PRIVACY POLICY

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and this Website operator (“Operator”, “I”, “me” or “my”). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not use the Website and Services. By using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that I do not own or control, or to individuals that I do not employ or manage.

 

Collection of personal information

You can use the Website and Services without telling me who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Website, you may be asked to provide certain Personal Information (for example, your name and email address). I receive and store any information you knowingly provide to me when you fill any forms, want to receive my free guide, book a free Chemistry and Change Talk on the Website, or sign up in my 1:1 program. When required, this information may include the following:

- Contact information (such as email address, phone number, etc)

- Basic personal information (such as name, country of residence, etc)

 

You can choose not to provide me with your Personal Information, but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact me.

 

Privacy of children

I do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to me through the Website and Services, please contact me to request that I delete that child’s Personal Information from my Services. I encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. I also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.

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Use and processing of collected information

I act as a data controller and a data processor in terms of the GDPR when handling Personal Information, unless I have entered into a data processing agreement with you in which case you would be the data controller and I would be the data processor.

My role may also differ depending on the specific situation involving Personal Information. I act in the capacity of a data controller when I ask you to submit your Personal Information that is necessary to ensure the use of the Website and Services. In such instances, I am a data controller because I determine the purposes and means of the processing of Personal Information and I comply with data controllers’ obligations set forth in the GDPR.

I act in the capacity of a data processor in situations when you submit Personal Information through the Website and Services. I do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller in terms of the GDPR.

In order to make the Website and Services available to you, or to meet a legal obligation, I may need to collect and use certain Personal Information. If you do not provide the information that I request, I may not be able to provide you with the requested products or services. Any of the information I collect from you may be used for the following purposes:

- Deliver products or services

- Improve products and services

- Send administrative information

- Send marketing and promotional communications

- Send product and service updates

- Respond to inquiries and offer support

- Post customer testimonials

- Run and operate the Website and Services

 

Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to European data protection law or California Consumer Privacy Act; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by me or by a third party.

 

I rely on the following legal bases as defined in the GDPR upon which I collect and process your Personal Information:

- User’s consent

- Compliance with the law and legal obligations

- Legal claims and proceedings

- My own legitimate interests

 

Note that under some legislations I may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases above. In any case, I will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

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Payments and payment processing

In case of Services requiring payment, you may need to provide your bank account information, credit card details or other payment account information, which will be used solely for processing payments. I use wire transfers, international wire transfers, and third-party payment processors (“Payment Processors”) to assist me in processing your payment information securely.

Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private data exchange happens over a SSL secured communication channel and is encrypted and protected with digital signatures, and the Website and Services are also in compliance with strict vulnerability standards in order to create as secure of an environment as possible. I will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.

Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments (e.g., your email address, address, credit card details, and bank account number) and handle all the steps in the payment process through their systems, including data collection and data processing. The Payment Processors’ use of your Personal Information is governed by their respective privacy policies. I suggest that you review their respective privacy policies.

 

Disclosure of information

Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, I may share your information with my affiliates, contracted companies, and service providers (collectively, “Service Providers”) I rely upon to assist in the operation of the Website and Services available to you and whose privacy policies are consistent with mine or who agree to abide by my policies with respect to the GDPR and Personal Information. I will not share any personally identifiable information with third parties and will not share any information with unaffiliated third parties.

Service Providers are not authorized to use or disclose your information except as necessary to perform services on my behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and I do not authorize them to use or disclose any of the provided information for their own marketing or other purposes. I will share and disclose your information only with the following categories of Service Providers:

- Website, email hosting service providers

- Cloud computing services

- Communication and collaboration services

- Order fulfillment services

- Payment processors

- Performance monitoring services

- Data analytics services

 

I may also disclose any Personal Information I collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when I believe in good faith that disclosure is necessary to protect my rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

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Domain/email hosting via Namecheap 

I use the services of Namecheap Inc., 4600 East Washington Street, Suite 305, Phoenix, AZ 85034, USA to host my domain and email address and have concluded an order processing contract with Namecheap Inc. in accordance with Art. 28 GDPR. This is a contract required by data protection law, which ensures that the personal data of my Website visitors and Services will only be processed in accordance with my instructions and under processed in compliance with the GDPR. For more information please visit Namecheap Inc.'s privacy policy at https://www.namecheap.com/about/privacy-commitment/.

