Data protection
Preamble
With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “Online Offer”).
The terms used are not gender-specific.
Status: 8 June 2023
Table of contents
– Preamble
– Person responsible
– Contact Data Protection Officer
– Overview of processing operations
– Relevant legal basis
– Security measures
– Transfer of personal data
– Data processing in third countries
– Deletion of data
– Use of cookies
– Fulfilment of tasks according to statutes or rules of procedure
– Provision of the online offer and web hosting
– Registration, login and user account
– Community functions
– Contact and enquiry management
– Presence in social networks (social media)
– Amendment and updating of the data protection declaration
– Rights of data subjects
– Definitions of terms
Person responsible
Huberta von Voss
Institute for Strategic Dialogue gGmbH
PO Box 80647
10006 Berlin
Authorised representatives:
Huberta von Voss
E-mail address:
Contact data protection officer
Overview of processing operations
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
– Inventory data.
– Payment data.
– Contact data.
– Content data.
– Contract data.
– Usage data.
– Meta, communication and procedural data.
Categories of data subjects
– Communication partners.
– Users.
– Members.
– Business and contractual partners.
Purposes of processing
– Provision of contractual services and customer service.
– Contact requests and communication.
– Security measures.
– Managing and responding to enquiries.
– Feedback.
– Marketing.
– Provision of our online services and user experience.
– Information technology infrastructure.
Relevant legal basis
Below you will find an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.
– Consent (Art. 6 (1) p. 1 lit. a) GDPR) – The data subject has given consent to the processing of personal data relating to him or her for a specific purpose or purposes.
– Performance of a contract and pre-contractual enquiries (Art. 6(1)(b) DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject’s request.
– Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission as well as automated decision-making in individual cases including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Security measures
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
TLS encryption (https): In order to protect your data transmitted via our online offer, we use TLS encryption. You can recognise such encrypted connections by the prefix https:// in the address line of your browser.
Transmission of personal data
In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
Data transfer within the organisation: We may transfer personal data to other bodies within our organisation or grant them access to this data. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate business and operational interests or is made where it is necessary for the performance of our contract-related obligations or where we have obtained the consent of the data subjects or legal permission.
Data processing in third countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, entities or companies, this will only be done in accordance with legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not necessary for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is required for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Our privacy notices may also contain further information on the retention and deletion of data, which will take precedence for the respective processing operations.
Use of cookies
Cookies are small text files or other storage devices that store information on end devices and read information from the end devices. For example, to save the login status in a user account, the contents of a shopping basket in an e-shop, the contents called up or the functions used in an online offer. Cookies can further be used for various purposes, e.g. for purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.
Notes on consent: We use cookies in accordance with legal requirements. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service (i.e. our online offer) that they have expressly requested. Cookies that are strictly necessary usually include cookies with functions that serve the display and operability of the online offer, load balancing, security, storage of users’ preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offer requested by users. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.
Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the aid of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. The purposes for which the cookies are processed by us are explained in the course of this privacy policy or as part of our consent and processing procedures.
Storage duration: With regard to the storage duration, the following types of cookies are distinguished:
– Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g. browser or mobile app).
– Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
– Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Further notes on processing processes, procedures and services:
– Processing of cookie data based on consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or to the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. In this case, a pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).
Fulfilment of tasks according to statutes or rules of procedure
We process the data of our members, supporters, interested parties, business partners or other persons (collectively “data subjects”) if we have a membership or other business relationship with them and perform our tasks and are recipients of services and benefits. In addition, we process the data of data subjects on the basis of our legitimate interests, e.g. when it concerns administrative tasks or public relations work.
The data processed in this way, the nature, scope and purpose of the data and the necessity of its processing are determined by the underlying membership or contractual relationship, from which the necessity of any data disclosures also arises (in other respects we refer to required data).
We delete data that is no longer required to fulfil our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. We retain the data for as long as they may be relevant for the transaction of business, as well as with regard to any warranty or liability obligations based on our legitimate interest in regulating them. The necessity of retaining the data is reviewed regularly; in all other respects, the statutory retention obligations apply.
– Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. subject matter of contract, term, customer category).
– Data subjects: Users (e.g. website visitors, users of online services); members; business and contractual partners.
– Purposes of processing: provision of contractual services and customer service; contact requests and communication; administration and response to requests.
– Legal grounds: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Provision of the online offer and web hosting
We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.
– Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status); content data (e.g. entries in online forms).
– Data subjects: Users (e.g. website visitors, users of online services).
– Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures.
– Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further information on processing processes, procedures and services:
– Provision of online offer on rented storage space: for the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as “web hoster”); legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
– Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilisation of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
– WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offerings; service provider: Aut O’Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://wordpress.com; Privacy policy: https://automattic.com/de/privacy/; Order processing agreement: https://wordpress.com/support/data-processing-agreements/.
Registration, login and user account
Users can create a user account. In the course of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfilment. The processed data includes in particular the login information (user name, password and an e-mail address).
Within the scope of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. As a matter of principle, this data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by e-mail about events relevant to their user account, such as technical changes.
– Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
– Data subjects: Users (e.g. website visitors, users of online services).
– Purposes of processing: provision of contractual services and customer service; security measures; administration and response to enquiries; provision of our online offer and user-friendliness.
– Legal grounds: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing operations, procedures and services:
– Users’ profiles are not public: Users’ profiles are not publicly visible or accessible.
– Deletion of data after termination: If users have terminated their user account, their data with regard to the user account will be deleted, subject to legal permission, obligation or consent of the users; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
– No obligation to retain data: It is the users’ responsibility to save their data in the event of termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Community functions
The community functions provided by us allow users to enter into conversations or other exchanges with each other. In this regard, we ask you to note that the use of the community functions is only permitted in compliance with the applicable legal situation, our terms and guidelines and the rights of other users and third parties.
– Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
– Data subjects: Users (e.g. website visitors, users of online services).
– Purposes of processing: provision of contractual services and customer service; security measures.
– Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further guidance on processing operations, procedures and services:
– Storage of data for security purposes: The contributions and other input of users are processed for the purposes of the community and conversation functions and, subject to legal obligations or legal permission, are not released to third parties. An obligation to surrender may arise in particular in the case of illegal contributions for the purposes of legal prosecution. We would like to point out that, in addition to the content of the contributions, their time and the IP address of the user are also stored. This is done in order to be able to take appropriate measures to protect other users and the community; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
– Right to delete content and information: The deletion of contributions, content or information of users is permissible to the extent necessary after proper consideration insofar as there are concrete indications that they represent a violation of legal regulations, our specifications or the rights of third parties; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
– Protection of own data: Users themselves decide what data they disclose about themselves within our online offering. For example, when users provide personal information or participate in conversations. We ask users to protect their data and to publish personal data only with caution and only to the extent necessary. In particular, we ask users to take special care to protect their access data and to use secure passwords (i.e. especially character combinations that are as long and random as possible); legal basis: performance of contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Contact and enquiry management
When contacting us (e.g. by post, contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any measures requested.
– Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
– Data subjects: Communication partners.
– Purposes of processing: contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.
– Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).
Further notes on processing processes, procedures and services:
– Contact form: If users contact us via our contact form, email or other communication channels, we process the data communicated to us in this context to process the communicated request; legal basis: contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
– Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
– Data subjects: Users (e.g. website visitors, users of online services).
– Purposes of processing: Contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
– Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Amendment and updating of the data protection declaration
We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.
Rights of data subjects
As a data subject, you have various rights under the GDPR, in particular as set out in Articles 15 to 21 of the GDPR:
– Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
– Right to withdraw consent: You have the right to revoke any consent given at any time.
– Right to information: You have the right to request confirmation as to whether 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 the legal requirements.
– Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
– Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with the law.
– Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another person responsible.
– Complaint to the supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the requirements of the GDPR.
Definitions
This section provides you with an overview of the terms used in this Privacy Notice. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
– Personal data: “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. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
– Controller: “Controller” means 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.
– Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission or deletion.
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