Privacy Policy

(Information on data protection regarding our data processing in accordance with Articles 12, 13, 14 and 21 of the General Data Protection Regulation)

We, gyde GmbH (hereinafter "gyde" or "we"), are pleased about your visit to our website https://www.gyde.io (hereinafter "Website") and your use of our Gyde platform via the mobile application (hereinafter "App" or "App Application") or web application (hereinafter "Web App" or "App Application") at app.gyde.io (hereinafter, if website-related content is included, also "Website") and your interest in our company. The protection of your personal data is important to us. Below, we inform you in accordance with Art. 12, 13, 14 and 21 of the General Data Protection Regulation (GDPR) about how we handle your personal data when using our website and app applications and when providing the services offered on the website and app applications.

Personal data is information about personal or factual circumstances of a specific or identifiable natural person. This includes, for example, information such as name, address, telephone number and date of birth, but also the IP address.

A. General Information

I) Controller

gyde GmbH Friedrichstraße 9 70174 Stuttgart Phone: (+49) 01575 5525175 E-mail: info@gyde.io

We are not legally obliged to appoint a data protection officer.

B. Use of our Website: Purposes and Legal Bases of Data Processing

I) Informational Use of the Website

You can visit our website without providing any personal information. If you only use our website for informational purposes, i.e., if you do not register via the provided Google Docs form, write an email or otherwise transmit information about yourself to us, we do not process any personal data, except for the data that your browser transmits to enable you to visit the website and information transmitted to us in the context of cookies used.

1. Technical Provision of the Website

a) Log files/Website Provision

For the purpose of technically providing the website, our system (i.e., the web server) automatically records information from your browser with each call to the website. The temporary storage of your IP address by our system is necessary to enable delivery of the website to your computer. For this, the user's IP address must necessarily be stored for the duration of the session.

The storage of the IP address in the log files is done to ensure the functionality of our website. In addition, this data serves us to optimize the website and to ensure the security of our information technology systems (e.g., attack detection).

The following information is collected:

IP address and port;
Browser type/version (e.g.: Firefox 59.0.2 (64 Bit));
Browser language (e.g.: German);
Operating system used (e.g.: Windows 10);
Inner resolution of the browser window;
Screen resolution;
JavaScript activation;
Cookies On / Off;
Stored cookie contents;
Time of access;
The previous website from which you came to us.

Furthermore, we use cookies to provide you with certain technical functions of our website for use. Some functions of our website cannot be offered without the use of cookies. You can find more detailed information about the cookies in the consent management.

We process your personal data for the technical provision of our website to protect our legitimate interests pursuant to Art. 6 para. 1 f) GDPR, in order to be able to provide you with the website technically. Our legitimate interest in this is to be able to provide you with an attractive, technically functioning and user-friendly website as well as to take measures to protect our website against cyber risks and to prevent cyber risks from our website for third parties.

b) Consent Management

We use a Consent Manager on our website. With the help of the Consent Manager, we obtain your consent for certain data processing that requires consent (e.g. analysis, tracking, etc.). Through the use of the Consent Manager, we can inform you about the individual cookies and tools we use. You can use the Consent Manager to choose which cookies and tools you want to allow or reject categorically. In addition, the Consent Manager also provides an overview of the cookies used and the possibility to change or revoke your consents. This enables you to make an informed decision about sharing your data and allows us to use cookies and tools in a privacy-compliant, transparent and documented manner.

The Consent Manager processes your personal data to record your decision about the approval of cookies and tools and to store it for a renewed visit to our website. This includes, among other things, the corresponding cookie with your (consent) decision as well as other usage data, e.g. IP address, domain name, time of request, server data (including data transfer types, server status, etc.), country, browser and operating system.

We process your personal data for the technical provision of the Consent Manager on the basis of the following legal grounds:

for the use of cookie management to fulfill a legal obligation to which we as the controller are subject pursuant to Art. 6 para. 1 c) GDPR. The legal obligation lies in informing you about the cookies we use and obtaining and documenting your consent to data processing; and
to protect our legitimate interests pursuant to Art. 6 para. 1 f) GDPR, in order to be able to provide you with the cookie management technically. Our legitimate interest in this is to be able to provide you with an attractive, technically functioning and user-friendly cookie management, as well as to take measures to protect the cookie management against cyber risks and to prevent cyber risks from the cookie management for third parties.

2. Analysis and Tracking

For the purpose of analyzing and tracking the use of our website, we or the service providers working for us use cookies that enable an evaluation of your surfing behavior. This allows us to improve the quality of our website and its content. We learn how the website is used and can thus continuously optimize our offer. More detailed information about the cookies and tools we use, their purposes and functions, the data processed in each case, the data recipients, the location of processing or transfer to so-called third countries (outside the EU/EEA), as well as the storage periods can be obtained via the Consent Manager.

In particular, we use the following tools from third-party providers:

Hubspot
Google Forms
Microsoft Forms
Youtube (for videos)
Calendly
Google Analytics
LinkedIn Insight Tag / Ad Conversion Tracking
Google Ads / Ad Conversion Tracking

a) Google Ads/ Ad Conversion Tracking We use the online advertising program "Google AdWords/Google Ads" (hereinafter together "AdWords") and within the framework of Google AdWords, the Conversion Tracking as well as Remarketing. AdWords and the aforementioned functions include analysis and tracking services of Google Inc. (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). When you click on an ad placed by Google, a cookie for conversion tracking is placed on your computer. These cookies lose their validity after 30 days, do not contain any personal data and thus do not serve for personal identification. If you visit certain internet pages before our website and the cookie has not yet expired, Google and we can recognize that you clicked on the ad and were redirected to this page. Each Google AdWords customer receives a different cookie. Thus, there is no possibility that cookies can be tracked across the websites of AdWords customers. The information obtained using the conversion cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. Here, customers learn the total number of users who clicked on their ad, were redirected to a page tagged with a conversion tracking tag, and, for example, purchased a product or signed up for a newsletter. However, they do not receive any information that can be used to personally identify users. The remarketing function, in turn, serves to re-address users on other websites or other content who have, for example, previously visited our websites. Through the remarketing cookie, Google recognizes the user on other websites as a former visitor to our website and can thus display optimized advertising to the user. If you do not wish to participate in the tracking, you can object to this use by preventing the installation of cookies through a corresponding setting of your browser software (deactivation option). You will then not be included in the conversion tracking statistics. Further information and Google's privacy policy can be found at: http://www.google.com/policies/technologies/ads http://www.google.de/policies/privacy/

We process your personal and non-personal data for analysis on our website based on the following legal basis:

Your consent according to § 25 para. 1 TDDDG regarding the initial storage and reading of data as well as;
Your consent according to Art. 6 para. 1 lit. a GDPR for further data processing (e.g. tracking). You can revoke a once given consent at any time for the future by calling up the Consent Manager again on any page of our website and removing the check mark you set for consent under the respective category and then confirming the setting.

b) Google Analytics We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, on our website. Google Analytics uses cookies. The information generated by the cookie about your use of our website is usually transmitted to and stored by Google on servers in the United States. We use Google Analytics 4 on our website. In Google Analytics 4, IP addresses are neither logged nor stored, which is why IP address anonymization is not necessary. Direct personal identifiability can thus be excluded. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activities and to provide other services related to website use and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. Within Google Analytics, we use, among other things, the feature "Google Signals" to understand your user behavior and optimize our website, which collects data especially about your user behavior on the internet. This includes, among other things, the browser you use, which device and on which device, for example, information is searched and on which device buyers tend to complete a purchase. However, this data is only made available to us by Google in aggregated and already evaluated form, i.e. aggregated and thus anonymized. It is therefore not possible for us to access individual data sets or to trace back to individual users.

We process your personal and non-personal data for analysis on our website based on the following legal basis:

Your consent according to § 25 para. 1 TDDDG regarding the initial storage and reading of data as well as;
Your consent according to Art. 6 para. 1 lit. a GDPR for further data processing (e.g. analysis). You can revoke a once given consent at any time for the future by
preventing the storage of cookies by setting your browser software accordingly; however, we point out that in this case you may not be able to use all functions of our website to their full extent;
downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de or
calling up the Consent Manager again on any page of our website and removing the check mark you set for consent under the respective category and then confirming the setting. For more information about terms of use and privacy at Google Analytics, please visit http://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies/

c) LinkedIn Insight Tag / Ad Conversion Tracking Our website uses the conversion tool "LinkedIn Insight Tag" of LinkedIn Ireland Unlimited Company. This tool creates a cookie in your web browser, which allows the collection of the following data, among others: IP address, device and browser properties, and page events (e.g. page views). This data is encrypted, anonymized within seven days, and the anonymized data is deleted within 90 days. LinkedIn does not share any personal data with us, but provides anonymized reports about the website audience and ad performance. Additionally, LinkedIn offers the possibility of retargeting via the Insight Tag. We can use this data to display targeted advertising outside our website without you as a website visitor being identified in the process. For more information about LinkedIn's privacy policy, please refer to the LinkedIn Privacy Policy and the LinkedIn Cookie Policy. LinkedIn members can control the use of their personal data for advertising purposes in their account settings. To deactivate the Insight Tag on our website ("opt-out"), adjust your consent in the Consent Manager by calling it up again on any page of our website. We process your personal and non-personal data for analysis on our website based on the following legal basis:

Your consent according to § 25 para. 1 TDDDG regarding the initial storage and reading of data as well as;
Your consent according to Art. 6 para. 1 lit. a GDPR for further data processing (e.g. tracking). You can revoke a once given consent at any time for the future by calling up the Consent Manager again and removing the check mark you set for consent under the respective category and then confirming the setting.

