Privacy Policy

This page contains extensive legal information. The most important contact details and orientation points are summarized first.

We appreciate your interest in our company. Data protection is of particular importance to the management of Pröhl Consulting Dr. Thorsten Pröhl. In principle, it is possible to use the websites of Pröhl Consulting Dr. Thorsten Pröhl without providing personal data. However, if a data subject wishes to use special services offered by our company via our website, processing of personal data may become necessary. If such processing is necessary and there is no statutory basis for it, we generally obtain the data subject's consent.

The processing of personal data, for example a data subject's name, address, email address, or phone number, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with country-specific data protection provisions applicable to Pröhl Consulting Dr. Thorsten Pröhl. By means of this Privacy Policy, we would like to inform the public about the type, scope, and purpose of the personal data collected, used, and processed by us. In addition, data subjects are informed of their rights by means of this Privacy Policy.

As controller, Pröhl Consulting Dr. Thorsten Pröhl has implemented numerous technical and organizational measures to ensure the most complete protection possible for personal data processed via this website. Nevertheless, internet-based data transmissions may generally contain security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us via alternative channels, for example by telephone.

1. Definitions

The Privacy Policy of Pröhl Consulting Dr. Thorsten Pröhl is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our Privacy Policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

In this Privacy Policy, we use, among others, the following terms:

a) Personal Data

Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as the "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more specific factors expressing the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

b) Data Subject

Data subject means any identified or identifiable natural person whose personal data is processed by the controller.

c) Processing

Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

d) Restriction of Processing

Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements of that natural person.

f) Pseudonymization

Pseudonymization means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.

g) Controller

Controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

i) Recipient

Recipient means a natural or legal person, public authority, agency, or another body to which personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a specific inquiry in accordance with Union or Member State law are not considered recipients.

j) Third Party

Third party means a natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k) Consent

Consent means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

2. Name and Address of the Controller

Controller within the meaning of the GDPR, other data protection laws applicable in the Member States of the European Union, and other provisions of a data protection nature is:

3. Collection of General Data and Information

The website of Pröhl Consulting Dr. Thorsten Pröhl collects a series of general data and information each time a data subject or an automated system accesses the website. This general data and information is stored in the server log files. The following may be collected: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the subpages accessed via an accessing system on our website, (5) the date and time of access, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information used for security in the event of attacks on our information technology systems.

When using this general data and information, Pröhl Consulting Dr. Thorsten Pröhl does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website and related advertising, (3) ensure the long-term functionality of our information technology systems and website technology, and (4) provide law enforcement authorities with information necessary for prosecution in the event of a cyberattack. Therefore, these anonymously collected data and information are evaluated both statistically and with the aim of increasing data protection and data security in our company, in order to ensure an optimal level of protection for personal data processed by us. The anonymous data in server log files is stored separately from all personal data provided by a data subject.

4. Routine Deletion and Restriction of Personal Data

The controller processes and stores the data subject's personal data only for the period necessary to achieve the storage purpose, or as provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the storage purpose no longer applies, or if a storage period prescribed by the European legislator or another competent legislator expires, personal data is routinely restricted or deleted in accordance with statutory provisions.

5. Rights of the Data Subject

a) Right of Confirmation

Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right of confirmation, they may contact our data protection officer or another employee of the controller at any time.

b) Right of Access

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain free information from the controller at any time about the personal data stored concerning them, as well as a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:

• the purposes of processing
• the categories of personal data being processed
• the recipients or categories of recipients to whom personal data has been or will be disclosed, especially recipients in third countries or international organizations
• where possible, the planned period for which personal data will be stored, or, if not possible, the criteria used to determine that period
• the existence of the right to rectification or erasure of personal data concerning them, or restriction of processing by the controller, or the right to object to such processing
• the existence of the right to lodge a complaint with a supervisory authority
• where personal data is not collected from the data subject: any available information as to its source
• the existence of automated decision-making, including profiling pursuant to Article 22(1) and (4) GDPR and, at least in such cases, meaningful information about the logic involved, as well as the significance and intended consequences of such processing for the data subject

Furthermore, the data subject has the right to be informed whether personal data has been transferred to a third country or an international organization. If this is the case, the data subject also has the right to obtain information about appropriate safeguards related to the transfer.

If a data subject wishes to exercise this right of access, they may contact our data protection officer or another employee of the controller at any time.

c) Right to Rectification

Every data subject affected by the processing of personal data has the right granted by the European legislator to demand immediate rectification of inaccurate personal data concerning them. Furthermore, taking into account the purposes of processing, the data subject has the right to have incomplete personal data completed, including by means of a supplementary statement.

If a data subject wishes to exercise this right to rectification, they may contact our data protection officer or another employee of the controller at any time.

d) Right to Erasure (Right to be Forgotten)

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, provided one of the following grounds applies and insofar as processing is not necessary:

• The personal data has been collected or otherwise processed for purposes for which it is no longer necessary.
• The data subject withdraws consent on which processing is based according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and there is no other legal ground for processing.
• The data subject objects to processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for processing, or the data subject objects to processing pursuant to Article 21(2) GDPR.
• The personal data has been unlawfully processed.
• Erasure of personal data is required to comply with a legal obligation under Union or Member State law to which the controller is subject.
• The personal data has been collected in relation to the offer of information society services pursuant to Article 8(1) GDPR.

If one of the above reasons applies and a data subject wishes to request deletion of personal data stored by Pröhl Consulting Dr. Thorsten Pröhl, they may contact our data protection officer or another employee of the controller at any time. The data protection officer of Pröhl Consulting Dr. Thorsten Pröhl or another employee will arrange for the deletion request to be complied with immediately.

