PRIVACY POLICY
The responsible person within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is:
SunGalaa
Ox meadow 1
76228 Karlsruhe
Germany
Tel.: 0160-5330.199
Email: contact@sungalaa.com
Website: www.sungalaa.com
Name of the data protection officer
Eirini Klinis
General information on data processing
1. scope of the processing of personal data
As a matter of principle, we process personal data of our users only insofar as this is necessary for the provision of a functional website as well as our content and services. The processing of personal data of our users is regularly carried out only with the consent of the user. An exception applies in those cases where it is not possible to obtain prior consent for factual reasons and the processing of the data is permitted by legal regulations.
2. legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) as the legal basis.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b DSGVO as the legal basis. This also applies to processing operations that are necessary for the performance 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 Para. 1 lit. c DSGVO as the legal basis.
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as the legal basis.
If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 para. 1 lit. f DSGVO as the legal basis for the processing.
3. data deletion and storage period
The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage ceases to apply. In addition, storage may take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or fulfillment of a contract.
Provision of the website and creation of log files
4. description and scope of data processing
Each time you visit our website, our system automatically collects data and information from the computer system of the calling computer.
The following data is collected:
(1) Information about the browser type and version used.
(2) The operating system of the user
(3) The Internet service provider of the user
(4) The IP address of the user
(5) Date and time of access
(6) Websites from which the user’s system accesses our Internet site
(7) Websites that are called up by the user’s system via our website
The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.
5. legal basis for data processing
The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f GDPR.
6. purpose of data processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.
The storage in log files is done to ensure the functionality of the website. In addition, we use the data to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
These purposes are also our legitimate interest in data processing according to Art. 6 para. 1 lit. f GDPR.
7. duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
8. possibility of objection and elimination
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. Consequently, there is no possibility for the user to object.
Cookies use
a) Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string that allows the browser to be uniquely identified when the website is revisited.
We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.
The following data is stored and transmitted in the cookies:
(1) Language settings
(2) Items in a shopping cart
(3) Log-in information
When calling up our website, the user is informed about the use of cookies for analysis purposes and his consent to the processing of personal data used in this context is obtained. In this context, a reference to this privacy policy is also made.
b) Legal basis for data processing
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f GDPR.
The legal basis for the processing of personal data using cookies for analysis purposes, if the user has given his consent in this regard, is Art. 6 para. 1 lit. a GDPR.
c) Purpose of the data processing
The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.
We require cookies for the following applications:
(1) Shopping cart
(2) Adoption of language settings
(3) Remembering search terms
The user data collected through technically necessary cookies are not used to create user profiles.
e) Duration of storage, possibility of objection and elimination
Cookies are stored on the user’s computer and transmitted by the user to our site. Therefore, as a user, you also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transfer of cookies. Cookies that have already been saved can be deleted at any time. This can also be automated. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.
Newsletter
9. description and scope of data processing
The newsletter is sent based on the user’s registration on the website:
On our website there is the possibility to subscribe to a free newsletter. When registering for the newsletter, the data from the input mask is transmitted to us.
(1) Name
(2) E-mail address of the user.
In addition, the following data is collected during registration:
(1) IP address of the calling computer
(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.
The newsletter dispatch takes place due to the sale of goods or services:
If you purchase goods or services on our website and enter your e-mail address, this may subsequently be used by us to send you a newsletter. In such a case, only direct advertising for our own similar goods or services will be sent via the newsletter.
No data is passed on to third parties in connection with the processing of data for the dispatch of newsletters. The data will be used exclusively for sending the newsletter.
10. legal basis for data processing
The newsletter is sent based on the user’s registration on the website:
The legal basis for the processing of data after registration for the newsletter by the user is, if the user has given his consent, Art. 6 para. 1 lit. a DSGVO.The newsletter dispatch takes place due to the sale of goods or services:
The legal basis for sending the newsletter as a result of the sale of goods or services is § 7 para. 3 UWG.
11. purpose of data processing
The collection of the user’s e-mail address is used to deliver the newsletter.
The newsletter is sent based on the user’s registration on the website:
The collection of other personal data during the registration process serves to prevent misuse of the services or the e-mail address used.
12. duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. Accordingly, the user’s e-mail address is stored for as long as the subscription to the newsletter is active.
The newsletter is sent based on the user’s registration on the website:
The other personal data collected during the registration process is usually deleted after a period of seven days.
13. possibility of objection and elimination
The subscription to the newsletter can be cancelled by the user concerned at any time. For this purpose, there is a corresponding link in each newsletter.
The newsletter is sent based on the user’s registration on the website:
This also enables the revocation of consent to the storage of personal data collected during the registration process.
Registration
14. description and scope of data processing
On our website, we offer users the opportunity to register by providing personal data. The data is entered in an input mask and transmitted to us and stored. The data will not be passed on to third parties. The following data is collected as part of the registration process:
(1) Name
(2) E-mail address of the user.
The following data is also stored at the time of registration:
(1) The IP address of the user
(2) Date and time of registration
As part of the registration process, the user’s consent to the processing of this data is obtained.
15. legal basis for data processing
The legal basis for the processing of the data, if the user has given his consent, is Art. 6 para. 1 lit. a GDPR.
