Privacy Policy

1. Controller

The controller responsible for data processing within the meaning of the GDPR is:

Mario Raczek und Michael Sauerwein GbR
Rubensstraße 8
66663 Merzig
Germany

Represented by: Mario Raczek and Michael Sauerwein

Phone: +49 6861 9086823
Email: info@hundeschule-unterhunds.de

Data protection officer

We have not appointed a data protection officer, as the legal requirements for a mandatory appointment under Section 38 of the German Federal Data Protection Act (BDSG) are not met. For all questions about data protection, you can contact us directly using the details above.

2. General information on the processing of personal data

We process personal data exclusively within the scope of the GDPR and other applicable data protection laws.

Processing takes place in particular for the purpose of:

• providing our websites and online services
• performing contracts and bookings
• providing digital content
• managing user accounts
• processing payments
• communicating with customers and prospective customers
• ensuring technical security

Legal bases

• Art. 6(1)(a) GDPR – consent
• Art. 6(1)(b) GDPR – performance of a contract or pre-contractual measures
• Art. 6(1)(c) GDPR – compliance with a legal obligation
• Art. 6(1)(f) GDPR – legitimate interests

As a rule, we do not deliberately process special categories of personal data under Art. 9 GDPR, in particular health data. If you provide such information to us without being asked, we process it only where a legal basis under Art. 9 GDPR applies. Where necessary, we obtain your explicit consent before any further processing.

3. Recipients and transfers to third countries

Within our organization, only those persons who need access to your data to perform their duties receive it.

In addition, we use service providers who process data on our behalf. These are in particular the following categories:

• hosting and IT service providers
• providers of AI-based evaluation services
• payment service providers
• providers of analytics and marketing services
• providers of communication and booking services
• tax advisors as well as legal and accounting service providers

Where these service providers act on our behalf, processing is based on a data processing agreement pursuant to Art. 28 GDPR.

Transfers to third countries

In individual cases, personal data is transferred to recipients outside the European Union, in particular to the USA. This concerns the services specifically identified in this policy.

Such a transfer takes place only if one of the following safeguards applies:

• an adequacy decision of the European Commission pursuant to Art. 45 GDPR – for certified companies in the USA, in particular the decision on the EU-U.S. Data Privacy Framework of July 10, 2023
• standard contractual clauses pursuant to Art. 46(2)(c) GDPR
• your explicit consent pursuant to Art. 49(1)(a) GDPR

Please note that third countries may not offer a level of data protection comparable to that of the EU, and access by government authorities cannot be completely ruled out.

4. Retention periods

We store personal data only for as long as necessary for the respective purposes or as required by statutory retention obligations. After that, the data is deleted or restricted.

Type of data	Retention period	Basis
Server log data	usually 7 days, at most 30 days	Operational security
Inquiries by email or contact form	until the inquiry has been fully handled, then up to 6 months	Traceability of follow-up questions
User account and learning progress	for the duration of use; deletion after 24 months of inactivity	Performance of the contract
Free-text entries and feedback in learning products	for the duration of use; deleted together with the user account	Performance of the contract
Exam results and certificates	up to 10 years after completion	Evidence toward authorities
Accounting records, invoices and other tax-relevant documents	8 years from the end of the calendar year in which the record was created	Section 147(3) German Fiscal Code (AO), Section 257(4) German Commercial Code (HGB)
Commercial and business letters received and sent	6 years from the end of the calendar year	Section 147(3) AO, Section 257(4) HGB
Records of consent	until 3 years after withdrawal	Accountability, Art. 5(2) GDPR

5. Website access and hosting

When you visit our websites and online services, technical information is processed automatically. This includes in particular:

• IP address
• date and time of access
• browser type and version
• operating system
• pages and files accessed
• amount of data transferred and notification of successful retrieval
• previously visited page (referrer)

This processing serves to ensure the functionality, security and stability of our services and to detect and defend against attacks.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a secure and functioning online service)

Hosting providers

Our online services are hosted by two providers:

ALL-INKL.COM – Neue Medien Münnich
Owner René Münnich
Hauptstraße 68
02742 Friedersdorf
Germany

This is where the website unterhunds.de with all its content and subpages is hosted.

