Informed & Safe

Privacy Statement

We, the TRILOGIE GbR, thank you for visiting our homepage. As a training and consulting company, the secure handling of your data is of particular importance to us. We would, therefore, like to inform you in detail about the use of your data when visiting our website.

1. Definitions

The  TRILOGIE GbR Privacy Statement is based on the terms used by the European Directive and Regulation Makers in the adoption of the Basic Data Protection Regulation (DSGVO). Our privacy statement should be easy to read and understood, for the public as well as for our customers and business partners. To guarantee this, we would like to explain the terms used in advance.

We use the following terms in this data protection declaration:

Personal Data: Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as the “data subject”). A natural person shall be considered identifiable if he 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 or one or more specific characteristics expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

Data Subject: A data subject is an identified or identifiable natural person whose personal data are processed by the controller.

Processing: Processing means any operation or set of operations which is carried out with or without the aid of automated processes, and which is related to personal data, such as collection, recording, organization sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interlinking, restriction, deletion or destruction.

Restriction of Processing: Restriction of processing is the marking of stored personal data, intending to restrict further processing of that data.

Profiling: Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects pertaining to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movement of that natural person.

Pseudonymization: Pseudonymization means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without additional information, provided that such additional information is kept separately and is subject to technical and organizational measures, ensuring that the personal data are not attributed to an identified or identifiable natural person.

Data Controller: The data controller is a natural or legal person, public authority, agency or another body, which alone or jointly with others, decides on the purposes and means of the processing of personal data. Where the purposes and means of such processing are laid down by Union Law or by the law of the Member States, the controller or respectively the specific criteria for his designation may be laid down by Union Law or by the law of the Member States.

Processor: A processor is a natural or legal person, public authority, agency or another body which processes personal data on behalf of the Data Controller.

Recipient: A recipient is a natural or legal person, public authority, agency or another body to whom personal data are disclosed, regardless if the recipient is a third party. However, authorities which may receive personal data in the context of a specific investigative mandate under Union Law or the law of the Member States shall not be considered recipients.

Third Party: the third party means any natural or legal person, public authority, agency or body other than the data subject, the data controller, the processor and the persons authorized to process the personal data under the direct responsibility of the data controller or processor.

Consent: Consent shall mean any voluntary, informed and unambiguous expression by the data subject of his or her will in the particular case, in the form of a statement or other unequivocal confirmatory act, indicating that he or she consents to the processing of his or her personal data.

2. Data Collection

The TRILOGIE GbR website collects a series of general data and information each time the site is accessed by a data subject or an automated system. This general data and information are stored in the log files of the server. The following can be collected

a) browser types and versions used,

b) the operating system used by the accessing system,

c) the website from which an accessing system accesses our website (so-called referrer),

d) the sub-websites which are accessed via an accessing system on our website,

e) the date and time of access to the website,

f) an Internet Protocol address (IP address),

g) the Internet service provider of the accessing system; and

h) other similar data and information used to avert dangers in the event of attacks on our information technology systems.

When using this general data and information, TRILOGIE GbR does not draw any conclusions about the data subject.

Instead, this information is required to

a) deliver the contents of our website correctly,

b) optimize the content of our website and the advertising for it,

c) ensure the long-term operability of our information technology systems and the technology of our website; as well as

(d) provide law enforcement authorities with the information necessary for law enforcement in the event of a cyber attack.

This anonymous data and information is therefore evaluated by TRILOGIE GbR both statistically and to increase data protection and data security in our company to ultimately ensure an optimum level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by the person concerned.

3. Legal or contractual regulations for the provision of personal data

The necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of not providing the data

We will inform you that the provision of personal data is partly required by law (e.g., tax regulations) or may result from contractual regulations (e.g., information on the contractual partner). Sometimes, it may be necessary for a contract to be concluded that a person concerned makes personal data available to us, which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide personal data would result in the fact that the contract could not be concluded with the data subject. Before the data subject provides personal data, the data subject must contact our data protection officer. Our data protection officer informs the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of a contract, whether there is an obligation to provide the personal data and what consequences the non-availability of the personal data would have.

4. Use of data when registering for the e-Mail newsletter

On the TRILOGIE GbR website, users are given the opportunity to subscribe to our company’s newsletter. When ordering the newsletter, the personal data transmitted to the data controller is determined by the input mask used for this purpose.

