Data protection

Introduction

With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context 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.

RESPONSIBLE

Humän Design
A brand of VFC International FZCO

E-mail address: info@humaendesign.com.
Imprint: http://humaendesign.com/impressum.

OVERVIEW OF PROCESSING

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

Types of data processed

1. event data (Facebook) ("event data" is data that can be transmitted by us to Facebook, e.g. via Facebook pixels (via apps or in other ways), and relates to people or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed to form target groups for content and advertising information (custom audiences); event data does not include actual content (such as comments written, login information, product purchases, etc.).The event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups formed from it are deleted when our Facebook account is deleted.)

2. inventory data (e.g. names, addresses).

3. content data (e.g. entries in online forms).

4. contact details (e.g. e-mail, telephone numbers).

5. meta/communication data (e.g. device information, IP addresses).

6. usage data (e.g. websites visited, interest in content, access times).

7. contract data (e.g. subject matter of the contract, term, customer category).

8. payment data (e.g. bank details, invoices, payment history).

Purposes of the processing

1. conversion measurement (measurement of the effectiveness of marketing measures).

2. office and organizational procedures.

3. direct marketing (e.g. by e-mail or post).

4. target group formation.

5. marketing

6. contact requests and communication

7. remarketing

8. managing and responding to inquiries and providing contractual services and customer service.

Relevant legal bases

Below you will find an overview of the legal bases of the GDPR 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. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.

1. consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) - The data subject has given their consent to the processing of their personal data for one or more specific purposes.

2. performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

3. legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.

4. legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations 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. It also regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. The data protection laws of the individual federal states may also apply.

SAFETY MEASURES

We take appropriate technical and organizational 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, input, disclosure, safeguarding availability and separation of the data.

Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

USE OF COOKIES

Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after their visit to an online service. The information stored may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched. The term "cookies" also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as "user IDs")

1. temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their browser.

2. permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users that are used for reach measurement or marketing purposes can also be stored in such a cookie.

3. first-party cookies: First-party cookies are set by us.

4. third party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.

5. necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user input or for security reasons).

6. statistics, marketing and personalization cookies: Cookies are also generally used to measure reach and when a user's interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that corresponds to their potential interests. This process is also referred to as "tracking", i.e. tracking the potential interests of users. If we use cookies or "tracking" technologies, we will inform you separately in our privacy policy or when obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offering and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection using your browser settings, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. You can also obtain further information on how to object in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies or the processing and providers mentioned in the cookie consent management procedure can be obtained, managed and revoked by users. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: Consent may be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.

Processed data types: 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).

Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

BUSINESS SERVICES

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships and associated measures and in the context of communication with the contractual partners (or pre-contractual), e.g. in order to answer inquiries.

We process this data to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. We only pass on the data of contractual partners to third parties within the framework of applicable law insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities).

The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, as part of this privacy policy. We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally 10 years).

We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order. Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

Education and training services: We process the data of participants in our education and training services (uniformly referred to as "trainees") in order to be able to provide them with our training services. The data processed in this context, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and training relationship.

The forms of processing also include the performance assessment and evaluation of our services and those of our instructors. As part of our activities, we may also process special categories of data, in particular information on the health of trainees and students as well as data revealing ethnic origin, political opinions, religious or philosophical beliefs. Where necessary, we obtain the express consent of the trainees for this purpose and otherwise only process the special categories of data if it is necessary for the provision of training services, for the purposes of health care, social protection or the protection of vital interests of the trainees.

If it is necessary for the fulfillment of our contract, for the protection of vital interests or by law, or if the consent of the trainees has been obtained, we disclose or transfer the data of the trainees to third parties or agents, such as authorities or in the field of IT, office or comparable services, in compliance with professional regulations.

PROVISION OF THE ONLINE OFFER AND WEBHOSTING

In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering 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 in the context of providing the hosting service may include all information relating to the users of our online service that is generated in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every 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, date and time of access, data volumes 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 can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.

Processed data types: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content

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

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

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.the answering of contact inquiries in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.

Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms).

Affected persons: Communication partner

Purposes of processing: Contact requests and communication.

ONLINE MARKETING

We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as "content") based on the potential interests of users and the measurement of their effectiveness. for these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by means of which the user data relevant to the presentation of the aforementioned content is stored.

This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times.

If users have consented to the collection of their location data, this can also be processed and the IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles, which is usually stored in cookies or by means of similar procedures.

These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.

In exceptional cases, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing process we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration, and that we only receive access to summarized information about the success of our advertisements.

However, as part of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. pThe conversion measurement is used solely to analyze the success of our marketing measures. pUnless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Facebook pixel and target group formation (custom audiences): With the help of the Facebook pixel (or comparable functions, for the transmission of event data or contact information by means of interfaces in apps), it is possible for Facebook, on the one hand, to determine the visitors of our online offer as a target group for the display of ads (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those users on Facebook and within the services of the partners cooperating with Facebook (so-called "Audience Network" https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not annoying. With the help of the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether

Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), event data (Facebook) ("event data" is data that can be transmitted by us to Facebook via Facebook pixels (via apps or other means), for example, and relates to individuals or their actions; the data includes, for example. Information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups created from it are deleted when our Facebook account is deleted.)

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

Purposes of processing: marketing, profiles with user-related information (creation of user profiles), remarketing, conversion measurement (measurement of the effectiveness of marketing measures), target group formation, target group formation (determination of target groups relevant for marketing purposes or other output of content).

Security measures: IP masking (pseudonymization of the IP address).

Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Possibility of objection (opt-out): We refer you to the data protection notices of the respective providers and the opt-out options specified for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-territory: https://optout.aboutads.info.

DELETION OF DATA

The data processed by us will be deleted in accordance with the legal requirements as soon as the consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose); if the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted to these purposes. This means that 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 defense of legal claims or to protect the rights of another natural or legal person.our data protection information may also contain further information on the retention and deletion of data that takes priority for the respective processing.

AMENDMENT AND UPDATE OF THE PRIVACY POLICY

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to 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 organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

RIGHTS OF THE PERSONS CONCERNED

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, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

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

Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain access to this data and further information and a copy of the data in accordance with legal requirements.

Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.n whether data concerning you is being processed and for information about this data and for further information and a copy of the data in accordance with the statutory provisions.

Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.

Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.

Complaint to the 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 relating to you infringes the provisions of the GDPR.

Status: January 30, 2025, Dubai

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