PRIVACY POLICY
Privacy Policy
Preamble
With the following privacy policy, we would like to inform you about the types of personal data, hereinafter referred to as ‘data’, that we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and on our websites, hereinafter collectively referred to as ‘online offering’.
The terms used are not gender-specific.
As of 19 January 2026
Table of contents
• Preamble
• Responsible party
• Overview of processing
• Relevant legal basis
• Security measures
• Transfer of personal data
• International data transfers
• General information on data storage and deletion
• Rights of data subjects
• Business services
• Provision of the online offering and web hosting
• Contact and enquiry management
• Changes and updates
Responsible
Lorscheider Productivity & Humanity,
Owner: Prof. Dr.-Ing. Bernd Lorscheider, MSc. Org. Psych.
Leydelstraße 20
52064 Aachen
Authorised representative: Prof. Dr Bernd Lorscheider
Email address: contact@lorscheider.pro
Telephone: +49 176 720 268 04
Legal notice: www.lorscheider.pro/impressum
Overview of processing
The following overview summarises the types of data processed and the purposes for which they are processed, and refers to the data subjects.
Types of data processed
• Inventory data
• Contact
• Content data
• Contract data
• Usage data
• Meta, communication and procedural data
• Log data
Categories of data subjects
• Service recipients and clients
• Prospective customers
• Communication partners
• Users
• Business and contractual partners
Purposes of processing
• Provision of contractual services and fulfilment of contractual obligations
• Communication
• Security measures
• Office and organisational procedures
• Organisational and administrative procedures
• Feedback
• Provision of our online services and user-friendliness
• Information technology infrastructure
• Business processes and business management procedures
Relevant legal bases
Relevant legal bases under the GDPR
Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply at your or our place of residence or business. If more specific legal bases are relevant in individual cases, we will inform you of this in the privacy policy.
Contract fulfilment and pre-contractual enquiries [Art. 6(1)(b) GDPR] Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legal obligation [Art. 6(1)(c) GDPR]Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests [Art. 6(1)(f) GDPR] Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany
In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act, BDSG). The BDSG contains, in particular, special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transfer, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Reference to the applicability of the GDPR and the Swiss DSG
This privacy policy serves to provide information in accordance with both the Swiss DSG and the General Data Protection Regulation (GDPR). For this reason, please note that the terms used in the GDPR are used due to their broader geographical application and comprehensibility. In particular, instead of the terms ‘processing of personal data’, ‘overriding interest’ and ‘sensitive personal data’ used in the Swiss Data Protection Act, the terms ‘processing of personal data’, ‘legitimate interest’ and ‘special categories of data’ used in the GDPR are used. However, the legal meaning of the terms continues to be determined in accordance with the Swiss Data Protection Act within the scope of its application.
Security measures
In accordance with legal requirements, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.
These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability and separation. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted and responses are made to data threats. Furthermore, we take the protection of personal data into account during the development and selection of hardware, software and procedures in accordance with the principle of data protection, through technical design and data protection-friendly default settings.
Securing online connections with TLS/SSL encryption technology (HTTPS)
In order to protect user data transmitted via our online services from unauthorised access, we use TLS/SSL encryption technology. These technologies encrypt the information transmitted between the website or app and the user's browser, or between two servers, thereby protecting the data from unauthorised access. TLS, as the advanced and more secure version of SSL, ensures that all data transmissions meet the highest security standards.
If a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL.
Transfer of personal data
In the course of our processing of personal data, it may happen that this data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.
International data transfers
Data processing in third countries
If we transfer data to a third country, i.e. outside the European Union (EU) or the European Economic Area (EEA), or if this occurs in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is always done in accordance with the legal requirements.
For data transfers to the USA, we primarily rely on the Data Privacy Framework (DPF), which was recognised as a secure legal framework by an adequacy decision of the EU Commission on 10 July 2023. In addition, we have concluded standard contractual clauses with the respective providers that comply with the requirements of the EU Commission and stipulate contractual obligations for the protection of your data.
This double safeguard ensures comprehensive protection of your data. The DPF forms the primary level of protection, while the standard contractual clauses serve as additional security. Should changes arise within the framework of the DPF, the standard contractual clauses serve as a reliable fallback option. In this way, we ensure that your data remains adequately protected even in the event of any political or legal changes.
We will inform you whether individual service providers are certified under the DPF and whether standard contractual clauses are in place. Further information on the DPF and a list of certified companies can be found on the US Department of Commerce website at https://www.dataprivacyframework.gov/ (in English).
Appropriate security measures apply to data transfers to other third countries, in particular standard contractual clauses, explicit consent or transfers required by law. Information on third country transfers and applicable adequacy decisions can be found in the information provided by the EU Commission:
https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.
General information on data storage and deletion
We delete personal data in accordance with the statutory provisions as soon as the underlying consents are revoked or there are no further legal grounds for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be retained for commercial or tax law reasons, or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons, must be archived accordingly.
