Data Protection
Table of Contents
I. Name and address of the controller
II. Contact details of the data protection officer
III. General information on data processing
IV. Rights of the data subject
V. Provision of the website and creation of log files
VI. Use of cookies
VII. Contact form
VIII. Application by email and application form
IX. Company websites
X. Hosting
XI. Geotargeting
XII. Plugins used
XIII. Information for our customers and interested parties
I. Name and address of the controller
The controller within the meaning of the General Data Protection Regulation (GDPR) and other data protection regulations is:
Babette Kucinski
Xuliganka Holding OÜ
Pärnu mnt. 139b
Tallinn, 11317
Estonia
Email: b@babettekucinski.com
II. Contact details of the data protection officer
The data protection officer of the controller is:
Babette Kucinski
Pärnu mnt. 139b
Tallinn, 11317
Estonia
Email: b@babettekucinski.com
III. General information on data processing
1. Scope of processing of personal data
We only process our users' personal data to the extent necessary to provide a functional website and our content and services. The processing of our users' personal data is carried out regularly only with the user's consent. An exception applies in cases where prior consent cannot be obtained for practical reasons and the processing of the data is required by law.
2. Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 sentence 1 lit. a GDPR serves as the legal basis.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) (b) GDPR serves as the legal basis. This also applies to processing operations that are necessary for the implementation of pre-contractual measures.
Insofar as the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Art. 6 (1) (c) GDPR serves as the legal basis.
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 sentence 1 lit. d GDPR serves as the legal basis.
If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights, and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 sentence 1 lit. f GDPR serves as the legal basis for processing.
3. Data deletion and storage period
The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws, or other provisions to which the controller is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfillment of a contract.
IV. Rights of the data subject
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
1. Right of access
You can request confirmation from the controller as to whether personal data concerning you is being processed by them.
If such processing is taking place, you may request the following information from the controller:
the purposes for which the personal data is being processed;
the categories of personal data being processed;
the recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;
the planned duration of storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
the existence of a right to lodge a complaint with a supervisory authority;
any available information on the origin of the data, if the personal data does not originate from the data subject
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the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
You have the right to request information about whether personal data concerning you is being transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.
2. Right to rectification
You have the right to obtain from the controller the rectification and/or completion of your personal data if the personal data processed concerning you is inaccurate or incomplete. The controller shall carry out the rectification without delay.
3. Right to restriction of processing
You may request the restriction of the processing of personal data concerning you under the following conditions:
if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
the controller no longer needs the personal data for the purposes of the processing, but you require it for the establishment, exercise, or defense of legal claims; or
you have objected to processing pursuant to Article 21(1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override your grounds.
If the processing of personal data concerning you has been restricted, such data may, with the exception of storage, only be processed with your consent or for the establishment, exercise, or defense 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 Union or of a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
4. Right to erasure
a) Obligation to erase
You may request that the controller erase personal data concerning you without undue delay, and the controller is obliged to erase such data without undue delay if one of the following reasons applies:
The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
You withdraw your consent on which the processing was based in accordance with Art. 6 (1) (a) or Art. 9 (2) (a) GDPR, and there is no other legal basis for the processing.
You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
The personal data concerning you has been processed unlawfully.
The erasure of the personal data concerning you is necessary to comply with a legal obligation under Union or Member State law to which the controller is subject.
The personal data concerning you has been collected in relation to the services offered by information society services pursuant to Art. 8 (1) GDPR.
b) Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Art. 17 (1) GDPR, the controller shall take reasonable steps, including technical measures, taking into account the available technology and implementation costs, to inform controllers who process the personal data that you, as the data subject, have requested them to delete all links to this personal data or copies or replications of this personal data.
c) Exceptions
The right to erasure does not apply if the processing is necessary
for exercising the right of freedom of expression and information.
for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
for reasons of public interest
to inform them that you, as the data subject, have requested the deletion of all links to this personal data or copies or replications of this personal data.
c) Exceptions
The right to erasure does not apply if the processing is necessary
for exercising the right of freedom of expression and information.
to comply with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
for reasons of public interest in the area of public health pursuant to Art. 9 (2) (h) and (i) and Art. 9 (3) GDPR;
for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89(1) GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
for the establishment, exercise or defense of legal claims.
5. Right to be informed
If you have asserted your right to rectification, erasure, or restriction of processing against the controller, the controller is obliged to notify all recipients to whom your personal data has been disclosed of this rectification, erasure, or restriction of processing, unless this proves impossible or involves disproportionate effort.
