We are very delight­ed that you have shown inter­est in our enter­prise. Data pro­tec­tion is of a par­tic­u­lar­ly high pri­or­i­ty for the man­age­ment of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL. The use of the Inter­net pages of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL is pos­si­ble with­out any indi­ca­tion of per­son­al data; how­ev­er, if a data sub­ject wants to use spe­cial enter­prise ser­vices via our web­site, pro­cess­ing of per­son­al data could become nec­es­sary. If the pro­cess­ing of per­son­al data is nec­es­sary and there is no statu­to­ry basis for such pro­cess­ing, we gen­er­al­ly obtain con­sent from the data subject.

The pro­cess­ing of per­son­al data, such as the name, address, e‑mail address, or tele­phone num­ber of a data sub­ject shall always be in line with the Gen­er­al Data Pro­tec­tion Reg­u­la­tion (GDPR), and in accor­dance with the coun­try-spe­cif­ic data pro­tec­tion reg­u­la­tions applic­a­ble to the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL. By means of this data pro­tec­tion dec­la­ra­tion, our enter­prise would like to inform the gen­er­al pub­lic of the nature, scope, and pur­pose of the per­son­al data we col­lect, use and process. Fur­ther­more, data sub­jects are informed, by means of this data pro­tec­tion dec­la­ra­tion, of the rights to which they are entitled.

As the con­troller, the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL has imple­ment­ed numer­ous tech­ni­cal and orga­ni­za­tion­al mea­sures to ensure the most com­plete pro­tec­tion of per­son­al data processed through this web­site. How­ev­er, Inter­net-based data trans­mis­sions may in prin­ci­ple have secu­ri­ty gaps, so absolute pro­tec­tion may not be guar­an­teed. For this rea­son, every data sub­ject is free to trans­fer per­son­al data to us via alter­na­tive means, e.g. by telephone.

1. Definitions

The data pro­tec­tion dec­la­ra­tion of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL is based on the terms used by the Euro­pean leg­is­la­tor for the adop­tion of the Gen­er­al Data Pro­tec­tion Reg­u­la­tion (GDPR). Our data pro­tec­tion dec­la­ra­tion should be leg­i­ble and under­stand­able for the gen­er­al pub­lic, as well as our cus­tomers and busi­ness part­ners. To ensure this, we would like to first explain the ter­mi­nol­o­gy used.

In this data pro­tec­tion dec­la­ra­tion, we use, inter alia, the fol­low­ing terms:

• a) Personal data

  Per­son­al data means any infor­ma­tion relat­ing to an iden­ti­fied or iden­ti­fi­able nat­ur­al per­son (“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 or to one or more fac­tors spe­cif­ic to the phys­i­cal, phys­i­o­log­i­cal, genet­ic, men­tal, eco­nom­ic, cul­tur­al or social iden­ti­ty of that nat­ur­al person.

• b) Data subject

  Data sub­ject is any iden­ti­fied or iden­ti­fi­able nat­ur­al per­son, whose per­son­al data is processed by the con­troller respon­si­ble for the processing.

• c) Processing

  Pro­cess­ing is any oper­a­tion or set of oper­a­tions which is per­formed on per­son­al data or on sets of per­son­al data, whether or not by auto­mat­ed means, such as col­lec­tion, record­ing, organ­i­sa­tion, struc­tur­ing, stor­age, adap­ta­tion or alter­ation, retrieval, con­sul­ta­tion, use, dis­clo­sure by trans­mis­sion, dis­sem­i­na­tion or oth­er­wise mak­ing avail­able, align­ment or com­bi­na­tion, restric­tion, era­sure or destruction.

• d) Restriction of processing

  Restric­tion of pro­cess­ing is the mark­ing of stored per­son­al data with the aim of lim­it­ing their pro­cess­ing in the future.

• e) Profiling

  Pro­fil­ing means any form of auto­mat­ed pro­cess­ing of per­son­al data con­sist­ing of the use of per­son­al data to eval­u­ate cer­tain per­son­al aspects relat­ing to a nat­ur­al per­son, in par­tic­u­lar to analyse or pre­dict aspects con­cern­ing that nat­ur­al per­son­’s per­for­mance at work, eco­nom­ic sit­u­a­tion, health, per­son­al pref­er­ences, inter­ests, reli­a­bil­i­ty, behav­iour, loca­tion or movements.