II) Active Use of the Website

1. Contact Requests

If you have questions about our website, the services we offer, or otherwise want to contact us, you can contact us directly using the contact details provided in Section A. I).

In order to process and answer your inquiries to us, we process the personal data you provide in this context. This includes, in any case, your name and email address to send you a response, as well as any other information you send us as part of your message.

We process your personal data to respond to contact requests according to the following legal basis:

to protect our legitimate interests pursuant to Art. 6 para. 1 f) GDPR; our legitimate interest is in the proper response to customer inquiries;
if the inquiry is aimed at the conclusion of a contract, the additional legal basis is Art. 6 para. 1 b) GDPR;
if the inquiry is aimed at asserting your data subject rights, the additional legal basis is Art. 6 para. 1 c) GDPR, as the processing of your data is necessary for the fulfillment of legal obligations.

In addition to the above-mentioned contact options, there is also the possibility to contact us via the chat functions of Youtube and LinkedIn, HubSpot, Google Forms, Microsoft Forms and Calendly. For more information about data collection regarding Youtube, LinkedIn, Google Forms, Microsoft Forms and Calendly, please refer to Section J. "Data Processing in Social Media Use" of this Privacy Policy.

2. Registration for gyde Courses

You can register on our website to sign up for our training courses. In these cases, you must enter personal data into an input mask and transmit it to us.

You must provide the following data:

First and last name
Email address
Position in and name of the company for which the registration is made or indication that you are registering yourself
If the registration is for a company: Number of people to be registered
Course title for which the registration should be made

At the time of sending the registration, the following data is also stored:

The IP address of the user
Mobile device yes/no
Date and time of registration

We process your data for registration to a course for the performance of a contract or to carry out pre-contractual measures in accordance with Art. 6 para. 1 b) GDPR.

3. Business Analysis and Market Research

In order to operate our business economically, recognize market trends, wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata, whereby the persons concerned include contractual partners, interested parties, customers, visitors and users of our services and website.

The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we can take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve us to increase user-friendliness, to optimize our offer and to ensure economic efficiency. The analysis data serve only us and are not passed on to third parties. A transfer of analysis results takes place at most under complete anonymization by aggregation of the data.

We process your personal data for this purpose on the basis of the following legal basis:

to protect our legitimate interests pursuant to Art. 6 para. 1 f) GDPR;
if provided for in individual cases, based on your consent pursuant to Art. 6 para. 1 a) GDPR.

4. Newsletter and Promotional Emails

With your consent, we use your data for advertising purposes, such as sending our newsletter, promotional surveys, transmitting product information, inviting you to events and training courses of interest to you, follow-ups, status messages, birthday mailings, market research and other marketing and promotional activities. We collect mandatory information such as your email address, but also information that you voluntarily provide to us. We use the voluntary information to continuously improve our customer relationship.

If we receive your email address in connection with the conclusion of a contract and the provision of our services and you have not objected to this, we reserve the right to regularly send you offers for similar services from our range by email. You can object to this use of your email address at any time by sending a message to the contact details provided under Section A. I) or via a link provided for this purpose in the promotional email or other unsubscribe or objection options described in the respective email, without incurring any costs other than the transmission costs according to the basic rates.

We process your data for sending newsletters and promotional emails on the following legal bases:

if you have given us your consent pursuant to Art. 6 para. 1 a) GDPR;
if you have provided us with your email address in connection with the purchase of goods or services, to protect our legitimate interests pursuant to Art. 6 para. 1 f) GDPR in conjunction with § 7 para. 3 UWG; our legitimate interest is based on our economic interests in carrying out promotional measures and targeted advertising.

5. Analysis of Reaction to Promotional Emails

With your consent, we also analyze, with the help of our service provider HubSpot, when and how you open and react to our newsletters and promotional emails. The following data is usually stored:

Email address of the user
Send status of the receiving mail server
Delivery status of the email
Time at which the email was opened
Clicks on links in the email and their time

The evaluation and analysis of this data help us to not send you random advertising. Rather, we send you advertising that corresponds to your areas of interest. In this respect, for example, we also compare which of our newsletters and promotional emails you open in order to avoid sending unnecessary emails to you. In addition, we want to provide you with information that is suitable for you. By tracking open and click rates, we can better recognize which content is interesting for you. You can view HubSpot's privacy policy here: https://legal.hubspot.com/de/privacy-policy.

The processing of data for the analysis of reactions to newsletters and promotional emails is carried out if you have given us your consent pursuant to Art. 6 para. 1 a) GDPR.

6. Legal Enforcement

We also process your personal data in order to assert our rights and enforce our legal claims. We also process your personal data in order to defend ourselves against legal claims. Finally, we process your personal data to the extent necessary to prevent or prosecute criminal offenses.

We process your personal data for this purpose on the basis of the following legal basis:

to protect our legitimate interests pursuant to Art. 6 para. 1 f) GDPR, insofar as we assert legal claims or defend ourselves in legal disputes or we prevent or investigate criminal offenses.

7. Compliance with Legal Regulations

We also process your personal data to fulfill other legal obligations. These may affect us, among other things, in connection with the processing of registrations or business communication. This includes in particular retention periods under commercial, trade or tax law.

We process your personal data on the basis of the following legal basis:

to fulfill a legal obligation to which we are subject pursuant to Art. 6 para. 1 c) GDPR in conjunction with commercial, trade or tax law, insofar as we are obliged to record and retain your data.

C. Use of Our Training Services: Purposes and Legal Bases of Data Processing

We process your personal data as part of our training services. We receive the data we process from you either from your employer, if they have registered you for one of our courses, or directly from you, if you have registered yourself or provided the corresponding data in our app applications and group coaching sessions.

1. App Applications/Gyde Platform

In the app applications, learning content on leadership topics is provided via the Gyde platform in the form of microlearning units. In addition to simple text content, the app applications offer small quizzes and reflection tasks that can be answered through multiple-choice or text inputs. The aim of the app applications is to convey the relevant learning content in a short time, to consolidate what has been learned through tasks, and to transfer it into everyday life through reflection tasks. The data we collect from you is necessary to achieve the intended goal of coaching and to continuously improve rho data's services.

For this purpose, we process the following data in particular in the app applications:

Email address of the user
If login via third-party provider: Token from Google, Apple, etc.
Master data of the user
First and last name of the user
Company in which the user is employed
Role in the company
Number of employees in the company or the respective work area of the user
Time spent in the app application
Number and time of completed units
Times of use
Approximate location (when using the app)
Diagnostic data
Multiple choice answers or free text entries (possibly also special categories of personal data according to Art. 9 para. 1 GDPR, if voluntarily provided)

2. Virtual Group Coaching

Group coaching sessions are offered at regular intervals (e.g., every 2 weeks) as part of the program. Here, the user participates in a video conference together with executives from other companies and a coach commissioned by rho data. During these group coaching sessions, the content learned in the app application is discussed and concrete situations from the users' everyday life are reflected upon. The aim of the group coaching is to consolidate the content learned in the app application and transfer it to one's own everyday life, as well as to find solutions to specific challenging situations through joint exchange and consultation with the coaches.

During the group coaching sessions, the coach may take notes on the user's situation. These can be used by the coach to improve the quality of the coaching sessions and by rho data to improve the overall quality of the services offered.

The data processed here cannot be generally defined. The resulting data depends individually on the answers given by users in the app application, the statements of users in the coaching sessions, and the respective evaluation or notes of the coach. This may also include special categories of personal data within the meaning of Art. 9 para. 1 GDPR.

The virtual group coaching sessions are conducted via Google Meet. rho data has no influence on the data processing by Google Meet. Each user enters into an independent usage relationship with Google when using Zoom. For more information on Google's data processing, please visit https://support.google.com/meet/answer/9852160, https://cloud.google.com/privacy and https://cloud.google.com/privacy/gdpr.

3. Legal Basis for Processing

We process your personal data on the basis of the following legal basis:

Insofar as we have received your data from your employer for the purpose of setting up pre-registration, we process the data provided, such as name and email address, based on your consent given to your employer pursuant to Art. 6 para. 1 a) GDPR. Insofar as you have registered yourself for our course and are our contractual partner, we process the data you have provided for the fulfillment or initiation of a contract with you pursuant to Art. 6 para. 1 b) GDPR.
With regard to the information you have provided in the app application and in the coaching sessions, we process your data based on your consent pursuant to Art. 6 para. 1 a) GDPR or Art. 9 para. 2 a) GDPR.

