This entire website is intended for an international, english speaking audience. All content that I provide and all services that I offer require an understanding of the English language. Accordingly this privacy policy is provided in English as well.
Privacy Policy
Hello.
First of all: Thank you for your interest in my site and me. 🙂
I am Patrick Östreicher, Online Educator and both creator as well as maintainer of the contents of this website.
Data protection is a very important subject and I do treat it as such.
This Privacy Policy describes how your personal information is used, collected and shared when you visit or otherwise interact with this website "www.seekinglightfx.com".
Should you wish to utilize specific products or services offered by me, be it through my website or otherwise, processing of personal data may become necessary.
In general, user consent is requested before any processing of personal data, unless the processing required falls under an exemption as specified in the regulatory framework.
The way that personal data is processed - for example name, e-mail address, address or telephone number of a data subject - shall always be in accordance with the General Data Protection Regulation (GDPR), and conform to the country-specific data protection regulations applicable to Patrick Östreicher Online Educator.
This Privacy Policy document will also supply to you details about the nature, scope, and purpose of the personal data that is collected, used and processed. On top of this you will be informed about the rights to which you are entitled regarding your data.
I, Patrick Östreicher Online Educator, have as the controller put into place a bunch of 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 and perfect protection can never be guaranteed. For this reason, every data subject is free to transfer personal data to me through other means as well, for example by telephone.
1. Definitions
This Privacy Policy uses certain terms that are based on the ones used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Since the point of a Privacy Policy is to be understandable for everyone potentially impacted by its contents - so basically everyone, from the general public to my direct customers and business partners - it is only sensible to explain a few of the terms used first.
The following terms are used throughout this document:
-
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
A "data subject" is any identified or identifiable natural person, who is the subject of data processing.
-
c) Processing
Processing means 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 means 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 means 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
Controller means 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 means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
-
i) Recipient
Recipient means 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 means 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 means 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:
Patrick Östreicher Online Educator
Augustinerstr. 31
55116 Mainz
Deutschland
Phone: +4916099605433
Email: impressumalias201902@seekinglightfx.com
Website: www.seekinglightfx.com
3. Cookies
The website of Patrick Östreicher Online Educator uses cookies. These so called cookies are really text files that are stored on a computer system by an Internet browser. They often include an anonymous unique identifier.
A whole lot of internet sites, CMS and servers use cookies. As mentioned, cookies can contain a cookie ID. This cookie ID is a unique identifier of the cookie. The unique identifier consists of a character string, with which Internet pages and servers can recognize the specific internet browser in which the cookie was stored. This lets visited internet sites and servers differentiate the individual browser of the data subject from other internet browsers that have other cookies. So, a specific internet browser can be recognized and identified with the help of this unique cookie ID.
The reason for using cookies in the first place is this: Through the use of cookies, I, Patrick Östreicher Online Educator, can provide users of this website with more user-friendly services that would not be possible without cookies.
With the help of cookies, information and offers on this website can be optimized for the user. Cookies allow, as already mentioned, to recognize website users. The purpose of this is to make it easier for users to use the website and to enable some functionalities at all. For example using cookies allows to set preferences. Cookies are also mandatory in order to remember login data so that one does not have to enter access data each time the website is accessed. It is similiar with shopping carts. Cookies make it possible to remember articles that have been placed in the virtual shopping cart. It is not possible to list all potential possible uses of cookies here, but the overall idea of using cookies is to provide personalized convenience and function.
However, should for any reason you, the data subject, not wish to allow the setting of cookies, you have ways and means to prevent this. Your internet browser has options that can disable the setting of cookies. This way, you can permanently deny the setting of cookies. Should some cookies already have been stored on your device, you also have the option to delete any and all already existing cookies in your internet browsers settings as well. Third party software programs can also facilitate this. But in general, managing cookies and deleting them is possible in all popular Internet browsers. Please bear in mind that if you choose to delete or completely disable cookies, some or all advanced or enhanced functions of this website may not be useable.