STRATO GmbH
Pascalstraße 10
10587 Berlin
Germany

This is where the learning tools and booking applications at hundeschule-unterhunds.de and our email mailboxes are hosted.

The servers of both providers are located in Germany. No transfer to third countries takes place in this respect.

We have concluded a data processing agreement pursuant to Art. 28 GDPR with both providers. Processing takes place exclusively to provide our online services.

Encryption

Our websites use TLS encryption. You can recognize an encrypted connection by the address bar of your browser.

6. Contacting us

If you contact us by email, contact form, phone or other means of communication, we process the information you provide in order to handle your inquiry. This may include in particular:

• name
• email address
• phone number
• content of your message
• information about your dog, if you provide it
• other information you provide voluntarily

Legal basis: Art. 6(1)(b) GDPR for pre-contractual or contractual matters, otherwise Art. 6(1)(f) GDPR (legitimate interest in answering inquiries).

7. Appointment booking and course registration

To arrange training appointments, courses and seminars, we process the contact and appointment details you provide. These include in particular your name, contact details, preferred date, the service booked and information about your dog.

Appointments are managed using a system that we have developed and operate ourselves on our own infrastructure. No external booking service provider is used; your booking data is not transferred to third-party providers. The information in section 5 applies to hosting.

Legal basis: Art. 6(1)(b) GDPR (pre-contractual measures and performance of the contract)

8. Online shop, digital products and user account

Digital products, training, courses and other services can be purchased through our online services. Certain services require a personal user account.

When you register and use a user account, we process in particular:

• first and last name
• email address
• user name or login data
• password (stored in hashed form only)
• products purchased and services booked
• date of registration and times of access
• access and authorization information

Passwords are stored exclusively as a cryptographic hash. It is technically impossible for us to recover the plain-text password.

Processing takes place to set up and manage your user account, to provide purchased content and to perform the contractual relationship.

Legal basis: Art. 6(1)(b) GDPR (performance of the contract)

Retention and deletion of the user account

Your user account remains in place for as long as you use our digital services. After 24 months without a login, we delete the account including the associated learning progress. We will inform you by email before deletion.

You can request the deletion of your user account at any time. This does not affect data subject to statutory retention obligations, in particular invoice and booking data and exam records. Such data is restricted from further use and deleted once the retention periods have expired.

9. Payment processing via Stripe

For processing payments within our online services, we use the payment service provider:

Stripe Payments Europe Limited
1 Grand Canal Street Lower
Grand Canal Dock
Dublin 2
Ireland

Stripe enables the secure processing of payments, in particular by credit card, SEPA direct debit or other payment methods supported by Stripe. Payment data such as full credit card numbers is transmitted directly to Stripe and is never visible to us.

The following data may be processed in the course of payment processing:

• customer name
• email address and billing address
• payment information
• transaction data and payment status
• information about the product purchased or the service booked
• technical data for fraud prevention, such as IP address and device information

Role of Stripe and legal bases

Stripe processes personal data partly as an independent controller for the provision of payment services and partly as a processor pursuant to Art. 28 GDPR where Stripe acts on our behalf. A corresponding agreement is in place for processing on our behalf.

Purpose	Legal basis
Processing payments and providing purchased services	Art. 6(1)(b) GDPR (performance of the contract)
Preventing payment fraud	Art. 6(1)(f) GDPR (legitimate interest in protection against payment default and misuse)
Fulfilling documentation and accounting obligations	Art. 6(1)(c) GDPR (legal obligation)

Transfers to third countries

Stripe Payments Europe Limited belongs to the group of companies of Stripe, Inc., 354 Oyster Point Boulevard, South San Francisco, CA 94080, USA. A transfer of personal data to the USA is therefore possible. Stripe bases this transfer on standard contractual clauses pursuant to Art. 46(2)(c) GDPR. See also section 3.