D. Links

Some sections of our websites contain links to third-party websites. These websites are subject to their own privacy policies. We are not responsible for their operation, including data handling. If you send information to or through such third-party pages, you should review the privacy policies of these pages before providing them with information that can be associated with you.

E. Categories of Recipients

Initially, only our employees gain knowledge of your personal data.

Your data will only be passed on to third parties if this is legally permitted or prescribed or if you have given your consent. We also share your data to the extent necessary with the service providers we use to provide our services. We limit the sharing of data to what is necessary to provide our services to you. In some cases, our service providers receive your data as processors and are then strictly bound by our instructions when handling your data. In some cases, the recipients act independently with your data that we transmit to them.

Below we list the categories of recipients of your data:

Debt collection companies and legal advisors when asserting our claims,
Public authorities and institutions, insofar as we are legally obliged to do so,
Payment service providers and banks to collect outstanding payments from accounts or pay out refund amounts,
Agencies, printing companies and lettershops that support us in carrying out training courses, promotional measures, competitions, etc.,
IT service providers for the administration and hosting of our websites and services.

F. Third Country Transfer

As part of the use of cookies and similar applications, we transfer your IP address or your shortened IP address as well as possibly other data to countries outside the European Union. The transfer of data is based on the standard contractual clauses drafted and made available by the European Commission, which we have agreed upon with the respective providers.

If service providers in third countries are used and we can influence this, they are also obliged to comply with the European level of data protection through the agreement of the EU standard contractual clauses in addition to written instructions. Alternatively, we transfer the data on the basis of an adequacy decision by the EU Commission.

Otherwise, we do not transfer your personal data to countries outside the EU or the EEA or to international organizations.

Data processing within the scope of service provision by rho data takes place via a Google Firebase Cloud Server in Europe as well as other cloud servers in Europe. According to the contract, Google only processes the data in the EU. Therefore, no third country transfer takes place.

G. Duration of Storage

I) Informational Use of the Website

When using our website purely for informational purposes, we store your personal data on our servers exclusively for the duration of your visit to our website. After you have left our website, your personal data will be deleted within 7 days. Cookies installed by us are usually also deleted after leaving our website.

However, some cookies are stored for longer; more detailed information about the storage periods of the cookies and tools we use can be obtained via the Consent Manager. You also have the option to delete installed cookies yourself at any time.

II) Active Use of the Website

In the case of active use of our website, we initially store your personal data for the duration of answering your inquiry or for the duration of our business relationship. This also includes the potential future and actual initiation of a contract (pre-contractual legal relationship) and the execution of a contract.

We process your data for the duration of your subscription to our promotional emails until you object to the sending or revoke your consent.

In addition, we then store your personal data until the statute of limitations for any legal claims arising from the relationship with you expires, in order to use them as evidence if necessary. The limitation period is usually between 1 and 3 years, but can also be up to 30 years.

Upon expiration of the limitation period, we delete your personal data unless there is a legal obligation to retain it, for example from the German Commercial Code (§§ 238, 257 para. 4 HGB) or from the German Fiscal Code (§ 147 para. 3, 4 AO). These retention obligations can last from two to ten years. For this period, the data will be processed again solely in the event of an audit by the tax authorities.

III) Use of App Applications and Data Processing in Virtual Group Coaching

If you use our app applications or participate in virtual group coaching, we store your personal data collected in this context for the purpose of conducting the training courses in any case for the duration of the respective training program and are visible to the user until the user requests deletion or the contractual relationship is terminated. As soon as users no longer have access to the platform, the data will be deleted unless there are compelling reasons against it (e.g. legal retention obligations, law enforcement, etc.)

Your data may be aggregated by us so that it is no longer possible to assign it to you personally. These aggregated data can then be continuously evaluated and permanently used to optimize our services. If at all, data is only passed on to third parties in anonymized aggregated form.

H. Scope of Your Obligations to Provide Data

In principle, you are not obliged to provide us with your personal data. However, if you do not do so, we may not be able to make the website or app applications available to you with all technical functionalities, may not be able to answer your inquiries to us, and may not be able to enter into a contract with you or provide the training services.

I. Profiling / Automated Decision-Making

As part of the analysis and evaluation of your reaction to our promotional emails, your data is partially processed automatically with the aim of evaluating certain personal aspects (profiling). This is done in order to be able to inform and advise you in a targeted manner about products and services. This enables communication and advertising tailored to your needs, including market and opinion research.

Otherwise, we do not carry out profiling and do not use purely automated decision-making procedures in accordance with Article 22 GDPR. If we should use further procedures in individual cases in the future, we will inform you separately about this.

J. Data Processing in Social Media Use

To present our company and for direct communication with you, we use social media platforms from providers such as LinkedIn, Youtube, HubSpot, Calendly and Co. ("Providers"), through which we maintain our presence (e.g. in the context of company and employee profiles) and process your data.

I) Joint Responsibility

If data is collected on our website that both the provider and we process and use for joint purposes (e.g. in the context of analysis or advertising), there is joint responsibility between the operator and us. Often this function cannot be deactivated by us. You can therefore address your concern to both the respective provider and us. We currently use the following providers:

LinkedIn (including LinkedIn Sales Navigator) of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland (Address of the German branch: LinkedIn Germany GmbH, Sendlinger Str. 12, 80333 Munich)
Youtube of Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (Address of the German branch: Google Germany GmbH, ABC-Straße 19, 20354 Hamburg),
HubSpot of HubSpot, Inc., 25 First Street, Cambridge, MA 02141, USA
Calendly of Calendly LLC, 271 17th St NW Ste 1000, Atlanta, GA 30363, USA

Below you will find the links to the privacy policies and information of the respective providers:

LinkedIn: https://de.linkedin.com/legal/privacy-policy
Google (YouTube): https://policies.google.com/privacy
Microsoft: https://privacy.microsoft.com/en-us/privacystatement
HubSpot: https://legal.hubspot.com/de/privacy-policy
Calendly: https://calendly.com/privacy

II) Data Protection Officers of the Providers

In addition to us, you can also contact the following data protection officers of the respective providers:

LinkedIn: https://www.linkedin.com/help/linkedin/ask/TSO-DPO
Google (YouTube): https://support.google.com/policies/contact/general_privacy_form
HubSpot: privacy@hustle.co
Microsoft: https://www.microsoft.com/de-de/concern/privacy
Calendly: privacy@calendly.com

III) Purposes and Legal Bases of Data Processing

1. Informational Use of Our Presence

a) Provision of the Presence

For the purpose of technically providing our social media presence, the web server automatically records information from your browser with each call to the website. You can visit our presence without providing any personal information. If you only use our presence for informational purposes, i.e. if you do not register or otherwise transmit information about yourself to us, we do not process any personal data, with the exception of the data that the operator collects in the context of its platform and the cookies it uses and may transmit to us.

We or the provider process your personal data for the technical provision of our website on the basis of the following legal grounds:

to protect our legitimate interests pursuant to Art. 6 para. 1 f) GDPR, in order to be able to make the presence technically available to you. Our legitimate interest in this is to be able to provide you with an appealing, technically functioning and user-friendly presence as well as to take measures to protect our presence from cyber risks and to prevent cyber risks from our presence for third parties.

b) Analysis and Tracking

For the purpose of analyzing and tracking the use of its social media platform and our presence, the provider uses cookies that enable an evaluation of your surfing behavior. This allows the quality of the platform and presence and their contents to be improved. We learn how the platform and the presence are used and can thus continuously optimize our offer.

However, we have neither influence on the collected data and data processing operations, nor are we aware of the full extent of the data collection, the exact purposes of the processing or the storage periods. We also have no information on the deletion of the collected data by the operator of the platform.

Web analysis is the collection, gathering and evaluation of data about the behavior of visitors to websites. A web analysis service collects, among other things, data about which website a data subject came from to a website (so-called referrers), which subpages of the website were accessed or how often and for which length of stay a subpage was viewed. Web analysis is regularly used to optimize a website and for cost-benefit analysis of internet advertising. It may also happen that the information obtained in the context of the analysis and tracking of our presence is combined with your other data collected in the context of the use of the presence and the platform. If you register on the platform, the operator could link data regarding your platform activities with your personal information (including name/email address) on the basis of given consent, thus collect it in a personalized manner and inform you individually and in a targeted manner about, among other things, your preferred subject areas.

With regard to statistics that the operator of the platform makes available to us, we can only influence these to a limited extent and cannot switch them off. However, we make sure that no additional optional statistics are made available to us.

We process your personal data on the basis of the following legal basis:

Your consent according to Art. 6 para. 1 a) GDPR, which you have given to the provider when registering for the respective social media platform.

