top of page

1. Data protection officer

 

The person responsible within the meaning of data protection laws, in particular the EU General Data Protection Regulation (DSGVO), is:

Dr. Nicolas Stephan

Co-Founder & Managing Director

SPARRKS Service GmbH

Schönhauser Allee 167c, 10435 Berlin, Germany

 

You can reach him at +49 (0)30 52014961  or by email at nicolas.stephan@sparrks.de.

 


2. Your data subject rights

 

You can exercise the following rights at any time using the contact details provided by our data protection officer

 

  • Information about your data stored by us and its processing (Art. 15 DSGVO),

  • Correction of incorrect personal data (Art. 16 DSGVO),

  • Deletion of your data stored by us (Art. 17 DSGVO),

  • Restriction of data processing if we are not yet allowed to delete your data due to legal obligations (Art. 18 DSGVO),

  • objection to the processing of your data by us (Art. 21 DSGVO) and

  • Data portability, provided that you have consented to the data processing or have concluded a contract with us (Art. 20 DSGVO).


If you have given us consent, you can revoke it at any time with effect for the future.

You may at any time lodge a complaint with a supervisory authority, e.g. the competent supervisory authority in the federal state of your residence or the authority responsible for us as the controller.

A list of supervisory authorities (for the non-public sector) with address can be found at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

 


3. Additional privacy policy for coaches

 

3.1 Disclosure of certain data to the user

We call the employees of our clients who have booked our coaching "users". When we suggest you as a coach for a user, we disclose the following information about you to the user: practice experience, education, and personal information. You provide this information to us yourself.

When a user chooses you for coaching, we share the following information about the user with you: First name, last name, language, employer, position, work experience, leadership experience, concerns.

You may not use the user's data for any purpose other than to fulfill the specific coaching assignment; any processing beyond this is prohibited. After the coaching has ended, it is contractually stipulated that you delete all personal data related to the user.

We process all of the above data in order to properly fulfill our contracts concluded with you and with our clients regarding the User's coaching (Article 6(1)(b) GDPR).

 

3.2 Disclosure of certain data to our client

3.2.1 During the contractual relationship, we will provide the following information to our respective client.

3.2.1.1 The first and last name of all coaches who have provided coaching,

3.2.1.2 the keywords you have chosen on the topics of the coaching sessions, but without information about which coach sent which keywords to which user.

3.2.2 However, we will only provide the above information if there are at least five users who have completed at least 10 coaching sessions in total. Otherwise, we will only disclose the number of registered users.

 


4. Additional privacy policy for users


Disclosure of certain data to Coach
In order to provide suitable coaching, we will disclose the following data to one or more suitable coaches from our selective pool: First name, last name, language, employer, position, work experience, leadership experience, concerns. The coaches will not process this data for any purpose other than the fulfillment of the specific coaching assignment; any processing beyond this is prohibited. It is contractually stipulated that the coaches delete all personal data related to a user after the coaching is completed.
We collect all the above data in order to properly fulfill our contract concluded with the client for the coaching of the user (Article 6(1)(b) GDPR).
We will delete the collected personal data when the contractual relationship with the customer is terminated.
Insofar as we have included names or pseudonyms in an invoice for billing purposes at the instruction of the customer, this invoice component cannot be deleted before the expiry of the tax retention period.

 

 

5. Contacting by e-mail

 

If you contact us by email, we will process your message along with your contact information (name, email address and any other information added by your email client and the servers that transmit your email).

This data processing is based on our legitimate interest in responding to your request and processing any follow-up messages (Article 6(1)(f) GDPR). We delete the data collected from you at the end of the calendar year following the last communication to you.

Our mail servers work with TLS and SSL, which means that the data transfer between your mail servers and ours is encrypted as long as your email provider supports at least one of these features.

 

 

6. Processors and other recipients of personal data

 

For the operation of our website on the Internet, we use services of the following processor: INWX GmbH & Co. KG, Prinzessinnenstraße 30, 10969 Berlin. 

