Privacy policy

1. Data protection at a glance

General information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on the subject of data protection, please refer to my privacy policy set out below this text.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator’s contact details in the section “Information on the controller” in this privacy policy.

How do I collect your data?

On the one hand, your data is collected when you provide it to me. This may, for example, be data that you enter into a contact form.

Other data is collected automatically or after your consent by my IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time of the page view). This data is collected automatically as soon as you enter this website.

What do I use your data for?

Part of the data is collected to ensure that the website is provided without errors. Other data may be used to analyse your user behaviour.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipients and purpose of your stored personal data. You also have the right to request the rectification or erasure of this data. If you have given consent to data processing, you can withdraw this consent at any time with effect for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact me at any time about this and any other questions on the subject of data protection.

2. Hosting

I host the content of my website with the following provider:

IONOS

The provider is IONOS SE, Elgendorfer Str. 57, 56410 Montabaur (hereinafter IONOS). When you visit my website, IONOS records various log files including your IP addresses. For details, please refer to the privacy policy of IONOS: https://www.ionos.de/terms-gtc/terms-privacy.

IONOS is used on the basis of Art. 6(1)(f) GDPR. I have a legitimate interest in presenting my website as reliably as possible. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG (German Telecommunications and Telemedia Data Protection Act), insofar as the consent covers the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.

3. General information and mandatory information

Data protection

As the operator of these pages, I take the protection of your personal data very seriously. I treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains which data I collect and what I use it for. It also explains how and for what purpose this is done.

Please note that data transmission over the internet (e.g. when communicating by e-mail) may have security gaps. Complete protection of data against access by third parties is not possible.

Information on the controller

The controller responsible for data processing on this website is:

secureIT UG (haftungsbeschränkt)
Weinstraße 9
79282 Ballrechten-Dottingen
E-mail: info@secureit-online.de

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses or similar).

Storage period

Unless a more specific storage period has been stated in this privacy policy, your personal data will remain with me until the purpose for the data processing no longer applies. If you assert a justified request for erasure or withdraw consent to data processing, your data will be erased unless I have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, erasure takes place once these reasons cease to apply.

General information on the legal bases for data processing on this website

If you have consented to data processing, I process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR if special categories of data pursuant to Art. 9(1) GDPR are processed. In the case of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information in your terminal device (e.g. via device fingerprinting), data processing is additionally carried out on the basis of § 25(1) TTDSG. Consent can be withdrawn at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, I process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, I process your data if it is required to comply with a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of my legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the legal bases relevant in each individual case is provided in the following paragraphs of this privacy policy.

Withdrawal of your consent to data processing

Many data processing operations are only possible with your express consent. You can withdraw consent you have already given at any time. The lawfulness of the data processing carried out until the withdrawal remains unaffected by the withdrawal.

Right to object to data collection in special cases and to direct marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, 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 TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of infringements of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged infringement. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.

Right to data portability

You have the right to have data that I process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, erasure and rectification

Within the framework of the applicable statutory provisions, you have the right at any time to information free of charge about your stored personal data, its origin and recipients and the purpose of the data processing and, where applicable, a right to rectification or erasure of this data. You can contact me at any time about this and any other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact me about this at any time. The right to restriction of processing exists in the following cases:

• If you contest the accuracy of your personal data stored with me, I usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
• If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of erasure.
• If I no longer need your personal data, but you need it for the exercise, defence or establishment of legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
• If you have lodged an objection pursuant to Art. 21(1) GDPR, your interests and mine must be weighed against each other. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to me as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the padlock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to me cannot be read by third parties.

4. Data collection on this website

Cookies

This website uses only technically necessary cookies. This is a session cookie that is strictly necessary for the operation of the application (e.g. login, CSRF protection). The cookie is automatically deleted at the end of the browser session or after the session period has expired.

I use no tracking, analytics or advertising cookies. No third-party cookies are set.

The technically necessary cookie is stored on the basis of Art. 6(1)(f) GDPR and § 25(2) no. 2 TTDSG. I have a legitimate interest in the technically error-free provision of my services. Consent is not required for this.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases. Deactivating cookies may limit the functionality of this website (in particular login and forms).

Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to me. These are:

• Browser type and browser version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server request
• IP address

This data is not merged with other data sources.

This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – for this purpose, the server log files must be recorded.

Contact form

If you send me enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by me for the purpose of processing the enquiry and in case of follow-up questions. I do not pass on this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR if your enquiry is related to the performance of a contract or is required for the implementation of pre-contractual measures. In all other cases, processing is based on my legitimate interest in the effective handling of the enquiries addressed to me (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be withdrawn at any time.

The data you enter in the contact form will remain with me until you ask me to erase it, withdraw your consent to storage or the purpose for the data storage no longer applies (e.g. after your enquiry has been processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Registration and company accounts

You can create a user account on this website in order to book and manage training courses. The following data is collected during registration: name, e-mail address and, where applicable, company name. Within a company account, administrators can store e-mail addresses of their employees in order to send them training invitations and phishing simulations.

Processing is carried out on the basis of Art. 6(1)(b) GDPR (performance of a contract). The data is stored for as long as the account exists and is then erased, unless statutory retention obligations prevent this.