2. Active Use of the Presence

In addition to the purely informational use of our presence, you can also actively use our presence to contact us. In addition to the processing of your personal data described above for purely informational use, we then also process further personal data from you that we need, for example, to process your request. This also applies if we actively use the presence on our part, e.g. for initiative contact or the initiation of business contacts with you.

a) Sharing and Publishing of and Interacting with Posts, Reviews, Photos, etc.

You can comment on, share, or otherwise interact with (like, recommend, review, etc.) posts, photos, videos, etc. created by us on the provider's platform and on our presence. We may share your content on our presence if this is a function of the operator's platform and communicate with you via the platform. Public messages, etc. may be published by the operator, but will not be used or processed by us for other purposes at any time.

In the case of reviews, we reserve the right to publish a statement (e.g. to clarify a problem, goodwill actions, etc.) on your message and to request further contact. In doing so, processing of the personal data you voluntarily published in the review may take place.

We also reserve the right to delete content if this should be necessary.

We process your personal data on the following legal basis:

To protect our legitimate interests pursuant to Art. 6 para. 1 sentence 1 f) GDPR. The data processing takes place in the interest of our public relations and communication.

b) User Inquiries

In order to process your inquiries to us, e.g. via contact forms, a chat or our email address, to answer them specifically and to provide you with the desired information, we process the personal data you provide in this context. This includes your contact details to send you a response or to ask necessary follow-up questions, as well as other information you provide to us in this context.

If you make an inquiry to us via the platform, we may also refer you to other secure communication channels that guarantee confidentiality, depending on the required response. You always have the option of sending us confidential inquiries to our addresses specified in the imprint or in this privacy policy. We may contact you electronically, by telephone or by post, depending on the subject of the inquiry, the availability of your contact details and appropriateness.

We process your personal data to respond to user inquiries, requests for materials, etc. on the basis of the following legal grounds:

to protect our legitimate interests pursuant to Art. 6 para. 1 f) GDPR; our legitimate interest lies in the proper response to or execution of (customer) inquiries;
if the inquiry is aimed at the conclusion of a contract or the services to be provided or otherwise relates to a contractual and/or business relationship between us and you, the additional legal basis is Art. 6 para. 1 b) GDPR;
with your consent in the context of using the chat, Art. 6 para. 1 a) GDPR.

c) Legal Enforcement

We process your personal data for this purpose on the basis of the following legal basis:

to protect our legitimate interests pursuant to Art. 6 para. 1 f) GDPR, insofar as we assert legal claims or defend ourselves in legal disputes or we prevent or investigate criminal offenses.

d) Compliance with Legal Regulations

We also process your personal data on our social media presence to fulfill other legal obligations. These may affect us, among other things, in connection with the processing of registrations or business communication. This includes in particular retention periods under commercial, trade or tax law. We process your personal data on the basis of the following legal basis:

to fulfill a legal obligation to which we are subject pursuant to Art. 6 para. 1 c) GDPR in conjunction with commercial, trade or tax law, insofar as we are obliged to record and retain your data.

e) Third Country Transfer

As part of the use of social media, your data may be transferred to countries outside the European Union, including the USA. We have no influence on this. You can find further information in the linked privacy policies of the platform operators.

f) Storage Duration

When using our social media presence, the operator stores your personal data on its servers. Personal data and installed cookies are usually deleted by the operator. However, we are unfortunately not aware of the exact storage and deletion periods, but they may be found in the respective linked privacy policies.

g) Profiling / Automated Decision

There is a possibility that the operator of a social media platform processes your data partly automatically with the aim of evaluating certain personal aspects (profiling). This may be done to be able to inform and advise you in a targeted manner about products and services. This enables communication and advertising tailored to your needs, including market and opinion research.

K. Company Sale/Mergers, etc.

We may process your personal data in order to carry out a (partial) company sale or a merger (or similar transactions such as takeover in the context of liquidation, insolvency, dissolution, etc.) with another company. In the event that another company acquires or intends to acquire the assets, which may include your personal data, from us or we carry out or aim for a merger with another company, we may need to grant this company access to your personal data stored with us or transfer it for the purpose of examining and carrying out the company sale/merger (e.g. to determine the company value or business risks, to transfer the data/assets, or similar).

We process your personal data on the basis of the following legal basis:

to protect our legitimate interests pursuant to Art. 6 para. 1 f) GDPR, in order to be able to organize and carry out a planned company sale or planned merger.

L. Data Subject Rights

If personal data about you is processed, you are a "data subject" within the meaning of the GDPR. You are entitled to the following rights as a data subject under the legal requirements, which you can assert against us or, in the context of using a social media service, also against the operator. Please note that we do not have full influence on the data processing operations of the operator. Our possibilities are largely determined by the company policy of the respective operator. Your data subject rights are as follows:

Right to information: You are entitled at any time, within the framework of Art. 15 GDPR, to request confirmation from us as to whether we are processing personal data concerning you. If this is the case, you are further entitled under Art. 15 GDPR to receive information about this personal data as well as certain other information (including processing purposes, categories of personal data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and in the case of third country transfer the appropriate safeguards) and a copy of your data.
Right to rectification: If personal data about you is not (or no longer) accurate or incomplete, you can request a correction and, if necessary, completion of this data (Art. 16 GDPR).
Right to erasure or restriction of processing: If the legal requirements are met, you can request the erasure of your personal data (Art. 17 GDPR) or the restriction of processing of this data (Art. 18 GDPR). However, the right to erasure under Art. 17 para. 1 and 2 GDPR does not exist, among other things, if the processing of personal data is necessary to fulfill a legal obligation (Art. 17 para. 3 lit. b GDPR).
Right to object: For reasons arising from your particular situation, you can object to the processing of personal data concerning you by us at any time (Art. 21 GDPR). If the legal requirements are met, we will subsequently no longer process your personal data.
Right to data portability: You are entitled, under the conditions of Art. 20 GDPR, to request that we provide you with the personal data concerning you that you have provided to us in a structured, common and machine-readable format.
Right to revoke the data protection consent: You have the right to revoke your consent at any time. The revocation only takes effect for the future; this means that the revocation does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, a data subject (you) has the right to lodge a complaint with a supervisory authority - in particular in the Member State of your place of residence - if you consider that the processing of personal data relating to you by us infringes the GDPR.

The supervisory authority responsible for us is:

Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg
Lautenschlagerstraße 20
70173 Stuttgart
Phone: 0711/61 55 41 – 0
Fax: 0711/61 55 41 – 15
E-mail: poststelle@lfdi.bwl.de

The social media platform operators and thus also the responsible supervisory authority are based abroad within the EU. This is usually the Irish Data Protection Commission (Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02RD28, Ireland). However, you can also address your complaints to the following German supervisory authorities. This is basically:

LinkedIn: The Bavarian State Office for Data Protection Supervision, Promenade 18, 91522 Ansbach;
Google (incl. YouTube): The Hamburg Commissioner for Data Protection and Freedom of Information, Ludwig-Erhard-Str 22, 7th floor, 20459 Hamburg;

Your requests for the exercise of your rights should, if possible, be addressed in writing to the above-mentioned address of the supervisory authorities or directly to us at the contact details given under Section A. I).

M. Right to Object Art. 21 GDPR

You have the right to object at any time to the processing of your data which is carried out on the basis of Art. 6 para. 1 f GDPR (data processing on the basis of a balance of interests) or Art. 6 para. 1 e GDPR (data processing in the public interest) if there are grounds for doing so arising from your particular situation. This also applies to profiling based on this provision within the meaning of Art. 4 No. 4 GDPR.

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

In individual cases, your personal data may also be processed to conduct direct marketing. If you do not wish to receive advertising, you have the right to object at any time; this also applies to profiling insofar as it is associated with such direct advertising. This objection will be observed for the future.

Your data will no longer be processed for direct marketing purposes if you object to processing for these purposes.

The objection can be made without any formalities and should be addressed to us at the contact details given under Section A. I) or to the contact details of the respective platform operator.

N. Changes

This privacy policy is a transparency document. We are obliged to update it if our data processing changes.

Last updated in July 2024

Privacy Policy

Information on Data Protection regarding our DataProcessing pursuant to Articles 12, 13, 14, and 21 of the General DataProtection Regulation (GDPR).

We, gyde GmbH (hereinafter referred to as“gyde” or “we”), appreciate your visit to our website at (https://www.gyde.io)(hereinafter referred to as the “Website”) and your use of the Gyde platform via our mobile application (hereinafter “App” or “App Application”) or our web application (hereinafter “Web App” or also “App Application”) at app.gyde.io (also referred to as the “Website” where applicable). We are pleased about your interest in our company. Protecting your personal data is important to us. This privacy policy provides information in accordance with Articles 12, 13, 14, and21 of the General Data Protection Regulation (GDPR) about how we process your personal data when you use our Website and App Applications and the services offered through them.

