Privacy Policy

Out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “Online Offer”).

The terms used are not gender-specific.

Status: June 12, 2022

Introduction
Person responsible
Contact Data Protection Officer
Overview of processing operations
Relevant legal basis
Security measures
Deletion of data
Performance of tasks according to statutes or rules of procedure
Payment procedures
Provision of online services and web hosting
Blogs and publication media
Contact and inquiry management
Newsletter and electronic notifications
Presence in social networks (social media)
Modification and updating of the privacy policy
Rights of data subjects
Definitions

Responsible

Transnational Community Federation e. V.

Reinhäuser Landstr. 30, 37083 Göttingen, Germany

Authorised representatives:

Arman Torkzaban and Marlene Neumann

E-mail address: info@transcf.org

Contact data protection officer

atorkzaban@transcf.org

Overview of processing operations

The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects.

Types of data processed

Inventory data
Payment data
Contact data
Content data
Contract data
Usage data
Meta/communication data

Categories of data subjects

Customers.
Interested parties.
Communication partners.
Users.
Members.
Business and contractual partners.

Purposes of processing

Provision of contractual services and customer service
Contact requests and communication
Direct marketing
Management and response to requests
Feedback
Marketing
Provision of our online services and user experience
Information technology infrastructure

Relevant legal bases

In the following, you will find an overview of the legal bases of the DSGVO, on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.

Performance of a contract and pre-contractual requests (Art. 6 (1) p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject’s request.

Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Our data protection notices may also contain further information on the retention and deletion of data, which shall have priority for the respective processing operations.

Performance of tasks according to the articles of association or rules of procedure

We process the data of our members, supporters, interested parties, business partners or other persons (collectively, “data subjects”) if we have a membership or other business relationship with them and perform our tasks and are recipients of services and benefits. In addition, we process the data of data subjects on the basis of our legitimate interests, e.g. when administrative tasks or public relations work are involved.

The data processed in this context, the nature, scope and purpose of the data and the necessity of its processing, are determined by the underlying membership or contractual relationship, which also determines the necessity of any data disclosures (in other respects, we refer to required data).

We delete data that is no longer required to fulfil our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. We retain the data for as long as they may be relevant for business processing, as well as with regard to any warranty or liability obligations based on our legitimate interest in regulating them. The necessity of retaining the data is reviewed regularly; in all other respects, the statutory retention obligations apply.

Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. e-mail, telephone numbers); contract data (e.g. subject matter of contract, term, customer category).

Data subjects: Users (e.g. website visitors, users of online services); members; business and contractual partners.

Purposes of processing: provision of contractual services and customer service; contact requests and communication; administration and response to requests.

Legal Grounds: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Payment procedure

Credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and the data protection notices of the payment service providers.

For payment transactions, the terms and conditions and data protection notices of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.

Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).

Data subjects: Customers; prospective customers.

Purposes of processing: provision of contractual services and customer service.

Legal grounds: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO).

Further notes on processing processes, procedures and services:

PayPal: payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); service provider:PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; legal basis: contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO); website: https://www.paypal.com/de;

Provision of the online offer and web hosting

In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. web pages visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).

Data subjects: Users (e.g. website visitors, users of online services).

Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).).

Legal grounds: legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO). In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers for this purpose in addition to banks and credit institutions (collectively, “payment service providers”).

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required in order to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data on the part of the payment service providers is passed on to us. We do our best to remove this kind of data as quickly as possible.

Further notes on processing procedures, methods and services:

Collection of access data and log files: we ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilisation of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.

WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offerings; service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO);

Website: https://wordpress.com;

Privacy policy: https://automattic.com/de/privacy/;

Order processing agreement: concluded with provider: https://wordpress.com/support/data-processing-agreements/.

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

Types of data processed: inventory data (e.g., names, addresses); contact data (e.g., e-mail, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta/communication data (e.g., device information, IP addresses).

Data subjects: Users (e.g., website visitors, users of online services).

Purposes of processing: provision of contractual services and customer service; feedback (e.g. collecting feedback via online form); provision of our online offer and user friendliness.

Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Contact and inquiry management

When contacting us (e.g. via contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The response to the contact inquiries as well as the management of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries and maintaining user or business relationships.

Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).

Data subjects: Communication partners.

Purposes of processing: provision of contractual services and customer service; contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.

Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further guidance on processing operations, procedures and services:

Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfilment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our statutory cancellation request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called “block list”) for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Option to object (opt-out): You can cancel receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably e-mail, for this purpose.

Further information on processing, procedures and services:

Measurement of opening and click-through rates: The newsletters contain a so-called “web beacon”, i.e., a pixel-sized file that is retrieved from our server or, if we use a shipping service provider, from its server when the newsletter is opened. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes the determination of whether the newsletters are opened, when they are opened and blocked, blocked;
Legal basis: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO).

Prerequisite for the use of free services: Consent to the sending of mailings may be made conditional as a prerequisite for the use of free services (e.g. access to certain content or participation in certain promotions). If users wish to take advantage of the free service without subscribing to the newsletter, please contact us.

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we also point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need assistance, you can contact us.

Data subjects: Users (e.g., website visitors, users of online services).

Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.

Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further information on processing operations, procedures and services:

Instagram: Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.

Facebook pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights,” to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information,” https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (i.e., users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO); Website: https://www.facebook.com; Privacy policy:https://www.facebook.com/about/privacy; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data.

Twitter: social network; service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; parent company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).

YouTube: Social network and video platform; service provider:Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO); Privacy policy: https://policies.google.com/privacy; Opt-out:https://adssettings.google.com/authenticated.

Amendment and updating of the data protection declaration

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

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

Right to withdraw consent: You have the right to revoke any consent given at any time.

Right to information: you have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.

Right to rectification: you have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.

Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data.

Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand its transfer to another responsible party.

Complaint to 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 habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.

Definitions

This section provides you with an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Controller: “Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means.