Our data protection information contains additional information on the storage and deletion of data that applies specifically to certain processing procedures.
If there are several specifications regarding the retention period or deletion deadlines for a piece of data, the longest period shall always apply. We process data that is no longer required for its original purpose but is retained due to legal requirements or other reasons exclusively for the reasons that justify its retention.
Storage and deletion of data
The following general periods apply to storage and archiving under German law
• 10 years – retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets and the work instructions and other organisational documents necessary for their understanding [Section 147 (1) No. 1 in conjunction with (3) AO, Section 14b (1) UStG, § 257 (1) No. 1 in conjunction with (4) HGB].
• 8 years – Accounting documents, such as invoices and expense receipts [Section 147(1) No. 4 and 4a in conjunction with (3) sentence 1 AO and Section 257(1) No. 4 in conjunction with (4) HGB].
• 6 years – Other business documents: commercial or business letters received, copies of commercial or business letters sent, other documents relevant to taxation, e.g. hourly wage slips, operating accounts, calculation documents, price tags, but also payroll documents, insofar as they are not already accounting documents, and cash register receipts [Section 147 (1) Nos. 2, 3, 5 in conjunction with (3) AO, Section 257 (1) Nos. 2 and 3 in conjunction with (4) HGB].
• 3 years – Data required to consider potential warranty and damage claims or similar contractual claims and rights, as well as to process related enquiries, based on previous business experience and customary industry practices, is stored for the duration of the regular statutory limitation period of three years [Sections 195, 199 BGB].
Start of the period at the end of the year
If a period does not expressly begin on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the date on which the termination or other termination of the legal relationship takes effect.
Rights of data subjects
Rights of data subjects under the GDPR
As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
• Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing. This also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw your consent at any time.
• Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of incorrect data concerning you.
• Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
• Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with legal requirements, or to request that it be transferred to another controller.
• Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.
Business services
We process data of our contractual and business partners, e.g. customers and interested parties, collectively referred to as ‘contractual partners’, within the framework of contractual and comparable legal relationships and associated measures and with regard to communication with contractual partners, or on a pre-contractual basis, for example to respond to enquiries.
We use this data to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to protect our rights and for the purposes of administrative tasks associated with these obligations and company organisation. We also process the data on the basis of our legitimate interests in both proper and economic business management and in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights, e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or financial authorities. Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about other forms of processing, such as for marketing purposes, within the framework of this data protection declaration.
We inform contractual partners of the data required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special markings, e.g. colours or symbols, e.g. asterisks, or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for archiving purposes for legal reasons, such as for tax purposes, which is usually ten years. We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications and, as a rule, after the end of the order.
• Types of data processed: Inventory data, e.g. full name, residential address, contact information, customer number, etc.; Payment data, e.g. bank details, invoices, payment history; contact details, e.g. postal and email addresses or telephone numbers; contract data, e.g. subject matter of the contract, term, customer category.
• Data subjects: Service recipients and clients; interested parties; business and contractual partners.
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures; business processes and business management procedures.
• Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’.
• Legal basis: Contract fulfilment and pre-contractual enquiries [Art. 6(1)(b) GDPR]; Legal obligation [Art. 6(1)(c) GDPR]. Legitimate interests [Art. 6(1)(f) GDPR].
Further information on processing procedures, processes and services
• Agency services: We process our customers' data within the scope of our contractual services, which may include conceptual and strategic consulting, campaign planning, implementation of campaigns and processes, handling, server administration, consulting services and training services.
• Legal basis: Contract fulfilment and pre-contractual enquiries [Art. 6(1)(b) GDPR].
• Education and training services: We process the data of participants in our education and training programmes in order to provide them with our training services. The data processed in this context, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and training relationship. The forms of processing also include performance assessment and evaluation of our services and those of our teachers. In the course of our activities, we may also process special categories of data, in particular information on the health of service recipients, as well as data revealing ethnic origin, political opinions, religious or philosophical beliefs. To this end, we obtain the express consent of the service recipients where necessary and otherwise only process the special categories of data if it is necessary for the provision of training services, for the purposes of health care, social protection or the protection of vital interests of the service recipients. Legal basis: performance of a contract and pre-contractual enquiries [Art. 6(1)(b) GDPR].
• Project and development services: We process the data of our customers and clients in order to enable them to select, purchase or commission the selected services or works and related activities, as well as to pay for and make available or execute or provide them. The required information is marked as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for service provision and billing, as well as contact information for any necessary consultations. Insofar as we obtain access to information from end customers, employees or other persons, we process this in accordance with the legal and contractual requirements; legal basis: Contract fulfilment and pre-contractual enquiries [Art. 6 (1) (b) GDPR].
Provision of online services and web hosting
We process user data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.
• Types of data processed: Usage data, e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions; Meta, communication and procedural data, e.g. IP addresses, time stamps, identification numbers, persons involved; log data, e.g. log files relating to logins or the retrieval of data or access times; content data, e.g. text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation.