• f) Pseudonymisation

  Pseu­do­nymi­sa­tion is the pro­cess­ing of per­son­al data in such a man­ner that the per­son­al data can no longer be attrib­uted to a spe­cif­ic data sub­ject with­out the use of addi­tion­al infor­ma­tion, pro­vid­ed that such addi­tion­al infor­ma­tion is kept sep­a­rate­ly and is sub­ject to tech­ni­cal and organ­i­sa­tion­al mea­sures to ensure that the per­son­al data are not attrib­uted to an iden­ti­fied or iden­ti­fi­able nat­ur­al person.

• g) Controller or controller responsible for the processing

  Con­troller or con­troller respon­si­ble for the pro­cess­ing is 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; where the pur­pos­es and means of such pro­cess­ing are deter­mined by Union or Mem­ber State law, the con­troller or the spe­cif­ic cri­te­ria for its nom­i­na­tion may be pro­vid­ed for by Union or Mem­ber State law.

• h) Processor

  Proces­sor is a nat­ur­al or legal per­son, pub­lic author­i­ty, agency or oth­er body which process­es per­son­al data on behalf of the controller.

• i) Recipient

  Recip­i­ent is a nat­ur­al or legal per­son, pub­lic author­i­ty, agency or anoth­er body, to which the per­son­al data are dis­closed, whether a third par­ty or not. How­ev­er, pub­lic author­i­ties which may receive per­son­al data in the frame­work of a par­tic­u­lar inquiry in accor­dance with Union or Mem­ber State law shall not be regard­ed as recip­i­ents; the pro­cess­ing of those data by those pub­lic author­i­ties shall be in com­pli­ance with the applic­a­ble data pro­tec­tion rules accord­ing to the pur­pos­es of the processing.

• j) Third party

  Third par­ty is a nat­ur­al or legal per­son, pub­lic author­i­ty, agency or body oth­er than the data sub­ject, con­troller, proces­sor and per­sons who, under the direct author­i­ty of the con­troller or proces­sor, are autho­rised to process per­son­al data.

• k) Consent

  Con­sent of the data sub­ject is any freely giv­en, spe­cif­ic, informed and unam­bigu­ous indi­ca­tion of the data sub­jec­t’s wish­es by which he or she, by a state­ment or by a clear affir­ma­tive action, sig­ni­fies agree­ment to the pro­cess­ing of per­son­al data relat­ing to him or her.

2. Name and Address of the controller

Con­troller for the pur­pos­es of the Gen­er­al Data Pro­tec­tion Reg­u­la­tion (GDPR), oth­er data pro­tec­tion laws applic­a­ble in Mem­ber states of the Euro­pean Union and oth­er pro­vi­sions relat­ed to data pro­tec­tion is:

Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL
Rue du Trône 194
1050 Brus­sels (Ixelles)
Belgium
Phone: +32(0)2.644.00.43
Email: [email protected]
Web­site: www.ecswe.eu

3. Cookies

The Inter­net pages of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL use cook­ies. Cook­ies are text files that are stored in a com­put­er sys­tem via an Inter­net browser.

Many Inter­net sites and servers use cook­ies. Many cook­ies con­tain a so-called cook­ie ID. A cook­ie ID is a unique iden­ti­fi­er of the cook­ie. It con­sists of a char­ac­ter string through which Inter­net pages and servers can be assigned to the spe­cif­ic Inter­net brows­er in which the cook­ie was stored. This allows vis­it­ed Inter­net sites and servers to dif­fer­en­ti­ate the indi­vid­ual brows­er of the dats sub­ject from oth­er Inter­net browsers that con­tain oth­er cook­ies. A spe­cif­ic Inter­net brows­er can be rec­og­nized and iden­ti­fied using the unique cook­ie ID.

Through the use of cook­ies, the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL can pro­vide the users of this web­site with more user-friend­ly ser­vices that would not be pos­si­ble with­out the cook­ie setting.

