I.  Name and address of theresponsible entity

The responsible entity within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is the:

Elucidmind Digital Health GmbH

Ober der Roeth 4

65824 Schwalbach am Taunus

Germany

Website:www.elucidmind.com&www.elucidmind.de

 E-Mail address of the protection officer of the responsible entity is:

Email: ds-elucidmind[@]elucidmind.com

II. General information about data processing

1. Extent of processing of personal data

In principle, we process personal data of our users only to the extent necessary for the provision of a functional website and our content and services. The processing of personal data of our users takes place regularly only with the consent of the user. An exception applies to cases in which prior consent is not possible for reasons of fact and the processing of the data is permitted by law.

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for processing of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) as legal basis.

In the processing of personal data, is used to perform a contract, the contracting party is the person concerned is required Art. 6 para. 1 lit. b GDPR as legal basis. This also applies to processing operations required to carry out pre-contractual measures.

To the extent that processing of personal data is required to fulfill a legal obligation, the subject to our company, Art. 6 para. 1 lit. c GDPR serves as legal basis.

In the event that vital interests of the data subject or any other natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as legal basis.

If processing is necessary to safeguard the legitimate interests of our company or a third party, and the interests, fundamental rights and fundamental freedoms of the person concerned do not outweigh the former interest, Art. 6 para. 1 lit. f GDPR as legal basis for processing.

3. Data deletion and storage duration

The personal data of the data subject will be deleted or blocked as soon as the purpose for the storage is not given anymore. A storage can also be done if this was provided by the European or national legislation in EU law regulations, laws or regulations, where the responsible subject. Blocking or deletion of the data also takes place when a storage period prescribed by the standards mentioned above expires, unless there is a need for further storage of the data for concluding a contract or fulfillment of the contract.

III.  Provision of the website and creation of log files

1. Description and scope of dataprocessing

Each time our website is accessed, our system automatically collects data and information from the computer system of the calling computer.

The following data is collected: 

1. IP address
2. Date and time of the request
3. Time Zone Difference to Greenwich Mean Time (GMT)
4. Content of the requirement (concrete page)
5. Access Status / HTTP status code
6. Each transmitted amount of data
7. Website from which the request comes
8. Browser
9. Operating system and its interface
10. Language and version of the browser software

The data is also stored in the log files of our system. A storage of this data together with other personal data of the user does not take place.

2. Legal basis for data processing

Legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.

3. Third   Purpose of data processing

The temporary storage of the IP address by the system is necessary to allow delivery of the website to the computer of the user. To do this, the user's IP address needs to be kept for the duration of the session.

 The storage in log files is done to ensure the functionality of the website. Moreover, the data to optimize the website and to ensure the security of our information technology systems serve us. An evaluation of the data for marketing purposes does not take place in this context.

In these purposes also our legitimate interest in the data processing in the manner of Art. 6 para. 1 lit. f GDPR.

4. Duration of Storage

The data are deleted as soon as it is no longer necessary to achieve the purpose of its collection. In the case of collecting the data for providing the website, this is the case when the respective session is completed.

 In the case of storing the data in log files, this is the case after no more than seven days. An additional storage is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible

5. Objection and removal possibility

The collection of the data for the provision of the website and the storage of the data in log files is essential for the operation of the website. There is consequently no contradiction on the part of the user.

IV.  Use of Cookies

a) Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or the Internet browser on the user's computer system. When a user browses a Web site, a cookie can be stored on the user's operating system. This cookie contains a characteristic string that allows the browser to be uniquely identified when the website is reopened.

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser be identified even after a page break.

The following data are stored and transmitted in the cookies:  Language settings.

In addition, we use cookies on our website that allow an analysis of users' browsing behavior.

In this way, the following data can be transmitted:

The following is a list of the collected data:

(1) Entered search terms

(2) Frequency of page views

(3) Use of website functions

The data of the users collected in this way are pseudonymised by technical precautions. Therefore, an assignment of the data to the calling user is no longer possible. The data will not be stored together with other personal data of the users.

When the user calls our website, the user is informed about the use of cookies for analysis purposes and his consent is obtained to the processing of personal data collected during this site visit. In this context, there is also a reference to this privacy policy.

b) Legal basis for data processing

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f GDPR.

The legal basis for the processing of personal data using cookies for analysis purposes is the consent of the user Art. 6 para. 1 lit. a GDPR.

c) The purpose of data processing

The purpose of using technically necessary cookies is the use of websites for the users to simplify. Some features of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page break.

