Privacy Policy

1) Introduction and contact details of the controller

1.1 We are pleased that you are visiting our website and thank you for your interest. The following provides information on how your personal data is handled when you use our website. Personal data in this context is all data with which you can be personally identified.

1.2 The controller for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Gramke consulting s.r.o., Myslikova 284/32, 12000 Praha 2, Czech Republic, Tel.: 00491703277562, E-mail: gramke@gramke-consulting.de. The controller of personal data processing is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data.

2) Data collection when visiting our website

2.1 When you merely use our website for informational purposes, meaning you do not register or otherwise provide us with information, we only collect data that your browser transmits to the web server (so-called „server log files“). When you access our website, we collect the following data, which is technically necessary for us to display the website to you:

• The website we visited
• Date and time of access
• Amount of data sent in bytes
• Source/Reference from which you reached the page
• Browser used
• Operating system used
• Used IP address (if applicable: in anonymised form)

Processing is carried out in accordance with Article 6(1)(f) of the GDPR, based on our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to retrospectively review the server log files should there be concrete indications of unlawful use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or enquiries to the controller). You can recognise an encrypted connection by the „https://“ string and the padlock icon in your browser bar.

3) Hosting & Content Delivery Network

For the hosting of our website and the display of page content, we utilise a provider that offers its services exclusively on servers within the European Union, either directly or through selected subcontractors.

All data collected on our website will be processed on these servers.

We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.

4) Cookies

To make visiting our website appealing and enable the use of certain features, we use cookies, which are small text files stored on your end device. Some of these cookies are automatically deleted after you close your browser (so-called „session cookies“), while others remain on your end device for longer and enable the saving of page settings (so-called „persistent cookies“). In the latter case, you can see the storage duration in the overview of your web browser's cookie settings.

If personal data is also processed by individual cookies used by us, the processing will be carried out in accordance with Art. 6(1)(b) GDPR in order to fulfil the contract, in accordance with Art. 6(1)(a) GDPR in the event of consent being given, or in accordance with Art. 6(1)(f) GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the site visit.

You can adjust your browser settings to be informed about the setting of cookies and to decide individually on their acceptance, or to exclude the acceptance of cookies for specific cases or in general.

Please note that if you do not accept cookies, the functionality of our website may be restricted.

5) Getting in touch

When you contact us (e.g. via contact form or email), personal data is collected. The data collected when using a contact form is shown on the respective contact form. This data is stored and used solely for the purpose of responding to your enquiry or for contacting you and the associated technical administration.

The legal basis for processing this data is our legitimate interest in responding to your enquiry, in accordance with Article 6(1)(f) of the GDPR. If your contact aims at the conclusion of a contract, the additional legal basis for processing is Article 6(1)(b) of the GDPR. Your data will be deleted upon final processing of your request. This will be the case when it can be inferred from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

6) Registration on the website

You can register on our website by providing personal data. The personal data processed for registration are specified in the input mask used for registration. We use the so-called double opt-in procedure for registration, meaning your registration is only complete once you have confirmed your sign-up via a confirmation email sent to you for this purpose by clicking on the link contained therein. If your confirmation in this regard does not occur within 24 hours, your sign-up will be automatically deleted from our database. Providing the aforementioned data is mandatory. All further information can be provided voluntarily by using our portal.

When you use our portal, we store the data required for contract fulfilment, including any payment method details, until you permanently delete your account. We also store the voluntary data you provide for the duration of your use of the portal, unless you delete it beforehand. You can manage and change all information in the protected customer area. The legal basis is Art. 6(1)(f) GDPR.

In addition, we store all content published by you (such as public posts, wall entries, guestbook entries, etc.) in order to operate the website. We have a legitimate interest in providing the website with the full user-generated content. The legal basis for this is Art. 6(1)(f) GDPR. If you delete your account, your public statements, particularly in the forum, will remain visible to all readers, but your account will no longer be accessible. All other data will be deleted in this case.

