PRIVACY POLICY


Effective Date: May 14, 2018

Thanks for visiting CHRISTIAN KURTZKE CONSULTANCY GMBH! CHRISTIAN KURTZKE CONSULTANCY GMBH (“CKC”, “we”, “us” or “our”) respects your privacy. When it comes to your personal information, we believe in transparency, not surprises. That’s why we’ve set out here what personal information we collect, what we do with it and your choices and rights.

By using CKC´s website and/or services, you confirm you have read and understood this Privacy Policy and our Cookie Policy.

1. Some key terms

In our Privacy Policy, when we refer to “Users”, we mean visitors to our site.  


2. How does this Privacy Policy apply?

This Privacy Policy describes what we do with personal information that we collect.

We use cookies and similar technologies. Our Cookie Policy describes what we do in that regard.  

Please also read our Data Processing Addendum to learn more about how we process User Content.


3. Personal information we collect

We collect various personal information regarding you or your device. This includes the following:

  • Information you provide when editing a contact form, specifically email address, first name and last name, as well as your contact details.

  • The emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. 

  • Information from your use of the sites. This includes: IP addresses, preferences, web pages you visited prior to coming to our or our site, information about your browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the our site (such as timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors).

  • Information we get from our partners to support our marketing initiatives, improve our Services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.

  • Other information you submit to us directly.
     

4. How we collect personal information

We obtain personal information from various sources. We do this in three main ways:

  • You provide some of it directly (such as by filling in a form, by sending a direct mail or by calling us).

  • We record some of it automatically when you use our sites (including with technologies like cookies - see cookie policy above.).

  • We receive some of it from third parties (like when you register for an account using a Third Party Service or when you make payments to us using our payment processor).

We’ve described this in more detail below.

a. Personal information you provide

When you use our Services, we collect information from you in a number of ways.  For instance, we ask you to provide your name and email address when filling in the contact form. We also maintain the emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts. You might also provide us with information in other ways, including by responding to surveys, submitting a form or participating in contests or similar promotions.

Sometimes we require you to provide us with information for contractual or legal reasons. We’ll normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the service or if we are legally required to collect it.

b. Personal information obtained from your use of our Services

When you use our Services, we collect information about your activity on and interaction with the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our sites, what pages on our sites you visit and for how long and identifiers associated with your devices. If you’ve given us permission through your device settings, we may collect your location information in our mobile apps.

We also get information about your interactions with their sites, though we use this in anonymous, aggregated or pseudonymized form which does not focus on you individually. We use this data to evaluate, provide, protect or improve our Services (including by developing new products and services).

Some of this information is collected automatically using cookies and similar technologies when you use our site. We let our Users control what cookies and similar technologies are used through their sites (except those we need to use to provide the Services properly, such as for performance or security related reasons). You can read more about our use of cookies in our Cookie Policy. Some of this information is similarly collected automatically through your browser or from your device.

c. Personal information obtained from other sources

If you use a Third Party Service (such as Google) or automated browser form filling, the Third Party Service may provide us with your Third Party Service account information on your behalf, such as your name and email address (we don’t store passwords you use to access Third Party Services). Your privacy settings on the Third Party Service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the Third Party Service.

5. How we use your personal information

We use the personal information we obtain about you to:

  • Provision of the Services. Provide and personalize our Services, and respond to your inquiries.

  • Communicating with you. Communicate with you, including by sending you emails about your requests and Service-related announcements.

  • Customizing the Services. Provide you with customized services. For example, we use your location information to determine your language preferences or display accurate date and time information. We also use cookies and similar technologies for this purpose, such as remembering which of Your Sites you most recently edited.

  • Improving our Services. Analyze and learn about how the Services are accessed and used, evaluate and improve our Services (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually. For example, if we learn that most Users of Paid Services use a particular integration or feature, we might wish to expand on that integration or feature.

  • Security. Ensure the security and integrity of our Services.

  • Third party relationships. Manage our vendor and partner relationships.

  • Enforcement. Enforce our Terms of Service and other legal terms and policies.

  • Protection. Protect our and others’ interests, rights and property (e.g., to protect our Users from abuse).

  • Complying with law. Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts and law enforcement requests.

We process your personal information for the above purposes when:

  • Consent. You have consented to the use of your personal information in a particular way. When you consent, you can change your mind at any time.  

  • Performance of a contract. We need your personal information to provide you with services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. 

  • Legal obligation. We have a legal obligation to use your personal information, such as to comply with applicable tax and other government regulations or to comply with a court order or binding law enforcement request.

  • Legitimate interests. We have a legitimate interest in using your personal information. In particular, we have a legitimate interest in the following cases:

    • To operate the CKC business

    • To analyze and improve the safety and security of our Services - we do this as it is necessary to pursue our legitimate interests in ensuring our website is secure, such as by implementing and enhancing security measures and protections and protecting against fraud, spam and abuse.

