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1. Introduction and contact details of the responsible party

1.1 We are pleased that you are visiting our website and thank you for your interest. Below, we inform you about how we handle your personal data when you use our website. Personal data is any data that can be used to personally identify you.

1.2 The data controller for this website within the meaning of the General Data Protection Regulation (GDPR) is Hermela Solomon, SOHL Insights, Meerfeldstr. 11, 68163 Mannheim, Germany, Tel.: +49 175 7002428, Email: hermela.solomon@web.de. The data controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data.

2. Data collection when visiting our website

2.1 When you use our website for purely informational purposes, i.e., if you do not register or otherwise provide us with information, we only collect data that your browser transmits to the website 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:

- Our visited website

- Date and time of access

- Amount of data sent in bytes - Source/referrer from which you accessed the page

- Browser used - Operating system used

- IP address used (possibly in anonymized form)

The processing is carried out in accordance with Article 6(1)(f) GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be disclosed or used for any other purpose. However, we reserve the right to subsequently 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 inquiries to us). You can recognize an encrypted connection by the "https://" prefix and the padlock symbol in your browser's address bar.

3. Cookies

To make your visit to our website more enjoyable and to enable the use of certain features, we use cookies, which are small text files that are stored on your device. Some of these cookies are automatically deleted after you close your browser (so-called "session cookies"), while others remain on your device for a longer period and allow us to save your website settings (so-called "persistent cookies"). In the latter case, you can find information about the storage duration in your web browser's cookie settings.

If any of the cookies we use process personal data, this processing is carried out in accordance with Art. 6 para. 1 lit. b GDPR either for the performance of the contract, in accordance with Art. 6 para. 1 lit. a GDPR in the case of consent given, or in accordance with Art. 6 para. 1 lit. f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the website visit.

You can configure your browser to notify you when cookies are set and allow you to decide whether to accept them individually, or to block cookies in certain cases or entirely.

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

4. Making contact

4.1 Wix Bookings/Wix Events For the provision of an online appointment booking function, we use the services of the following provider: Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo, Israel

Data will also be transferred to: Wix Inc., 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA.

For the purpose of scheduling appointments, your first and last name, email address (and, if applicable, your telephone number if you request a telephone appointment) will be collected in accordance with Article 6 Paragraph 1 Letter b of the GDPR and transmitted to the provider in accordance with Article 6 Paragraph 1 Letter f of the GDPR based on our legitimate interest in effective customer management and efficient appointment scheduling. This data will be stored by the provider for appointment organization purposes. Your data will be deleted by the provider after the appointment has taken place or after the agreed appointment period has expired.

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

When data is transferred to the provider's location, an adequate level of data protection is ensured by an adequacy decision of the European Commission. For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision of the European Commission, ensures compliance with the European level of data protection.

4.2 When you contact us (e.g. via contact form or email), personal data will be processed – exclusively for the purpose of processing and responding to your request and only to the extent necessary.

The legal basis for processing this data is our legitimate interest in responding to your inquiry, pursuant to Article 6(1)(f) GDPR. If your contact is aimed at a contract, the additional legal basis for processing is Article 6(1)(b) GDPR. Your data will be deleted when it is clear from the circumstances that the matter has been resolved and provided that no statutory retention obligations apply.

5. Data processing when opening a customer account

In accordance with Article 6(1)(b) GDPR, personal data will continue to be collected and processed to the extent necessary if you provide it to us when opening a customer account. You can find out which data is required for account opening in the input fields of the corresponding form on our website.

You can delete your customer account at any time by sending a message to the above address of the data controller. After your customer account is deleted, your data will be deleted provided that all contracts concluded through it have been fully processed, no statutory retention periods apply, and we have no legitimate interest in continuing to store it.

6. Data processing for order fulfillment

6.1 To the extent necessary for the performance of the contract for delivery and payment purposes, the personal data we collect will be disclosed to the contracted shipping company and the contracted financial institution in accordance with Article 6(1)(b) of the GDPR.

 

If we are obligated to provide you with updates for goods containing digital elements or for digital products based on a corresponding contract, we will process the contact information you provided when placing your order (name, address, email address) to personally inform you, within the scope of our legal information obligations pursuant to Art. 6(1)(c) GDPR, via an appropriate communication channel (such as by mail or email) about upcoming updates within the period prescribed by law. Your contact details will be used strictly for the specific purpose of communicating updates we are obligated to provide and will be processed by us for this purpose only to the extent necessary for the respective information.

 

To process your order, we also work with the following service provider(s), who assist us in whole or in part with the execution of concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information.