4. Collection of general data and information
The website of Patrick Östreicher Online Educator collects a variety of general data as well as information when a data subject or automated system loads and navigates this website. This general data as well as information are stored in server log files on the server storing this website. Things that are collected may be (1) the browser type and version of the web browser used, (2) the operating system that is used by the system accessing the website, (3) the website from which a system accessing this website reaches this website (this is called a "referrer"), (4) sub-websites reached, (5) the date and time of when this internet site was accessed, (6) an internet protocol address (IP address), (7) the name of the internet service provider of the system accessing this website, and (8) any other similar data and information that may be used should there be any kind of attacks on this information technology system.
Patrick Östreicher Online Educator can not and does not draw any conclusions about you, the data subject, when utilizing this general data and information. Here, too, this information is required in order to (1) deliver the content of this website properly and correctly, (2) optimize and improve the content of this website as well as its advertisement and display, (3) ensure the long-term viability of the involved information technology systems as well as website technology, and (4) in case of attack, for example cyber-attacks - such as hacking attempts, DDOS or any other - or other criminal activities, provide law enforcement authorities with the information necessary for criminal prosecution. Therefore, Patrick Östreicher Online Educator the anonymously collected data and information will be used and analyed statistically, with the overall goad of increasing data protection and data security of the business and enterprise, as well as to ensure an optimum and ideally maximum achievable level of protection for all of the personal data processed. To be clear, the anonymous data that is stored in the server log files is stored separately from all other personal data that is provided by a data subject.
5. Registration on our website
It is possible for the data subject to register on this website and supply some kind of personal data. Which personal data is supplied and transmitted to this website and the controller of this website is determined by the respective utilized input mask used for the registration. This personal data that is entered by the data subject is only collected and stored exclusively for the internal use through the controller and only for his own purposes. It is possible for the controller to request transfer of this personal data to one or more processors (e.g. a parcel service or other services) where this processor also uses personal data for an internal purpose, however the controller is and remains responsible.
The act of registering on the website of the controller also has the consequence that the IP address that was assigned by the Internet Service Provider (ISP) to the data subject - and that is being used by the data subject at the point of time of registration - as well as the current date and time of the registration process are stored. The reason for storing this data is that it is necessary. This is because it is the only way to prevent the misuse of services, as well as ensuring that, if necessary, it is possible to investigate committed offenses or crimes. So the storage of this data is necessary to secure the controller. It is however not passed to third parties unless a statutory obligation to pass on said data exists or the transfer of the data is required for the scope of a criminal prosection.
Registration has the purpose of offering different amounts and tiers of information by distinguishing between different access levels to said information. With the voluntary registration by the data subject and the voluntary submission of personal data, it is possible for the controller to offer the data subject content or services that are only possible be offered to registered users due to the nature of the matter in question, for example (but not limited to) premium content.
At any point in time any person that has registered is able to change the personal data that has been specified during the registration process, as well as being able to delete their overall registration and registered user identity. It is also possible to request the deletion of all user data relating to the data subject in question by contacting the controller.
The data controller shall, at any given point in time, respond to requests from any data subject for information and subsequently provide information about what personal data is being stored about said data subject. Also, the data controller shall execute requests to correct or erase personal data from the data subject, insofar it is possible for the given data to be modified or erased under the scope of given statutory storage obligations. Currently there are no employees and accordingly no other contact points for such requests other than Patrick Östreicher Online Educator so be sure to direct any and all such requests and inquiries to him. However, should there be employees in the future, then these, too, shall be available for these kind of inquiries and requests.
6. Contact possibility via the website
My website, the website of Patrick Östreicher Online Educator, offers two ways of contacting me by means of email. One, there is a directly supplied email address listed under the legal information for the website which you are also free to use for general contact and information. Two, you can use a contact form that is supplied on my website. If you, the data subject, should contact me, the controller, by means of either the contact form or a directly sent email, then whichever personal data you choose to include by doing so will be automatically stored. This voluntarily submitted data is stored for the purpose of processing and for potentially contacting the data subject. To put it plainly, if you contact me by means of email and with your email address - usually with the intention of getting a reply as well - then the only way I can reply to you is by using the personal contact information you supplied to me in turn. For this, I have to have and store it. I will not submit or transfer your data to a third party.
7. Usage of the s2member membership plugin
In order to manage my membership-only content I use the free version of the WordPress plugin "s2member". This plugin can be downloaded by anyone and its source code checked for its data use and function.
