Data Protection

Privacy Policy

We are delighted that you are visiting our website. The protection and security of your personal information when using our website is very important to us. We would therefore like to take this opportunity to inform you about which of your personal data we collect when you visit our website and for what purposes it is used. Personal data refers to individual details about the personal or factual circumstances of an identified or identifiable natural person (data subject), e.g., name, address, email addresses, user behavior. This is therefore data that we can use to identify you. In addition, you will also find occasional information here about data processing procedures outside this website (e.g., video conferences or newsletters).

Data controller

Data controller for the processing of personal data within the meaning of the EU General Data Protection Regulation (GDPR):

KC Commercial Solutions GmbH (in formation), Liebigstraße 9, 52070 Aachen, Germany — Phone: +49 (0) 241 91380920 — Email: post@klickdojo.de

General information

This privacy policy meets the legal requirements for transparency in the processing of personal data. This includes all information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, email address, IP address, or user behavior when visiting a website. Information that we cannot link to your person (or only with disproportionate effort), e.g., through anonymization, is not personal data. The processing of personal data (e.g., collection, retrieval, use, storage, or transmission) always requires a legal basis and a defined purpose.

Stored personal data will be deleted as soon as the purpose of processing has been achieved and there are no legitimate reasons for further storage of the data. We will inform you of the specific storage periods or criteria for storage in the individual processing operations. Irrespective of this, we store your personal data in individual cases for the assertion, exercise, or defense of legal claims and in the event of statutory retention obligations.

Information pursuant to Art. 13 GDPR

This information is intended for customers, interested parties, suppliers, and employees. We process your personal data for the following purposes:

• To fulfill our contractual obligations to you (Art. 6(1)(b) GDPR). • To carry out pre-contractual obligations (Art. 6(1)(b) GDPR). • To respond to inquiries (Art. 6(1)(b) GDPR). • If you have given us your consent to process your personal data for specific purposes (such as to receive our newsletter), data processing takes place on the basis of your consent (Art. 6(1)(a) GDPR). • To comply with legal obligations to which our company is subject (Art. 6(1)(c) GDPR). • To the extent necessary, we also process your data to protect our legitimate interests, in particular to assert legal claims and defend ourselves in legal disputes, to ensure IT security, to consult with and exchange data with credit bureaus to assess creditworthiness and default risks, for direct marketing and market research—provided you have not objected to the use of your data for these purposes— in connection with measures for business management and the further development of services and products, in connection with measures for product and sales optimization, in connection with risk management measures, and for the prevention or investigation of criminal offenses (Art. 6(1)(f) GDPR).

Categories of recipients of personal data

Within our company, only those employees who absolutely need the data to perform their tasks have access to it (need-to-know principle). Individual processes and services are carried out by carefully selected service providers who are based within the EEA and who comply with data protection regulations. If service providers commissioned by us have access to personal data when performing their services, data processing agreements in accordance with Art. 28 (3) GDPR have been concluded with them.

Duration of data storage

The data we process is stored for the duration of the contractual relationship and in compliance with statutory retention periods. These include, in particular, commercial and tax law retention obligations under the German Commercial Code (HGB) and the German Fiscal Code (AO). The regular retention and documentation periods are up to ten years. If no contractual relationship is established, we only process the data for as long as the specific purpose requires.

Your rights as a data subject

As a data subject, you have the following rights with regard to your personal data:

• Right to access the personal data we process about you. • Right to rectification or erasure if the data is incorrect, out of date, or was collected by us unlawfully. • Right to restrict processing if complete erasure is not possible, e.g., because we are required to comply with statutory retention obligations. • Right to object to processing, provided the data processing is based on a balancing of interests (so-called “legitimate interest”), as described above under “Purpose of Processing.” This is the case, in particular, when the processing is not necessary for the performance of a contract with you. If you exercise your right to object, please explain the reasons why we should not process your data in the manner we have been doing.

Of course, you can also object to the processing of your personal data for advertising purposes at any time. Please send your objection to the address given in our legal notice or send us an email to the address given in the legal notice.

• Right to withdraw consent, provided that you have given us consent to process your data. You may withdraw your consent at any time by notifying our company, without having to provide a reason. • In addition, you have the right to file a complaint with a data protection supervisory authority regarding our company’s processing of your personal data.

If you have any questions regarding data protection, please feel free to contact us via email at the address listed in the legal notice.

cookies

Cookies are small text files that we send to your device's browser and store there when you visit our website. As an alternative to using cookies, information can also be stored in your browser's local storage. Some functions of our website cannot be offered without the use of cookies or local storage (technically necessary cookies). Other cookies, on the other hand, enable us to perform various analyses, so that we are able, for example, to recognize the browser you are using when you visit our website again and to transmit various information to us (non-necessary cookies). Cookies enable us, among other things, to make our website more user-friendly and effective for you by tracking your use of our website and determining your preferred settings (e.g., country and language settings). If third parties process information via cookies, they collect the information directly via your browser. Cookies do not cause any damage to your device. They cannot execute programs or contain viruses.