We require cookies for the following applications:

Below is a list of applications. Examples can be:

1. Transfer of language settings
2. Remember keywords

The user data collected by technically necessary cookies will not be used to create user profiles.

The use of the analysis cookies is for the purpose of improving the quality of our website and its contents. Through the analysis cookies we learn how the website is used and so we can constantly optimize our offer.

For these purposes, our legitimate interest lies in the processing of personal data by Art. 6 para. 1 lit. f GDPR.

d) Duration of storage, objection and removal options

Cookies are stored on the computer of the user and transmitted by this on our side. Therefore, as a user, you have full control over the use of cookies. By changing the settings in your internet browser, you can turn off or limit the transmission of cookies. At any time, already saved cookies can be deleted manually or automated. If for our website cookies are disabled, it may not be possible to use all the functions of the website to the fullest.

V.  Contact form ande-mail contact

1. Description and scope of data processing

On our website is a contact form available for electronic contact. If the user uses this communication option and enters data into this form the data is sent to us and stored. These data are:

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

(1)       Title

(2)       First Name

(3)       Last Name

(4)       Subject

(5)       Email

(6)       Phone

(6)       Message

(7)       Date and time of registration

During the process of sending your consent is obtained for the processing of the data and a reference is made to this privacy policy.

Alternatively, contact via the provided e-mail address is possible. In this case, the user's personal data transmitted by e-mail will be stored.

There is no disclosure of data to third parties in this context. The data are used only for the processing of the respective conversation.

2. Legal basis for data processing

Legal basis for the processing of the data is in the presence of the consent of the user Art. 6 para. 1 lit. a GDPR.

The legal basis for the processing of the data received during the sending of an e-mail, is Art. 6 para. 1 lit. f GDPR. If the e-mail contact aims to conclude a contract, then additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.

3. Purpose of data processing

The processing of the personal data from the input mask serves us only to process the contact. In the case of contact via e-mail, this also includes the required legitimate interest in the processing of the data.

The other personal data processed during the sending process step are used to prevent misuse of the contact form and ensure the security of our information technology systems.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary to achieve the purpose of its collection. For the personal data from the input form of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation ends when it can be inferred from the circumstances that the matter in question has been finally clarified.

The additional personal data collected during the sending process will be deleted at the latest after a period of seven days.

5. Objection and removal possibility

The user always has the option to withdraw their consent for the processing of personal data. If the user contacts us by e-mail, he may object to the storage of his personal data at any time. In such a case, the conversation cannot continue.

All personal data that has been stored in the course of the contact, are deleted in this case.

VI.   Rights of the data subject

If your personal data is processed you are concerned in the sense of GDPR you have the following rights to the responsible person/entity:

1. Information Right

You may ask the person in charge to confirm if your personal data is processed by us.

If such processing is available, you can request information from the person responsible about the following information:

1. the purposes for which the personal data are processed;
2. the categories of personal data that are processed;
3. the recipients or the categories of recipients to whom your personal data have been or will be disclosed;
4. the planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage;
5. the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
6. the existence of a right of appeal to a supervisory authority;
7. all available information on the source of the data if the personal data are not collected from the data subject;
8. the existence of automated decision making including profiling according to Art. 22 para. 1 and 4 GDPR and - at least in these cases - meaningful information about the logic involved, as well as the scope and intended impact of such processing on the data subject.

You have the right to request information about whether your personal data are transferred to a third country or an international organization. In this regard, you can request the appropriate warranties in accordance with Art. 46 GDPR in connection with the transmission to be informed.

2. Right to rectification

You have a right to rectification and / or completion to the controller, if the personal data you process is incorrect or incomplete. The person in charge must make the correction without delay.

3. Right to restrict the processing

You may request the restriction of the processing of your personal data under the following conditions:

1. if you contest the accuracy of your personal information for a period of time that enables the controller to verify the accuracy of your personal information;
2. the processing is unlawful and you refuse to delete the personal data and instead request the restriction of the use of the personal data;
3. the controller no longer needs the personal data for the purposes of processing, but you need them to assert, exercise or defend legal claims; or
4. if you object to the processing in accordance with Art. 21 para. 1 GDPR and has not yet determined whether the legitimate reasons of the person responsible outweigh their reasons.

If you have restricted the processing of your personal data, beside the storage this data may only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

If the restriction on processing has been restricted in accordance with the above conditions, the responsible person informs you before lifting the restriction.

