1. Privacy at a Glance
The following notes provide an overview of what happens to your personal data when you visit this website.
They apply to traction.eu and to campus.traction.eu. Both are operated by the same entity, see section 2.
2. Controller
Steven Strehl Consulting
Europaplatz 2
10557 Berlin
Germany
Email: Show email
3. Data Collection on This Website
Server log files: The host automatically collects information in server log files (browser type, OS, referring URL, IP address, time of access). This data is not merged with other sources. Legal basis: Art. 6(1)(f) GDPR.
Fonts: The fonts of this website are served from the same server as the site itself. Loading them transfers no data to third parties.
4. Appointment Booking (Cal.eu)
We use Cal.eu for appointment booking. The booking window is only loaded once you click a booking button.
On pages with a contact section, the page queries the next free slot from Cal.eu on load so it can be shown there. This transfers your IP address to Cal.eu, nothing else.
After the click, your IP address and the data you enter (name, email and whatever else you provide) are transferred to Cal.eu. Legal basis: Art. 6(1)(b) GDPR. Privacy policy: cal.eu/privacy.
5. Contact Form (Formward)
The contact form is processed via Formward, a provider based in Stockholm, Sweden. The data you enter (name, email, phone, message) is transferred to Formward and forwarded to us by email. Processing takes place within the European Union, so no transfer to a third country is involved. A data processing agreement under Art. 28 GDPR is in place. Legal basis: Art. 6(1)(b) and (f) GDPR. Privacy policy: formward.eu/privacy.
6. Advance List (Brevo)
On individual pages you can join a list to be informed when our offerings start. We run this list with Brevo (Sendinblue SAS, 106 boulevard Haussmann, 75008 Paris, France). A data processing agreement under Art. 28 GDPR is in place.
What is transferred is your email address. To display and submit the form, the page loads a script from sibforms.com, which transfers your IP address to Brevo. The legal basis is your consent under Art. 6(1)(a) GDPR, which you give explicitly in the form. You can withdraw it at any time with effect for the future; an email to us is enough. Privacy policy: brevo.com/legal/privacypolicy.
7. Your Rights
You have the right to information, correction, deletion and restriction of processing of your stored personal data at any time, as well as the right to data portability. Please contact: Show email
Objection: Where we process your data on the basis of a legitimate interest (Art. 6(1)(f) GDPR), you may object to that processing under Art. 21 GDPR. Consent you have given can be withdrawn at any time with effect for the future.
Complaint: Regardless of the above, Art. 77 GDPR gives you the right to lodge a complaint with a supervisory authority, in particular in the member state of your residence, place of work or the place of the alleged infringement. The authority responsible for us is the Berlin Commissioner for Data Protection and Freedom of Information.
8. External Links (LinkedIn)
This website contains links to LinkedIn. Clicking them takes you off this website. LinkedIn's privacy terms apply.
9. Hosting
This website is hosted with BunnyWay d.o.o., Cesta komandanta Staneta 4A, 1215 Medvode, Slovenia. A data processing agreement under Art. 28 GDPR is in place. Processing is based on Art. 6(1)(b) and (f) GDPR.
campus.traction.eu runs with Scalingo SAS, 13 rue Jacques Peirotes, 67000 Strasbourg, France. The data sits in data centres in Paris. A data processing agreement under Art. 28 GDPR is in place. The same server log files described in section 3 arise there and are deleted after seven days at the latest.
10. Analytics with Pirsch Analytics
This website uses Pirsch Analytics, a cookie-free and privacy-friendly web analytics service by Pirsch Analytics GmbH, Am Anger 1, 93059 Regensburg, Germany. Pirsch sets no cookies and collects no personal data. Instead of identifying visitors, an anonymised hash is generated from a shortened IP address, the date, the user agent and the referrer; it expires after 24 hours. Conclusions about individual visitors are therefore not possible. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in data-minimal analytics). More information: pirsch.io/privacy.
11. Purchase Processing (ablefy)
You buy courses and trainings through ablefy. The provider is ablefy GmbH, Potsdamer Straße 125, 10783 Berlin, Germany (District Court Charlottenburg, HRB 151956 B; until 2024 elopage GmbH). A data processing agreement under Art. 28 GDPR is in place.
We sell in our own name; ablefy handles the payment for us and issues the invoice in our name. What is processed is what you enter during the purchase: name, billing address, email address, the payment method you choose and its details, plus date of purchase, product and amount. Legal basis: Art. 6(1)(b) GDPR for performing the contract and Art. 6(1)(c) GDPR for keeping the records.
The purchase form is embedded in our page. As soon as it is displayed, your browser loads content from ablefy, which transfers your IP address to ablefy. This happens even if you do not complete the purchase.
For the payment itself, ablefy involves further providers depending on the method you choose, for instance for SEPA direct debit, credit card, PayPal, Klarna, Google Pay or Apple Pay. Which ones in detail is set out in the ablefy privacy policy.
We keep invoices and accounting records for ten years, as commercial and tax law require. ablefy privacy policy: myablefy.com/privacy.
12. Sign-in and Account (Hanko)
You can create an account for the campus. Signing in runs through Hanko (Hanko GmbH, Kiel, Germany) at auth.campus.traction.eu. Your browser talks to that address directly, and in doing so your email address, your IP address and the public part of your passkey are transmitted to Hanko. A data processing agreement under Art. 28 GDPR is in place, and the processing takes place in Germany.
We store no password and neither does Hanko. Signing in works with a passkey that never leaves your device, or with a one-time link sent to your email address. What sits with us is your email address and the time you signed up, so that we can recognise your account. Legal basis: Art. 6(1)(b) GDPR, because without an account there is no campus. You can have your account deleted at any time; an email to us is enough. Privacy policy: hanko.io/privacy.