A. General Information

I) Controller

gyde GmbH
Friedrichstraße 9
70174 Stuttgart
Germany

Phone: (+49) 01575 5525175
E-mail: info@gyde.io

We are not legally required to appoint adata protection officer.

II) Data Protection Officer

rsdatenschutz
Bismarckstraße 2
71634 Ludwigsburg
Germany

E-mail: info@rsdatenschutz.de

B. Use of our Website: Purposes and Legal Bases of Data Processing

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I) Informational Use of the Website

You can visit our Website without providing any personal information. If you use our Website for informational purposes only—that is, if you do not register using the provided Google Docs form, send us an email, or otherwise transmit personal information to us—we do not process any personal data, except for the data your browser automatically transmits to enable your visit to the Website, as well as information provided to us through cookies used on the Website.

1. Technical Provision of the Website
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a) Log Files / Website Access

For the purpose of providing our Website technically, our system (i.e., the web server) automatically collects certain information from your browser each time the Website is accessed. Temporarily storing your IP address is necessary to deliver the Website to your device. For this reason, your IP address must be stored for the duration of your session.

We also store IP addresses in log files to ensure the functionality of the Website. Additionally, these data help us optimize the Website and ensure the security of our IT systems (e.g., to detect cyberattacks).

In particular, the following data are processed:

- IP address and port

- Browser type and version (e.g., Firefox59.0.2 (64-bit))

- Browser language (e.g., German)

- Operating system (e.g., Windows 10)

- Internal resolution of the browser window

- Screen resolution

- JavaScript activation

- Cookies enabled/disabled

- Stored cookie contents

- Time of access

- The previous website from which you reached us

We also use cookies to provide you with certain technical functionalities of our Website. Some features of our Website cannot be offered without the use of cookies. Further information on the cookies used can be found in our consent management.

The processing of your personal data forthe technical provision of our Website is based on our legitimate interests inaccordance with Art. 6 para. 1 f) GDPR. Our legitimate interest lies inproviding you with an attractive, technically functional, and user-friendlyWebsite, as well as in protecting our Website from cyber risks and preventingsuch risks from being passed on to third parties.

b) Consent Management

We use a consent management tool (“ConsentManager”) on our Website. This tool enables us to obtain your consent for certain types of data processing that require consent (e.g., analytics, tracking). Through the Consent Manager, we inform you about the cookies and tools we use and give you the option to accept or reject them by category. You can also view a list of all cookies and tools in use and update or withdraw your consent at any time. This allows you to make an informed decision about how your data is used, while enabling us to manage cookies and tools in a transparent, GDPR-compliant, and documented manner.

The Consent Manager processes your personal data to record your choices regarding cookies and tools and to store them for future visits to our Website. This includes, among other things, the relevant cookie with your consent decision, as well as other usage data such as your IP address, domain name, time of request, server data (e.g., transfer methods, server status), country, browser, and operating system.

We process your personal data for the technical provision of the consent manager based on the following legal grounds:

for the use of cookie management to fulfill a legal obligation to which we are subject as the responsible party pursuant to Art. 6 para 1 c) GDPR. This legal obligation includes informing you about the cookies we use as well as obtaining and documenting your consent to data processing; and

to protect our legitimate interests pursuant to Art. 6 para 1 f) GDPR in providing the cookie management system from a technical standpoint. Our legitimate interest lies in offering you a functional, user-friendly, and technically sound cookie management tool, as well as in taking measures to protect the system from cyber risks and to prevent the cookie management system from posing cyber risks to third parties.

2. Analysis and Tracking

For the purpose of analyzing and tracking the use of our Website, we—and service providers acting on our behalf—use cookies that allow us to evaluate your browsing behavior. This enables us to improve the quality of our Website and its content. We gain insights into how the Website is used and can continuously optimize our offering.

Detailed information on the cookies and tools we use, their respective purposes and functionalities, the data processed, the recipients of the data, where the data is processed (including any transfer to so-called third countries outside the EU/EEA), as well as the storage periods, can be found in our Consent Manager.

We use the following third-party tools in particular:

- HubSpot

- Google Forms

- Microsoft Forms

- YouTube (for videos)

- Calendly

- Google Analytics

- LinkedIn Insight Tag / Ad ConversionTracking

- Google Ads / Ad Conversion Tracking

a) Google Ads / Ad Conversion Tracking

We use the online advertising service “Google Ads” and, as part of it, employ both conversion tracking and remarketing features provided by Google Ireland Limited, Gordon House, BarrowStreet, Dublin 4, Ireland.

When you click on an ad placed by Google, a cookie is stored on your device for conversion tracking. These cookies expire after 30 days and do not contain personal data—they are not used to personally identify users. If the cookie is still active and you visit certain pages on our website, Google and we can recognize that you clicked on the ad and were redirected to our site. Each Google Ads customer receives a different cookie, meaning the cookies cannot be tracked across multiple websites.

The information collected using the conversion cookie is used to create conversion statistics for advertisers who have opted in to conversion tracking. Advertisers learn the total number of users who clicked on their ad and were redirected to a conversion-tagged page(e.g., completed a purchase or signed up for a newsletter). However, they do not receive any information that can personally identify users.

The remarketing function enables us tore-engage with visitors across other websites and content. For example, if you previously visited our Website, Google can recognize you and display ads tailored to your interests on other sites.

If you do not wish to participate in tracking, you can object to its use by disabling cookies in your browser settings. In that case, you will not be included in the conversion tracking statistics.

For more information on Google’s data processing and privacy practices, please visit:

https://www.google.com/policies/technologies/ads

https://www.google.com/policies/privacy

We process your personal and non-personal data for analysis purposes on the basis of the following legal grounds:

- Your consent under Section 25 para. 1 of the German Telecommunications and Telemedia Data Protection Act (TDDDG) for the initial storage and readout of data; and

- Your consent under Art. 6 para. 1 a) GDPR for further data processing (e.g., tracking).

You can withdraw your consent at any time with effect for the future by reopening the Consent Manager on any page of ourWebsite, deselecting the previously selected category, and saving your preferences.

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b) Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin4, Ireland, on our Website. Google Analytics uses cookies. The information generated by these cookies about your use of our Website is typically transferred to a Google server in the United States and stored there.

We use Google Analytics 4 on our website, which does not log or store IP addresses. As a result, anonymization of IP addresses is not necessary, and a direct personal reference is excluded. Google processes this information on our behalf to evaluate the use of our Website, compile reports on website activity, and provide other services related to website and internet usage.

The IP address transmitted by your browser within the context of Google Analytics is not merged with other Google data.

We also use the “Google Signals” feature within Google Analytics. This enables us to gain deeper insights into user behavior across devices, helping us understand how users interact with ourWebsite. This may include information such as the browser and device used, and which device is more likely to be used to complete a purchase. However, this data is only provided to us by Google in a summarized and already evaluated form, i.e. aggregated and thus anonymized. It is therefore not possible for us to access individual data records or trace them back to individual users.

We process your personal and non-personal data for analysis on our Website based on the following legal grounds:

- Your consent under Section 25 para. 1 of the German Telecommunications and Telemedia Data Protection Act (TDDDG) for the initial storage and readout of data; and

- Your consent under Art. 6 para. 1 a) GDPR for further data processing (e.g., analytics).

You can withdraw your consent at any time with effect for the future by:

- Adjusting your browser settings to prevent the storage of cookies (note that this may limit the functionality of theWebsite);

- Downloading and installing the browser add-on available at: http://tools.google.com/dlpage/gaoptout?hl=en;or

- Reopening the Consent Manager on any page of our Website, deselecting the relevant category, and saving your new preferences.

Further information about Google Analytics’ terms of use and data protection can be found at:

https://www.google.com/analytics/terms/

https://www.google.de/intl/en/policies/

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c) LinkedIn Insight Tag / Ad Conversion Tracking

Our Website uses the “LinkedIn Insight Tag”conversion tool provided by LinkedIn Ireland Unlimited Company. This tool places a cookie in your web browser that enables the collection of data such as your IP address, device and browser characteristics, and website interactions (e.g., page views).

The collected data is encrypted, anonymized within seven days, and the anonymized data is deleted within 90 days. LinkedIn does not share personal data with us but provides aggregated reports on website audience and ad performance. Additionally, the Insight Tag enables retargeting.We can display targeted advertising outside our Website based on this data—without identifying you as a visitor.

For more information on how LinkedIn processes data, please refer to the LinkedIn Privacy Policy and the LinkedIn CookiePolicy. LinkedIn members can control the use of their personal data for advertising purposes through their account settings.

To deactivate the Insight Tag on ourWebsite (“opt-out”), you can adjust your consent preferences by reopening theConsent Manager on any page of our Website.

We process your personal and non-personal data for analysis on our Website based on the following legal grounds:

- Your consent under Section 25 para. 1 of the German Telecommunications and Telemedia Data Protection Act (TDDDG) for the initial storage and access to information on your device; and

- Your consent under Art. 6 para. 1 lit. a GDPR for further data processing (e.g., tracking).