Further information on data processing by Stripe: stripe.com/privacy

9a. Purchases of digital guides sold through Link

We sell our English-language digital guides internationally through Stripe Managed Payments. In this case, Stripe acts as the merchant of record through its service Link: the guide is sold through Link, and Link, not unterHUNDs, is the seller you enter into the purchase contract with. The seller is named on the checkout page and on your receipt.

At checkout, Link collects and processes the data required for the purchase, in particular your name, email address, billing address and country, your payment details and technical data such as your IP address, which is also used to determine the applicable sales tax and to prevent fraud. Link also sends your receipt and invoice and handles payment-related support and refund requests. For this processing, Link is an independent controller. Its privacy policy applies: link.com/privacy-center

We receive from Stripe the information needed to provide the guide you purchased and to assist you with questions about its content, in particular your name, email address, country, the product purchased and the order status. We do not receive your full payment details.

Legal basis: Art. 6(1)(b) GDPR (providing the purchased content) and Art. 6(1)(c) GDPR (statutory documentation and retention obligations).

Transfers to third countries: Stripe and Link belong to the group of companies of Stripe, Inc. in the USA. A transfer of personal data to the USA is therefore possible; the information in sections 3 and 9 applies accordingly.

10. Order and contract data

In connection with purchases and bookings, we store contract and transaction data, in particular:

• products or services purchased
• payment status
• invoice information
• communication in connection with the purchase

This data is stored to perform the contract, to support customers and to comply with statutory retention obligations.

Legal basis: Art. 6(1)(b) GDPR and Art. 6(1)(c) GDPR (where statutory retention obligations apply)

11. Learning platforms and digital training products

User accounts may be required for our digital training products and learning platforms. They give access to protected content, courses, materials and learning progress.

When you use them, we process in particular:

• name
• email address
• user ID
• access and authorization information
• courses and content booked
• learning progress
• processing times and activities within the platform

Processing takes place to provide digital content, to manage access and to deliver our training products.

Legal basis: Art. 6(1)(b) GDPR (performance of the contract)

Recording of learning progress

To provide and organize our courses, we store information about your learning progress, for example:

• completed modules and lessons worked on
• times of activities
• status of assignments
• repetition intervals and learning status of individual questions
• selected learning mode

This data serves to deliver the training product and to manage your access. It is stored individually so that your learning status is available again the next time you log in.

Legal basis: Art. 6(1)(b) GDPR (performance of the contract)

Evaluation to improve our products

In addition, we evaluate learning and exam data in aggregated form to improve content, questions and levels of difficulty – for example, to identify questions that are answered incorrectly unusually often. This evaluation is carried out without reference to individual persons.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the quality assurance of our training products). We protect your interest in the protection of your data by carrying out the evaluation exclusively in aggregated form and without personal reference.

11a. Dog folder (Hundemappe)

The dog folder is a digital tool in which you record information about your dog and from which you can create an emergency plan and a short report for the veterinary practice. Its use requires a user account; section 8 also applies.

In the dog folder, we process the information you enter yourself, in particular:

• information about the dog: call name, breed, sex, date of birth, weight, markings, microchip number and registration number
• information about keeping the dog: feeding, daily routine, handling, known cues
• information about the animal's health: illnesses, medication, vaccinations, observations and progress entries
• contact details: owner, second contact, caretakers as well as veterinary practices and clinics
• appointments, reminders and your own notes
• information about the animal's insurance

Information about an animal's health is not health data within the meaning of Art. 9 GDPR, as this provision refers to natural persons. Personal data arises where you enter contact details of yourself and other persons.

Legal basis: Art. 6(1)(b) GDPR (performance of the contract)

Information about other persons

If you enter the contact details of other persons, such as a caretaker, a family member or a neighbor, we process this data exclusively on your behalf and display it to no one but you. Please only enter data whose disclosure has been agreed with the persons concerned, and inform them about it. Contact details of veterinarians and clinics usually concern businesses rather than private individuals.

