Alpha Progression

Privacy Policy

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations is:

Alpha Progression - Schnabel & Sinapius GbR
Goltzstr. 13a
10781 Berlin
Germany

+49 171 7887 989
info@alphaprogression.com
https://alphaprogression.com

2. General

2.1. Scope of the processing of personal data

As a matter of principle, we only process your personal data to the extent that it is necessary to provide a functional website and app as well as content and services. Your personal data is regularly processed only with your consent. An exception applies in cases where it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by law.

2.2. Legal basis for the processing of personal data

Unless the legal basis is stated in our privacy policy, the processing of personal data is based on the following legal bases:

Insofar as we obtain your consent for processing operations of personal data, Art. 6 (1) (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

When processing personal data that is necessary for the performance of a contract to which you are a party, Art. 6 (1) (b) GDPR serves as the legal basis. This also applies to processing operations that are necessary for the implementation of pre-contractual measures.

Insofar as the processing of personal data is necessary for the fulfillment of a legal obligation to which our company is subject, Art. 6 (1) (c) GDPR serves as the legal basis.

In the event that vital interests of you or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis.

If processing is necessary to protect a legitimate interest of our company or a third party and your interests, fundamental rights and freedoms do not outweigh the first-mentioned interest, Art. 6 (1) (f) GDPR serves as the legal basis for the processing.

2.3. Data deletion and storage period

Unless otherwise specified in our privacy policy in the following sections regarding data deletion and retention period, the following shall apply:

Your personal data will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other regulations to which the responsible party is subject. Blocking or deletion of the data will also take place if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

2.4. Marketing and Advertising our Products and Services

We may use personal data to provide tailored content and advertising, as permitted by applicable law. This may include email campaigns, custom audiences advertising, and personalized advertising. However, we will not use or disclose any health and fitness data for advertising or marketing.

3. Data that you enter yourself in the app

3.1. Description and scope of data processing

To use the app, you must provide us with the following information:

(1) gender
(2) training experience
(3) bodyweight.

If you decide to register, you will need to enter your email address and a password of your choice in order to authenticate yourself.

In order to generate a training plan tailored to your needs, we need the following information from you:

(1) training frequency
(2) training duration
(3) muscle focus
(4) periodization preferences.

Furthermore, we store certain training data in order to a) present the training progress to you and b) provide you with appropriate progression recommendations. For example, this training data includes the following:

(1) number of sets
(2) number of repetitions
(3) weight
(4) reps in reserve
(5) notes.

You also have the option to save information about your body fat percentage and various circumferences (e.g. hips and thighs) in the app.

3.2. Legal basis for data processing

The legal basis for the processing of personal data that you enter yourself in the app is Art. 6 (1) (b) GDPR, as the collection of this data serves in the context of the performance of a contract to which the user is a party or the implementation of pre-contractual measures.

3.3. Purpose of data processing

We store data that you enter yourself in the app,

(1) to authenticate your access to your app account;
(2) to generate a workout plan customized to your needs;
(3) to provide you with appropriate progression recommendations;
(4) to display your workout progress;
(5) to display your workout duration and date;
(6) to respond to your inquiries, conduct research, and resolve service issues;
(7) to meet our business needs;
(8) to improve and analyze the performance and use of our app;
(9) to conduct research to further develop our products and provide you with an even better experience when using the app.

Your data will be processed by us in accordance with all applicable laws and regulations and to fulfill our obligations.

If we deem it necessary to investigate possible fraud or other violations of our GTS or this privacy policy, we will process your data.

3.4. Storage period

The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. For example, this is the case when you delete your account.

3.5 Possibility of objection and removal

If you have your account deleted, all your data will be deleted.

If the storage is legally necessary, a deletion request will not affect the data.

4. Apple HealthKit

4.1. description and scope of data processing

We use Apple's HealthKit framework (Apple Inc., 1 Infinite Loop, Cupertino, CA 95014, USA; "Apple"), which provides a central repository for health and fitness data on the iPhone and Apple Watch, and - with the user's express consent - lets apps communicate with the HealthKit store to access and share this data.