You can withdraw your consent at any time with future effect by reopening the Consent Manager, deselecting the relevantcategory, and confirming your settings.

II) Active Use of the Website
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1. Contact Requests

If you have questions about our Website, the services we offer, or would like to get in touch with us for any other reason, you can contact us directly using the contact details listed in SectionA. I.

To process and respond to your inquiry, we will process the personal data you provide in this context. This typically includes your name and email address so that we can reply to you, as well as any additional information you submit as part of your message.

We process your personal data for the purpose of responding to contact requests on the following legal grounds:

- Based on our legitimate interests pursuant to Art. 6 para. 1 f) GDPR; our legitimate interest lies in the proper handling of customer inquiries;

- If your request relates to entering into a contract, the additional legal basis is Art. 6 para. 1 b) GDPR;

- If your request concerns the exercise of your data subject rights, the additional legal basis is Art. 6 para. 1 c) GDPR, as the processing is necessary to fulfill legal obligations.

In addition to the above-mentioned contact options, you may also reach out to us via the chat functionalities of YouTube, LinkedIn, HubSpot, Google Forms, and Calendly. Further information about data collection in connection with YouTube, LinkedIn, Google Forms, and Calendly can be found in Section J. “Data Processing When Using Social Media” of this Privacy Policy.

2. Registration for gyde Courses

You have the option to register for our training courses via our Website. In such cases, you are required to enter personal data into a registration form and submit it to us.

The following data must be provided:

- First and last name

- Email address

- Job title and name of the company on whose behalf the registration is being made, or an indication that the registration is made for yourself

- If the registration is made on behalf of a company: the number of participants to be registered

- Title of the course for which you are registering

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At the time of registration, the following additional data are also stored:

- The user’s IP address

- Mobile device yes/no

- Date and time of registration

We process your data for the purpose of course registration in order to fulfill a contract or carry out pre-contractual measures in accordance with Art. 6 para. 1 b) GDPR.

3. Business Analysis and Market Research

In order to operate our business efficiently and identify market trends and the needs of our customers and users, we analyze the data available to us from business transactions, contracts, inquiries, and more. This includes the processing of inventory data, communication data, contract data, payment data, usage data, and metadata. The data subjects may include contractual partners, interested parties, customers, visitors, and users of our services and Website.

These analyses are carried out for the purposes of business evaluations, marketing, and market research. In doing so, we may link the profiles of registered users with information such as the services they have used. The analyses help us improve user experience, optimize our offering, and ensure the economic viability of our business. The resulting analysis data is used solely by us and is not shared with third parties. If any analysis results are disclosed, this is done only in fully anonymized, aggregated form.

We process your personal data for this purpose on the following legal grounds:

- Based on our legitimate interests pursuant to Art. 6 para. 1 f) GDPR;

- If applicable in individual cases, based on your consent pursuant to Art. 6 para. 1 a) GDPR.

4. Newsletter and Promotional Emails

With your consent, we use your data for promotional purposes, such as sending our newsletter, marketing surveys, product information, invitations to relevant events and training sessions, follow-ups, status updates, birthday greetings, market research, and other marketing and promotional activities. We collect mandatory information, such as your email address, as well as any voluntary information you choose to provide.This voluntary information helps us continuously improve our customer relationships.

If we have received your email address in connection with a contractual relationship or the provision of our services and you have not objected, we reserve the right to send you regular email offers for similar services from our portfolio. You can object to the use of your email address for this purpose at any time by sending a message to the contact details provided in Section A. I), by clicking the unsubscribe link included in the promotional email, or by using any other opt-out option described in the respective email. No costs other than transmission costs in accordance with basic rates will be incurred.

We process your data for sending newsletters and promotional emails on the following legal bases:

- With your consent, pursuant to Art. 6 para.1 a) GDPR;

- If you provided us with your email address in connection with the purchase of goods or services, based on our legitimate interests pursuant to Art. 6 para. 1 f) GDPR in conjunction with Section 7 para. 3 of the German Act Against Unfair Competition (UWG) our legitimate interest lies in carrying out marketing activities and delivering targeted advertising in line with our business objectives.

5. Analysis of Reactions to Promotional Emails

With your consent, we also analyze how and when you open and interact with our newsletters and promotional emails, using the services of our provider HubSpot. The following data is typically collected and stored:

- User’s email address

- Delivery status from the recipient’s mailserver

- Delivery confirmation of the email

- Timestamp of when the email was opened

- Clicks on links within the email and corresponding timestamps

The evaluation and analysis of this data help us avoid sending you irrelevant advertisements. Instead, we aim to provide you with content that matches your interests. For example, we assess which of our newsletters and promotional emails you open, allowing us to avoid sending unnecessary emails. We also aim to provide information that is tailored to you. By tracking open and click rates, we gain better insight into which content you find engaging.

You can view HubSpot’s privacy policy here:https://legal.hubspot.com/de/privacy-policy

We process this data for the purpose of analyzing reactions to newsletters and promotional emails based on your consent in accordance with Art. 6 para. 1 a) GDPR.

6. Legal Enforcement

We also process your personal data in order to assert our legal rights and enforce claims. Likewise, we process your personal data to defend ourselves against legal claims. In addition, we process your personal data to the extent necessary for the prevention, investigation, or prosecution of criminal offenses.

We process your personal data for this purpose based on the following legal ground:

- To safeguard our legitimate interests pursuant to Art. 6 para. 1 f) GDPR, in cases where we assert legal claims, defend ourselves in legal disputes, or prevent or investigate criminal offenses.

7. Compliance with Legal Obligations

We also process your personal data to fulfill legal obligations. These may arise, for example, in connection with course registrations or business communications. This includes, in particular, retention periods required under commercial, trade, or tax law.

We process your personal data for this purpose on the following legal basis:

- To comply with a legal obligation to which we are subject pursuant to Art. 6 para. 1 c GDPR in conjunction with commercial, trade, or tax law, insofar as we are legally required to record and retain your data.

C. Use of Our Training Services: Purposes and Legal Bases of Data Processing

We process your personal data in the context of delivering our training services. We receive this data either from your employer—if they have registered you for one of our courses—or directly from you, if you have registered yourself or shared the relevant data within our app applications or during group coaching sessions.

1. App Applications / gyde Platform

Our app applications provide learning content on leadership topics via the gyde platform, using microlearning units.In addition to basic text content, the app includes short quizzes and reflection exercises, which can be completed through multiple-choice selections or written input. The purpose of the app is to deliver relevant learning content efficiently, reinforce knowledge through practice, and promote the transfer of insights into daily routines through reflection tasks. The data we collect from you is necessary to achieve the intended coaching outcomes and to continuously improve the services provided by gyde.

In this context, we process in particular the following data:

- User’s email address

- If using third-party login: token from Google, Apple, etc.

- User profile data

- First and last name

- Company the user is employed at

- Role within the company

- Number of employees in the company or the user’s department

- Time spent in the app

- Number and timestamps of completed units

- Usage timestamps

- Approximate location (when using the app)

- Diagnostic data

- Multiple-choice answers or free-text entries (which may, if voluntarily provided, include special categories of personal data under Art. 9 para. 1 GDPR)

2. Virtual Group Coachings

As part of the program, group coaching sessions are offered at regular intervals (e.g., every two weeks). In these sessions, the user participates in a video conference together with leaders from other organizations and a coach assigned by gyde. During the coaching sessions, participants discuss content learned in the app and reflect on real-life situations from their daily work. The goal of these sessions is to deepen the knowledge gained through the app, transfer it into daily routines, and collaboratively find solutions to specific challenges through peer exchange and professional guidance.

During group coaching, the coach may take notes about the participant’s situation. These notes may be used by the coach to improve the quality of coaching sessions, and by gyde to enhance the overall quality of its services.

The data processed during these sessions cannot be defined in advance, as they depend on the user's individual input in the app, their verbal contributions during the coaching, and the respective assessments or notes taken by the coach. This may also include special categories of personal data within the meaning of Art. 9 para. 1 GDPR, if voluntarily shared.

The virtual group coaching sessions are conducted via Google Meet. gyde has no influence over data processing carried out by Google Meet. By using Google Meet, each user enters into a separate user relationship with Google. Further information on Google’s data processing can be found at:

https://support.google.com/meet/answer/9852160

https://cloud.google.com/privacy

https://cloud.google.com/privacy/gdpr

3. Legal Basis for Processing

We process your personal data on the following legal bases:

If we received your data (such as your name and email address) from your employer for the purpose of setting up a preregistration, we process this data based on the consent you granted to your employer in accordance with Art. 6 para. 1 a) GDPR. If you registered for the course yourself and are our contractual partner, we process the data you provided for the performance or initiation of a contract with you pursuant to Art.6 para. 1 b) GDPR.

With regard to the information you provide in the app and during coaching sessions, we process your data based on your consent in accordance with Art. 6 para. 1 a) GDPR and, where applicable, Art. 9para. 2 a) GDPR.