Email reminders

If you switch this on in your account, we remind you by email of appointments you have entered yourself. For this purpose, we process your email address, the appointment and the name of the dog. Every reminder contains an unsubscribe link; you can also switch reminders off in your account at any time. We log sending processes so that we can trace delivery problems.

Legal basis: Art. 6(1)(a) GDPR (consent). You can withdraw your consent at any time with effect for the future. The lawfulness of processing carried out until then remains unaffected.

Calendar subscription

On request, we provide your appointments as a calendar file that you can subscribe to in Outlook, Google Calendar or Apple Calendar. The address of this file contains a random key and can be accessed without logging in, because calendar programs cannot log in. Anyone who knows this address can see the appointments it contains, so please do not share it. You can generate a new key in your account at any time; the previous address then stops working immediately.

Legal basis: Art. 6(1)(b) GDPR (performance of the contract)

Emergency plan and short report

The emergency plan and short report are generated on our server from your information and made available to you for viewing, printing or downloading. We do not pass them on to third parties. Whether and to whom you pass on the document is your decision.

Downloading and deleting your data

In your account, you can download all information about your dogs as a file at any time. You can also delete your account in your account settings, including all dogs and all entries. Deletion takes effect immediately and cannot be undone. This does not affect data subject to statutory retention obligations, in particular invoice and booking data.

If your account is not used for 24 months, we delete it including the information about your dogs. We will inform you by email beforehand.

12. Evaluation of exams, assignments and tests

Within our learning platforms, we offer assignments, tests and exams, in particular as part of the unterHUNDs Trainerakademie. In this context, we process your entries, answers and results in order to conduct and assess the respective training product.

We process in particular:

• free-text and multiple-choice answers
• times and duration of processing
• scores and assessments achieved
• exam results and resulting certificates

Legal basis: Art. 6(1)(b) GDPR (performance of the contract within the training relationship)

No automated individual decision-making

No decision based solely on automated processing within the meaning of Art. 22(1) GDPR takes place. You have the right to request a review of your assessment, to express your point of view and to contest the assessment.

13. Transfer of entries to OpenAI

In some of our digital learning products, you enter answers as free text. To generate feedback, we transfer these entries to an external service provider.

The following is transferred:

• the text you entered
• the associated question and assignment

Your name, email address and other information from your user account are not transferred. The service provider cannot tell who an entry comes from.

Recipient

OpenAI Ireland Limited
1st Floor, The Liffey Trust Centre
117–126 Sheriff Street Upper
Dublin 1, D01 YC43
Ireland

Legal basis: Art. 6(1)(b) GDPR (performance of the contract – the feedback is part of the service you booked)

Processing on our behalf

The transfer takes place via OpenAI's application programming interface (API), not via a publicly accessible chat interface. OpenAI processes the transferred entries within the API services we use on the basis of a data processing agreement pursuant to Art. 28 GDPR. The transferred content is not used to improve or train general AI models.

Transfers to third countries

Processing also takes place outside the European Union, in particular in the USA. OpenAI bases this transfer on standard contractual clauses pursuant to Art. 46(2)(c) GDPR. The information in section 3 also applies.

Retention by the service provider

Unless other settings or contractual agreements apply, OpenAI stores transferred inputs and outputs for up to 30 days to detect misuse and deletes them afterwards. We store the feedback itself in your user account so that you can access it again later; the information in section 4 applies.

Further information on data processing by OpenAI: openai.com/policies/eu-privacy-policy

14. Cookies and similar technologies

Our online services use cookies and comparable technologies. Cookies are small text files that are stored on your device and enable certain functions. Comparable technologies include, for example, your browser's local storage (local storage and session storage).

Strictly necessary cookies

We use strictly necessary cookies where they are required to operate our websites, the login area, security functions or to provide services you have requested. These include in particular session cookies that keep you logged in and cookies that store your cookie settings.

Another strictly necessary cookie (unterhunds_nicht_zaehlen) is set only at your express request and ensures that our own page count described in section 15a does not count visits from this browser. We use it so that our own visits do not distort the statistics. It contains no personal data and is valid for one year.