Only with your explicit consent do we access or share the following data with the HealthKit framework:

(1) activity energy
(2) weight
(3) body fat percentage
(4) exercise

4.2. Legal basis for data processing

The legal basis for the processing of personal data that we synchronize with the HealthKit framework is Art. 6 (1) (a) GDPR, as the processing is based on your consent.

Please also read Apple's privacy policy for Apple Health, as the legal basis for Apple Health storing your data is explained within this privacy policy:
https://apple.com/ios/health

4.3. Purpose of data processing

We store data we receive from the HealthKit framework to display them to you in the app in lists and graphs. Bodyweight is additionally used to calculate how much weight you moved in total for exercises that involve body weight.

Of course, we do not use this data for advertising purposes or similar services, nor do we share it with third parties.

Data we share with the HealthKit framework can be analyzed in the Apple Health app.

4.4. Storage period

The data will be deleted in our app as soon as it is no longer necessary to achieve the purpose for which it was collected. This is the case, for example, when you delete the data in Apple Health or our app.

Please also read Apple's privacy policy for Apple Health, as the retention period of your data in Apple Health is explained in the context of this privacy policy:
https://apple.com/ios/health

4.5. Possibility of objection and removal

You can enable or disable the automatic synchronization of data between the app with the HealthKit framework at any time in the settings of your iPhone.

You also have the option to irrevocably delete data in our app. Data synced from Apple Health to our app must be deleted from Apple Health to be deleted from our app.

Please also read Apple's privacy policy for Apple Health, as the deletion of your data in Apple Health is explained within this privacy policy:
https://apple.com/ios/health

You can find more information about HealthKit here:
https://developer.apple.com/documentation/healthkit

5. Provision of the app and creation of log files

5.1. Description and scope of data processing

In order to use this app, you must be registered with the App Store or Google Play Store and enter your relevant personal data there, such as name, email address, account customer number, time of download, payment information and individual device identification number.

We have no influence on this data collection and are not responsible for it. We process this data only insofar as it is necessary for the execution of the contract.

In order for you to use the app and for us to improve the app in the future, we collect the following data when you install the app on your mobile device:

(1) login data of your mobile device (including the device ID)
(2) anonymized IP address
(3) date and time of the call, time zone difference to Greenwich Mean Time (GMT), access jams/http status code
(4) transmitted data volumes, messages about successful transmissions to your mobile device
(5) data that you generate through the use of the app, namely the pages you call up and entries, for example in search

The data will be stored separately from all other personal data provided by you.

5.2. Legal basis for data processing

The legal basis for the processing of this data is Art. 6 (1) (f) GDPR.

5.3. Purpose of data processing

Our legitimate interest in data processing according to Art. 6 (1) (f) GDPR is that the data is technically necessary for us to offer you the functions of our app and to ensure stability and security.

5.4. Storage period

As soon as the data is no longer required to achieve the purpose for which it was collected, it is deleted. This is the case after 7 days at the latest, if the data is stored in log files. A storage of your data beyond this is possible. In this case, your IP address will be deleted or alienated.

5.5. Possibility of objection and removal

The collection of data for the provision of the app and the storage of the data in log files is mandatory for the operation of the app. Therefore, you do not have the option to object.

6. Establishment of a contractual agreement

6.1. Description and scope of data processing

When you subscribe to the Pro version, we store the start and end date and transmit this data to the App Store or Play Store. When subscribing in the app, your payment information is collected directly by the App Store or Play Store. When subscribing via the website, you must provide your payment processing data (email address, address, and credit card details) in Stripe's checkout. In this case, further processing is handled by the payment service provider Stripe (Stripe Payments Europe Ltd, Block 4, Harcourt Centre, Harcourt Road, Dublin 2, Ireland).

Apple's privacy policy can be found here:
https://apple.com/privacy

Google's privacy policy can be found here:
https://policies.google.com/privacy

Stripe's privacy policy can be found here:
https://stripe.com/legal

6.2. Legal basis for data processing

The legal basis for the processing of personal data is Art. 6 (1) (b) GDPR, as the processing of this data serves in the context of the execution of a contract to which the user is a party.

6.3. Purpose of data processing

We process the data so that the Pro version can be activated and deactivated successfully and the correct amount can be transferred with your provided payment method.