By means of a cook­ie, the infor­ma­tion and offers on our web­site can be opti­mized with the user in mind. Cook­ies allow us, as pre­vi­ous­ly men­tioned, to rec­og­nize our web­site users. The pur­pose of this recog­ni­tion is to make it eas­i­er for users to uti­lize our web­site. The web­site user that uses cook­ies, e.g. does not have to enter access data each time the web­site is accessed, because this is tak­en over by the web­site, and the cook­ie is thus stored on the user’s com­put­er sys­tem. Anoth­er exam­ple is the cook­ie of a shop­ping cart in an online shop. The online store remem­bers the arti­cles that a cus­tomer has placed in the vir­tu­al shop­ping cart via a cookie.

The data sub­ject may, at any time, pre­vent the set­ting of cook­ies through our web­site by means of a cor­re­spond­ing set­ting of the Inter­net brows­er used, and may thus per­ma­nent­ly deny the set­ting of cook­ies. Fur­ther­more, already set cook­ies may be delet­ed at any time via an Inter­net brows­er or oth­er soft­ware pro­grams. This is pos­si­ble in all pop­u­lar Inter­net browsers. If the data sub­ject deac­ti­vates the set­ting of cook­ies in the Inter­net brows­er used, not all func­tions of our web­site may be entire­ly usable.

Anoth­er cook­ie called “privacy_embeds” is set. This saves the user’s set­tings regard­ing the con­sent to load con­tent (third par­ty providers, such as YouTube) as well as the select­ed set­tings for set­ting track­ing cookies.

 

4. Collection of general data and information

The web­site of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL col­lects a series of gen­er­al data and infor­ma­tion when a data sub­ject or auto­mat­ed sys­tem calls up the web­site. This gen­er­al data and infor­ma­tion are stored in the serv­er log files. Col­lect­ed may be (1) the brows­er types and ver­sions used, (2) the oper­at­ing sys­tem used by the access­ing sys­tem, (3) the web­site from which an access­ing sys­tem reach­es our web­site (so-called refer­rers), (4) the sub-web­sites, (5) the date and time of access to the Inter­net site, (6) an Inter­net pro­to­col address (IP address), (7) the Inter­net ser­vice provider of the access­ing sys­tem, and (8) any oth­er sim­i­lar data and infor­ma­tion that may be used in the event of attacks on our infor­ma­tion tech­nol­o­gy systems.

When using these gen­er­al data and infor­ma­tion, the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL does not draw any con­clu­sions about the data sub­ject. Rather, this infor­ma­tion is need­ed to (1) deliv­er the con­tent of our web­site cor­rect­ly, (2) opti­mize the con­tent of our web­site as well as its adver­tise­ment, (3) ensure the long-term via­bil­i­ty of our infor­ma­tion tech­nol­o­gy sys­tems and web­site tech­nol­o­gy, and (4) pro­vide law enforce­ment author­i­ties with the infor­ma­tion nec­es­sary for crim­i­nal pros­e­cu­tion in case of a cyber-attack. There­fore, the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL ana­lyzes anony­mous­ly col­lect­ed data and infor­ma­tion sta­tis­ti­cal­ly, with the aim of increas­ing the data pro­tec­tion and data secu­ri­ty of our enter­prise, and to ensure an opti­mal 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 a data subject.

5. Subscription to our newsletters

On the web­site of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL, users are giv­en the oppor­tu­ni­ty to sub­scribe to our enter­prise’s newslet­ter. The input mask used for this pur­pose deter­mines what per­son­al data are trans­mit­ted, as well as when the newslet­ter is ordered from the controller.

The Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL informs its cus­tomers and busi­ness part­ners reg­u­lar­ly by means of a newslet­ter about enter­prise offers. The enter­prise’s newslet­ter may only be received by the data sub­ject if (1) the data sub­ject has a valid e‑mail address and (2) the data sub­ject reg­is­ters for the newslet­ter ship­ping. A con­fir­ma­tion e‑mail will be sent to the e‑mail address reg­is­tered by a data sub­ject for the first time for newslet­ter ship­ping, for legal rea­sons, in the dou­ble opt-in pro­ce­dure. This con­fir­ma­tion e‑mail is used to prove whether the own­er of the e‑mail address as the data sub­ject is autho­rized to receive the newsletter.