    • To provide and improve the Services, including any personalized services - we do this as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Users on a sustained basis.

    • To anonymize and subsequently use anonymized information.

  • Protecting you and others. To protect your vital interests, or those of others. 

  • Others’ legitimate interests. Where necessary for the purposes of a third party’s legitimate interests, such as our partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness or our Users who have a legitimate interest in having their sites function properly and securely and analyzing the usage of their sites so they can understand trends and improve their services.  

6. How we share your personal information

We share personal information in the following ways:

  • Users.  We rely on third-party services for gaining data regarding usage by Users of our site. For example, we gather information on about what web page the User visited before coming to their site and how the Users interacted with our site. This is so we can analyze the usage of our site and improve our services-

  • Service providers. We share personal information with our service providers that perform services on our behalf. For example, we may use third parties to help us provide customer support, manage our advertisements on other sites, send marketing and other communications on our behalf or assist with data storage.  

  • Following the law or protecting rights and interests. We disclose your personal information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests for prevent fraud or abuse or our Users. In particular, we may disclose your personal information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.

  • Business transfers. If we're involved in a reorganization, merger, acquisition or sale of some or all of our assets, your personal information may be transferred as part of that deal.

7. Your rights and choices

Where applicable law requires (and subject to any relevant exceptions under law), you may have the right to access, update, change or delete personal information.

You can access, update, change or delete personal information by contacting us at info@christiankurtzke.com to request the required changes. You can exercise your other rights (including deleting your data records) by contacting us at the same email address.

Please note that, for technical reasons, there is likely to be a delay in deleting your personal Information from our systems when you ask us to delete it. We also will retain personal Information in order to comply with the law, protect our and others’ rights, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.

You may have the right to restrict or object to the processing of your personal information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. Additionally, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

Our Cookie Policy explains how you can manage cookies and similar technologies.

8. How we protect your personal information

We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. We employ security measures such as using firewalls to protect against intruders.

9. How we retain your personal information

We retain personal information regarding you or your use of the Services for as long as needed to provide you or our Users with the Services. We also retain personal information for as long as necessary to achieve the purposes described in this Privacy Policy, for example, to comply with our legal obligations, to protect us in the event of disputes and to enforce our agreements and to protect our and others’ interests.  

The precise periods for which we keep your personal information vary depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. 

Please note that in the course of providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.

10. Data transfers

Personal information that you submit through the site may be transferred to countries other than where you live, such as, for example, to servers in the U.S. The third party services provides that we use also store personal information locally on the devices you use to access the Services.

Your personal information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.

We rely upon a number of means to transfer personal information which is subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR.  These include:

  • Privacy Shield. Transfers are executed, in accordance with Article 45 of the GDPR, personal information to companies that have certified their compliance with the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks (each individually and jointly, the “Privacy Shield”), including CHRISTIAN KURTZKE CONSULTANCY GMBH.

  • Standard data protection clauses. We may, in accordance with Article 46 of the GDPR, transfer personal information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area.  

  • Other means. We may, in accordance with Articles 45 and 46 of the GDPR, transfer personal information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.

11. Privacy Shield

CKC is committed to treating personal information received from the European Economic Area and Switzerland pursuant to the Privacy Shield Frameworks in accordance with the applicable Principles. You can learn more about the Frameworks and Principles by visiting https://www.privacyshield.gov/.

Our accountability for personal information we receive under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, we may use third parties to process data on our behalf as described in this Privacy Policy, and we remain liable if they do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

If you have a question or complaint you believe to be within the scope of our Privacy Shield, please contact us first at info@christiankurtzke.com, or using the contact details in the “Contact us” section. We'll respond within 45 days.

12. Updates to this Privacy Policy

We’ll update this Privacy Policy from time to time to reflect changes in technology, law, our business operations or any other reason we determine is necessary or appropriate. When we make changes, we’ll update the “Effective Date” at the top of the Privacy Policy and post it on our sites. If we make material changes to it or the ways we process personal information, we’ll notify you (by, for example, prominently posting a notice of the changes on our sites before they take effect or directly sending you a notification).

We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit.  This will help ensure you better understand your relationship with us, including the ways we process your personal information.

13. Who is CKC?

When we say “CKC” (or “we”, “us” or “our”), we mean: (a) CHRISTIAN KURTZKE CONSULTANCY GMBH. 

14. How to contact us

If you have questions, comments or complaints about this Privacy Policy or our privacy practices or if you would like to exercise your rights and choices, please email us at info@christiankurtzke.com, or write to us at the addresses below:

 

CHRISTIAN KURTZKE CONSULTANCY GMBH
ATTN: PRIVACY
KOENIG-KARL-STRASSE 44
70372 STUTTGART
GERMANY