6.4. Storage period

The data will be deleted in our app as soon as it is no longer necessary to achieve the purpose for which it was collected.

Please also read the privacy policies of Apple, Google or Stripe, as the storage period of your data by Apple, Google or Stripe is explained within their privacy plolicies.

Apple's privacy policy can be found here:
https://apple.com/privacy

Google's privacy policy can be found here:
https://policies.google.com/privacy

Stripe's privacy policy can be found here:
https://stripe.com/legal

6.5. Possibility of objection and removal

The processing of the data is mandatory for the activation and deactivation of the Pro version and the correct billing. Therefore, you do not have the option to object.

7. Provision of the website and creation of log files

7.1. Description and scope of data processing

Each time our website is called up, our system automatically saves data from the operating system of the accessing end device in so-called server log files.

The following data is collected:

(1) your browser type and version
(2) your operating system
(3) your internet service provider
(4) your IP address
(5) the date and time of your access
(6) websites from which your system accesses our website
(7) websites that are accessed by your system through our website.

Option 2: The log files do not contain any IP addresses or other data that could be assigned to you.

The data is also stored in the log files of our system. Not affected by this are your IP addresses or other data that allow the assignment of the data to you. A storage of this data together with your other personal data does not take place.

7.2. Legal basis for data processing

The legal basis for the processing of this data is Art. 6 (1) (f) GDPR.

7.3. Purpose of data processing

Our legitimate interest in data processing according to Art. 6 (1) (f) GDPR is that the data is technically necessary for us to offer you the functions of our website and to ensure stability and security.

7.4. Storage period

As soon as the data is no longer required to achieve the purpose for which it was collected, it is deleted. This is the case after 7 days at the latest, if the data is stored in log files. A storage of your data beyond this is possible. In this case, your IP address will be deleted or alienated.

7.5. Possibility of objection and removal

The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. Therefore, you do not have the option to object.

8. Use of cookies

A cookie consent banner will be shown the first time you visit our website. No scripts and cookies from 9. and 10. will be loaded until you have given explicit consent.

Cookies are stored on your device and transmitted from it to our website. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your browser, you can disable or restrict the transmission of cookies.

You can delete already stored cookies at any time. This can also be done automatically. If you deactivate cookies for our website, it may no longer be possible to fully use all functions of the website.

9. Google Analytics

We use Google Analytics, a web analytics service provided by Google LLC ("Google"), for our website on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 (1) (f) GDPR).

Google uses cookies. The information generated by the cookie about your use of the online offering is usually transferred to a Google server in the USA and stored there.

Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law:
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI

Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, a pseudonymous usage profile can be created from your processed data.

We use Google Analytics only with IP anonymization enabled. This means that your IP address is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there.

The IP address transmitted by your browser is not merged with other data from Google. You can prevent the storage of cookies by selecting the appropriate settings on your browser software. In addition, you can prevent the collection of data generated by the cookie and related to your use of the online offering to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link:
https://tools.google.com/dlpage/gaoptout

For more information about Google's use of data, settings and opt-out options, see Google's privacy policy and the settings for the display of advertising by Google.

Google's privacy policy can be found here:
https://policies.google.com/privacy

The settings for the display of advertising by Google can be found here:
https://adssettings.google.com/authenticated

Your personal data will be deleted or anonymized after 14 months.

10. Facebook Marketing Services

We use the "Facebook Pixel" of the social network Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on our website based on our legitimate interests in the analysis, optimization and economic operation of our online offering.

This allows us to track user behavior after users have been redirected to the provider's website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, which means that we cannot view the personal data of individual users.

The data is stored and processed by Facebook. Facebook can assign this data to your Facebook account and use it for its own advertising purposes in accordance with Facebook's privacy policy.

Facebook's privacy policy can be found here:
https://facebook.com/policy.php

You can object to the collection of data by Facebook Pixel or the use of your data for the purpose of placing Facebook ads by contacting the following address:
https://facebook.com/settings?tab=ads.

Facebook is certified under the Privacy Shield Agreement, guaranteeing compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI).

The legal basis for the processing of data is Art. 6 (1) (b and f) GDPR.