Storing intermediate entries in your browser's local storage is also strictly necessary. This keeps entries in our learning products that you have started but not yet submitted if the browser is closed or the connection is lost. This data remains on your device and is not transferred to us.

Legal basis: Section 25(2) No. 2 German Telecommunications Digital Services Data Protection Act (TDDDG) and Art. 6(1)(f) GDPR (legitimate interest in a functioning online service)

Cookies requiring consent

We use analytics, marketing and comparable technologies only if you have given your prior consent via our cookie banner.

Legal basis: Section 25(1) TDDDG and Art. 6(1)(a) GDPR

Withdrawing your consent

You can withdraw your consent or change your selection at any time with effect for the future. The lawfulness of processing carried out until the withdrawal remains unaffected.

To withdraw consent and change your cookie settings, we provide a dedicated page that is permanently linked in the footer of all our online services: Change cookie settings (page in German)

15. Analytics and marketing services

If you have given your consent, we use the services described below to evaluate the use of our services and to improve them. Without your consent, these services are not loaded.

Google Tag Manager

We use Google Tag Manager of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Tag Manager is used to manage and trigger website tags. It does not create user profiles itself and is not used for independent analysis of user behavior; however, connection and diagnostic data may be processed by Google when it is technically retrieved. It enables the services described below to be triggered.

Google Analytics 4

We use Google Analytics 4 for the statistical analysis of the use of our websites. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The measurement ID used is G-MYSHK9LZP8.

The following data is processed in particular:

• truncated IP address
• pages accessed, time spent and interactions
• device and browser information
• approximate location data based on the IP address
• source of access (referrer)
• pseudonymous identifiers to recognize returning visits

The IP address is truncated by Google before it is stored. We do not combine the collected data with other Google data.

Retention: User-level data in Google Analytics 4 is automatically deleted after 14 months.

Legal basis: Art. 6(1)(a) GDPR and Section 25(1) TDDDG (consent)

Transfers to third countries: A transfer to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, cannot be ruled out. Google LLC is certified under the EU-U.S. Data Privacy Framework; the transfer is therefore covered by an adequacy decision of the European Commission of July 10, 2023. In addition, Google has concluded standard contractual clauses.

Further information: policies.google.com/privacy

Google Ads

We use Google Ads of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, to advertise our services and to measure the effectiveness of this advertising.

Conversion tracking

If you click on an ad placed by us, a cookie is set. This allows us to record whether certain actions take place on our website after the click, such as a booking or a purchase. We receive only aggregated statistics from Google and no information that could be used to identify individual persons.

Retention: The cookies used for conversion tracking usually expire after 90 days.

Enhanced conversions

If you submit a form on our website, the email address and phone number you enter are encrypted (hashed) in your browser and transferred to Google in this form. Google matches them against its own accounts in order to attribute an inquiry to a click on an ad. The plain data itself does not leave your browser, and we continue to receive only aggregated statistics from Google.

This happens only if you have consented to the Marketing category. Without this consent, the Google advertising service is not loaded at all. You can change your selection at any time in the cookie settings.

Remarketing

Remarketing functions allow visitors to our website to be shown tailored advertising again within the Google advertising network. For this purpose, usage behavior on our website is recorded pseudonymously and used to create target groups.

Legal basis: Art. 6(1)(a) GDPR and Section 25(1) TDDDG (consent)

Transfers to third countries: The information on Google Analytics 4 applies accordingly. You can also adjust your advertising settings directly with Google: myadcenter.google.com

Access by automated systems

Our publicly accessible specialist content is also retrieved by automated systems, such as search engine crawlers. Only the server log data described in section 5 is generated. No further processing of personal data takes place.

15a. Our own cookie-free page count

In addition to Google Analytics 4, we carry out our own simple count of page views. It works without cookies and does not store any data on your device. No information is transferred to third parties; the evaluation takes place exclusively on our own server.