This plugin makes it possible to give different levels of registered users different levels of access and navigation to the content of my website.
However, the way I have implemented this, there is no requirement to sign up on my website with a chosen username and password and email.
Instead, I use a randomized and automated sheet which generates completely random and personal data free user accounts, each with their own completely random username, password and randomly generated, non-existing email address, that can then be used to access the membership restricted area on my website.
These user accounts are time-limited and automatically expire based on specific price and time tiers. As there are monthly, quarterly and yearly time packages available for purchase, these are also the time periods for which user accounts exist.
If someone purchases access for a month through my reseller product page, they will receive the login data for a user account that automatically expires after one month.
If someone purchases access for a quarter through my reseller product page, they will receive the login data for a user account that automatically expires after one quarter.
If someone purchases access for a year through my reseller product page, they will receive the login data for a user account that automatically expires after one year.
Should at any point in time there be more time period tiers, the same logic will apply and a user account supplied according to the purchased time tier will automatically expire after the time period that was chosen and purchased.
The process of user account expiration and user account deletion is automatic.
The s2member plugin offers several features that this website has enabled, which actively monitors for abuse, which, in order to function, stores and processes the internet protocol address (IP address) of the data subject.
These features are the detection of brute force login attempts, unique IP access restrictions and simultaneous login monitoring. These are described in much better and greater detail under the following link:
Here are short summaries:
Brute force protection: The brute force protection detects an IP address that is repeatedly and consistently failing to provide proper login credentials. This is a pattern that suggests someone is trying to force their way into this website by guessing. This is abusive behavior and I am forced to protect my business and myself from this. For this to be possible, the internet protocol address (IP address) of the data subject must be stored and processed and thus is stored and processed.
Unique IP access restriction, coupled with simultaneous login monitoring: Some people illegally sign up and share their login credentials with third parties without permission. Therefore there are checks in place, whether too many simultaneous logins are occuring and whether a large number of internet protocol address (IP address) are being used for the same user account. In order to do so, the website stores and processes the internet protocol address (IP address) of the data subject in order to identify and block such abuse.
In summary, the reason for enabling these functions and for processing and storing the data subject's internet protocol address (IP address) is to safeguard the core functioning of my business enterprise and to protect myself from criminal cyber-attacks, as well as to be able to provide law enforcement authorities with the information necessary for criminal prosecution. This is similiar as also explained in (4.) above.
You may also like to visit and refer to the privacy policy of s2member itself, which can be found at https://s2member.com/privacy-policy/
8. Use of Digistore24 features
Digistore24 offers the possibility to embed different services on your own website via HTML and JavaScript codes e.g. the Social Proof Bubble, the Digistore24 shopping cart or the Digistore24 Trust Badge.
Each time you embed something, non-personal data is loaded from the Digistore24 server (e.g. a JavaScript file).
Currently only the Digistore24 Trust Badge element has been incorporated, as this is required by Digistore24 in order to be able to use their services for clients located in the USA at all. In turn this means this element is required for the core business function of my website.
When loading a webpage with such an embedded element, your web browser retrieves data from the Digistore24 server. Our server has no control over the extent to which your web browser transmits data to the Digistore24 server. In this context, our server does not transmit any data to the Digistore24 servers.
The data that Digistore24 stores and processes when you access this website is set out by Digistore24 GmbH as the contractor in its own privacy policy. The Digistore24 privacy policy can be found here: https://www.digistore24.com/dataschutz
9. Routine erasure and blocking of personal data
The data subject's personal data will be blocked or deleted as soon as the purpose of the storage is no longer valid. Processing and storing of the data subject's personal data by the data controller will only be for the amount of time needed in order to meet 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.
Should the storage purpose not be applicable, or if a period for storage as prescribed by the European legislator or another competent legislator expires, then the personal data is routinely blocked or erased in accordance with the applicable legal requirements.
11. Rights of the data subject
-
a) Right of access by the data subject: right of confirmation
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to make use of this right, he or she may, at any time, contact the controller, or, should there eventually be any, any employee of the controller.
-
b) Right of access
The data subject shall have the right to access the personal data.
The controller shall provide free information about the personal data stored and a copy of this information at any time.
On top of this, 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 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.