In regular intervals, TRILOGIE GbR informs its customers and business partners about their offers using a newsletter. Our company’s newsletter can only be received by the person concerned if

a) the data subject has a valid e-mail address; and

b) the person concerned registers to receive the newsletter.

For legal reasons, a confirmation e-Mail in the double opt-in procedure will be sent to the e-mail address entered for the first time by the person concerned, to send the newsletter. This confirmation e-Mail is used to check whether the owner of the e-mail address has authorized the receipt of the newsletter as the person concerned.

When registering for the newsletter, we also store the IP address assigned by the Internet Service Provider (ISP) to the computer system used by the person concerned at the time of registration as well as the date and time of registration. The collection of this data is necessary to be able to trace any (possible) misuse of the e-Mail address of a data subject at a later point in time, and therefore, serves to legally safeguard the data controller.

The personal data collected during registeration for the newsletter will be used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter could be informed by e-Mail, if this is necessary for the operation of the newsletter service or registration in this respect, as might be the case in the event of changes to the newsletter offer or modifications to the technical conditions. The personal data collected as part of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be canceled by the person concerned at any time. The consent to the storage of personal data, which the person concerned has given us for the newsletter dispatch, can be revoked at any time. For the purpose of the revocation of consent, a respective link can be found in each newsletter- It is also possible at any time to unsubscribe from the newsletter directly on the website provided by the data controller or to inform the data controller of this in any other manner.

5. Possibility to contact us via the website

Due to legal regulations, the website of TRILOGIE GbR contains information that enables quick electronic contact to our company as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the data controller by e-mail or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted voluntarily by a data subject to the data controller will be stored for the purposes of processing or contacting the data subject. This personal data will not be passed on to third parties.

6. Use of cookies

To make visiting our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your end device. Some of the cookies we use are deleted after the end of a browser session, i.e., after closing your browser (so-called session cookies). Other cookies remain on your end device and enable us to recognize your browser during your next visit (persistent cookies). You can set your browser so that you are informed about cookies being set, and can decide individually whether to accept them cookies in some instances or exclude them in general. If cookies are not accepted, the functionality of our website may be restricted.

7. Use of Google (Universal) Analytics for Web Analytics

We use neither Google Analytics nor any other analysis technology.

8. Embedded videos and images from external websites

Some of our pages contain embedded content from YouTube or Instagram. If you only visit a website from our website with integrated videos or images from our YouTube and/or Instagram channels, no personal data will be transmitted, except for the IP address. In the case of YouTube, the IP address will be sent to Google Inc., 600 Amphitheater Parkway, Mountain View, CA 94043 USA (“Google”) and, in the case of Instagram, to Instagram Inc., 181 South Park Street 2, San Francisco, California 94107, USA (“Instagram”).

9. Announcement of changes

Changes in the law or in our internal processes may require us to adjust this privacy statement.

In the event of such a change, we will notify you at least six weeks before it becomes effective. In general (No. 6), you have the right to revoke your given consent.

Please note that (unless you make use of your right of revocation) the current version of the privacy statement is the valid one.

10. Update/deletion of your personal data

You have the possibility at any time to check, change or delete the personal data provided to us by sending us an e-mail to the e-mail address Info at trilogie.de. If you are a member, you may also opt out of receiving further information from us in the future.

You also have the right to revoke your consent at any time with effect for the future.

The stored personal data will be deleted if you revoke your consent to storage.

The data controller processes and stores the personal data of the data subject only for the period necessary to achieve the storage purpose or insofar as this has been provided for by the European Directive and regulators or another legislator in laws or regulations to which the data controller is subject.

If the storage purpose no longer applies or if a storage period prescribed by the European directive and legislator or another competent legislator expires, the personal data shall be blocked or deleted routinely in accordance with the statutory provisions.

11. Rights of data subjects

Every data subject shall have the right, granted by the European directive and legislator, to obtain confirmation from the controller as to whether data subject’s personal data relating to him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may at any time contact our data protection officer or another employee of the controller.