 

6.2 Use of Payment Service Providers

 

- Wix Payments

 

One or more online payment methods from the following provider are available on this website: Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo, Israel

 

If you select a payment method from this provider that requires you to make an advance payment (such as credit card payment), your payment details provided during the ordering process (including name, address, bank and payment card information, currency, and transaction number) as well as information regarding the contents of your order will be transferred to the provider in accordance with Art. 6(1)(b) GDPR. In this case, your data is transferred exclusively for the purpose of processing payment with the provider and only to the extent necessary for this purpose.

 

As part of the aforementioned services, data may also be transferred through further processing on behalf of Wix Inc., 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA.

 

When data is transferred to the provider’s location, an adequate level of data protection is ensured by an adequacy decision of the European Commission.

 

For the transfer of data to the USA, the provider relies on the European Commission’s Standard Contractual Clauses, which are intended to ensure compliance with European data protection standards.

 

6.3 Electronic Termination Option for Continuing Contracts with Consumers

 

Consumers who have entered into contracts for fee-based continuing contracts (such as subscription contracts) on this website have the option to terminate these contracts via an electronic button in accordance with the applicable notice periods.

 

Clicking the button leads to a confirmation page where the consumer can provide further details regarding the termination, clearly identify themselves, and subsequently submit their notice of termination electronically.

 

The collection of personal data and its transmission to us in this context is carried out in accordance with Art. 6(1)(b) GDPR and only to the extent necessary for the proper processing of the termination. Also based on Article 6(1)(b) of the GDPR, the personal data provided is used to confirm receipt of the notice of termination and the effective date of termination electronically in text form. A further legal basis for the processing is Article 6(1)(c) of the GDPR. We are legally obligated to provide an electronic termination option for consumer contracts concluded via electronic commerce that involve ongoing contractual relationships subject to fees.

7. Web analytics services

Wix Analytics

This website uses the web analytics service of the following provider: Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo, Israel.

Using cookies and/or similar technologies (tracking pixels, web beacons, algorithms for reading device and browser information), this service collects and stores pseudonymized visitor data, including information about the device used, such as the IP address and browser information, in order to evaluate it for statistical analysis of user behavior on our website and to create pseudonymized user profiles. Among other things, this enables the analysis of movement patterns (so-called heatmaps), which show the duration of page visits and interactions with page content (e.g., text input, scrolling, clicks, and mouse-overs). Pseudonymization fundamentally prevents any direct identification of individuals. This data is not combined with clear personal data collected through other means.

All processing described above, in particular the reading or storage of information on your device, will only be carried out if you have given us your explicit consent in accordance with Article 6(1)(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.

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

When data is transferred to the provider's location, an adequate level of data protection is ensured by an adequacy decision of the European Commission.

8. Page functionalities

8.1 Google Customer Reviews (formerly the Google Certified Merchant Program)

 

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

 

If you give your consent in accordance with Art. 6(1)(a) GDPR, we will transmit your email address to Google. You will receive an email from Google Customer Reviews asking you to rate your shopping experience on our website. The review you submit will then be aggregated with our other reviews and displayed in our Google Customer Reviews logo as well as in our Merchant Center dashboard. Additionally, your review will be used for Google Merchant Reviews. As part of the use of Google Customer Reviews, personal data may also be transferred to the servers of Google LLC in the United States.

 

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

 

For data transfers to the U.S., the provider has joined the EU-U.S. Data Privacy Framework, which ensures compliance with European data protection standards based on an adequacy decision by the European Commission. Further information on Google’s privacy policy can be found here: https://business.safety.google/intl/de/privacy/

 

8.2 Ecosero

 

We use this provider to conduct online meetings, video conferences, and/or webinars: Bilduin GmbH, Wilhelmstraße 92, 13593 Berlin, Germany

 

The provider processes various types of data, with the scope of the processed data depending on what information you provide before or during your participation in an online meeting, video conference, or webinar. Your data is processed as a communication participant and stored on the provider’s servers. This may include, in particular, your login details (name, email address, phone number (optional), and password) and session data (topic, participant IP address, device information, description (optional)).

 

In addition, participants’ video and audio contributions as well as text entries in chats may be processed. Article 6(1)(b) of the GDPR serves as the legal basis for the processing of personal data necessary for the performance of a contract with you (this also applies to processing operations necessary for the implementation of pre-contractual measures). To the extent that you have given us consent to process your data, the processing is based on Article 6(1)(a) of the GDPR.

You may revoke any consent you have given at any time with future effect. Furthermore, the legal basis for data processing during the conduct of online meetings, video conferences, or webinars is our legitimate interest pursuant to Article 6(1)(f) of the GDPR in the effective conduct of the online meeting, webinar, or video conference.

 

We have entered into a data processing agreement with the provider that ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.

 

8.3 Microsoft Forms

We use the services of the following provider to conduct surveys or for online forms:

Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA, and Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland (as the responsible provider for the European Economic Area).