Data collected:

• time of access
• page accessed
• type of source (such as search engine, social network or direct access) – without the full address of the referring page
• rough device type (computer, tablet or phone)
• a daily identifier
• whether a further link was clicked, for example to one of our learning tools, to a bookseller or to a social network – only the destination is counted, not who clicked

The identifier is created from a hash value (SHA-256) of the IP address, the browser identifier and a random value that changes daily. It cannot be traced back to the original data, and the same person receives a different identifier every day. The IP address itself is never stored. Recognition beyond the day is therefore impossible.

Scope: We count the pages of this website and, in addition, the learning tools at hundeschule-unterhunds.de, which are also operated by us. They are located on a different server; so that both come together in one evaluation, the respective page there reports the page view to our server. The same information as above is transmitted – the address accessed and the type of source. Unlike on this website, this is done via a small script in the browser: anyone who has disabled JavaScript or uses a content blocker is not counted there.

Purpose: We want to know which content is read and how people find us, in order to improve our services.

Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest lies in designing our website according to demand. Consent under Section 25 TDDDG is not required because no information is stored on or read from your device.

Retention: The count data is deleted after 400 days at the latest.

Objection: On this website, the count takes place on our server, not in your browser; disabling JavaScript or using a content blocker therefore does not prevent it. For the learning tools at hundeschule-unterhunds.de, the opposite is true – either is sufficient to not be counted there. Since there is no lasting recognition and we cannot identify any individual person from the stored identifier, an objection relating to a specific person against count data that has already been stored is technically not feasible. If you have questions about this, please contact us at the address given in section 1.

16. Embedded videos

YouTube

Videos from the YouTube service are embedded on our pages. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube's privacy-enhanced mode. Data is transferred to YouTube only when you actively start a video. In particular, your IP address, device information and information about the video accessed may be processed. If you are logged into your Google account at the same time, Google can assign the use to your account. You can prevent this by logging out of your Google account before visiting our pages.

Legal basis: Art. 6(1)(a) GDPR and Section 25(1) TDDDG (consent)

The information on transfers to third countries in section 15 applies accordingly.

Our own videos

Videos that we provide directly through our own systems are delivered without embedding external video platforms. They are not passed on to external providers for analytics or advertising purposes. Only the server log data described in section 5 is generated.

17. Social media

We maintain online presences on social networks, in particular Facebook, Instagram and YouTube. When you visit these presences, personal data is processed by the respective providers, among other things through the use of cookies and comparable technologies.

The providers are:

• Facebook and Instagram: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland
• YouTube: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

Joint controllership

For the processing of data as part of so-called Page Insights – the statistical evaluation of the use of our Facebook and Instagram presences – we are joint controllers with Meta within the meaning of Art. 26 GDPR. We receive only aggregated statistics and no information about individual persons.

Meta has assumed primary responsibility for the processing of Insights data under data protection law and provides the necessary information pursuant to Art. 13 GDPR. You can view the joint controllership agreement here: Page Insights Controller Addendum

You can exercise your rights as a data subject both against us and against Meta. Since we do not have the underlying raw data, a request directly to Meta is usually more effective; we forward requests where necessary.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in public presentation, customer communication and the reach of our services). At platform level, processing is also based on the consent given to the respective provider.

Further information can be found in the privacy policies of the respective platform providers. We recommend that you send inquiries with sensitive content to us by email rather than via social networks.

18. Photos and videos from training sessions, events and courses

Photos and videos may be taken during our dog training sessions, events, seminars and other services. We distinguish between recordings that show only animals and recordings in which persons are recognizable.

Recordings without recognizable persons

We use recordings showing only dogs or training situations without identifiable persons for our own purposes, for example to present our services on our websites or on social media.

We take into account that a dog, in combination with other information such as its name, breed, location or course title, may allow conclusions to be drawn about its owner. In such cases, we treat the recording like a recording with a recognizable person and obtain consent.

We do not publish recordings together with information about a dog's state of health or specific behavior problems unless we have separate consent for this. This applies in particular to recordings from behavior therapy.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in presenting our work), provided there is no personal reference.