11. Blubrry Podcast

Our podcast is hosted by Blubrry (Rawvoice, Inc., 5000 Arlington Centre Blvd, Suite 2115 Upper Arlington, OH 43220, USA) and transmitted from their servers.

In the process, Blubrry collects IP addresses and device information. This is necessary to enable playback and to create statistics. The storage of this data is anonymized or pseudonymized by Blubrry.

The basis for this is our legitimate interest in a secure and efficient provision as well as analysis and optimization of our podcast according to Art. 6 (1) (f) GDPR.

Blubrry is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with European data protection law:
https://create.blubrry.com/resources/about-blubrry/privacy-shield

Blubrry's privacy policy can be found here:
https://create.blubrry.com/resources/about-blubrry/privacy-policy

12. Newsletter

12.1. Description and scope of data processing

On our website you have the option to subscribe to a free newsletter. When you register for the newsletter, your email address from the input mask is transmitted to us.

In addition, the following data is collected during registration:

(1) IP address of the calling terminal
(2) date and time of registration

For the processing of data, your consent is obtained during the registration process and reference is made to this privacy policy.

No data will be passed on to third parties in connection with the data processing for sending newsletters. The data is used exclusively for sending the newsletter.

12.2. Legal basis for data processing

The legal basis for the processing of data after your registration for the newsletter is, with your consent, Art. 6 (1) (a) GDPR.

The legal basis for sending the newsletter as a result of the sale of goods or services is Art. 7 (3) UWG.

12.3. Purpose of data processing

The collection of your email address serves to deliver the newsletter.

The collection of other personal data during the registration process serves to prevent misuse of the services or the email address used.

12.4. Period of storage

The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. Your email address will therefore be stored as long as the subscription to the newsletter is active.

The other personal data collected during the registration process is usually deleted after a period of seven days.

12.5. Possibility of objection and removal

You can unsubscribe from the newsletter at any time. For this purpose, you will find a corresponding link in each newsletter.

This also enables the revocation of consent to the storage of personal data collected during the registration process.

12.6. Use of a newsletter service

We use the service provider SendinBlue (47, rue de la Chaussée d'Antin, 75009 Paris) to send our newsletters and manage our email contacts. According to SendinBlue, the latter are stored on servers located in the European Union. SendinBlue is committed to ensuring that the processing of data is carried out in compliance with applicable laws and regulations, in particular the French Data Protection Act No. 78-17 of January 6, 1978, Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data ("GDPR").

SendinBlue's privacy policy and general terms and conditions can be found here:

Privacy policy:
https://de.sendinblue.com/legal/privacypolicy

General terms and conditions:
https://de.sendinblue.com/legal/termsofuse

The consents to the sending of email addresses are based on Art. 6 (1) (a), 7 GDPR and Art. 7 (2) No. 3, or (3) UWG. The use of SendinBlue, the collection of statistical data and analyses and the documentation of the registration, are carried out on the basis of our legitimate interest according to Art. 6 (1) (f) GDPR.

This interest is aimed at the safe use of a user-friendly newsletter that serves our business interests and provides you with the best possible experience. For this purpose, the newsletters contain small files that are retrieved from SendinBlues' server when you open the newsletter. This retrieval reveals technical information, such as your browser, operating system, and IP address, as well as the time of the retrieval, and can be used to track open and click-through rates. This helps us to improve our newsletter in accordance with the above-mentioned legitimate interest.

Unfortunately, this performance measurement cannot be revoked separately. Instead, the entire newsletter would have to be canceled.

13. Google Fonts

Our website uses Google Fonts fonts (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).

The privacy policy of the provider can be found here:
https://google.com/policies/privacy

14. Social media appearances

We use social networks and platforms for customer communication and information. On these platforms, the terms and conditions and privacy statements of the operators apply. We process your data when you contact us on these platforms.

15. Youtube

On our website, we embed videos from the YouTube platform (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).

The privacy policy of the provider can be found here:
https://google.com/policies/privacy

16. Your rights

The following list includes all your rights against the controller according to the GDPR. Rights that are not relevant to our website and app do not need to be mentioned. In this respect, the list can be shortened.

16.1. Right of access

You may request confirmation from the controller as to whether personal data concerning you is being processed by us.