To receive, store and send e-mails, we use services provided by the following processors: Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland).

 


7. Cookies

 

7.1 General

Like many other websites, we also use so-called cookies. Cookies are small text files that are stored on your laptop, tablet, smartphone or similar when they visit our website.

You can delete individual cookies or the entire cookie inventory. In addition, you will receive information and instructions on how to delete cookies or block their storage in advance. Depending on the browser provider, you can find the necessary information under the following links:

 

7.2 Use of cookies

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:

  • Language settings

  • Frequency of page views

  • Use of website functions

 

The data collected in this way is pseudonymized by technical precautions. Therefore, an assignment of the data to the calling user is no longer possible. The data is not stored together with other personal data of you.

When you access our website, you will be informed about the use of cookies for analysis purposes and your consent to the processing of personal data used in this context will be obtained. In this context, a reference to this data protection declaration is also made.

 

7.3 Technically necessary cookies - type and purpose of processing.

The purpose of using technically necessary cookies is to simplify the use of websites for you. 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.

 

 

8. Legal basis and legitimate interest

 

The processing is carried out in accordance with Art. 6 para. 1 lit. f DSGVO on the basis of our legitimate interest in a user-friendly design of our website.

Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website.

 

 

9. Provision prescribed or required

 

The provision of the aforementioned personal data is not required by law or contract. However, without this data, the service and functionality of our website cannot be guaranteed. In addition, individual services and services may not be available or may be limited.

Objection:

Please read the information about your right to object according to Art. 21 DSGVO below.

 


10. Contact form

 

10.1 Type and purpose of processing

The data you enter, when arranging an information meeting, will be stored for the purpose of individual communication with you. For this purpose, it is necessary to provide a valid e-mail address and your name. This serves the assignment of the request and the subsequent response to the same. The provision of further data is optional.

 

10.2 Legal basis

The processing of the data entered in the contact form is based on a legitimate interest (Art. 6 para. 1 lit. f DSGVO).

By providing the contact form, we would like to enable you to contact us in an uncomplicated manner. The information you provide will be stored for the purpose of processing the request and for possible follow-up questions.

If you contact us to request a quote, the data entered in the contact form will be processed to carry out pre-contractual measures (Art. 6 para. 1 lit. b DSGVO).

 

10.3 Recipients

Recipients of the data are, if applicable, order processors.

 

10.4 Storage period

Data will be deleted no later than 6 months after the request has been processed.

If there is a contractual relationship, we are subject to the statutory retention periods under the German Commercial Code (HGB) and delete your data after these periods have expired.

 

10.5 Provision mandatory or required

The provision of your personal data is voluntary. However, we can only process your request if you provide us with your name, e-mail address and the reason for the request.

 

 

11. Use of Google Analytics

 

11.1 General

Insofar as you have given your consent, this website uses Google Analytics, a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (hereinafter: Google). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, due to the activation of IP anonymization on these web pages, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.

For more information on terms of use and data protection, please visit https://www.google.com/analytics/terms/de.html and https://policies.google.com/?hl=de.

On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.

The data sent by us and linked to cookies, user IDs (e.g. user ID) or advertising IDs are automatically deleted after 14 months. The deletion of data whose retention period has been reached takes place automatically once a month.

 

11.2 Revocation of consent

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link:

Browser Add On to disable Google Analytics.

 


12. SSL Encryption

 

To appreciate the security of your data during transmission, we use state-of-the-art encryption methods (e.g. SSL) via HTTPS.

 

 

13. Information about your right to object according to Art. 21 DSGVO

 

Individual 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 relating to you which is carried out on the basis of Art. 6(1)(f) DSGVO (data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Art. 4 No. 4 DSGVO.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

 


14. Change of our privacy policy

 

We reserve the right to adapt this privacy policy so that it always complies with the current legal requirements or to implement changes to our services in the privacy policy, e.g. when introducing new services. The new privacy policy will then apply to your next visit.

Privacy policy

bottom of page