We provide information about the respective services for which we use cookies in the individual processing operations. Detailed information about the cookies used can be found in the cookie settings or in the consent manager of this website.

Data processing in detail

Below, we provide information about the individual processing operations, the scope and purpose of data processing, the legal basis, the obligation to provide your data, and the respective storage period. Automated decision-making in individual cases, including profiling, does not take place.

Provision of the website

When you access and use our website, we collect the personal data that your browser automatically transmits to our server. The following information is temporarily stored in a so-called log file: the IP address of the requesting computer, the date and time of access, the name and URL of the file accessed, the website from which the access originated (referrer URL), the browser used and, if applicable, your computer’s operating system, as well as the name of your Internet service provider.

Our website is not hosted by us, but by a service provider who processes the aforementioned data on our behalf for the purpose of providing the website in accordance with Art. 28 GDPR.

The use of the host is for the purpose of fulfilling our contractual obligations towards our potential and existing customers (Art. 6 (1) (b) GDPR) and in the interest of a secure, fast, and efficient provision of our online services by a professional provider (Art. 6 (1) (f) GDPR).

Contact

Nature and Scope of Processing: When you submit inquiries to us (e.g., via the contact form, email, or phone), we store all data obtained from these inquiries (e.g., name, email address, subject of the inquiry, etc.). We need this data to process your inquiry and to answer any follow-up questions. We do not share this data without your consent.

Purpose and Legal Basis: The processing of this data is based on Article 6(1)(b) of the GDPR, provided that your inquiry is related to the performance of a contract or is necessary for the implementation of precontractual measures. Otherwise, the processing is based on our legitimate interest in the effective handling of inquiries directed to us (Article 6(1)(f) of the GDPR) or on your consent (Article 6(1)(a) of the GDPR) if you have previously provided it.

Retention Period: The data you enter in the contact form will remain with us until you request that we delete it, revoke your consent to its storage, or the purpose for storing the data no longer applies (e.g., after your inquiry has been processed). Mandatory legal provisions—in particular, retention periods—remain unaffected.

applications

Nature and Scope of Processing: You have the option to apply for a job with us on our website (e.g., by email, mail, or through the online application form).

Purpose and Legal Basis: We process applicants’ personal data in accordance with legal requirements for the purpose of handling the application process and carrying out pre-contractual measures within the meaning of Article 6(1)(b) of the GDPR (initiation of an employment relationship) and—provided you have given your consent—Article 6(1)(a) of the GDPR. You may withdraw your consent at any time. Within our company, your personal data will be disclosed exclusively to individuals involved in processing your application. If your application is successful, the data you submitted will be stored in our data processing systems pursuant to Article 6(1)(b) of the GDPR for the purpose of carrying out the employment relationship.

Retention Period: Your data will be retained for a period of 6 months following the conclusion of the application process. This is generally done to fulfill legal obligations or to defend against any claims arising from statutory provisions. Thereafter, we are required to delete or anonymize your data. If it becomes apparent that the data will be needed after the 6-month period has expired (e.g., due to an impending or pending legal dispute), the data will not be deleted until the purpose for its continued retention no longer applies.

Admission to the applicant pool

As part of the application process, we offer applicants the opportunity to be included in our "talent pool" for a period of 12 months on the basis of consent within the meaning of Art. 6 (1) (a) GDPR.

The application documents in the talent pool will only be processed in connection with future job postings and employee searches and will be destroyed at the latest after the deadline has expired. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process, and that they can revoke this consent at any time in the future.

If you receive an offer of employment from us as part of the application process and accept it, we will store the personal data collected during the application process for at least the duration of the employment relationship.

Presence on social media platforms

We maintain publicly accessible profiles on social media platforms. Social media platforms such as Facebook, Twitter, etc., are generally able to comprehensively analyze your user behavior. Visiting our social media profiles triggers the following data processing activities relevant to data protection: If you are logged into your social media account and visit our profile, the operator of that social media platform can track your visit. Regardless of this, the operator may also process your data (e.g., IP address) under certain circumstances even if you are not logged into your account or do not have an account at all.

The operator compiles this data into user profiles that contain your preferences and interests. These profiles are used to display personalized advertising both on and off the respective social media platform. If you have an account with the respective social network, personalized advertising may be displayed on all devices on which you are currently logged in or have previously been logged in. Depending on the platform, the operators of the social media portals may carry out additional processing activities; we have no influence over this. For details, please refer to the terms of use and privacy policies of the respective social media portals.

Legal Basis: Our social media accounts are intended to ensure the broadest possible online presence in accordance with Article 6(1)(f) of the GDPR. The analysis processes carried out by social media platform operators may be based on different legal grounds, which must be specified by the respective providers.