Microsoft Forms enables us to create, design, and evaluate online surveys and forms. In addition to the personal data you enter directly into the forms, information about your operating system, browser, date and time of your visit, referrer URL, and your IP address is also collected and transmitted to Microsoft as part of your use of the service. Form data is stored within the Microsoft 365 infrastructure provided by Microsoft, which is regularly made available to European users via servers in the EU or the EEA.

 

The data you enter is stored exclusively in a password-protected manner, thereby preventing unauthorized access by third parties. Only we can view the data and evaluate it exclusively for the purpose specified in the respective form.

The legal basis for processing is Article 6(1)(b) of the GDPR, provided that the processing is necessary for the performance of a contract or for the implementation of pre-contractual measures. If you have given us your consent to process your data, the processing is based on Article 6(1)(a) of the GDPR. You may revoke any consent you have given at any time with future effect.

We have entered into a Data Processing Agreement (DPA) with Microsoft, which ensures that the personal data of our website visitors is protected and not disclosed to third parties without authorization. In the event of data transfers to third countries, Microsoft ensures an adequate level of data protection within the framework of the EU Standard Contractual Clauses and supplementary security measures.

9. Tools and other items

9.1 - Lexware Office

For our accounting, we use the cloud-based accounting software service of the following provider: Haufe-Lexware GmbH & Co. KG, Munzinger Straße 9, 79111 Freiburg, Germany

We process incoming and outgoing invoices, as well as, if applicable, our company's bank transactions, in order to automatically record invoices, match them to transactions, and create the financial accounting from this in a semi-automated process.

If personal data is processed in this context, the processing is based on our legitimate interest in the efficient organization and documentation of our business processes in accordance with Art. 6 para. 1 lit. f GDPR.

9.2 Cookie Consent Tool

This website uses a "cookie consent tool" to obtain valid user consent for cookies and cookie-based applications that require consent. The cookie consent tool is displayed as an interactive user interface when you visit the site, allowing you to grant consent for specific cookies and/or cookie-based applications by ticking boxes. By using this tool, all cookies/services requiring consent are only loaded if you grant the corresponding consent by ticking the boxes. This ensures that such cookies are only placed on your device if you have given your consent.

This tool uses technically necessary cookies to save your cookie preferences. No personal user data is processed in this process.

If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 para. 1 lit. 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.

A further legal basis for processing is Article 6(1)(c) GDPR. As data controllers, we are subject to the legal obligation to make the use of cookies that are not technically necessary dependent on the respective user's consent.

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

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

10. Rights of the data subject

10.1 The applicable data protection law grants you the following rights as a data subject (rights of access and intervention) vis-à-vis us as the controller with regard to the processing of your personal data, whereby reference is made to the legal basis stated for the respective conditions of exercise:

- Right of access pursuant to Art. 15 GDPR;

- Right to rectification pursuant to Art. 16 GDPR;

- Right to erasure pursuant to Art. 17 GDPR;

- Right to restriction of processing pursuant to Art. 18 GDPR;

- Right to information pursuant to Art. 19 GDPR;

- Right to data portability pursuant to Art. 20 GDPR;

- Right to withdraw consent pursuant to Art. 7 para. 3 GDPR;

- Right to lodge a complaint pursuant to Art. 77 GDPR.

10.2 Right of objection

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

If you exercise your right to object, we will cease processing the data in question. However, further processing remains possible if we can demonstrate compelling legitimate grounds for the processing which override your interests, fundamental rights and freedoms, or if the processing serves the purpose of establishing, exercising or defending legal claims.

If we process your personal data for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing. You can exercise your right to object as described above.

If you exercise your right to object, we will cease processing the data in question for direct marketing purposes.

11. Duration of storage of personal data

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

When processing personal data based on explicit consent pursuant to Art. 6 para. 1 lit. a GDPR, the data concerned will be stored until you withdraw your consent.

If statutory retention periods exist for data processed within the framework of contractual or quasi-contractual obligations on the basis of Art. 6 para. 1 lit. b GDPR, this data will be routinely deleted after the expiry of the retention periods, provided that it is no longer required for the performance of the contract or the initiation of a contract and/or we no longer have a legitimate interest in its continued storage.

When processing personal data on the basis of Art. 6 para. 1 lit. f GDPR, this data will be stored until you exercise your right to object pursuant to Art. 21 para. 1 GDPR, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of establishing, exercising or defending legal claims.

When processing personal data for direct marketing purposes on the basis of Art. 6 para. 1 lit. f GDPR, this data will be stored until you exercise your right to object pursuant to Art. 21 para. 2 GDPR.

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

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Company/Management

SOHL Insights

Hermela Solomon

Address

Meerfeldstr. 11

68163 Mannheim

E-mail

Phone

+49 175 7002428

Social Media

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