You have the right to be informed by the controller about these recipients.
6. Right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data has been provided, provided that
the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and
the processing is carried out using automated means.
In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another controller, where technically feasible. The freedoms and rights of other persons must not be affected by this.
The right to data portability does not apply to the processing of personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7. Right to object
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless the controller can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
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 such marketing purposes; this also applies to profiling insofar as it is related to such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
In connection with the use of information society services, you have the option of exercising your right to object by means of automated procedures using technical specifications, irrespective of Directive 2002/58/EC.
8. Right to revoke the declaration of consent under data protection law
You have the right to withdraw your declaration of consent under data protection law at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
9. Automated decision-making in individual cases, including profiling
You have the right not to be subject to a decision based solely on automated processing, including
Profiling – to be subject to a decision based solely on profiling that produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
is necessary for the conclusion or performance of a contract between you and the controller,
is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or
is based on your explicit consent.
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 (1) GDPR, unless Art. 9 (2) (a) or (b) GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.
With regard to the cases referred to in 1 and 3, the controller shall take appropriate measures to safeguard your rights and freedoms and your legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.
10. Right to lodge a complaint with 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, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.
The supervisory authority with which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 of the GDPR.
V. Provision of the website and creation of log files
1. Description and scope of data processing
Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.
The following data is collected:
Information about the browser type and version used
The user's operating system
The user's Internet service provider
The user's IP address
Date and time of access
Websites from which the user's system accesses our website
Websites accessed by the user's system via our website
This data is stored in our system's log files. This data is not stored together with other personal data of the user.
2. Purpose of data processing
The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.
The data is stored in log files to ensure the functionality of the website. In addition, the data helps us to optimize the website and to ensure the security of our information technology systems. The data is not evaluated for marketing purposes in this context.
These purposes also constitute our legitimate interest in data processing pursuant to Art. 6 (1) (f) GDPR.
3. Legal basis for data processing
The legal basis for the temporary storage of data and log files is Art. 6 (1) (f) GDPR.
4. Duration of storage
The data is deleted as soon as it is no longer necessary for the purpose for which it was collected. In the case of data collection for the provision of the website, this is the case when the respective session has ended.
In the case of data storage in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or alienated so that it is no longer possible to assign the calling client.
5. Right to object and right to erasure
The collection of data for the provision of the website and the storage of data in log files is essential for the operation of the website. Consequently, there is no right to object on the part of the user.
VI. Use of cookies
1. Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that uniquely identifies the browser when the website is accessed again.
We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.
The following data is stored and transmitted in the cookies:
We also use cookies on our website that enable us to analyze the surfing behavior of users.
This allows the following data to be transmitted:
Search terms entered
The user data collected in this way is pseudonymized by technical measures. This means that it is no longer possible to assign the data to the user accessing the website. The data is not stored together with other personal data of the users.
2. Purpose of data processing
The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.
We require cookies for the following applications:
Remembering search terms
The user data collected by technically necessary cookies is not used to create user profiles.
Analysis cookies are used for the purpose of improving the quality of our website and its content. Analysis cookies tell us how the website is used, enabling us to continuously optimize our offering.
User behavior
3. Legal basis for data processing
The legal basis for the processing of personal data using cookies that are not technically necessary is Art. 6 (1) (a) GDPR.
The legal basis for the processing of personal data using cookies that are technically necessary is Art. 6 (1) (f) GDPR.
4. Duration of storage, possibility of objection and removal
Cookies are stored on the user's computer and transmitted by the user to our site. Therefore, as a user, you have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website to their full extent.
If you use a Safari browser from version 12.1 onwards, cookies are automatically deleted after seven days. This also applies to opt-out cookies, which are set to prevent tracking measures.
Email to: b@babettekucinski.com
VII. Contact form
1. Description and scope of data processing
Our website has a contact form that can be used to contact us electronically. If a user takes advantage of this option, the data entered in the input mask will be transmitted to us and stored.
When the message is sent, the following data is stored:
-Email address
-Last name
-First name
-Date and time of contact
Your consent is obtained for the processing of the data during the sending process and reference is made to this privacy policy.
Alternatively, you can contact us via the email address provided. In this case, the user's personal data transmitted with the email will be stored.
The data will be used exclusively for processing the conversation.
2. Purpose of data processing
The processing of personal data from the input mask serves us solely for the purpose of processing the contact request. In the case of contact by email, this also constitutes the necessary legitimate interest in the processing of the data.
The other personal data processed during the sending process serves to prevent misuse of the contact form and to ensure the security of our information technology systems.