If personal data has been made public by Pröhl Consulting Dr. Thorsten Pröhl and our company, as controller, is obliged to erase personal data pursuant to Article 17(1) GDPR, Pröhl Consulting Dr. Thorsten Pröhl shall take reasonable steps, including technical measures, taking account of available technology and implementation costs, to inform other controllers processing the published personal data that the data subject has requested erasure by such controllers of all links to, or copies or replications of, that personal data, insofar as processing is not required. The data protection officer of Pröhl Consulting Dr. Thorsten Pröhl or another employee will arrange the necessary measures in each individual case.

e) Right to Restriction of Processing

Every data subject affected by processing of personal data has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes erasure of the personal data and requests restriction of their use instead.
• The controller no longer needs the personal data for processing purposes, but it is required by the data subject for the establishment, exercise, or defense of legal claims.
• The data subject has objected to processing pursuant to Article 21(1) GDPR pending verification whether the controller's legitimate grounds override those of the data subject.

If one of the above conditions is met and a data subject wishes to request restriction of personal data stored by Pröhl Consulting Dr. Thorsten Pröhl, they may contact our data protection officer or another employee of the controller at any time. The data protection officer of Pröhl Consulting Dr. Thorsten Pröhl or another employee will arrange the restriction of processing.

f) Right to Data Portability

Every data subject affected by processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which has been provided to a controller by the data subject, in a structured, commonly used, and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data was provided, where processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, or on a contract pursuant to Article 6(1)(b) GDPR, and the processing is carried out by automated means, insofar as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising their right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others. To assert the right to data portability, the data subject may contact the data protection officer appointed by Pröhl Consulting Dr. Thorsten Pröhl or another employee at any time.

g) Right to Object

Every data subject affected by processing of personal data has the right granted by the European legislator to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on those provisions.

Pröhl Consulting Dr. Thorsten Pröhl shall no longer process personal data in the event of an objection, unless we demonstrate compelling legitimate grounds for processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.

If Pröhl Consulting Dr. Thorsten Pröhl processes personal data for direct marketing purposes, the data subject has the right to object at any time to processing of personal data for such marketing. This also applies to profiling insofar as it is related to direct marketing. If the data subject objects to processing for direct marketing purposes, Pröhl Consulting Dr. Thorsten Pröhl will no longer process personal data for these purposes.

In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them carried out by Pröhl Consulting Dr. Thorsten Pröhl for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

To exercise the right to object, the data subject may contact the data protection officer of Pröhl Consulting Dr. Thorsten Pröhl or another employee directly. In addition, the data subject is free to exercise their right to object by automated means using technical specifications in connection with the use of information society services, notwithstanding Directive 2002/58/EC.

h) Automated Individual Decision-Making, Including Profiling

Every data subject affected by processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which lays down suitable measures to safeguard the data subject's rights, freedoms, and legitimate interests, or (3) is based on the data subject's explicit consent.

If the decision is (1) necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) based on the data subject's explicit consent, Pröhl Consulting Dr. Thorsten Pröhl shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, including at least the right to obtain human intervention by the controller, to express their point of view, and to contest the decision.

If the data subject wishes to assert rights regarding automated decisions, they may contact our data protection officer or another employee of the controller at any time.

i) Right to Withdraw Data Protection Consent

Every data subject affected by processing of personal data has the right granted by the European legislator to withdraw consent to processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, they may contact our data protection officer or another employee of the controller at any time.

6. Legal Basis of Processing

Article 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, for processing operations required for the delivery of goods or provision of other services or consideration, processing is based on Article 6(1)(b) GDPR. The same applies to processing operations necessary for carrying out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation requiring processing of personal data, such as for compliance with tax obligations, processing is based on Article 6(1)(c) GDPR. In rare cases, processing of personal data may be necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and their name, age, health insurance data, or other vital information had to be passed on to a doctor, hospital, or other third parties. In that case, processing would be based on Article 6(1)(d) GDPR. Finally, processing operations could be based on Article 6(1)(f) GDPR. Processing operations not covered by any of the above legal bases are based on this legal basis if processing is necessary for the purposes of legitimate interests pursued by our company or a third party, except where such interests are overridden by the interests, fundamental rights, and freedoms of the data subject. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator, who considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 sentence 2 GDPR).

7. Legitimate Interests Pursued by the Controller or a Third Party

Where processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is to conduct our business activities for the well-being of all our employees and shareholders.

8. Period for Which Personal Data Is Stored

The criterion for the duration of storage of personal data is the respective statutory retention period. After expiry of that period, the corresponding data is routinely deleted, provided it is no longer required for contract fulfillment or contract initiation.

9. Statutory or Contractual Requirements for Providing Personal Data; Necessity for Contract Conclusion; Obligation to Provide Data; Possible Consequences of Failure to Provide Data

We inform you that providing personal data is partly required by law (e.g., tax regulations) or may result from contractual provisions (e.g., details about the contractual partner). In some cases, conclusion of a contract may require a data subject to provide personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data when our company enters into a contract with them. Failure to provide personal data would result in the contract not being concluded with the data subject. Before personal data is provided by the data subject, the data subject must contact our data protection officer. Our data protection officer clarifies, on a case-by-case basis, whether providing personal data is required by law or contract, whether it is necessary for contract conclusion, whether there is an obligation to provide personal data, and what consequences failure to provide personal data would have.

10. Existence of Automated Decision-Making

As a responsible company, we do not use automated decision-making or profiling.

This Privacy Policy is currently valid and has the status of April 2026.

Due to the further development of our website and offerings, or due to changed legal or regulatory requirements, it may become necessary to amend this Privacy Policy.