The legal basis is my legitimate interest in the operation and maintenance of the operational security of my domain and my email address of this Website and Services in accordance with Article 6 § 1 Sentence 1 lit. f GDPR.

 

Website hosting via Wix

I host my website at Wix.com Ltd., 40 Namal Tel Aviv St., Tel Aviv 6350671, Israel (hereinafter "WIX"). WIX is a website building and hosting tool. When you visit my Website, user behavior, visitor sources, the region of the website visitors and the number of visitors are analyzed with the help of WIX. WIX stores cookies on your browser that are required to display the website and to ensure security (necessary cookies). The data is stored on the WIX servers in Israel. Israel is considered to be more secure in terms of data protection third country. This means that Israel has a level of data protection that is equivalent to the level of data protection in the equivalent to the European Union. Details can be found in the WIX data protection declaration: http://www.wix.com/about/privacy and https://de.wix.com/about/privacy-dpa-users

WIX is used according to Art. 6 Abs. 1 lit. f GDPR. The legal basis is my legitimate interest in the operation and maintenance of operational security and the most reliable possible presentation of my Website and Services. If a corresponding consent was requested, the processing takes place exclusively on the basis by Art. 6 Abs. 1 lit. a GDPR and 25 Abs. 1 TTDSG insofar that the consent includes the storage of cookies or access to information in the user's end device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time. I have concluded an order processing contract with Wix in accordance with Art. 28 GDPR.

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Luckycloud

I use the services of luckycloud GmbH, Solmsstraße 26, 10961 Berlin, Germany for cloud storage services. The legal basis is my legitimate interest in the operation and maintenance of operational security and the most reliable possible delivery of my Services. Luckycloud facilitates the processing of sensitive data and offers appropriate measures to guarantee the highest possible data protection and compliance according to Art. 6 Abs. 1 lit. f GDPR. Details can be found in the luckycloud data protection declaration: https://luckycloud.de/en/data-and-privacy

 I have concluded an order processing contract with luckycloud in accordance with Art. 28 GDPR.

 

SSL or TLS encryption

This Website uses for security reasons and to protect the transmission of confidential content, such as inquiries a SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and the lock symbol in your browser line. If SSL or TLS encryption is activated, the data that you transmit to me cannot be read by third parties.

 

Retention of information

I will retain and use your Personal Information for the period necessary to comply with my legal obligations, to enforce my agreements, resolve disputes, and unless a longer retention period is required or permitted by law.

Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

 

Transfer of information

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. The transfer of your Personal Information to countries outside the European Union will be made only if you have explicitly consented to it or in the cases provided for by the GDPR and will be processed in your interest.

 

Data protection rights 

Adhering to the GDPR you have certain data protection rights and I aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information I hold about you and if you want it to be removed from my systems, please contact me. In certain circumstances, you have the following data protection rights:

 

• You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for my processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

• You have the right to learn if your Personal Information is being processed by me, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.

• You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request me to complete the Personal Information you believe is incomplete.

• You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in me, or for the purposes of the legitimate interests pursued by me, you may object to such processing by providing a ground related to your particular situation to justify the objection.

• You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and I must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; I no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether my legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or defense of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest.

• You have the right, under certain circumstances, to obtain the erasure of your Personal Information from me. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes (Art. 21 GDPR); and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or defense of legal claims (contradiction by ART. 21 ABS. 1 GDPR).

• You have the right to receive your Personal Information that you have provided to me in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from me, provided that such transmission does not adversely affect the rights and freedoms of others.

• You have the right to complain to a data protection authority about my collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with me, you have the right to lodge a complaint with your local data protection authority. For more information, please contact your local data protection authority in the EEA. In Austria, this is the Data Protection Authority whose websites you can find at https://www.dsb.gv.at/.

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This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof. 