Dur­ing the reg­is­tra­tion for the newslet­ter, we also store the IP address of the com­put­er sys­tem assigned by the Inter­net ser­vice provider (ISP) and used by the data sub­ject at the time of the reg­is­tra­tion, as well as the date and time of the reg­is­tra­tion. The col­lec­tion of this data is nec­es­sary in order to under­stand the (pos­si­ble) mis­use of the e‑mail address of a data sub­ject at a lat­er date, and it there­fore serves the aim of the legal pro­tec­tion of the controller.

The per­son­al data col­lect­ed as part of a reg­is­tra­tion for the newslet­ter will only be used to send our newslet­ter. In addi­tion, sub­scribers to the newslet­ter may be informed by e‑mail, as long as this is nec­es­sary for the oper­a­tion of the newslet­ter ser­vice or a reg­is­tra­tion in ques­tion, as this could be the case in the event of mod­i­fi­ca­tions to the newslet­ter offer, or in the event of a change in tech­ni­cal cir­cum­stances. There will be no trans­fer of per­son­al data col­lect­ed by the newslet­ter ser­vice to third par­ties. The sub­scrip­tion to our newslet­ter may be ter­mi­nat­ed by the data sub­ject at any time. The con­sent to the stor­age of per­son­al data, which the data sub­ject has giv­en for ship­ping the newslet­ter, may be revoked at any time. For the pur­pose of revo­ca­tion of con­sent, a cor­re­spond­ing link is found in each newslet­ter. It is also pos­si­ble to unsub­scribe from the newslet­ter at any time direct­ly on the web­site of the con­troller, or to com­mu­ni­cate this to the con­troller in a dif­fer­ent way.

6. Newsletter-Tracking

The newslet­ter of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL con­tains so-called track­ing pix­els. A track­ing pix­el is a minia­ture graph­ic embed­ded in such e‑mails, which are sent in HTML for­mat to enable log file record­ing and analy­sis. This allows a sta­tis­ti­cal analy­sis of the suc­cess or fail­ure of online mar­ket­ing cam­paigns. Based on the embed­ded track­ing pix­el, the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL may see if and when an e‑mail was opened by a data sub­ject, and which links in the e‑mail were called up by data subjects.

Such per­son­al data col­lect­ed in the track­ing pix­els con­tained in the newslet­ters are stored and ana­lyzed by the con­troller in order to opti­mize the ship­ping of the newslet­ter, as well as to adapt the con­tent of future newslet­ters even bet­ter to the inter­ests of the data sub­ject. These per­son­al data will not be passed on to third par­ties. Data sub­jects are at any time enti­tled to revoke the respec­tive sep­a­rate dec­la­ra­tion of con­sent issued by means of the dou­ble-opt-in pro­ce­dure. After a revo­ca­tion, these per­son­al data will be delet­ed by the con­troller. The Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL auto­mat­i­cal­ly regards a with­draw­al from the receipt of the newslet­ter as a revocation.

7. Contact possibility via the website

The web­site of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL con­tains infor­ma­tion that enables a quick elec­tron­ic con­tact to our enter­prise, 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 con­troller by e‑mail or via a con­tact form, the per­son­al data trans­mit­ted by the data sub­ject are auto­mat­i­cal­ly stored. Such per­son­al data trans­mit­ted on a vol­un­tary basis by a data sub­ject to the data con­troller are stored for the pur­pose of pro­cess­ing or con­tact­ing the data sub­ject. There is no trans­fer of this per­son­al data to third parties.

8. Routine erasure and blocking of personal data

The data con­troller shall process and store the per­son­al data of the data sub­ject only for the peri­od nec­es­sary to achieve the pur­pose of stor­age, or as far as this is grant­ed by the Euro­pean leg­is­la­tor or oth­er leg­is­la­tors in laws or reg­u­la­tions to which the con­troller is sub­ject to.

If the stor­age pur­pose is not applic­a­ble, or if a stor­age peri­od pre­scribed by the Euro­pean leg­is­la­tor or anoth­er com­pe­tent leg­is­la­tor expires, the per­son­al data are rou­tine­ly blocked or erased in accor­dance with legal requirements.