If the registration serves the fulfillment of a contract to which the data subject is a party or the performance of pre-contractual measures.
If the registration serves the fulfillment of a contract to which the user is a party or the implementation of pre-contractual measures, an additional legal basis for the processing of the data is Art. 6 para. 1 lit. b GDPR.
16. purpose of data processing
Registration does not serve to conclude a contract with the user:
User registration is required for the provision of certain content and services on our website.
The identification of the user is necessary for the provision of the contents of the learning platform, as the contents are part of the training contract.
Registration serves to conclude a contract with the user:
A registration of the user is necessary for the fulfillment of a contract with the user or for the implementation of pre-contractual measures, the processing of personal data of the contracting party at the conclusion of the contract are required by law.
17. duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected.
Registration does not serve to conclude a contract with the user:
This is the case for the data collected during the registration process, if the registration on our website is cancelled or modified.
Registration serves to conclude a contract with the user:
This is the case for the data collected during the registration process for the fulfillment of a contract or for the implementation of pre-contractual measures when the data is no longer required for the implementation of the contract. Even after the conclusion of the contract, there may be a need to store personal data of the contractual partner in order to comply with contractual or legal obligations.
18. possibility of objection and elimination
As a user, you have the option to cancel the registration at any time. You can have the data stored about you changed at any time.
Registration serves to conclude a contract with the user:
If the data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, early deletion of the data is only possible insofar as contractual or legal obligations do not prevent deletion.
Contact form and e-mail contact
19. description and scope of data processing
A contact form is available on our website, which can be used for electronic contact. If a user takes advantage of this option, the data entered in the input mask will be transmitted to us and stored. These data are:
(1) Name
(2) E-mail address of the user.
The following data is also stored at the time the message is sent:
(1) The IP address of the user
(2) Date and time of registration
For the processing of the data, your consent is obtained during the submission process and reference is made to this privacy policy.
Alternatively, it is possible to contact us via the e-mail address provided. In this case, the user’s personal data transmitted with the e-mail will be stored.
In this context, the data will not be passed on to third parties. The data will be used exclusively for the processing of the conversation.
20. legal basis for data processing
The legal basis for the processing of the data, if the user has given his consent, is Art. 6 para. 1 lit. a GDPR.
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.
21. purpose of data processing
The processing of personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.
The other personal data processed during the submission process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.
22. duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is ended when the circumstances indicate that the matter in question has been conclusively clarified.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
23. possibility of objection and elimination
The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.
All personal data stored in the course of contacting us will be deleted in this case.
Rights of the data subject
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
Right to information
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 may request information from the controller about the following:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data which are processed;
(3) the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage duration;
(4) the existence of a right to rectify or erase the personal data concerning you, a right to have the controller restrict processing or a right to object to such processing;
(5) the existence of a right of appeal to a supervisory authority;
You have the right to request information about whether 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 pursuant to. Article 46 of the GDPR in connection with the transfer.
25. right to rectification
You have a right to rectification and/or completion vis-à-vis the data controller, insofar as the personal data processed concerning you are inaccurate or incomplete. The responsible party shall make the correction without undue delay.
26. right to restriction of processing
Under the following conditions, you may 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 instead the restriction of the use of the personal data;
(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 pursuant to Art. 21 para. 1 DSGVO and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.
Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of their storage, only with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of 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.
27. right to erasure
a) Obligation to delete
You may request the controller to delete the personal data concerning you without undue delay, and the controller is obliged to delete such data without undue 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 according to. Art. 6 par. 1 lit. a or Art. 9 para. 2 lit. a GDPR and there is no other legal basis for the processing.
(3) They shall lay down in accordance with Art. 21 par. 1 DSGVO and there are no overriding legitimate grounds for the processing, oryou object to the processing in accordance with Article 1 DSGVO. Art. 21 par. 2 DSGVO to object to the processing.
(4) The personal data concerning you have been processed unlawfully.
(5) The deletion of 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 have been processed in relation to information society services offered pursuant to Art. 8 para. 1 DSGVOcollected.
b) Information to third parties
If the controller has made the personal data concerning you public and is responsible pursuant to. Art. 17 par. 1 DSGVO to erase them, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers processing the personal data that you, as data subject, have requested erasure of all links to or copies or replications of such personal data.
c) Exceptions
The right to erasure does not exist insofar as the processing is necessary to
(1) to exercise the right to freedom of expression and information;
(2) for compliance 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 pursuant to Art. 9 par. 2 lit. h and i and Art. 9 para. 3 GDPR;
(4) for archival purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to. Art. 89 par. 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) to assert, exercise or defend legal claims.
28. right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure 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.
29. 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 transmit 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 pursuant to. Art. 6 par. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to. Art. 6 par. 1 lit. b GDPRbased and
(2) the processing is carried out with the aid of automated procedures.
In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. 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.
30. right of objection
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 para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of 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, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures using technical specifications.
31. 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 shall not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
32. 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 legislation of the Union or the Member States to which the controller is subject and that legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests; or
(3) is done with your express consent.
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 DSGVO, unless Art. 9 para. 2 lit. a or g DSGVO applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.
With regard to the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms of, and the legitimate interests of, the data subject, which shall include, at least, the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.
33. 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, workplace 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 Article 78 GDPR.