4. Right to deletion

a)   Deletion obligations

You can ask the person responsible to delete your personal data without further delay, and the manager is obliged to delete that information immediately, unless one of the following reasons applies:

1. Your personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
2. You revoke your consent to the processing according Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR and there is no other legal basis for the processing.
3. If you have an objection according to Art. 21 para. 1 GDPR to the processing and there are no justifiable reasons with priority for processing, or you have an objection according to Art. 21 para. 2 GDPR to the processing.
4. Your personal data has been processed unlawfully.
5. The deletion of your personal data is required to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.
6. Your personal data collected in the context of the use of information society services in accordance with Art. 8 para. 1 GDPR levied.

b)   Information to third parties

If the person in charge has made your personal data public and is in accordance with Art. 17 para. 1 GDPR obliged to their deletion then this person has to take appropriate measures. These includes technical means and taking into account the technology available and the implementation costs, to inform data controllers and the ones who process the personal data, that you as the data subject requested the deletion of all links to these personal data or the copies or replications of your personal.

c)   Exceptions

The right to erasure does not exist if the processing is necessary

(1)    to exercise the right to freedom of expression and information;

(2)    to fulfill a legal obligation which requires processing under the law of the Union or of the Member States to which the controller is subject, or to carry out a task which is in the public interest or in the exercise of official authority delegated to the controller;

(3)    for reasons of public interest in the field of public health according to Art. 9 para. 2 lit. h and i as well as Art. 9 para. 3 GDPR ;

(4)    for archival purposes of public interest, scientific or historical research purposes or for statistical purposes according to Art. 89 para. 1 GDPR, insofar as the law referred to in section a) is likely to render impossible or seriously affect the achievement of the objectives of this processing, or

(5)    to assert, exercise or defend legal claims.

5. Right to be informed

If you have make use of the right of rectification, erasure or restriction of the data processing to the controller, he / she is obliged to notify all recipients to whom your personal data have been provided to correct or delete or to restrict the processing unless this proves to be impossible or involves unreasonable effort.

You have the right to be informed about these recipients.

6. Right of data portability

You have the right to receive the personal information that you have provided to the controller in a structured, common and machine-readable format. You also have the right to transfer this data to another person without hindrance by the person responsible for providing the personal data, provided that

(1)    the processing is based on a consent according to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract according to Art. 6 para. 1 lit. b GDPR and

(2)    the processing is done by automated methods.

In exercising this right, you have in addition the right that your personal data shall be transmitted directly from one to another responsible person if this is technically feasible. Freedoms and rights of other persons may not be affected.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the controller.

7. Right of objection

You have the right to object at any time, for reasons arising out of your particular situation, to prevent the processing of your personal data, which, pursuant to Art. 6 para. 1 lit. e or f GDPR. This also applies to profiling based on these provisions.

The controller will no longer process your personal data unless he can demonstrate compelling legitimate reasons for processing that outweigh your interests, rights and freedoms, or the processing is intended to assert, exercise or defend legal claims.

If your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct mail.

If you object to the processing for direct marketing purposes, your personal data will no longer be processed for these purposes.

Regardless of Directive 2002/58 / EC, you have the option, in the context of the use of information society services, of exercising your right to opt-out by means of automated procedures that use technical specifications.

8. Right to revoke the data protection consent declaration

You have the right to revoke your privacy statement at any time. The revocation of consent does not affect the legality of the processing carried out on the base of the consent until the revocation.

9. Automated decision in individual case including profiling

You have the right not to be subjected to a decision based solely on automated processing - including profiling - that will have legal effect or similarly affect you in a similar manner. This does not apply if the decision

(1)    is required for the conclusion or fulfillment of a contract between you and the controller,

(2)    is permitted under Union or Member State legislation to which the controller is subject, and where such legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests, or

(3) with your expressed consent.    

However, these decisions may not be based on special categories of personal data under Art. 9 (1) GDPR, unless Art. 9 (2) lit. a or g GDPR applies and reasonable measures have been taken to protect the rights and freedoms as well as your legitimate interests.  

With regard to the cases mentioned in (1) and (3), the person responsible shall take appropriate measures to uphold the rights and freedoms and their legitimate interests, including at least the right to obtain the intervention of a person by the controller, to express his / her own position and heard on challenge of the decision.

10.Right to complain to a supervisory authority

Notwithstanding of other administrative or legal proceedings, you have the right to appeal to an oversight authority, in particular in the Member State of your residency, your place of work or the location of the alleged violation to if you are of the opinion that the processing of your personal data violates GDPR.

The supervisory authority receiving the complaint shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy pursuant to Article 78 of the GDPR.

Further comments and questions please address to Data Protection Officer by e-mail
ds-elucidmind[a]elucidmind.com