• Data subjects: Users, e.g. website visitors, users of online services.
• Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment, i.e. computers, servers, etc.); security measures.
• Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’.
• Legal basis: Legitimate interests [Art. 6(1)(f) GDPR].
Further information on processing procedures, processes and services
• Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a ‘web host’). Legal basis: Legitimate interests [Art. 6(1)(f) GDPR].
• Collection of access data and log files: Access to our online offering is logged in the form of so-called ‘server log files’. Server log files may include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL, the previously visited page, and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to prevent server overload, especially in the event of malicious attacks, so-called DDoS attacks, and to ensure server utilisation and stability.
• Legal basis: Legitimate interests [Art. 6(1)(f) GDPR].
• Deletion of data: Log file information is stored for a maximum of 90 days and then deleted or anonymised. Data that needs to be kept for evidence purposes is excluded from deletion until the respective incident has been finally clarified.
• Email dispatch and hosting: The web hosting services we use also include the sending, receiving and storage of emails. For these purposes, the addresses of the recipients and senders as well as further information relating to the sending of emails, e.g. the providers involved, and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of detecting spam. Please note that emails are generally not sent in encrypted form on the internet. As a rule, emails are encrypted during transmission, but not on the servers from which they are sent and received, unless a so-called end-to-end encryption method is used. We therefore cannot accept any responsibility for the transmission of emails between the sender and the recipient on our server. Legal basis: Legitimate interests [Art. 6(1)(f) GDPR].
• 1&1 IONOS: Services in the field of providing information technology infrastructure and related services, e.g. storage space and/or computing capacity; Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: legitimate interests [Art. 6(1)(f) GDPR]; website: https://www.ionos.de; privacy policy: https://www.ionos.de/terms-gtc/terms-privacy. Data processing agreement: https://www.ionos.de/terms-gtc/avv/.
• Wix: Hosting and software for the creation, provision and operation of websites, blogs and other online offerings; Service provider: Wix.com Ltd., Nemal St. 40, 6350671 Tel Aviv, Israel; Legal basis: Legitimate interests [Art. 6(1)(f) GDPR]; Website: https://de.wix.com/; Privacy policy: https://de.wix.com/about/privacy; Data processing agreement: https://www.wix.com/about/privacy-dpa-users; Basis for third country transfers: Data Privacy Framework (DPF).
• Microsoft 365: Services in the field of providing information technology infrastructure and related services, in particular the receipt, sending and storage of emails; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement; Legal basis: Contract fulfilment and pre-contractual enquiries [Art. 6(1)(b) GDPR]; Legitimate interests [Art. 6(1)(f) GDPR].
Contact and enquiry management
When contacting us, e.g. by post, contact form, email or telephone, as well as within the framework of existing user and business relationships, the details of the persons making the enquiry are processed to the extent necessary to respond to the contact enquiries and any requested measures.
• Types of data processed: Contact details, e.g. postal and email addresses or telephone numbers; content data, e.g. text or image messages and posts, as well as information relating to them, such as details of authorship or time of creation; meta, communication and process data, e.g. IP addresses, time details, identification numbers, persons involved.
• Data subjects: Communication partners.
• Purposes of processing: Communication; organisational and administrative procedures; feedback, e.g. collecting feedback via online form; provision of our online services and user-friendliness.
• Storage and deletion: Deletion in accordance with the information in the section ‘General information on data storage and deletion’.
• Legal basis: Legitimate interests [Art. 6(1)(f) GDPR]; fulfilment of contract and pre-contractual enquiries [Art. 6(1)(b) GDPR].
Further information on processing procedures, methods and services
• Contact form: When you contact us via our contact form, by email or other means of communication, we process the personal data you provide in order to respond to and process your enquiry. This usually includes information such as your name, contact details and, if necessary, other information that you provide and that is required for appropriate processing.
We use this data exclusively for the stated purpose of establishing contact and communication; legal bases: performance of a contract and pre-contractual enquiries [Art. 6(1)(b) GDPR]; legitimate interests [Art. 6(1)(f) GDPR].
• Microsoft 365: Services in the field of providing information technology infrastructure and related services, in particular the receipt, sending and storage of emails; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement; Legal basis: Contract performance and pre-contractual enquiries [Art. 6(1)(b) GDPR]; Legitimate interests [Art. 6(1)(f) GDPR].
Changes and updates
We ask that you regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to our data processing practices make this necessary. We will inform you as soon as the changes require action on your part, e.g. consent, or other individual notification.
If we provide addresses and contact information for companies and organisations in this privacy policy, please note that the addresses may change over time and we ask you to check the information before contacting them.
Supervisory authority responsible for us:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
Kavalleriestraße 2-4
40213 Düsseldorf
Telefon: +49 211 38424-0
Fax: +49 211 38424-999
Email: poststelle@ldi.nrw.de
Based on datenschutz-generator.de, Dr Thomas Schwenke.