7) Commenting function

When using the comment function on this website, in addition to your comment, details of when the comment was created and the commenter name you chose will be stored and published on this website. Furthermore, your IP address will be logged and stored. This IP address storage is for security reasons and in case the person concerned infringes the rights of third parties or posts illegal content through a submitted comment. We require your email address to contact you should a third party object to your published content as being illegal.

The legal basis for storing your data is Art. 6(1)(b) and (f) GDPR. We reserve the right to delete comments that are objected to by third parties as unlawful.

You, as the user, can subscribe to follow-up comments. You will receive a confirmation email for this, to ensure that you are the owner of the specified email address (double opt-in procedure). The legal basis for data processing in the event of subscribing to comments is Art. 6(1)(a) GDPR. You can unsubscribe from ongoing comment subscriptions at any time with effect for the future; for more information on how to unsubscribe, please refer to the confirmation email.

8) Page functionalities

8.1 LinkedIn Plugins

Our website uses plugins from the social network provided by: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland

These plugins allow direct interactions with content on the social network.

To increase the protection of your data when visiting our website, plugins are initially integrated into the page deactivated via a so-called „2-click“ or „Shariff“ solution.

This integration ensures that when a page on our website containing such plugins is called up, no connection is established with the provider's servers.

Only when you activate the plugins and thereby give your consent to data transmission in accordance with Art. 6 (1) (a) GDPR, your browser establishes a direct connection to the provider's servers. In this process, regardless of whether you are logged into an existing user profile, certain information about your end device (including your IP address), your browser, and your browsing history will be transmitted to the provider and potentially processed there.

If you are logged into an existing user profile on the provider's social network, information about interactions via the plugins will also be published there and displayed to your contacts.
You can withdraw your consent at any time by deactivating the activated plugin by clicking on it again. However, the withdrawal will not affect data that has already been transferred to the provider.

Data can also be transferred to: LinkedIn Inc., USA

We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.

For the transfer of data to the USA, the provider refers to standard contractual clauses of the European Commission, which are intended to ensure compliance with the European data protection level.

8.2 YouTube

This website uses plugins to display and play videos from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data may also be transferred to: Google LLC, USA

When you visit a page of our website containing such a plugin, your browser establishes a direct connection to the provider's servers, at the latest when the video is played, in order to load the content. During this process, certain information, including your IP address, is transmitted to the provider.

When the playback of embedded videos is initiated via the plugin, the provider also uses cookies to collect information about user behaviour, generate playback statistics, and prevent abusive behaviour.

If, during your visit to the page, you are logged into a user account with the provider, your data will be directly assigned to your account when you click on a video. If you do not wish for this data to be associated with your account, you must log out before pressing the play button.

All of the aforementioned processing, in particular the setting of cookies for reading information on the device used, only takes place if you have given us your express consent in accordance with Art. 6 (1) lit. a GDPR. You can revoke the consent given at any time with effect for the future by deactivating this service via the „Cookie Consent Tool“ provided on the website.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.

8.3 Google Maps

This website uses an online map service provided by: Google Maps (API) from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”).

Google Maps is a web service for displaying interactive (land) maps in order to visually present geographical information. Using this service will display our location to you and facilitate any journey.

Even when you access those sub-pages where the Google Maps map is integrated, information about your use of our website (such as your IP address) is transmitted to Google's servers and stored there. This may also involve transmission to the servers of Google LLC in the USA. This occurs regardless of whether Google provides a user account that you are logged into or whether a user account exists. If you are logged into Google, your data will be assigned directly to your account. If you do not wish to be associated with your Google profile, you must log out before activating the button. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them.

The collection, storage, and analysis are carried out in accordance with Art. 6 sec. 1 lit. f GDPR on the basis of Google's legitimate interest in the display of personalised advertising, market research and/or the need-based design of Google websites. You have the right to object to the creation of these user profiles, and must contact Google to exercise it. If you do not agree with the future transfer of your data to Google within the scope of using Google Maps, there is also the option of completely deactivating the Google Maps web service by deactivating the JavaScript application in your browser. Google Maps and thus also the map display on this website cannot then be used.