D. Links

Some sections of our websites contain links to third-party websites. These websites are subject to their own privacy policies. We are not responsible for the operation of these websites, including how data is handled. If you provide information to or via such third-party sites, you should review their privacy policies before submitting any data that could be linked to you personally.

E. Categories of Recipients

In the first instance, only our employees have access to your personal data.

Your data is generally only shared with third parties if this is permitted or required by law or if you have given your consent. We also share your data with service providers we engage to the extent necessary for the provision of our services. In doing so, we limit data sharing to what is necessary to deliver our services to you. In some cases, these service providers act as processors and are strictly bound by our instructions when handling your data. In other cases, the recipients act independently with your data, which we have transmitted to them.

The following categories of recipients may receive your data:

Debt collection agencies and legal advisors for the enforcement of our claims

Public authorities and institutions where required by law

Payment service providers and banks to collect outstanding payments or issue refunds

Agencies, printing services, and mailing providers supporting us with training sessions, marketing campaigns, competitions, etc.

IT service providers for the administration and hosting of our websites and services

F. Data Transfers to Third Countries

As part of the use of cookies and similar technologies, your IP address—or a truncated version of it—and potentially other data may be transferred to countries outside the European Union. Suchtransfers are based on the Standard Contractual Clauses developed and provided by the European Commission, which we have concluded with the respective providers.

If we engage service providers in third countries and are able to influence the processing, they are also contractually bound—alongside written instructions—by the EU Standard Contractual Clauses to ensure compliance with the data protection standards applicable in Europe. Alternatively, we may base the transfer on an adequacy decision issued by the European Commission.

Aside from these cases, we do not transfer your personal data to countries outside the EU or EEA, nor to international organizations.

G. Data retention

I) Informational use of the website

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When you use our website for informational purposes only, we store your personal data on our servers solely for the duration of your visit. After you leave our website, your personal data is deleted within 7 days. Any cookies we install are usually deleted when you leave our website.
Some cookies may be stored for a longer period. For more information about thestorage periods of the cookies and tools we use, please refer to the ConsentManager. You can also delete installed cookies at any time.

II) Active use of the website

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When you actively use our website, we initially store your personal data for theduration required to respond to your request or for the duration of ourbusiness relationship. This includes the potential initiation of a contract (pre-contractualrelationship) and the execution of a contract.

We retain your data for the duration ofyour subscription to our marketing emails, until you withdraw your consent orobject to receiving them.

In addition, we store your personal datauntil the expiration of any legal limitation periods, in order to use it asevidence if necessary. The limitation period is typically between 1 and 3years, but can be up to 30 years in some cases.

After the limitation period has expired, wedelete your personal data unless we are required to retain it due to legalobligations, for example under the German Commercial Code (§§ 238, 257 para. 4HGB) or the German Fiscal Code (§ 147 para. 3, 4 AO). These retentionobligations can range from two to ten years. For this period, the data will beprocessed again solely in the event of a review by the tax authorities.

III) Use of the app and virtual group coaching

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If you use our app or participate in virtual group coaching sessions, we store the personal data collected in the course of these activities for the duration of the respective training program. This data remains accessible to you until you request its deletion or until the contractual relationship ends. Once access to the platform ends, the data is deleted—unless there are compelling reasons to retain it (e.g., legal obligations, legal enforcement).

We may aggregate your data in a way that no longer allows it to be linked to you personally. Such anonymized data may be continuously analyzed and used permanently to improve our services. If the data is ever shared with third parties, this is done—if at all—only in anonymized, aggregated form.

H. Scope of your obligations to provide data

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As a general rule, you are not obligated to provide us with your personal data.However, if you choose not to, we may be unable to offer you the full technicalfunctionality of our Website or App, respond to your inquiries, enter into acontract with you, or provide our training services.

I. Profiling / Automated decision-making
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As part of the analysis and evaluation of your response to our marketing emails, your data may be processed in part automatically in order to assess certain personal characteristics (profiling). This enables us to provide targeted information and advice regarding our products and services. It allows for personalized communication and marketing, including market and opinion research.

Beyond this, we do not use profiling or rely solely on automated decision-making as defined in Article 22 GDPR. If we decide to implement such procedures in individual cases in the future, we will inform you separately in advance.

J. Data processing in connection with social media use

To present our company and communicate directly with you, we use social media platforms operated by providers such as LinkedIn, YouTube, HubSpot, Calendly, and others (“providers”), through which we maintain our online presence (e.g., company and employee profiles) and process your data.

I) Joint responsibility

If data is collected on our website that is processed and used by both the provider and us for joint purposes (e.g., for analytics or advertising), there is joint responsibility between us and the operator. Often, this function cannot be disabled by us. You can therefore contact either the respective provider or us regarding your concerns. We currently use the following providers:

- LinkedIn (including LinkedIn SalesNavigator) by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place,Dublin 2, Ireland (German office: LinkedIn Germany GmbH, Sendlinger Str. 12,80333 Munich)

- YouTube by Google Ireland Ltd., GordonHouse, Barrow Street, Dublin 4, Ireland (German office: Google Germany GmbH,ABC-Straße 19, 20354 Hamburg)

- HubSpot by HubSpot, Inc., 25 First Street,Cambridge, MA 02141, USA

- Calendly by Calendly LLC, 271 17th St NWSte 1000, Atlanta, GA 30363, USA

Below you will find links to the privacy policies and information of each provider:

- LinkedIn: https://de.linkedin.com/legal/privacy-policy

- Google (YouTube): https://policies.google.com/privacy

- Microsoft: https://privacy.microsoft.com/en-us/privacystatement

- HubSpot: https://legal.hubspot.com/de/privacy-policy

- Calendly: https://calendly.com/privacy

II) Data protection officers of the providers

In addition to contacting us, you may also contact the following data protection officers of each provider:

- LinkedIn: https://www.linkedin.com/help/linkedin/ask/TSO-DPO

- Google (YouTube): https://support.google.com/policies/contact/general_privacy_form

- HubSpot: privacy@hustle.co

- Microsoft: https://www.microsoft.com/de-de/concern/privacy

- Calendly: privacy@calendly.com

III) Purposes and legal bases for data processing

1. Informational use of our presence

a) Provision of the presence

For the purpose of the technical provision of our social media presence, the web server automatically collects information from your browser each time the website is accessed. You can visit our presence without providing any personal information. If you use our presence purely for informational purposes, i.e., you do not register or otherwise transmit information about yourself to us, we do not process any personal data, except for the data collected by the platform provider through their platform and cookies, which may be transmitted to us.

We and/or the provider process yourpersonal data for the technical provision of our social media presence on thebasis of the following legal basis:

- To safeguard our legitimate interests pursuant to Art. 6 para. 1 f) GDPR, in order to technically enable the presence. Our legitimate interest lies in providing you with an appealing, technically functioning, and user-friendly presence, as well as in taking measures to protect our presence from cyber risks and to prevent our presence from becoming a source of cyber risks for third parties.

b) Analysis and tracking

For the purpose of analyzing and tracking the use of their social media platform and our presence, the provider uses cookies that enable the evaluation of your browsing behavior. This helps improve the quality of both the platform and our presence and their content. We gain insight into how the platform and our presence are used, which allows us to continuously optimize our offerings.

However, we have no influence over the data collected and data processing operations by the provider, nor are we fully aware of the scope of data collection, the specific purposes of processing, or the retention periods. We also do not have information on the deletion of the collected data by the platform operator.

Web analytics refers to the collection, aggregation, and analysis of data about the behavior of visitors to websites. A web analytics service collects data such as which website a user visited prior to accessing a page (so-called referrer), which subpages were accessed, how often they were visited, and how long users remained on those pages. Web analytics is regularly used to optimize websites and to perform cost-benefit analysis of online advertising. It is also possible that information obtained through analysis and tracking of our presence is merged with other data collected in the context of using the presence and platform. If you are registered on the platform, the provider may link data about your platform activity with your personal data (e.g., name/email address) based on your consent, thus collecting personal data and informing you individually and in a targeted manner—for example, based on your preferred topics.

With regard to statistics made available to us by the platform provider, we have only limited influence and cannot deactivate them. However, we ensure that we are not provided with any additional optional statistics.

We process your personal data based on the following legal basis:

Your consent pursuant to Art. 6 para. 1 a) GDPR, which you gave to the provider when registering on the respective social media platform.

2. Active use of our presence

In addition to the purely informational use of our social media presence, you can also actively use it to get in touch with us. In addition to the processing of your personal data described above for informational use, we then also process other personal data from you that we need to handle your inquiry, for example. This also applies in cases where we actively use our presence, for example, to contact you proactively or initiate business relationships.

a) Sharing, publishing, and interacting with posts, reviews, photos, etc.

