1) Introduction and contact details of the responsible person

1.1 We are pleased that you are visiting our website and thank you for your interest. In the following, we will inform you about how we handle your personal data when you use our website. Personal data in this context is all data with which you can be personally identified.

1.2 The person responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Florian Roloff, Steinkauler Straße 4, 53474 Bad Neuenahr-Ahrweiler, Germany, Tel.: +61 466341492, e-mail: florian@innercircle-development.com. The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

1.3 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or requests to the controller). You can recognize an encrypted connection by the string "https://" and the lock symbol in your browser line.

2) Data collection when visiting our website

During the mere informational use of our website, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data, which is technically necessary for us to display the website to you:

- Our visited website

- Date and time at the time of access

- Amount of data sent in bytes

- Source/reference from which you reached the page

- Browser used

- Operating system used

- IP address used (if applicable: in anonymized form)

The processing is carried out in accordance with Art. 6 para. 1 lit. f DSGVO on the basis of our legitimate interest in improving the stability and functionality of our website. The data is not passed on or used in any other way. However, we reserve the right to check the server log files retrospectively should concrete indications point to illegal use.

3) Cookies

In order to make visiting our website more attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your terminal device. In some cases, these cookies are automatically deleted after you close your browser (so-called "session cookies"), in other cases, these cookies remain on your end device for a longer period of time and allow you to save page settings (so-called "persistent cookies"). In the latter case, you can find the storage period in the overview of the cookie settings of your web browser.

If personal data is also processed by individual cookies used by us, the processing is carried out in accordance with Art. 6 para. 1 lit. b DSGVO either for the performance of the contract, in accordance with Art. 6 para. 1 lit. a DSGVO in the case of consent given, or in accordance with Art. 6 para. 1 lit. f DSGVO to protect our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit.

You can set your browser in such a way that you are informed about the setting of cookies and can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.

Please note that if you do not accept cookies, the functionality of our website may be limited.

4) Contacting

4.1 Calendly

This website uses the "Calendly" software of the provider Calendly, LLC, BB&T Tower, 271 17th St NW, Atlanta, GA 30363, USA to provide an online appointment booking function.

For the purpose of scheduling appointments, first and last name as well as email address (and telephone number, if a telephone appointment is desired) are collected pursuant to Art. 6 (1) lit. b DSGVO and transmitted to Calendly pursuant to Art. 6 (1) lit. f DSGVO based on our legitimate interest in effective customer management and efficient appointment management and stored there for the appointment organization. After the appointment has been held or after the agreed appointment period has expired, your data will be deleted by Calendly. We have concluded an order processing agreement with Calendly ("Data Processing Addendum", available at https://calendly.com/pages/dpa), in which we oblige Calendly to protect the data of our customers in accordance with the legal requirements. Calendly generally transfers collected information outside of the European Economic Area and relies on so-called standard data protection clauses of the European Commission, which are intended to ensure compliance with the European level of data protection.

Details on the data protection provisions of Calendly can be found here: https://calendly.com/de/pages/privacy.

4.2 When contacting us (e.g. via contact form or e-mail), personal data is processed - exclusively for the purpose of processing and responding to your request and only to the extent necessary for this purpose. The legal basis for processing this data is our legitimate interest in responding to your request pursuant to Art. 6 (1) lit. f DSGVO. If your contact is aimed at a contract, the additional legal basis for processing is Art. 6 (1) lit. b DSGVO. Your data will be deleted when the circumstances indicate that the matter in question has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

5) Data processing for order processing

5.1 Insofar as necessary for the processing of the contract for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 Para. 1 lit. b DSGVO.

If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we will process the contact data (name, address, e-mail address) provided by you when placing the order in order to inform you personally about upcoming updates within the legally stipulated period within the framework of our legal information obligations pursuant to Art. 6 (1) lit. c DSGVO by suitable means of communication (e.g. by post or e-mail). Your contact data will be used strictly for the purpose of informing you about updates owed by us and will only be processed by us for this purpose to the extent necessary for the respective information.

In order to process your order, we also work together with the service provider(s) listed below, who support us in whole or in part in the execution of concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information.

5.2 Use of payment service providers (payment services)

- Stripe

If you choose a payment method of the payment service provider Stripe, the payment processing is carried out via the payment service provider Stripe Payments Europe Ltd, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland, to whom we pass on your information provided during the ordering process together with information about your order (name, address, account number, bank code, possibly credit card number, invoice amount, currency and transaction number) in accordance with Art. 6 (1) lit. b DSGVO. You can find more information about Stripe's data protection at the URL https://stripe.com/de/privacy#translation.