9. Rights of the data subject

• a) Right of confirmation

  Each data sub­ject shall have the right grant­ed by the Euro­pean leg­is­la­tor to obtain from the con­troller the con­fir­ma­tion as to whether or not per­son­al data con­cern­ing him or her are being processed. If a data sub­ject wish­es to avail him­self of this right of con­fir­ma­tion, he or she may, at any time, con­tact any employ­ee of the controller.

• b) Right of access

  Each data sub­ject shall have the right grant­ed by the Euro­pean leg­is­la­tor to obtain from the con­troller free infor­ma­tion about his or her per­son­al data stored at any time and a copy of this infor­ma­tion. Fur­ther­more, the Euro­pean direc­tives and reg­u­la­tions grant the data sub­ject access to the fol­low­ing information:

  • the pur­pos­es of the processing;
  • the cat­e­gories of per­son­al data concerned;
  • 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 organisations;
  • where pos­si­ble, the envis­aged peri­od for which the per­son­al data will be stored, or, if not pos­si­ble, the cri­te­ria used to deter­mine that period;
  • the exis­tence of the right to request from the con­troller rec­ti­fi­ca­tion or era­sure of per­son­al data, or restric­tion of pro­cess­ing of per­son­al data con­cern­ing the data sub­ject, or to object to such processing;
  • the exis­tence of the right to lodge a com­plaint with a super­vi­so­ry authority;
  • where the per­son­al data are not col­lect­ed from the data sub­ject, any avail­able infor­ma­tion as to their source;
  • the exis­tence of auto­mat­ed deci­sion-mak­ing, includ­ing pro­fil­ing, referred to in Arti­cle 22(1) and (4) of the GDPR and, at least in those cas­es, mean­ing­ful infor­ma­tion about the log­ic involved, as well as the sig­nif­i­cance and envis­aged con­se­quences of such pro­cess­ing for the data subject.

  Fur­ther­more, the data sub­ject shall have a right to obtain infor­ma­tion as to whether per­son­al data are trans­ferred to a third coun­try or to an inter­na­tion­al organ­i­sa­tion. Where this is the case, the data sub­ject shall have the right to be informed of the appro­pri­ate safe­guards relat­ing to the transfer.

  If a data sub­ject wish­es to avail him­self of this right of access, he or she may, at any time, con­tact any employ­ee of the controller.

• c) Right to rectification

  Each data sub­ject shall have the right grant­ed by the Euro­pean leg­is­la­tor to obtain from the con­troller with­out undue delay the rec­ti­fi­ca­tion of inac­cu­rate per­son­al data con­cern­ing him or her. Tak­ing into account the pur­pos­es of the pro­cess­ing, the data sub­ject shall have the right to have incom­plete per­son­al data com­plet­ed, includ­ing by means of pro­vid­ing a sup­ple­men­tary statement.

  If a data sub­ject wish­es to exer­cise this right to rec­ti­fi­ca­tion, he or she may, at any time, con­tact any employ­ee of the controller.

• d) Right to erasure (Right to be forgotten)

  Each data sub­ject shall have the right grant­ed by the Euro­pean leg­is­la­tor to obtain from the con­troller the era­sure of per­son­al data con­cern­ing him or her with­out undue delay, and the con­troller shall have the oblig­a­tion to erase per­son­al data with­out undue delay where one of the fol­low­ing grounds applies, as long as the pro­cess­ing is not necessary:

  • The per­son­al data are no longer nec­es­sary in rela­tion to the pur­pos­es for which they were col­lect­ed or oth­er­wise processed.
  • The data sub­ject with­draws con­sent to which the pro­cess­ing is based accord­ing to point (a) of Arti­cle 6(1) of the GDPR, or point (a) of Arti­cle 9(2) of the GDPR, and where there is no oth­er legal ground for the processing.
  • The data sub­ject objects to the pro­cess­ing pur­suant to Arti­cle 21(1) of the GDPR and there are no over­rid­ing legit­i­mate grounds for the pro­cess­ing, or the data sub­ject objects to the pro­cess­ing pur­suant to Arti­cle 21(2) of the GDPR.
  • The per­son­al data have been unlaw­ful­ly processed.
  • The per­son­al data must be erased for com­pli­ance with a legal oblig­a­tion in Union or Mem­ber State law to which the con­troller is subject.
  • The per­son­al data have been col­lect­ed in rela­tion to the offer of infor­ma­tion soci­ety ser­vices referred to in Arti­cle 8(1) of the GDPR.