You may comment on, share, or otherwise interact with posts, photos, videos, etc. created by us on the provider's platform and on our profile (like, recommend, review, etc.). We may share your content on our presence if this is a function offered by the platform operator and communicate with you via the platform. Public messages etc. may be published by the provider but are not used or processed by us for any other purpose.

In the case of reviews, we may publish a response (e.g., to clarify an issue, offer goodwill gestures, etc.) and invite you to follow up. Personal data that you have voluntarily disclosed in your review may be processed in this context.

In addition, we reserve the right to delete content where necessary.

We process your personal data on the following legal basis:

- To safeguard our legitimate interests pursuant to Art. 6 para. 1 sentence 1 f) GDPR. The processing of data serves our public relations and communication efforts.

b) User inquiries

In order to handle your inquiries to us—e.g., via contact forms, chat, or email—respond to them appropriately, and provide you with the requested information, we process the personal data you provide in this context. This includes your contact details so we can respond to you or request additional information, as well as any other information you transmit to us.

If you send us an inquiry via the platform, we may, depending on the required level of confidentiality, refer you to alternative secure communication channels. You may always send confidential inquiries to the addresses listed in the imprint or this privacy policy. Our response may be provided electronically, by phone, or by mail, depending on the nature of your inquiry, the availability of your contact data, and what is deemed appropriate.

We process your personal data for responding to user inquiries, requests for materials, etc., on the following legal bases:

- To safeguard our legitimate interests pursuant to Article 6 para. 1f) GDPR; our legitimate interest lies inappropriately responding to (customer) inquiries;

- If the inquiry relates to the conclusion of a contract or to services to be provided, or otherwise relates to a contractual and/or business relationship between you and us, the additional legal basis is Article6 para. 1 b) GDPR;

- With your consent when using the chat function, pursuant to Art. 6 para. 1 a) GDPR.

c) Legal enforcement

We also process your personal data to assert our rights and enforce our legal claims. Likewise, we process your personal data to defend ourselves against legal claims. Finally, we process your personal data where necessary to prevent or prosecute criminal offenses.

We process your personal data for these purposes based on the following legal basis:

- To safeguard our legitimate interests pursuant to Article 6 para. 1 f) GDPR, insofar as we assert legal claims or defend ourselves in legal disputes or seek to prevent or investigate crimes.

d) Compliance with legal obligations

We also process your personal data on our social media presence to fulfill other legal obligations. These may include, for example, obligations related to registration processes or business communication.These include, in particular, commercial, trade, or tax-related retention requirements.

We process your personal data based on the following legal basis:

- To fulfill a legal obligation to which we are subject pursuant to Article 6 para. 1 c) GDPR in conjunction with commercial, trade, or tax law, where we are required to record and retain your data.

e) Data transfer to third countries

In the context of using social media platforms, your data may be transferred to countries outside the EuropeanUnion, including the USA. We have no influence over this. For further information, please refer to the linked privacy policies of the platform providers.

f) Retention period

When using our social media presence, the provider stores your personal data on their servers. Personal data and cookies are generally deleted by the provider. However, we do not know the exact retention and deletion periods. These may be found in the respective privacy policies of the providers.

g) Profiling / Automated decision-making

It is possible that the operator of a social media platform may process your data in part automatically with the aim of evaluating certain personal aspects (profiling). This may be done to provide you with targeted information and advice about products and services. This enables communication and advertising tailored to your needs, including market and opinion research.

K. Company sale / mergers, etc.

We may process your personal data in connection with a (partial) sale of our company or a merger (or similar transactions such as an acquisition in the context of liquidation, insolvency, dissolution, etc.) with another company. In the event that another company acquires or intends to acquire assets from us, which may include your personal data, or we undertake or plan a merger with another company, we may need to grant that company access to or transfer your stored personal data to enable the review and execution of the company sale or merger (e.g., for the purpose of determining the company’s value, assessing business risks, transferring data/assets, etc.).

We process your personal data on the following legal basis:

- To safeguard our legitimate interests pursuant to Article 6 para. 1 f) GDPR in order to organize and carry out a planned company sale or merger.

L. Data subject rights

If your personal data is processed, you are considered a "data subject" under the GDPR. As a data subject, you are entitled to the following rights under the legal requirements, which you may exercise either directly with us or—when using a social media service—also with the platform provider. Please note that we do not have full influence over the data processing activities of the providers. Our capabilities are largely determined by the corporate policies of each provider. Your rights as a data subject include:

Right of access: You have the right to request confirmation from us at any time within the scope of Art. 15 GDPR as to whether we are processing personal data concerning you. If this is the case, you are also entitled under Art. 15 GDPR to receive information about this personal data and certain other information(including processing purposes, categories of personal data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and, in the case of third country transfer, the appropriate guarantees) and a copy of your data.

Right to rectification: If the personal data we hold about you is inaccurate or incomplete, you may request its correction or completion (Art. 16 GDPR).

Right to erasure or restriction of processing: If the legal requirements are met, you can request the erasure of your personal data (Art. 17 GDPR) or the restriction of the processing of this data (Art. 18 GDPR). However, the right to erasure pursuant to Art. 17 (1) and (2) GDPR does not apply if, among other things, the processing of personal data is necessary for compliance with a legal obligation (Art. 17 (3) (b) GDPR).

Right to object: For reasons arising from your particular situation, you can also object to the processing of your personal data by us at any time (Art. 21GDPR). If the legal requirements are met, we will then no longer process your personal data.

Right to data portability: You are entitled, under the conditions of Art. 20 GDPR, to request that we provide you with the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format

Right to withdraw consent: You have the right to withdraw your consent at any time. The revocation is only effective for the future; this means that the revocation does not affect the legality of the processing carried out on the basis of the consent until the revocation.

Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a supervisory authority—particularly in the EU Member State of your habitual residence—if you believe that the processing of your personal data by us infringes the GDPR.

The supervisory authority responsible for us is:

The State Commissioner for DataProtection and Freedom of Information Baden-Württemberg
Lautenschlagerstraße 20
70173 Stuttgart, Germany
Phone: +49 (0)711 615541-0
Fax: +49 (0)711 615541-15
Email: poststelle@lfdi.bwl.de

The social media platform providers—and thus their responsible supervisory authorities—are often based outside Germany. Typically, this is the Irish Data Protection Commission (21 Fitzwilliam SquareSouth, Dublin 2, D02RD28, Ireland). However, you may also address your complaints to the following German supervisory authorities:

LinkedIn: Bavarian State Office for Data Protection Supervision (Promenade 18, 91522Ansbach)

Google (incl. YouTube): Hamburg Commissioner for Data Protection and Freedom of Information(Ludwig-Erhard-Str. 22, 7th floor, 20459 Hamburg)

Whenever possible, please submit yourrequests in writing to the addresses of the supervisory authorities listedabove or directly to us using the contact details provided under section A.I).

M. Right to object (Art. 21 GDPR)

You have the right to object at any time to the processing of your personal data carried out on the basis of Article 6para. 1 f) GDPR (data processing based on a balancing of interests) or Article6 para. 1 e) GDPR (data processing in the public interest), where reasons arise from your particular situation. This also applies to any profiling based on these provisions, as defined in Article 4 para. 4 GDPR.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.

In individual cases, your personal data may also be processed for direct marketing purposes. If you do not wish to receive advertising, you have the right to object to this at any time; this also applies to profiling insofar as it is associated with such direct advertising.This objection will be observed for the future.

You may object without specific form requirements. Please direct your objection preferably to the contact details provided in section A.I) or to the respective platform provider’s contact details.

N. Changes

This privacy policy is a transparency document. We are required to update it whenever our data processing practices change.

Last updated in July 2025

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Privacy Policy

A. General Information

I) Controller

II) Data Protection Officer

B. Use of our Website: Purposes and Legal Bases of Data Processing

‍I) Informational Use of the Website

1. Technical Provision of the Website‍

2. Analysis and Tracking

II) Active Use of the Website‍

1. Contact Requests

2. Registration for gyde Courses

3. Business Analysis and Market Research

4. Newsletter and Promotional Emails

5. Analysis of Reactions to Promotional Emails

6. Legal Enforcement

7. Compliance with Legal Obligations

C. Use of Our Training Services: Purposes and Legal Bases of Data Processing

1. App Applications / gyde Platform

2. Virtual Group Coachings

3. Legal Basis for Processing

D. Links

E. Categories of Recipients

F. Data Transfers to Third Countries

G. Data retention

I) Informational use of the website

II) Active use of the website

III) Use of the app and virtual group coaching

H. Scope of your obligations to provide data

I. Profiling / Automated decision-making‍

J. Data processing in connection with social media use

I) Joint responsibility

II) Data protection officers of the providers

III) Purposes and legal bases for data processing

1. Informational use of our presence

2. Active use of our presence

K. Company sale / mergers, etc.

L. Data subject rights

M. Right to object (Art. 21 GDPR)

N. Changes

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Request support

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I) Informational Use of the Website

1. Technical Provision of the Website
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II) Active Use of the Website
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I. Profiling / Automated decision-making
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