 

How to exercise your rights

Any requests to exercise your rights can be directed to me through the contact details provided in this document. Please note that I may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows me to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If I receive your request from an authorized representative, I may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.

You must include sufficient details to allow me to properly understand the request and respond to it. I cannot respond to your request or provide you with Personal Information unless I first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

 

Cookies

My Website use “cookies” to help personalize your online experience. Cookies are small pieces of data stored in text files that are saved on your computer or other devices when websites are loaded in a browser. They are widely used to remember you and your preferences, either for a single visit (through a "session cookie") or for multiple repeat visits (using a "persistent cookie"). Session cookies are temporary cookies that are used during the course of your visit to the Website, and they expire when you close the web browser. Persistent cookies are used to remember your preferences within my Website and remain on your desktop or mobile device even after you close your browser or restart your computer. They ensure a consistent and efficient experience for you while visiting the Website and Services.

Cookies may be set by the Website ("first-party cookies"), or by third parties, such as those who serve content or provide advertising or analytics services on the Website ("third party cookies"). These third parties can recognize you when you visit my website and also when you visit certain other websites. You may learn more about cookies and how they work here.

 

What type of cookies do I use?

- Necessary cookies

Necessary cookies allow me to offer you the best possible experience when accessing and navigating through my Website and using its features.

- Functionality cookies

Functionality cookies let me operate the Website and Services in accordance with the choices you make.

 

I have a legitimate interest in the storage of necessary cookies in order to provide technical error-free and optimized provision of my Website and Services. If you have given your consent to the use of cookies and comparable recognition technologies, the processing will exclusively take place on the basis of your given consent (Art. 6 Para. 1 lit. a GDPR and 25 Para. 1 TTDSG); the consent can be revoked at any time.

 

What are your cookie options?

If you don’t like the idea of cookies or certain types of cookies, you have the ability to accept or decline cookies, and you can change your browser’s settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit internetcookies.com

Please note, however, that if you delete cookies or do not accept them, you might not be able to use all of the features the Website and Services offer.

 

Do Not Track signals

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, I limit our use and collection of your Personal Information.

 

Calendly

You have the opportunity to book a free "Chemistry Call and Change Talk" regarding my 1:1 program Reclaim Your Control!. Through the secure integration of a calendar provider, my platform enables seamless planning of a free Chemistry Call and Change Talkl, including checking availability. I use the online calendar "Calendly" to request and select an appointment. "Calendly" is an offer from Calendly, LLC, 3423 Piedmont Road NE, Atlanta, GA 30305-1754, United States. When you click on the online appointment booking link, you will automatically be connected to my appointment booking page on Calendly. To enable digital appointment scheduling, Calendly automatically collects information about users of my platform, including appointments, email accounts and names. After choosing your appointment, confirming it and entering your contact details, you will receive an email from Calendly confirming your appointment. Please find further information about Calendly and information on compliance with the GDPR at https://help.calendly.com/hc/en-us/articles/360007032633-GDPR-FAQs. I have concluded an order processing contract with Calendly in accordance with Art. 28 GDPR.

 

Online-based audio and video conferences (conference tools), Zoom Communications Inc.

In order to provide you with my Services I use online conference tools. I use Zoom for that. The provider of this service is Zoom Communications Inc., San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. Please find further information about Zoom and information on compliance with the GDPR at https://zoom.us/de-de/privacy. html.

I have concluded an order processing contract with Zoom in accordance with Art. 28 GDPR.

 

Email marketing/free eBook

I offer a free eBook in the form of an electronic newsletter to which you may voluntarily subscribe at any time. That requires your email address as well as information that allows me to verify that you are the owner of the email address and that you consent to receiving electronic newsletter from me. I am committed to keeping your name and email address confidential and will not disclose your Personal Information to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. I will maintain the information sent via email in accordance with applicable laws and regulations. The processing of the data entered in the electronic newsletter registration form takes place exclusively on the basis of your consent (Art. 6 Abs. 1 lit. a GDPR). 

In compliance with the CAN-SPAM Act, all emails sent from me will clearly state who the email is from and provide clear information on how to contact the sender. You may choose to stop receiving my newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting me. However, you will continue to receive essential transactional emails if necessary. 