Recordings with recognizable persons

We publish or use recordings in which participants, customers, companions or other persons are recognizable only with prior explicit consent. We obtain this consent in text form and document it.

Consent is voluntary. Refusing it has no disadvantages for you; you can take part in our services regardless.

Consent can be withdrawn at any time with effect for the future. After a withdrawal, we remove the recordings from the channels we control. We may have no influence on further distribution by third parties that has already taken place or on archive copies in social networks.

Legal basis: Art. 6(1)(a) GDPR and, in addition, Sections 22 and 23 of the German Art Copyright Act (KunstUrhG)

19. Communication via WhatsApp

If you contact us via WhatsApp, communication takes place via the provider WhatsApp Ireland Limited, Merrion Road, Dublin 4, Ireland.

In particular, your phone number, communication content, profile information and technical metadata may be processed. Message content is end-to-end encrypted; the resulting metadata is not.

Processing of personal data outside the European Union, in particular in the USA, cannot be ruled out. The information in section 3 applies.

Legal basis: Art. 6(1)(b) GDPR for contract-related communication, otherwise Art. 6(1)(f) GDPR (legitimate interest in being easy to reach).

20. Data security

We use technical and organizational measures to protect personal data against loss, manipulation, unauthorized access or unauthorized disclosure. These include in particular:

• encrypted data transmission via TLS
• storage of passwords exclusively as a cryptographic hash
• access restrictions and role concepts for internal systems
• protected user accounts with session management
• regular updates of the systems used
• data backups

Our measures are continuously reviewed and adapted in line with technical developments. However, complete security of data transmissions over the internet cannot be guaranteed.

21. Your rights under the GDPR

You have the following rights with regard to the personal data concerning you:

• Access under Art. 15 GDPR – whether and which data we process about you
• Rectification under Art. 16 GDPR – to correct or complete inaccurate data
• Erasure under Art. 17 GDPR – unless retention obligations prevent it
• Restriction of processing under Art. 18 GDPR
• Data portability under Art. 20 GDPR – to receive your data in a common, machine-readable format
• Objection under Art. 21 GDPR – see the separately highlighted notice below
• Withdrawal of consent under Art. 7(3) GDPR – at any time with effect for the future, without affecting the lawfulness of processing carried out until then
• Complaint to a supervisory authority under Art. 77 GDPR

If you live in the United Kingdom, you have the corresponding rights under the UK GDPR.

Exercising these rights is free of charge. To exercise them, you can contact us at any time:

Mario Raczek und Michael Sauerwein GbR
Rubensstraße 8
66663 Merzig
Germany

Phone: +49 6861 9086823
Email: info@hundeschule-unterhunds.de

To process your request, we need to verify your identity. We may therefore ask you for additional information.

23. Right to lodge a complaint with a supervisory authority

Without prejudice to any other remedy, you have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your data infringes the GDPR.

The supervisory authority responsible for us is:

Unabhängiges Datenschutzzentrum Saarland
(Independent Data Protection Center Saarland)
Landesbeauftragte für Datenschutz und Informationsfreiheit
Fritz-Dobisch-Straße 12
66111 Saarbrücken
Germany

Phone: +49 681 94781-0
Email: poststelle@datenschutz.saarland.de
Web: datenschutz.saarland.de

You can also contact the supervisory authority of your habitual residence or place of work. In the United Kingdom, this is the Information Commissioner's Office (ICO): ico.org.uk

24. Obligation to provide data

The provision of personal data is neither required by law nor by contract. However, we need certain data to conclude a contract, set up a user account or take part in our training products.

If you do not provide this data, we cannot conclude the contract or provide the requested service. For exams and certificates, we also need information required for clear identification and for providing evidence.

Voluntary information is marked as such. Not providing it has no disadvantages for you.

25. Changes to this privacy policy

We reserve the right to amend this privacy policy if our services, technical systems or legal requirements change. The current version is published within our online services.

For repeat visits, bookings or orders, the version current at the time of use applies.

Last updated: September 2026