Any person concerned by the processing of personal data has the right granted by the European Directive and Legislation to obtain, at any time and free of charge, from the data controller, information about the personal data relating to that person that has been stored and a copy of that information. In addition, the European Directive and Legislation have granted the data subject access to the following information:

Processing Purposes

the categories of personal data processed,

the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations

if possible, the planned duration for which the personal data will be stored or, if that is not possible, the criteria for determining that duration

the existence of a right to rectification or deletion of personal data concerning him or her or to the limitation of the processing carried out by the controller or of a right to object to such processing

the existence of a right to appeal to a supervisory authority

if the personal data are not collected from the data subject: All available information on the origin of the data

The existence of automated decision-making including profiling in accordance with Art. 22(1) and (4) GDPR and – at least in these cases – conclusive information on the logic involved, and the scope and intended effects of such processing for the data subject

The data subject also has the right to know whether personal data have been transferred to a third country or to an international organization. If this is the case, the data subject shall also have the right to obtain information on the appropriate guarantees in connection with the transfer.

If a data subject wishes to exercise this right of access, he or she can contact our data protection officer or another employee of the data controller at any time.

Any person affected by the processing of personal data has the right, granted by the European directive and legislator to request the immediate rectification of any inaccurate personal data concerning him or her. Furthermore, the affected data subject shall have the right to request the completion of incomplete personal data, also using a supplemental declaration, taking into account the purposes of the processing.

If an affected data subject wishes to exercise this right of rectification, he or she can contact our data protection officer or another employee of the data controller at any time.

Any affected person subject to the processing of personal data shall have the right, granted by the European directive and legislator, to require the controller to delete without delay personal data concerning him or her, which are subject to one of the following conditions and to the extent that the processing is not necessary:

Personal data have been collected or otherwise processed for purposes, for which they are no longer needed.

The affected data subject withdraws his or her consent on which the processing was based pursuant to Art. 6 para. 1 letter a) GDPR or Art. 9 para. 2 letter a) GDPR and there is no other legal basis for the processing.

The affected data subject objects to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate reasons for the processing or the affected data subject objects to the processing pursuant to Art. 21 para. 2 GDPR.

Personal data have been processed unlawfully.

The deletion of personal data is necessary to fulfill a legal obligation under Union Law or the law of the Member States, to which the data controller is subject.

The personal data were collected in relation to services offered by the information society pursuant to Art. 8 para. 1 GDPR.

If one of the reasons above applies, and an affected data subject wishes to have personal data stored at TRILOGIE GbR deleted, he or she can contact our data protection officer or another employee of the data controller at any time. The data protection officer of TRILOGIE GbR or another employee will arrange for the deletion request to be complied with immediately.

If the personal data was made public by TRILOGIE GbR and if our company, as the responsible party, is obliged to delete the personal data according to Art. 17 para. 1 GDPR, TRILOGIE GbR shall take appropriate measures, including technical measures, taking the available technology and the implementation costs into account, to inform other persons responsible for data processing who process the published personal data; that the affected person concerned has requested the deletion of all links to this personal data or copies or replications of this personal data from these other persons responsible for data processing, insofar as the processing is not necessary. The data protection officer of TRILOGIE GbR or another employee will take the steps required in individual cases.

Any affected data subject to the processing of personal data has the right, granted by the European directive and legislator, to request the controller to restrict the processing if one of the following conditions is met:

The accuracy of the personal data shall be contested by the affected data subject for a period that allows the controller to verify the accuracy of the personal data.

The processing is unlawful and the affected data subject refuses the deletion of the personal data and instead requests that the use of the personal data be restricted.

The controller no longer needs the personal data for the purposes of processing, but the affected data subject, however, requires them for the assertion, exercise or defense of legal rights.

The affected data subject has lodged an objection against the processing pursuant to Art. 21 (1) GDPR and it is not yet clear whether the legitimate reasons of the data controller outweigh those of the affected data subject.

If one of the above Conditions is met, and an affected data subject wishes to request the restriction of personal data stored at TRILOGIE GbR, he or she can contact our data protection officer or another employee of the data controller at any time. The data protection officer of TRILOGIE GbR or another employee will initiate the restriction of the processing.

Any affected data subject involved in the processing of personal data has the right, granted by the European directive and legislator, to obtain personal data concerning him or her which have been provided by the data subject to a controller in a structured, common and machine-readable format. He or she also has the right to transmit these data to another controller without being hindered by the controller to whom the personal data have been provided, insofar that the processing is based on the consent pursuant to Art. 6 para. 1 letter a) GDPR or Art. 9 para. 2 letter a) GDPR or on a contract pursuant to Art. 6 para. 1 letter b) GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task in the public interest or in the exercise of official authority entrusted to the controller.