  If one of the afore­men­tioned rea­sons applies, and a data sub­ject wish­es to request the era­sure of per­son­al data stored by the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL, he or she may, at any time, con­tact any employ­ee of the con­troller. An employ­ee of Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL shall prompt­ly ensure that the era­sure request is com­plied with immediately.

  Where the con­troller has made per­son­al data pub­lic and is oblig­ed pur­suant to Arti­cle 17(1) to erase the per­son­al data, the con­troller, tak­ing account of avail­able tech­nol­o­gy and the cost of imple­men­ta­tion, shall take rea­son­able steps, includ­ing tech­ni­cal mea­sures, to inform oth­er con­trollers pro­cess­ing the per­son­al data that the data sub­ject has request­ed era­sure by such con­trollers of any links to, or copy or repli­ca­tion of, those per­son­al data, as far as pro­cess­ing is not required. An employ­ees of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL will arrange the nec­es­sary mea­sures in indi­vid­ual cases.

• e) Right of restriction of processing

  Each data sub­ject shall have the right grant­ed by the Euro­pean leg­is­la­tor to obtain from the con­troller restric­tion of pro­cess­ing where one of the fol­low­ing applies:

  • The accu­ra­cy of the per­son­al data is con­test­ed by the data sub­ject, for a peri­od enabling the con­troller to ver­i­fy the accu­ra­cy of the per­son­al data.
  • The pro­cess­ing is unlaw­ful and the data sub­ject oppos­es the era­sure of the per­son­al data and requests instead the restric­tion of their use instead.
  • The con­troller no longer needs the per­son­al data for the pur­pos­es of the pro­cess­ing, but they are required by the data sub­ject for the estab­lish­ment, exer­cise or defence of legal claims.
  • The data sub­ject has object­ed to pro­cess­ing pur­suant to Arti­cle 21(1) of the GDPR pend­ing the ver­i­fi­ca­tion whether the legit­i­mate grounds of the con­troller over­ride those of the data subject.

  If one of the afore­men­tioned con­di­tions is met, and a data sub­ject wish­es to request the restric­tion of the pro­cess­ing of per­son­al data stored by the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL, he or she may at any time con­tact any employ­ee of the con­troller. The employ­ee of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL will arrange the restric­tion of the processing.

• f) Right to data portability

  Each data sub­ject shall have the right grant­ed by the Euro­pean leg­is­la­tor, to receive the per­son­al data con­cern­ing him or her, which was pro­vid­ed to a con­troller, in a struc­tured, com­mon­ly used and machine-read­able for­mat. He or she shall have the right to trans­mit those data to anoth­er con­troller with­out hin­drance from the con­troller to which the per­son­al data have been pro­vid­ed, as long as the pro­cess­ing is based on con­sent pur­suant to point (a) of Arti­cle 6(1) of the GDPR or point (a) of Arti­cle 9(2) of the GDPR, or on a con­tract pur­suant to point (b) of Arti­cle 6(1) of the GDPR, and the pro­cess­ing is car­ried out by auto­mat­ed means, as long as the pro­cess­ing is not nec­es­sary for the per­for­mance of a task car­ried out in the pub­lic inter­est or in the exer­cise of offi­cial author­i­ty vest­ed in the controller.

  Fur­ther­more, in exer­cis­ing his or her right to data porta­bil­i­ty pur­suant to Arti­cle 20(1) of the GDPR, the data sub­ject shall have the right to have per­son­al data trans­mit­ted direct­ly from one con­troller to anoth­er, where tech­ni­cal­ly fea­si­ble and when doing so does not adverse­ly affect the rights and free­doms of others.

  In order to assert the right to data porta­bil­i­ty, the data sub­ject may at any time con­tact any employ­ee of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL.