Training and phishing simulation for employees (processing on behalf)

If your employer or your organisation enrols you in a training course, this organisation is the controller within the meaning of the GDPR; it decides who takes part. I then process your data on its behalf (Art. 28 GDPR) on the basis of a data processing agreement, which is concluded upon registration of the company account. The legal basis for your organisation is generally § 26(1) BDSG (German Federal Data Protection Act) in conjunction with Art. 6(1)(f) GDPR (training and awareness-raising of employees as part of information security); where a works council exists, in conjunction with a works agreement. You will find a template for this under “For works councils”.

The following is processed: first name, surname and e-mail address; the personal access link; learning progress (which lesson was marked as completed and when, completion date, chosen learning path and result of the knowledge test); in the phishing simulation, for each simulated e-mail, the time of sending and whether the e-mail was opened, whether a link in it was clicked and whether anything was entered on the practice page. Entered passwords are not stored, only the fact that an entry took place. Opening is recorded via a subsequently loaded image; in the process, the IP address and the e-mail program used may become visible. This technical information is used exclusively to attribute the opening.

Who sees what: Your personal result (which e-mails you opened, clicked or replied to) is seen only by you yourself via your personal results link. Your organisation sees whether you have started and completed the training and receives the results of the phishing simulation exclusively as an anonymised team evaluation without names. For this, at least three people must take part. A supporting partner (such as an IT service provider or insurance broker) sees only the team evaluation and only if your organisation has authorised this. As the operator of the platform, I have access to the individual data for maintenance and support purposes; this access is logged.

Storage period: Your training and simulation data remains stored for the duration of the contract with your organisation, because it forms the basis for the proof of training and the certificate of participation, and is removed when the organisation’s account is deleted. Your organisation can arrange for the erasure of individual persons at any time. Generated certificate files from school courses are automatically deleted 60 days after creation.

Free phishing test

If you use my free phishing self-test, you enter your e-mail address. You will then receive a confirmation e-mail (double opt-in). Only after confirmation will simulated phishing e-mails be sent to you. The e-mail address is used exclusively for the test and is deleted from the test run after its completion.

Processing is carried out on the basis of your consent (Art. 6(1)(a) GDPR). Consent can be withdrawn at any time.

If you come to the self-test via a partner’s referral link (such as that of your insurance broker or IT service provider), it is recorded that the test was started via this link. The partner learns neither your e-mail address nor your result. Only if, when starting, you expressly tick the box “My result may also be sent to the partner” will I transmit to the partner your e-mail address and the number of test e-mails you responded to; not which ones they were and not what you entered. This disclosure is based on your consent (Art. 6(1)(a) GDPR) and can be withdrawn at any time with effect for the future.

Certificates of participation and authenticity check

After completing the training and the practical test, participants receive a certificate of participation with a certificate number. Anyone who knows this number can check under “Verify certificate” whether the certificate is genuine; name, organisation, course and completion date are then displayed, but not the personal test result. The number is long and random and cannot be guessed. Processing serves the performance of the contract (Art. 6(1)(b) GDPR) and the legitimate interest in forgery-proof evidence (Art. 6(1)(f) GDPR).

Payment processing (PayPal)

For individual bookings, I offer payment via PayPal. For payment processing, you will be redirected to PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. For information on which data PayPal collects, please refer to PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Data is transmitted to PayPal on the basis of Art. 6(1)(b) GDPR (performance of a contract).

5. Embedded third-party content

YouTube videos

On some pages, I embed videos from YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

I use YouTube in privacy-enhanced mode (youtube-nocookie.com). Videos are not loaded automatically. Only when you actively click the play button is a connection to YouTube’s servers established. In the process, YouTube is informed which page you have visited, and cookies may be set by YouTube.

Embedding is based on your consent (Art. 6(1)(a) GDPR and § 25(1) TTDSG). You give your consent by clicking the play button. Further information on data protection at YouTube can be found in its privacy policy: https://policies.google.com/privacy.

6. Sending of e-mails

I send transactional e-mails (confirmations, training invitations, test results, invoices) via my e-mail server at IONOS. The e-mail addresses are processed on the basis of Art. 6(1)(b) GDPR (performance of a contract) or Art. 6(1)(a) GDPR (consent in the case of the free test).

As part of the phishing simulation, registered participants receive simulated phishing e-mails. These contain a personalised link and a subsequently loaded image in order to record whether a simulated e-mail was opened and whether a link was clicked. The results are provided to the organisation exclusively in anonymised form (team statistics). Individual results can only be viewed by the respective person themselves (see “Training and phishing simulation for employees” above).

AI-generated voice messages in the simulation

Some simulation templates contain a voice message that is generated using an AI speech synthesis service (ElevenLabs Inc., USA). For this purpose, I transmit to the service only the text to be read out; it contains at most your first name and no other personal data. The generated audio file is stored on my server and reused for the same version of the text. The legal basis is the legitimate interest in a realistic simulation (Art. 6(1)(f) GDPR) on behalf of your organisation; the transfer to the USA is based on the EU-US Data Privacy Framework, provided the provider is certified there, and otherwise on standard contractual clauses. Your organisation decides, when selecting the templates, whether such messages are used.