Should there be personal data transferred to a third country or to an international organisation, then the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
Should a data subject wish to make use of his or her right of access, he or she may, at any time, contact the controller or any employee of his.
-
c) Right to rectification
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate or wrong 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 make use of this right to rectification, he or she may, at any given time, contact the controller or any employee of the controller.
-
d) Right to erasure (Right to be forgotten)
The 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:
- 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 have to 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 above mentioned reasons applies, and a data subject requests the erasure of personal data stored by Patrick Östreicher Online Educator, he or she may, at any point in time, contact the controller or any employee of his, who shall then promptly make sure that the erasure request is complied with.
Where the controller has made the 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 controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
-
e) Right of restriction of processing
The 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 above mentioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Patrick Östreicher Online Educator, he or she may at any time contact the controller or any of the employees, who shall then arrange the restriction of the processing.
-
f) Right to notification
If you have asserted your right to rectification, erasure or restriction of processing, Patrick Östreicher Online Educator shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
You have the right to request information about these recipients from Patrick Östreicher Online Educator. -
g) Right to data portability
The data subject has the right to receive the personal data concerning the data subject, which the data subject has provided to a controller, in a structured, commonly used and machine-readable format. The data subject also has the right to transmit those data provided to another controller without hindrance from the controller to which the personal data have been provided, where
(1) the processing is based on consent pursuant to Art. 6 (1) lit. a EU-GDPR or Art. 9 (2) lit. a EU-GDPR or on a contract pursuant to Art. 6 (1) lit. b EU-GDPR and
(2) the processing is carried out by automated means.
In exercising this right you will also have the right to have the personal data concerning you transmitted directly from one controller to another controller, where technically feasible. This shall not adversely affect the rights and freedoms of other persons.
The right to data portability does not apply to any processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
In order to assert the right to data portability, the data subject may at any time contact Patrick Östreicher Online Educator or any of his employees.
-
h) Right to object
The data subject shall have the right 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, including profiling based on these provisions.
Patrick Östreicher Online Educator 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 Patrick Östreicher Online Educator 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 Patrick Östreicher Online Educator in regards to the processing for direct marketing purposes, Patrick Östreicher Online Educator will no longer process the personal data for such purposes.
Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data by Patrick Östreicher Online Educator concerning him or her, 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 Patrick Östreicher Online Educator or any of his employees. Also, 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.
-
i) Automated individual decision-making, including profiling
The data subject shall have the right 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.
This does not apply if the decision:(1) is necessary for the conclusion or performance of a contract between the data subject and Patrick Östreicher Online Educator,
(2) is authorised by Union or Member State law to which the controller is subject and such law prescribes suitable measures to safeguard your rights and freedoms and legitimate interests or
(3) is based on your 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 (3) it is based on the data subject's explicit consent, Patrick Östreicher Online Educator will 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 Patrick Östreicher Online Educator or any of his employees.
-
j) Right to withdraw data protection consent
The data subject shall have the right to withdraw his or her consent at any time in regards to the proecessing of his or her personal data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
If the data subject wants to exercise the right to withdraw consent, he or she may, at any time, contact Patrick Östreicher Online Educator or any of his employees.
12. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which consent is obtained for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract of which the data subject is a part of, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other kind of 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 inquiring about products or services offered. Should Patrick Östreicher Online Educator be subject to a legal obligation for 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.
Some cases may make necessary the processing of personal data to protect the vital interests of the data subject or of another natural person.
Here the processing would be based on Art. 6(1) lit. d GDPR.
Finally, processing operations may be based on Article 6(1) lit. f GDPR.
This legal basis concerns processing which is not covered by any of the other already outlined legal grounds.
The processing of personal data is lawful if 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.
13. The legitimate interests pursued by the controller or by a third party
In the cases where the processing of personal data is based on Article 6(1) lit. f GDPR my legitimate interest is to carry out my business in favor of the overall functioning and economic well-being of my business as well as for any and all possible future employees I may eventually have.
14. Period for which the personal data will be stored
The criteria on which determining the period of storage of personal data is based is the respective statutory retention period. Once that period has expired, the corresponding personal data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
15. Providing your personal data as statutory or contractual requirement; the requirements necessary to enter into a contract; the obligation of the data subject to provide the personal data; possible consequences of failing 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.
16. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.