Where legally required, we have obtained your consent for the processing of your data described above in accordance with Art. 6(1)(a) GDPR. You can withdraw your consent at any time with effect for the future. To exercise your right of withdrawal, please follow the procedure described above for lodging an objection.

For data transfers to the USA, the provider has acceded to the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision of the European Commission.

Further information on data protection at Google can be found here. https://business.safety.google/intlI am unable to fulfill this request./privacy/

8.4 Google Web Fonts

This page uses web fonts from the following provider for consistent font display: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

When a page is loaded, your browser downloads the required web fonts into its browser cache to display text and fonts correctly, and establishes a direct connection to the provider's servers. In doing so, certain browser information, including your IP address, is transmitted to the provider.

Data can also be transmitted to: Google LLC, USA

The processing of personal data in connection with establishing contact with the font provider will only be carried out if you have given us your express consent in accordance with Art. 6 (1) (a) GDPR. You can revoke your consent at any time with future effect by deactivating this service via the „Cookie Consent Tool“ provided on the website. If your browser does not support web fonts, a standard font from your computer will be used.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.

Further details on Google's data protection regulations can be found here: https://business.safety.google/intlI am unable to fulfill this request./privacy/

8.5 Google reCAPTCHA

On this website, we use the CAPTCHA service of the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

Data may also be transmitted to: Google LLC, USA.

For the visual design of the captcha window, Google Fonts, which are fonts loaded from the internet by Google, are used. No further information beyond the above-mentioned, which is already transmitted to Google via the functionality of ReCaptcha, is processed.

The service checks whether input is made by a natural person or abusively by machine and automated processing, and blocks spam, DDoS attacks, and similar automated malicious access. To ensure that an action is taken by a human and not an automated bot, the provider collects the IP address of the end device used, detection data of the type of browser and operating system used, as well as the date and duration of the visit, and transmits this to the provider’s servers for evaluation. Cookies, which are small text files stored in the end device’s browser, may be used for this purpose.

If the processing described above is based on cookies, these will only be set if you have given us your explicit consent in accordance with Art. 6 (1) lit. a GDPR. You can withdraw your consent at any time with effect for the future by deactivating this service in the „Cookie Consent Tool“ provided on the website.

If the processing described above is carried out without the use of cookies, the legal basis is our legitimate interest in determining individual responsibility on the internet and preventing abuse and spam ​​in accordance with Art. 6 (1) (f) GDPR.

We have concluded a contract processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.

8.6 Google Customer Reviews (formerly Google Trusted Stores programme)

We are collaborating with Google as part of the „Google Customer Reviews“ programme. The provider is Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). This programme gives us the opportunity to collect customer reviews from users of our website. After a purchase on our website, you will be asked if you would like to participate in an email survey from Google.

By giving your consent under Art. 6 Para. 1 lit. a GDPR, we will transmit your email address to Google. You will receive an email from Google Customer Reviews asking you to rate your purchasing experience on our website. The rating you provide will then be aggregated with our other ratings and displayed in our Google Customer Reviews logo and in our Merchant Center dashboard. Your rating will also be used for Google seller ratings. As part of the use of Google Customer Reviews, personal data may also be transferred to the servers of Google LLC. in the USA.

You can revoke your consent at any time by sending a message to the data controller or to Google.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.

Further details on Google's data protection regulations can be found here: https://business.safety.google/intlI am unable to fulfill this request./privacy/

8.7 Microsoft Teams

For conducting online meetings, video conferences and/or webinars, we use this provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA

The provider processes different data, with the scope of the processed data depending on what data you share before or during participation in an online meeting, video conference or webinar. Your data will be processed as a communication participant and stored on the provider's servers. This may particularly include your login details (name, e-mail address, telephone number (optional) and password) and session data (topic, participant IP address, device information, description (optional)).

