via an API. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

To use the functions of Google Maps it is necessary to store your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.

The use of Google Maps is in the interest of an attractive presentation of our online offers and easy findability of the locations we have indicated on the website. This represents a legitimate interest in the sense of Art. 6 Para. 1 lit. f DSGVO.

For more information on how we handle user data, please refer to Google’s privacy policy: https://www.google.de/intl/de/policies/privacy/.

10. Privacy notices for online meetings, telephone conferences and web seminars via video conferencing systems

We would like to inform you below about the processing of personal data in connection with the use of video conferencing systems such as „Zoom“, „Teams“ or other tools used.

I. Purpose of the processing

We use video conferencing systems to conduct telephone conferences, online meetings, video conferences, online trainings and/or web seminars (hereinafter: „online meetings“).
We currently use the following tools for this purpose:
„Zoom“ is a service of Zoom Video Communications, Inc. which is based in the USA.
„Teams“ is a system of Microsoft Corporation, One Microsoft Way, based in the USA.

II. Responsible person

The person responsible for data processing directly related to the implementation of „Online Meetings“ is

Cleohpatra UG
Römischer Ring 32
60486 Frankfurt am Main

Note: If you access the website from the provider, the provider is responsible for data processing. However, calling up the website is only necessary for using the online meetings conference systems in order to download the software for their use.

You can also use „Zoom“ if you enter the respective meeting ID and, if applicable, further access data for the meeting directly in the „Zoom“ app.

If you do not want to or cannot use the „Zoom“ app, the basic functions can also be used via a browser version, which you can also find on the „Zoom“ website.

If you do not want to or cannot use the „Microsoft Teams“ app, you can also use „Microsoft Teams“ via your browser. The service will then also be provided via the „Microsoft Teams“ website.

III. What data are processed?

When using the video conferencing systems, various types of data are processed. The scope of the data also depends on the data you provide before or during participation in an „online meeting“. The following personal data are processed:

User details:

• First name, last name
• Telephone (optional)
• E-mail address
• Password (if „Single-Sign-On“ is not used)
• Profile picture (optional)
• Department (optional)

Meeting metadata:

• Topic
• Description (optional)
• Participant IP addresses
• Device/hardware information

For recordings (optional):

• MP4 file of all video, audio and presentation recordings
• M4A file of all audio recordings
• Text file of the online meeting chat

When dialling in with the telephone:

• Incoming and outgoing telephone number information
• Country name
• Start and end time
• If necessary, further connection data such as the IP address of the device can be saved.

Text, audio and video data:

• You may have the option of using the chat, question or survey functions in an „online meeting“. In this respect, the text entries you make are processed in order to display them in the „online meeting“ and, if necessary, to log them.
• To enable the display of video and the playback of audio, data from your terminal’s microphone and any terminal video camera will be processed accordingly for the duration of the meeting.
• You can switch off or mute the camera or microphone yourself at any time via the applications.

In order to participate in an „online meeting“ or to enter the „meeting room“, you must at least provide information about your name.

IV. Scope of the processing

We use the video conferencing systems to conduct „online meetings“. If we want to record „online meetings“, we will inform you transparently in advance and – if necessary – ask for your consent. The fact of the recording will also be displayed to you in the applications.

If it is necessary for the purposes of recording the results of an online meeting, we will record the chat content. However, this will not usually be the case.

In the case of web seminars, we may also process questions asked by webinar participants for the purposes of recording and following up on web seminars.

If you are registered as a user with a video conferencing tool, then reports on „online meetings“ (meeting metadata, telephone dial-in data, questions and answers in web seminars, survey function in web seminars) may be stored for up to at least one month.

Automated decision-making within the meaning of Art. 22 DSGVO is not used.

V. Legal basis for data processing

Insofar as personal data of employees of Cleohpatra UG are processed, § 26 BDSG is the legal basis for data processing.
If, in connection with the use of video conferencing systems, personal data is not required for the establishment, implementation or termination of the employment relationship, but is nevertheless an elementary component of the use of these applications, then Art. 6 para. 1 lit. f) DSGVO is the legal basis for the data processing. In these cases, our interest lies in the effective implementation of „online meetings“.

In addition, the legal basis for data processing when conducting „online meetings“ is Art. 6 para. 1 lit. b) DSGVO, insofar as the meetings are conducted within the framework of contractual relationships.
If there is no contractual relationship, the legal basis is Art. 6 para. 1 lit. f) DSGVO. Here, too, our interest is in the effective conduct of „online meetings“.

VI. Recipients / Disclosure of Data

Personal data processed in connection with participation in „online meetings“ will not be passed on to third parties unless it is intended to be passed on. Please note that the content of online meetings, as well as personal meetings, is often used to communicate information with customers, interested parties or third parties and is therefore intended to be passed on.

Other recipients: The provider of online services necessarily receives knowledge of the above-mentioned data, insofar as this is provided for in the context of our order processing contract with online services.

VII. Data processing outside the European Union

„Zoom“ and „Teams“ are services provided by a provider from the USA. Processing of personal data may therefore also take place in a third country.

We have concluded an order processing contract with the provider that complies with the requirements of Article 28 of the GDPR.

In order to ensure an appropriate level of data protection, we only use the most necessary personal data for the implementation. This also applies to the recording of web seminars as part of our service offering.

VIII. Data Protection Officer

We have appointed a data protection officer.

You can reach him or her as follows:

Cleohpatra UG
Römischer Ring 32
60486 Frankfurt am Main
E-mail: butler@cleohpatra.com

IX. Your rights as a data subject

You have the right to obtain information about the personal data concerning you. You can contact us for information at any time.

In the case of a request for information that is not made in writing, we ask for your understanding that we may require proof from you that you are the person you claim to be.

Furthermore, you have a right to correction or deletion or to restriction of processing, insofar as you are entitled to this by law.

Finally, you have a right to object to processing within the scope of the law. You also have the right to data portability within the framework of data protection law.

X. Deletion of data

We generally delete personal data when there is no need for further storage. A requirement may exist in particular if the data is still needed in order to fulfil contractual services, to check and grant or ward off warranty and, if applicable, guarantee claims. In the case of statutory retention obligations, deletion is only considered after the expiry of the respective retention obligation.

XI. Right of appeal to a supervisory authority

You have the right to complain about the processing of personal data by us to a data protection supervisory authority.

XII. Amendment of this data protection notice

We revise this data protection notice in the event of changes to data processing or other occasions that make this necessary. You will always find the current version on this website.

XIII Further information

Furthermore, you can find information on our data protection guidelines and legal bases on our website. The providers have their own guidelines for the applications used.

Frankfurt, April 2022