If there is such processing, you can request information from the controller about the following:

(1) the purposes for which the personal data are processed;
(2) the categories of personal data that are processed;
(3) the recipients or the categories of recipients to whom the personal data relating to you have been or will be disclosed;
(4) the planned storage period of the personal data relating to you or, if specific information on this is not possible, criteria for determining the storage period;
(5) the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
(6) the existence of a right to lodge a complaint with a supervisory authority;
(7) any available information on the origin of the data if the personal data are not collected from you;
(8) the existence of automated decision-making including profiling according to Art. 22 (1) and (4) GDPR and - at least in these cases - meaningful information about the logic involved and the scope and intended effects of such processing for you.

You have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards according to Art. 46 GDPR in connection with the transfer.

16.2. Right to rectification

You have a right of rectification and/or completion against the controller, if the processed personal data concerning you are inaccurate or incomplete. The controller shall make the correction without undue delay.

16.3. Right to restriction of processing

Under the following conditions, you can request the restriction of the processing of personal data concerning you:

(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you object to the erasure of the personal data and request the restriction of the use of the personal data instead;
(3) the controller no longer needs the personal data for the purposes of processing, but you need them for the assertion, exercise or defense of legal claims, or
(4) if you object to the processing according to Art. 21 (1) GDPR and it is not yet clear whether the legitimate reasons of the controller outweigh your reasons.

If the processing of personal data relating to you has been restricted, such data may - apart from being stored - only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the Union or a member state.

If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

16.4. Right to deletion

a) Obligation to delete

You may request the controller to delete the personal data concerning you without delay, and the controller is obliged to delete such data without delay, if one of the following reasons applies:

(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You revoke your consent on which the processing was based according to Art. 6 (1) (a) or Art. 9 (2) (a) GDPR and there is no other legal basis for the processing.
(3) You object to the processing according to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing according to Art. 21 (2) GDPR. (4) The personal data concerning you has been processed unlawfully.
(5) The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or member state law to which the controller is subject.
(6) The personal data concerning you has been collected in relation to information society services offered according to Art. 8 (1) GDPR.

b) Information to third parties

If the controller has made the personal data concerning you public and is obliged to erase it according to Art. 17 (1) GDPR, he or she shall take reasonable measures, including technical measures, taking into account the available technology and the cost of implementation, to inform data controllers that process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.

c) Exceptions

The right to deletion does not exist insofar as the processing is necessary to

(1) to exercise the right to freedom of expression and information;
(2) to comply with a legal obligation which requires processing under Union or member state law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the field of public health according to Art. 9 (2) (h) and (i) and Art. 9 (3) GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes according to Art. 89 (1) GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
(5) for the establishment, exercise or defense of legal claims.

16.5. Right to information

If you have asserted the right to rectification, deletion or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or deletion of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right to be informed about these recipients by the data controller.

16.6. Right to data portability

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that

(1) the processing is based on consent according to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract according to Art. 6 (1) (b) GDPR and
(2) the processing is carried out with the help of automated procedures.

In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

16.7. 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) GDPR; this also applies to profiling based on these provisions.

The controller will no longer process the personal data concerning you, unless he can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.

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.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You have the possibility to exercise your right to object in connection with the use of information society services - notwithstanding Directive 2002/58/EC - by means of automated procedures using technical specifications.

16.8. Right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

16.9. Automated decision in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

(1) is necessary for the conclusion or performance of a contract between you and the controller,
(2) is permitted by legal provisions of the Union or the member states to which the controller is subject and these legal provisions contain appropriate measures to protect your rights and freedoms as well as your legitimate interests or
(3) is carried out with your express consent.

However, these decisions may not be based on special categories of personal data according to Art. 9 (1) GDPR, unless Art. 9 (2) (a) or (g) GDPR applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.

With regard to the cases referred to in (1) and (3), the controller shall take reasonable measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, which shall include, at least, the right to obtain the intervention of a person of the controller, to express his or her point of view and to contest the decision.

16.10. Right to complain to a 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 residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.

17. Amendment of the privacy policy

We reserve the right to change or adapt this data protection declaration at any time in compliance with the applicable data protection regulations.

The last change to this privacy policy was made on February 12, 2021.