 

ConvertKit 

I use the services of ConvertKit to send my free guide and electronic newsletter. The provider is ConvertKit LLC, 750 W Bannock Street 761, Boise, ID 83702, USA. ConvertKit is a service with which, among other things, the sending of electronic newsletters can be organized and analyzed. If you enter data for the purpose of subscribing to the electronic newsletter (e.g. email address, name), this will be processed by ConvertKit. With the help of ConvertKit I can plan, implement and analyze my newsletter campaigns. When you open an email sent with ConvertKit, a file contained in the email (so-called web beacon) connects to ConvertKit's servers. In this way it can be determined whether a newsletter message has been opened and which links have been clicked on. Technical information is also recorded (e.g. time of retrieval, IP address, browser type and operating system). This information cannot be assigned to the respective newsletter recipient. They are used exclusively for the statistical analysis of newsletter campaigns. The results of these analyzes can be used to better adapt future electronic newsletters to the interests of the recipients. If you do not want an analysis by ConvertKit, you must unsubscribe from the electronic newsletter. For this purpose, a corresponding unsubscribe link is available in every electronic newsletter message. The data processing takes place on the basis of your consent (Art. 6 Abs. 1 lit. a GDPR). You can revoke this consent at any time by unsubscribing from the electronic newsletter. The legality of the data processing operations that have already taken place remains unaffected by the revocation. The data you have stored with me for the purpose of subscribing to the electronic newsletter will be stored by me until you unsubscribe from the electronic newsletter and will be deleted both from my servers and from the servers of ConvertKit after you have canceled the electronic newsletter. Data stored by me for other purposes remain unaffected.

Please find further information about ConvertKit and information on compliance with the GDPR at ConvertKit's privacy policy at: https://convertkit.com/privacy

I have concluded a "Data Processing Agreement" with ConvertKit in accordance with Art. 28 GDPR.

 

Disable personalized advertising

If you have a Google Account, you can opt out of personalized advertising on the https://adssettings.google.com/authenticated page. Also, if you opt out of personalizing ads, you may continue to see ads based on factors such as your approximate location based on your IP address, browser type, and recent search terms. What data Google collects and how it uses this information can be found at https://www.google.com/intl/en/policies/privacy/.

 

YouTube 

On this Website, I have integrated videos embedded by YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal. The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES. With each call-up to one of the individual pages of this Website, and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of my Website was visited by you. If you have an account with YouTube and are logged in, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of my Website was visited by you. This information is collected by YouTube and Google and assigned to the respective YouTube account. YouTube and Google will receive information through the YouTube component that you have visited my Website, if you have been logged in at the time of the call to my Website on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for you, the delivery may be prevented if you log off from your own YouTube account before a call-up to my Website is made.

YouTube's data protection provisions, https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.

 

Links to other resources

The Website and Services contain links to other resources that are not owned or controlled by me. Please be aware that I am not responsible for the privacy practices of such other resources or third parties. I encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.

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Information security

I secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. I maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in my control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

Therefore, while I strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond my control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

As the security of Personal Information depends in part on the security of the device you use to communicate with me and the security you use to protect your credentials, please take appropriate measures to protect this information.

 

Data breach

In the event I become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, I reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, I will make reasonable efforts to notify affected individuals if I believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When I do, I will send you an email.

 

Changes and amendments

I reserve the right to modify this Policy or its terms related to the Website and Services at any time at my discretion. When I do, I will revise the updated date at the bottom of this page. I may also provide notice to you in other ways at my discretion, such as through the contact information you have provided.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, I will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

 

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By entering and using the Website and Services, and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to enter and use the Website and Services.

 

Contacting me

If you have any questions, concerns, or complaints regarding this Policy, the information I hold about you, or if you wish to exercise your rights, I encourage you to contact me using the details below:

 

Mirjam Blank

Kitzbüheler Straße 14

6365 Kirchberg in Tirol

office@mirjamblank.com

www.mirjamblank.com

 

I will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.

 

This document was last updated on January, 2024

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