3. Legal basis for data processing
The legal basis for the processing of the data is Art. 6 para. 1 sentence 1 lit. a GDPR if the user has given their consent.
The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 (1) (f) GDPR. If the email contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary for the purpose for which it was collected. For personal data from the input mask of the contact form and that sent by email, this is the case when the respective conversation with the user has ended.
The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
5. Right to object and right to erasure
The user has the right to withdraw their consent to the processing of their personal data at any time. If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.
Email to: b@babettekucinski.comƒ
In this case, all personal data stored in the course of establishing contact will be deleted.
VIII. Application by email and application form
1. Scope of processing of personal data
Our website features an application form that can be used for electronic applications. If an applicant chooses to use this option, the data entered in the input mask will be transmitted to us and stored. This data includes:
-Title
-First name
-Last name
-Address
-Telephone/mobile number
-Email address
-Curriculum vitae
Your consent will be obtained for the processing of your data during the submission process and reference will be made to this privacy policy.
Alternatively, you can also send us your application by email. In this case, we will collect your email address and the data you provide in the email.
After sending your application, you will receive a confirmation of receipt of your application documents from us by email.
Your data will not be passed on to third parties. The data will be used exclusively for the processing of your application.
2. Purpose of data processing
The processing of personal data from the application form serves solely to process your application. In the event of contact by email, this also constitutes the necessary legitimate interest in the processing of the data.
The other personal data processed during the submission process is used to prevent misuse of the application form and to ensure the security of our information technology systems.
3. Legal basis for data processing
The legal basis for the processing of your data is the initiation of a contract at the request of the data subject, Art. 6 (1) (b) Alt. 1 GDPR and § 26 (1) (1) BDSG.
4. Duration of storage
After completion of the application process, the data will be stored for up to six months. Your data will be deleted at the latest after six months. In the event of a legal obligation, the data will be stored in accordance with the applicable provisions.
The additional personal data collected during the submission process will be deleted after a period of seven days at the latest.
5. Right to object and right to erasure
Applicants have the right to object to the processing of their personal data at any time. If applicants contact us by email, they can object to the storage of their personal data at any time. In such cases, the application can no longer be considered.
By email
In this case, all personal data stored in the course of electronic applications will be deleted.
IX. Company profiles
Use of company profiles on social networks
LinkedIn Ireland Unlimited Company
Wilton Plaza
Wilton Place
Dublin 2
Ireland
On our company page, we provide information and offer LinkedIn users the opportunity to communicate. If you perform an action on our LinkedIn company profile (e.g., comments, posts, likes, etc.), you may be making personal data (e.g., your real name or photo from your user profile) public. However, as we generally have no influence on the processing of your personal data by Instagram, the company jointly responsible for the Babette Kucinski Xuliganka Holding OÜ company profile, we cannot provide any binding information on the purpose and scope of the processing of your data.
Our corporate presence on social networks is used for communication and information exchange with (potential) customers. In particular, we use the corporate presence for:
free learning content and for advertising purposes
The publications via the corporate presence may contain the following content:
-Information about services
-Advertising
Every user is free to publish personal data through activities.
The legal basis for data processing is Art. 6 (1) (a) GDPR.
The data generated by the company's presence is not
You may object to the processing of your personal data that we collect in connection with your use of our LinkedIn company profile at any time and assert your rights as a data subject as set out in section IV of this privacy policy. To do so, please send us an informal email to b@babettekucinski.com. For more information about the processing of your personal data by LinkedIn and the corresponding options for objection, please visit:
X. Hosting
The website is hosted on servers by a service provider commissioned by us.
XI. Geotargeting
We use the IP address and other information provided by the user (in particular the postal code provided during registration or when placing an order) for regional target group addressing (so-called “geotargeting”).
Regional target group addressing serves, for example, to automatically display regional offers or advertising that are often more relevant to users. The legal basis for the use of the IP address and, if applicable, other information provided by the user (in particular the postal code) is Art. 6 (1) lit. f GDPR, based on our interest in ensuring a more precise targeting of target groups and thus providing offers and advertising with higher relevance for users.
In this process, part of the IP address and the additional information provided by the user (in particular the postal code) are only read and not stored separately.
You can prevent geotargeting by using a VPN or proxy server, for example, which prevents accurate localization. In addition, depending on the browser you use, you can also deactivate location localization in the corresponding browser settings (if supported by the respective browser).