In addition, image and audio contributions from participants, as well as voice inputs in chats, can be processed.
For the processing of personal data that is necessary for the performance of a contract with you (this also applies to processing operations that are necessary for the performance of pre-contractual measures), Article 6(1)(b) of the GDPR serves as the legal basis. Where you have given us consent to process your data, the processing is based on Article 6(1)(a) of the GDPR. You can withdraw any consent given at any time with effect for the future.
Moreover, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR in the effective conducting of the online meeting, webinar or video conference.

We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.

9) Tools and Miscellaneous

Cookie Consent Tool

This website uses a „Cookie Consent Tool“ to obtain effective user consent for cookies and cookie-based applications requiring consent. The „Cookie Consent Tool“ is displayed to users upon page load in the form of an interactive interface, where consent for specific cookies and/or cookie-based applications can be granted by ticking boxes. By using this tool, all cookies/services requiring consent are only loaded if the respective user has granted the appropriate consent by ticking the boxes. This ensures that such cookies are only set on the respective user's end device if consent has been granted.

The tool uses technically necessary cookies to save your cookie preferences. Personal user data is not processed in this regard.

In individual cases, if personal data (such as the IP address) are processed for the purpose of storing, assigning, or logging cookie settings, this takes place in accordance with Art. 6(1)(f) GDPR on the basis of our legitimate interest in a legally compliant, user-specific, and user-friendly consent management for cookies, and thus in a legally compliant design of our website.

The further legal basis for processing is also Article 6(1)(c) GDPR. As controllers, we are subject to the legal obligation to make the use of technically non-essential cookies dependent on the respective user consent.

Where necessary, we have concluded a contract processing agreement with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorised disclosure to third parties.

Further information on the operator and the settings options for the cookie consent tool can be found directly in the relevant user interface on our website.

10) Data Subject Rights

10.1 The applicable data protection law grants you the following data subject rights (rights of access and intervention) in relation to the controller regarding the processing of your personal data, with reference to the legal basis specified for the respective exercise requirements:

• Right of access under Article 15 GDPR;
• Right to rectification pursuant to Article 16 GDPR;
• Right to erasure pursuant to Article 17 GDPR;
• Right to restriction of processing under Article 18 GDPR.;
• Right to information in accordance with Article 19 GDPR;
• Right to data portability pursuant to Article 20 GDPR;
• Right to revoke consent given in accordance with Art. 7 para. 3 GDPR;
• Right to lodge a complaint under Art. 77 GDPR.

10.2 RIGHT TO OBJECT

If we process your personal data as part of balancing interests due to our overriding legitimate interest, you have the right to object to this processing at any time, on grounds relating to your particular situation, with effect for the future.

EXERCISE YOUR RIGHT TO OBJECT, WE WILL CEASE PROCESSING THE RELEVANT DATA. HOWEVER, FURTHER PROCESSING IS RESERVED IF WE CAN DEMONSTRATE COMPELLING GROUNDS FOR PROCESSING WHICH OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS.

If your personal data is processed by us for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such advertising. You can exercise your right of objection as described above.

Should you exercise your right to object, we will cease processing the relevant data for direct marketing purposes.

11) Duration of personal data storage

The duration of the storage of personal data is determined by the respective legal basis, the purpose of processing, and – where applicable – additionally by the respective statutory retention periods (e.g. commercial and tax law retention periods).

When processing personal data based on explicit consent in accordance with Art. 6(1)(a) GDPR, the affected data will be stored until you withdraw your consent.

Are there statutory retention periods for data processed within the scope of legal transactions or legal transaction-like obligations based on Art. 6(1)(b) GDPR, and is this data routinely deleted after the expiry of the retention periods, provided it is no longer required for contract fulfilment or initiation and/or we no longer have a legitimate interest in its further storage?.

When processing personal data based on Article 6(1)(f) GDPR, this data will be stored for as long as you exercise your right to object under Article 21(1) GDPR, unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defence of legal claims.

When processing personal data for direct marketing purposes based on Article 6(1)(f) of the GDPR, this data will be stored until you exercise your right to object under Article 21(2) of the GDPR.

Unless otherwise indicated by other information in this declaration on specific processing situations, stored personal data will otherwise be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.