Stripe reserves the right to perform a credit check based on mathematical-statistical methods in order to safeguard the legitimate interest in determining the User's ability to pay. The personal data necessary for a credit check and obtained in the course of payment processing may be transmitted by Stripe to selected credit agencies, which Stripe discloses to Users upon request. The credit report may contain probability values (so-called score values). Insofar as score values are included in the result of the credit report, these have their basis in a scientifically recognized mathematical-statistical procedure. The calculation of the score values includes, but is not limited to, address data. Stripe uses the result of the credit check in relation to the statistical probability of non-payment for the purpose of deciding on the authorization to use the selected payment method.

You can object to this processing of your data at any time by sending a message to Stripe or the assigned credit agencies.

However, Stripe may still be entitled to process your personal data if this is necessary to process payments in accordance with the contract.

6) Site functionalities

- Zoom

We use the "Zoom" service of Zoom Video Communications Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA (hereinafter "Zoom") to conduct online meetings, video conferences and/or webinars.

In the case of the use of Zoom, different data are processed. Here, the scope of the processed data depends on the data you provide before or during participation in an online meeting or video conference or webinar. In the course of using Zoom, data of communication participants is processed and stored on Zoom servers. This data may include, in particular, your login data (name, email address, phone (optional) and password) and meeting data (topic, participant IP address, device information, description (optional)). In addition, visual and auditory contributions of the participants, as well as voice input in chats may be processed.

When processing personal data that is necessary for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures), Art. 6 (1) lit. b DSGVO serves as the legal basis. If you have given us your consent for the processing of your data, the processing is based on Art. 6 (1) a DSGVO. Consent given can be revoked at any time with effect for the future.

Otherwise, the legal basis for data processing when conducting online meetings, videoconferences or webinars is our legitimate interest pursuant to Art. 6 (1) lit. f DSGVO in the effective conduct of the online meeting, webinar or videoconference. For more information on Zoom's use of data, please see Zoom's privacy policy at https://zoom.us/docs/de-de/privacy-and-legal.html.

7) Tools and other

Cookie consent tool

This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "Cookie Consent Tool" is displayed to users in the form of an interactive user interface when they call up the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box. By using the tool, all cookies/services requiring consent are only loaded if the respective user grants the corresponding consent by setting a check mark. This ensures that such cookies are only set on the respective user's end device if consent has been granted.

The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed in this context.

If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) f DSGVO on the basis of our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.

Further legal basis for the processing is Art. 6 para. 1 lit. c DSGVO. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.

Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.

8) Rights of the data subject

8.1 The applicable data protection law grants you the following data subject rights (rights of information and intervention) vis-à-vis the controller with regard to the processing of your personal data, whereby reference is made to the stated legal basis for the respective exercise prerequisites:

- Right to information pursuant to Art. 15 DSGVO;

- Right to rectification pursuant to Art. 16 DSGVO;

- Right to erasure pursuant to Art. 17 DSGVO;

- Right to restriction of processing pursuant to Art. 18 DSGVO;

- Right to information pursuant to Art. 19 DSGVO;

- Right to data portability pursuant to Art. 20 DSGVO;

- Right to withdraw consent given pursuant to Art. 7(3) DSGVO;

- Right to lodge a complaint pursuant to Art. 77 DSGVO.

8.2 RIGHT OF OBJECTION

IF WE PROCESS YOUR PERSONAL DATA WITHIN THE FRAMEWORK OF A BALANCING OF INTERESTS ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO CONTINUE PROCESSING IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING IS FOR THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR THE PURPOSES OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSES OF SUCH MARKETING. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

9) Duration of the storage of personal data

The duration of the storage of personal data is measured on the basis of the respective legal basis, the purpose of processing and - if relevant - additionally on the basis of the respective statutory retention period (e.g. retention periods under commercial and tax law).

When processing personal data on the basis of explicit consent pursuant to Art. 6 (1) a DSGVO, this data is stored until the data subject revokes his or her consent.

If there are legal retention periods for data that is processed within the scope of legal business or similar obligations on the basis of Art. 6 Para. 1 lit. b DSGVO, this data will be routinely deleted after the retention periods have expired, insofar as it is no longer required for the fulfillment of a contract or the initiation of a contract and/or there is no continued legitimate interest on our part in the continued storage.

When processing personal data on the basis of Art. 6(1)(f) DSGVO, this data is stored until the data subject exercises his or her right to object pursuant to Art. 21(1) DSGVO, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

When processing personal data for the purpose of direct marketing on the basis of Article 6 (1) (f) DSGVO, this data is stored until the data subject exercises his or her right to object pursuant to Article 21 (2) DSGVO.

Unless otherwise stated in the other information in this statement about specific processing situations, stored personal data will otherwise be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.