• g) Right to object

  Each data sub­ject shall have the right grant­ed by the Euro­pean leg­is­la­tor to object, on grounds relat­ing to his or her par­tic­u­lar sit­u­a­tion, at any time, to pro­cess­ing of per­son­al data con­cern­ing him or her, which is based on point (e) or (f) of Arti­cle 6(1) of the GDPR. This also applies to pro­fil­ing based on these provisions.

  The Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL shall no longer process the per­son­al data in the event of the objec­tion, unless we can demon­strate com­pelling legit­i­mate grounds for the pro­cess­ing which over­ride the inter­ests, rights and free­doms of the data sub­ject, or for the estab­lish­ment, exer­cise or defence of legal claims.

  If the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL process­es per­son­al data for direct mar­ket­ing pur­pos­es, the data sub­ject shall have the right to object at any time to pro­cess­ing of per­son­al data con­cern­ing him or her for such mar­ket­ing. This applies to pro­fil­ing to the extent that it is relat­ed to such direct mar­ket­ing. If the data sub­ject objects to the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL to the pro­cess­ing for direct mar­ket­ing pur­pos­es, the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL will no longer process the per­son­al data for these purposes.

  In addi­tion, the data sub­ject has the right, on grounds relat­ing to his or her par­tic­u­lar sit­u­a­tion, to object to pro­cess­ing of per­son­al data con­cern­ing him or her by the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL for sci­en­tif­ic or his­tor­i­cal research pur­pos­es, or for sta­tis­ti­cal pur­pos­es pur­suant to Arti­cle 89(1) of the GDPR, unless the pro­cess­ing is nec­es­sary for the per­for­mance of a task car­ried out for rea­sons of pub­lic interest.

  In order to exer­cise the right to object, the data sub­ject may con­tact any employ­ee of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL. In addi­tion, the data sub­ject is free in the con­text of the use of infor­ma­tion soci­ety ser­vices, and notwith­stand­ing Direc­tive 2002/58/EC, to use his or her right to object by auto­mat­ed means using tech­ni­cal specifications.

• h) Automated individual decision-making, including profiling

  Each data sub­ject shall have the right grant­ed by the Euro­pean leg­is­la­tor not to be sub­ject to a deci­sion based sole­ly on auto­mat­ed pro­cess­ing, includ­ing pro­fil­ing, which pro­duces legal effects con­cern­ing him or her, or sim­i­lar­ly sig­nif­i­cant­ly affects him or her, as long as the deci­sion (1) is not is nec­es­sary for enter­ing into, or the per­for­mance of, a con­tract between the data sub­ject and a data con­troller, or (2) is not autho­rised by Union or Mem­ber State law to which the con­troller is sub­ject and which also lays down suit­able mea­sures to safe­guard the data sub­jec­t’s rights and free­doms and legit­i­mate inter­ests, or (3) is not based on the data sub­jec­t’s explic­it consent.

  If the deci­sion (1) is nec­es­sary for enter­ing into, or the per­for­mance of, a con­tract between the data sub­ject and a data con­troller, or (2) it is based on the data sub­jec­t’s explic­it con­sent, the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL shall imple­ment suit­able mea­sures to safe­guard the data sub­jec­t’s rights and free­doms and legit­i­mate inter­ests, at least the right to obtain human inter­ven­tion on the part of the con­troller, to express his or her point of view and con­test the decision.

  If the data sub­ject wish­es to exer­cise the rights con­cern­ing auto­mat­ed indi­vid­ual deci­sion-mak­ing, he or she may, at any time, con­tact any employ­ee of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL.

• i) Right to withdraw data protection consent

  Each data sub­ject shall have the right grant­ed by the Euro­pean leg­is­la­tor to with­draw his or her con­sent to pro­cess­ing of his or her per­son­al data at any time.

  If the data sub­ject wish­es to exer­cise the right to with­draw the con­sent, he or she may, at any time, con­tact any employ­ee of the Euro­pean Coun­cil for Stein­er Wal­dorf Edu­ca­tion AISBL.

10. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the 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 data sub­ject is par­ty, as is the case, for exam­ple, when pro­cess­ing oper­a­tions are nec­es­sary for the sup­ply of goods or to pro­vide any oth­er ser­vice, the pro­cess­ing is based on Arti­cle 6(1) lit. b GDPR. The same applies to such pro­cess­ing oper­a­tions which are nec­es­sary for car­ry­ing out pre-con­trac­tu­al mea­sures, for exam­ple in the case of inquiries con­cern­ing our prod­ucts or ser­vices. Is our com­pa­ny sub­ject to a legal oblig­a­tion by which pro­cess­ing of per­son­al data is required, such as for the ful­fill­ment of tax oblig­a­tions, the pro­cess­ing is based on Art. 6(1) lit. c GDPR.
In rare cas­es, the pro­cess­ing of per­son­al data may be nec­es­sary to pro­tect the vital inter­ests of the data sub­ject or of anoth­er nat­ur­al per­son. This would be the case, for exam­ple, if a vis­i­tor were injured in our com­pa­ny and his name, age, health insur­ance data or oth­er vital infor­ma­tion would have to be passed on to a doc­tor, hos­pi­tal or oth­er third par­ty. Then the pro­cess­ing would be based on Art. 6(1) lit. d GDPR.
Final­ly, pro­cess­ing oper­a­tions could be based on Arti­cle 6(1) lit. f GDPR. This legal basis is used for pro­cess­ing oper­a­tions which are not cov­ered by any of the above­men­tioned legal grounds, if pro­cess­ing is nec­es­sary for the pur­pos­es of the legit­i­mate inter­ests pur­sued by our com­pa­ny 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. Such pro­cess­ing oper­a­tions are par­tic­u­lar­ly per­mis­si­ble because they have been specif­i­cal­ly men­tioned by the Euro­pean leg­is­la­tor. He con­sid­ered that a legit­i­mate inter­est could be assumed if the data sub­ject is a client of the con­troller (Recital 47 Sen­tence 2 GDPR).

11. The legitimate interests pursued by the controller or by a third party

Where the pro­cess­ing of per­son­al data is based on Arti­cle 6(1) lit. f GDPR our legit­i­mate inter­est is to car­ry out our busi­ness in favor of the well-being of all our employ­ees and the shareholders.

12. Period for which the personal data will be stored

The cri­te­ria used to deter­mine the peri­od of stor­age of per­son­al data is the respec­tive statu­to­ry reten­tion peri­od. After expi­ra­tion of that peri­od, the cor­re­spond­ing data is rou­tine­ly delet­ed, as long as it is no longer nec­es­sary for the ful­fill­ment of the con­tract or the ini­ti­a­tion of a contract.

13. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clar­i­fy that the pro­vi­sion of per­son­al data is part­ly required by law (e.g. tax reg­u­la­tions) or can also result from con­trac­tu­al pro­vi­sions (e.g. infor­ma­tion on the con­trac­tu­al partner).

Some­times it may be nec­es­sary to con­clude a con­tract that the data sub­ject pro­vides us with per­son­al data, which must sub­se­quent­ly be processed by us. The data sub­ject is, for exam­ple, oblig­ed to pro­vide us with per­son­al data when our com­pa­ny signs a con­tract with him or her. The non-pro­vi­sion of the per­son­al data would have the con­se­quence that the con­tract with the data sub­ject could not be concluded.

Before per­son­al data is pro­vid­ed by the data sub­ject, the data sub­ject must con­tact any employ­ee. The employ­ee clar­i­fies to the data sub­ject whether the pro­vi­sion of the per­son­al data is required by law or con­tract or is nec­es­sary for the con­clu­sion of the con­tract, whether there is an oblig­a­tion to pro­vide the per­son­al data and the con­se­quences of non-pro­vi­sion of the per­son­al data.

14. Existence of automated decision-making

As a respon­si­ble com­pa­ny, we do not use auto­mat­ic deci­sion-mak­ing or profiling.

This Pri­va­cy Pol­i­cy has been gen­er­at­ed by the Pri­va­cy Pol­i­cy Gen­er­a­tor of the Ger­man Asso­ci­a­tion for Data Pro­tec­tion that was devel­oped in coop­er­a­tion with Pri­va­cy Lawyers from WILDE BEUGER SOLMECKE, Cologne.