Furthermore, when exercising his or her right to data transferability pursuant to Art. 20 para. 1 GDPR, the affected data subject shall have the right to obtain that the personal data be transferred directly from one responsible person to another responsible person, insofar as this is technically feasible, and insofar as this does not impair the rights and freedoms of other persons.

To assert the right to data transferability, the person concerned can contact the data protection officer appointed by TRILOGIE GbR or another employee at any time.

Any person affected by the processing of personal data has the right granted by the European directive and legislator to object, at any time, to the processing of personal data concerning him or her based on Art. 6 para. 1 letter e) or f) GDPR for reasons arising from his particular situation. This also applies to profiling based on these provisions.

In the event of an objection, TRILOGIE GbR will no longer process the personal data unless we can prove compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the affected data subject or serve the processing, assertion, exercise or defense of legal claims.

If TRILOGIE GbR processes personal data to carry out direct advertising, the person concerned has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling as far as it is connected with such direct advertising. If the data subject objects to TRILOGIE GbR processing for direct marketing purposes, TRILOGIE GbR will no longer process the personal data for these purposes.

In addition, the affected data subject has the right to object to the processing of personal data relating to him or her which is carried out at TRILOGIE GbR for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR for reasons arising from his or her particular situation unless such processing is necessary for the performance of a task in the public interest.

To exercise the right to object, the affected data subject may contact the data protection officer of TRILOGIE GbR or another employee directly. The affected data subject is also free to exercise his or her right of objection in connection with the use of information society services, notwithstanding Directive 2002/58/EC, using automated procedures using technical specifications.

Any affected data subject to the processing of personal data shall have the right, granted by the European directive and legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects upon him or her or significantly affects him or her in a similar manner, provided that the decision

(a) is not necessary for the conclusion or performance of a contract between the affected data subject and the person responsible; or

(b) is authorized by legislation of the Union or of the Member States, to which the data controller is subject and contains appropriate measures to guarantee the rights and freedoms and the legitimate interests of the affected data subject; or

(c) with the express consent of the affected data subject.

Is the decision

(a) necessary for the conclusion or performance of a contract between the affected data subject and the person responsible; or

b) if it takes place with the express consent of the data subject, TRILOGIE GbR shall take appropriate measures to guarantee the rights and freedoms as well as the legitimate interests of the affected data subject, including at least the right to obtain the intervention of a person on the part of the person responsible, to state his or her own position, and to challenge the decision.

If the affected data subject wishes to exercise rights relating to automated decisions, he or she may at any time contact our data protection officer or another employee of the data controller for this purpose.

Any person affected by the processing of personal data has the right, granted by the European directive and legislator, to revoke consent to the processing of personal data at any time.

If the affected data subject wishes to revoke his/her consent, he/she may at any time contact our data protection officer or another employee of the data controller.

12. The legal basis of the processing

Art. 6 para. 1 letter a) GDPR serves our company as a legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the affected data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the rendering of any other service or consideration, the processing is based on Art. 6 para. 1 letter b) GDPR. The same shall apply to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries regarding our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 Para. 1 Letter. c) GDPR. In rare cases, the processing of personal data may become necessary to protect the vital interests of the affected data subject or of another natural person. This would be the case, for example, if a visitor to our site were injured and his or her name, age, health insurance information or other vital information would need to be disclosed to a physician, hospital or another third party. The processing would then be based on Art. 6 para. 1 letter d) GDPR. Ultimately, processing operations could be based on Art. 6 (1) (f) GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis, if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and fundamental freedoms of the affected data subject do not predominate. We are particularly permitted such processing operations because they have been mentioned explicitly by the European legislation. In this respect, it adopted the view that a legitimate interest could be assumed if the affected data subject is a customer of the data controller (Recital 47 sentence 2 GDPR).

13. Legitimate interests in the processing pursued by the controller or by a third party

If the processing of personal data is based on Art. 6 para. 1 letter f) GDPR, our legitimate interest is to carry out our business activities for the benefit of all our employees and shareholders.

14. The person responsible or your contact person

If you have any questions regarding the collection, processing or use of your personal data, for information, correction, blocking or deletion of data as well as revocation of consents given or objections to a specific use of data, please contact us directly:

TRILOGIE GbR

Lorenz Haschtmann

Lokfeld 36
23858 Barnitz, Germany

T +49(0)4533/61 49 470
F +49(0)4533/20 49 489
E info@trilogie.de

Stand as of May 22, 2018