Data Controller and Exercising Your Rights: When you visit one of our social media pages, we are jointly responsible with the operator of the social media platform for the data processing activities triggered by that visit. You may generally exercise your rights (right of access, rectification, erasure, restriction of processing, data portability, and the right to lodge a complaint) with both us and the operator of the respective social media platform. Despite our joint responsibility with the social media platform operators, we do not have full control over the data processing activities of the platforms. Our options depend largely on the corporate policy of the respective provider.

Retention Period: The data we collect directly through our social media presence is deleted from our systems as soon as you request that we delete it, revoke your consent to its storage, or the purpose for storing the data no longer applies. We have no control over the retention period for data collected by the social networks. For details on this, please contact the social media platform operators directly.

Facebook page

We have a profile on Facebook. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The data collected is also transferred to the United States and other third countries. We have entered into a joint processing agreement (Controller Addendum) with Facebook. You can adjust your advertising settings yourself in your user account. Data transfers to the United States are based on the European Commission’s Standard Contractual Clauses; further details can be found here. The company is certified under the “EU-US Data Privacy Framework” (DPF). For more information on data processing by Facebook, please refer to Facebook’s Privacy Policy.

Instagram page

We have an Instagram profile. The service provider is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland. Data transfers to the U.S. are based on the European Commission’s Standard Contractual Clauses; further details can be found here. The company is certified under the “EU-U.S. Data Privacy Framework” (DPF). For details on how Instagram handles your personal data, please refer to Instagram’s Privacy Policy.

Twitter page

We use the microblogging service Twitter. The provider is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland. You can adjust your Twitter privacy settings yourself in your user account. Data transfers to the U.S. are based on the European Commission’s Standard Contractual Clauses; details can be found here. The company is certified under the “EU-U.S. Data Privacy Framework” (DPF). For details, please refer to Twitter’s Privacy Policy.

LinkedIn page

We have a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies, which you can disable here. Data transfers to the U.S. are based on the European Commission’s Standard Contractual Clauses; details can be found here and here. The company is certified under the “EU-U.S. Data Privacy Framework” (DPF). For details, please refer to LinkedIn’s Privacy Policy.

Using the Skool Community

Nature and Scope of Processing: We use the Skool.com platform to operate an online community. When you join and use our Skool community, we process personal data: identifiers (e.g., name, email address), usage data (e.g., posts, comments, interactions), and technical data (e.g., IP address, device information).

Purpose and Legal Basis: Data is processed for the purpose of providing and managing community features. The legal basis is Article 6(1)(b) of the GDPR (performance of a contract) for registered users and Article 6(1)(f) of the GDPR (legitimate interests) for the general provision of the platform.

Data Recipient: Skool.com processes the data as a data processor. We have not yet entered into a data processing agreement with Skool.com in accordance with Article 28 of the GDPR, as it is not yet available. Our website is accessible even without using Skool.com.

Retention Period: Your data will be stored for the duration of your membership in the community. Upon termination of your membership, your data will be deleted, unless there are any legal requirements to retain it.

Note on Data Transfer to the U.S.: Skool.com is headquartered in the U.S. Transferring data to the U.S. involves risks, as the U.S. does not offer a level of data protection equivalent to that of the EU. However, Skool.com has committed to complying with the EU-U.S. Data Privacy Framework. For detailed information, please refer to their privacy policy: skool.com/legal?t=privacy.

video conferences

We use online conferencing tools to communicate with our customers. When you communicate with us via video or audio conference, your personal data is collected and processed by us and the provider of the respective tool, including your email address, phone number, duration of the conference, number of participants, and technical data such as IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speakers, and connection type. If you share content, it is stored on the providers’ servers (cloud recordings, chat messages, voice messages, photos, videos).

Purpose and Legal Basis: The conferencing tools are used to communicate with prospective or existing contractual partners (Art. 6(1)(b) GDPR) and to generally streamline communication (Art. 6(1)(f) GDPR). If prior consent has been obtained, processing is carried out in accordance with Art. 6(1)(a) GDPR.

Retention Period: The data we collect directly will be deleted as soon as you request its deletion, revoke your consent, or the purpose for which it was collected no longer applies. Mandatory statutory retention periods remain unaffected. We have no control over the retention period for data stored by the operators of the conferencing tools for their own purposes. For details, please contact the operators of the respective tools directly.

Google Fonts

This website uses web fonts to ensure consistent font display, which are provided by Google. When you visit the page, your browser loads the required web fonts into your browser cache. To do this, the browser you are using establishes a connection to Google’s servers; as a result, Google obtains your IP address. If your browser does not support web fonts, a default font from your computer will be used. For more information: developers.google.com/fonts/faq. Google’s privacy policy can be found here: policies.google.com/privacy?hl=de.

Purpose and Legal Basis: The use of Google Web Fonts is based on our legitimate interest in ensuring a consistent font display on our website (Art. 6(1)(f) GDPR). If consent has been requested, the processing of data is based solely on your consent pursuant to Art. 6(1)(a) GDPR. This consent may be revoked at any time.