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PRIVACY POLICY

TOUGH Training GmbH takes the protection of your personal data seriously. We treat your personal data confidentially and in accordance with legal data protection regulations and this data protection information. The first part of this privacy policy contains information about the processing of your personal data in connection with your visit to the www.tough-gmbh.com website as well as a summary of your rights under the European General Data Protection Regulation (hereinafter referred to as "GDPR"). The second part contains information about the cookies we use.

 

Part 1

1. Name and address of the responsible party

This website is operated by TOUGH Training GmbH, Leightonstr. 3, 97074 Würzburg, Germany,

[info@tough-training.com] (hereinafter referred to as "TOUGH" or "we"). It is also the data controller for all data processing in connection with visits to the website within the meaning of Art. 4 para. 7 GDPR.

 

2. Contact details

If you have any questions about data protection, you can contact us at any time at the address of the responsible party with the addition "Data protection" or by e-mail to info@tough-training.com.

 

3. Data processing when visiting the website

a) Processed personal data

When you visit our website (purely for information purposes), we collect so-called log data (hereinafter referred to as "log data"). This log data is collected automatically or with your consent by our IT systems when you visit the website. This is a dataset (also known as server log files) that is only stored temporarily by us. The dataset contains the following data:

  • IP address

  • Date and time of access

  • Amount of data transferred

  • Browser characteristics

  • Operating system details

  • Websites displayed

When you use the contact form provided on our website, we collect the data you provide. This includes the following data (hereinafter referred to as "contact form data"):

  • Contact information (first name, last name and e-mail address as mandatory information).

 

In addition, data is collected by Wix.com Ltd (hereinafter referred to as "wix") and its affiliated companies (contact for the purposes of the GDPR: Wix Online Platforms Limited, 1 Grant's Row, Dublin 2 D02HX96, Ireland). Details can be found in wix's privacy policy (https://de.wix.com/about/privacy).

 

b) Purpose and legal basis of the processing

The log data is processed for statistical purposes and to improve the quality of our offer, in particular the stability and security of the connection and the error-free provision of the website, and thus serves our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR).

The contact form data is processed and stored exclusively for the purpose of responding to your request or for contacting you. The legal basis for the processing of this data is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.

 

c) Duration of storage

Unless a more specific storage period is specified in this data protection information, personal data will be deleted as soon as its processing is no longer necessary for the purpose for which it was collected. If statutory retention obligations apply, the data will be deleted after the respective retention period has expired. Otherwise, log data will be deleted seven days after your visit.

Contact form data: Your data will be deleted after final processing of your request. This applies when it is clear from the circumstances that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

 

d) Recipients of the data

The data will only be passed on if this is necessary and, in the cases, listed below. The recipients of the data are:

Log data: Your log data is collected and processed by our external service provider wix on our behalf. If you have any questions about our service provider and the basis of our cooperation with them, please use the contact option described in this privacy policy.

Contact form data: Your contact form data is collected and processed by our external service provider HubSpot Inc, 25 First Street, 2nd Floor, Cambridge, MA 02141, USA (hereinafter "HubSpot") on our behalf to enable and simplify communication with interested parties. We also share this information for storage and processing purposes with HOCHTIEF PPP Solutions GmbH, whose expertise and resources we use to implement our projects.

All data: Your data will be passed on to state institutions or supervisory authorities (e.g. competent data protection supervisory authority, public prosecutor's office, etc.) if we are subject to a legal obligation to transfer it. Otherwise, your data will only be passed on to other recipients if you have given us your explicit prior consent.

The services for hosting and displaying the website are partly provided by the service provider wix as part of processing on our behalf.

The contact and communication services are partially provided by the service provider HubSpot as part of processing on our behalf.

 

4. hosting by wix

Wix is a tool for creating and hosting websites. When you visit our website, your data is processed on the servers of wix. Personal data may also be transmitted to the parent company of wix, Wix.com Ltd, Yunitsman 5 St, Tel Aviv, Israel or Wix.com, Inc: 100 Gansevoort Street, New York, NY 10014.

We have concluded a data processing agreement (DPA) with wix. This ensures that the personal data of our website visitors is processed exclusively in accordance with our instructions and in compliance with the GDPR.

 

5. scheduling tool - Hubspot

We use the HubSpot Meeting Planner service ("HubSpot Forms") from Hubspot on our website. HubSpot is an integrated software solution with which we provide a contact form with an appointment scheduling option. The submitted through the contact forms is stored on the servers of our software partner HubSpot and may be used by us to contact our website visitors. We use HubSpot on the basis of your consent in accordance with Art. 6 para. 1 lit. a GDPR. We would like to point out that no personal tracking takes place when using HubSpot Meeting Planner.

We have concluded a data processing agreement (DPA) with HubSpot. This ensures that the personal submitted via the contact form is only processed in accordance with our instructions and in compliance with the GDPR.

 

6. Transfers to third countries

In order to provide the services, wix uses a number of sub-processors. The data is initially processed by wix in Israel. The European Commission has issued an adequacy decision for Israel, so that an adequate level of data protection is ensured despite the transfer of data to a country outside the EU.

If the data is forwarded to sub-processors in countries without an adequate level of data protection, wix provides for the conclusion of standard contractual clauses within the framework of Commission Implementing Decision (EU) 2021/914 of June 4, 2021 for the transfer of personal data to third countries in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council. For details, please refer to the wix privacy policy (https://de.wix.com/about/privacy) and the data processing agreement (https://de.wix.com/about/privacy-dpa-users). The list of sub-processors can be found at (https://support.wix.com/de/article/liste-der-unterauftragsverarbeiter-von-wix).

HubSpot is a software company based in the USA. When forwarding data to the USA, HubSpot provides for the conclusion of standard contractual clauses within the framework of Commission Implementing Decision (EU) 2021/914 of June 4, 2021 for the transfer of personal data to third countries in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (see https://www.hubspot.com/data-privacy/gdpr). Further information on data protection can be found in HubSpot's privacy policy (https://legal.hubspot.com/de/privacy-policy) as well as in the data processing agreement (https://legal.hubspot.com/dpa) and the information on the cookies used by HubSpot (https://legal.hubspot.com/de/cookie-policy).

 

7. your rights

You have the following rights under the GDPR with regard to the processing of your personal data by us:

  • Right to information about the origin, recipient and purpose of your stored personal data

  • Right to rectification

  • Right to erasure (right to be forgotten)

  • Right to restriction of processing

  • Right to data portability

  • Right to object to processing

  • Right to withdraw your consent at any time with effect for the future

To exercise your above rights, you can contact us at any time using the contact details above. In addition, you can complain to a supervisory authority at any time about the processing of your personal data by us.

 

8. consent management tool

Our website uses the mandatory consent management tool provided by wix to manage user consent. When the website is accessed, a CMT cookie is set, which is used to store the consents granted for the individual services and to control the corresponding functionalities. The CMT is used to fulfill the data protection obligations under Art. 6 para. 1 lit. c GDPR. The data is processed by wix on our behalf and stored until the cookie is deleted. Further information can be found in wix's privacy policy. (https://de.wix.com/about/privacy).

 

 

Part 2

Cookies

The website uses cookies to provide you with the best possible experience on our website. Cookies are small text files that are placed and stored on your end device (computer, laptop, smartphone, etc.). These text files contain certain information. With regard to cookies, a distinction is made between session cookies and persistent cookies. While session cookies are automatically deleted after the end of the respective session (closing your browser), persistent cookies can also be stored over several sessions.

Cookies are used to analyze usage data (so that the user remains logged in), to store settings, to provide services, to track users of the website, to monitor and analyze performance, functions and effectiveness, to track marketing campaigns, for security reasons and to protect against fraud and to detect and prevent cyber-attacks.

We use cookies from the service provider wix on our website. You can find a list of cookies here (https://www.wix.com/about/de-cookie-table). The use of these cookies is in our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR). They are necessary to present our website to you and to enable you to use it securely. Insofar as these cookies are not necessary, they will only be processed if you have given your consent in the consent management (Art. 6 para. 1 sentence 1 lit. a GDPR).

 

Some of the data generated is processed in third countries on behalf of HOCHTIEF (see Section I. 6.)

You can object to the data processing described above at any time, provided it is personal data. Your objection will not result in any disadvantages for you. You can find further information under the link (https://de.wix.com/about/privacy). If you do not accept cookies, the functionality of our website may be restricted.

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