We use geotargeting on our website for the following purposes:
-Advertising purposes
XII. Plugins used
We use plugins for various purposes. When using some services, personal data may be transferred to servers in the USA. The legal basis for this transfer is consent in accordance with Art. 6 (1) (a) GDPR. The United States of America does not offer an adequate level of data protection based on a decision by the European Union. The main risk of the transfer lies in the obligation of the plugin providers to make user data accessible to US authorities under certain circumstances. We currently have a data processing agreement with standard contractual clauses with all providers in order to make the transfer to third countries as data protection-friendly and secure as possible. We are currently working on adjustments to the ECJ ruling of July 16, 2020 (Schrems II, Ref. C-311/18), including additional security measures.
XIII. Information for our customers and interested parties
1. Scope of personal data processing
In the context of the inquiry, the existing customer relationship, and the implementation of pre-contractual measures, we process the following data about you:
Email address
Last name
First name
Individual coaching goals
Additional voluntary information that you have provided to us in the application form.
Age
Mobile phone number
Account details
2. Purpose of data processing
Within the scope of the free initial consultation, the existing customer relationship, and the implementation of pre-contractual measures, your personal data will be processed for the following purposes:
To process your inquiry as a prospective customer. For this purpose, we use your contact details to respond to your inquiry.
To conduct a free initial consultation with you. For this purpose, we process the personal data you have provided us with in the application form.
To prepare and implement pre-contractual measures – this includes, for example, the preparation and sending of an individual offer or individual agreement and transmission of contract terms with the aim of concluding a contract.
To add your contact details to our customer database.
To fulfill our contractual obligations under the main contract with you.
To provide you with the best possible information about our products and services. This also includes sending (direct) advertising by email.
To ensure smooth billing for the services provided. For this purpose, your personal data is processed in order to issue invoices. We use the services of our contract processor easybill GmbH, with whom we have concluded a contract processing agreement.
To comply with our legal obligations. This includes, for example, the transmission of your personal data to the tax office.
To provide you, our customer, with the best possible service. This includes, in particular, communicating with you by email, mobile phone, landline, or fax.
To fulfill post-contractual measures.
To assert, exercise, or defend legal claims.
3. Legal basis for the processing of your personal data
Processing of your personal data on the basis of consent
Insofar as we obtain your consent for the processing of your personal data, the processing of your personal data is based on Art. 6 (1) (a) GDPR in conjunction with Art. 7 GDPR.
Processing for the purpose of performing the contract with you
If we process your personal data for the purpose of performing a contract, Art. 6 (1) (b) GDPR serves as the legal basis. This also applies to processing operations that are necessary for the implementation of pre-contractual and post-contractual measures.
Processing for the fulfillment of a legal obligation
Insofar as the processing of your personal data is necessary for the fulfillment of a legal obligation to which our company is subject, Art. 6 para. 1 sentence 1 lit. c GDPR serves as our legal basis. Our legal obligation to process data arises, for example, from tax and/or commercial law retention obligations.
Processing based on legitimate interest
If processing is necessary to safeguard a legitimate interest of ours or a third party and your interests, fundamental rights, and freedoms do not outweigh the former interest, Art. 6 (1) (f) GDPR constitutes the relevant legal basis for data processing. Our legitimate interest arises in particular from the following reasons:
Our business interest in providing you, as our existing customer, with optimal information about our offers and consulting services by means of direct marketing.
Communication with you, in particular to be able to respond to your inquiries by email, telephone, and/or fax.
Assertion, exercise, or defense of legal claims
4. Recipients of your personal data
We only transfer your personal data to external recipients if you have consented to this or if it is permitted by law. External recipients of your personal data are in particular:
Processors
Authorities (e.g., tax offices, courts, trade supervisory authorities)
Debt collection agencies
Tax advisors
In addition, your personal data may be transferred to the following service providers based in a country outside the EU/EEA:
Google Drive (Google)
WhatsApp (Meta)
GHL
In the case of processors and service providers outside the EU/EEA, your above-mentioned personal data will only be processed to the extent that this is the subject of our data processing agreement with these recipients in accordance with Art. 28 GDPR.
5. Transfer of your personal data to a third country or to an international organization
As a matter of principle, your personal data collected and generated during the provision of relevant services is stored on our servers in the European Union. Since the providers of our software solutions offer their products and/or services worldwide based on available resources and servers, your personal data may be transferred to other jurisdictions outside the European Union and the European Economic Area or accessed from such jurisdictions outside the European Union. The service providers listed in section 4 have their registered offices in the United States of America and Australia (Atlassian). There is no adequacy decision by the European Commission pursuant to Art. 45 GDPR for data processing in the USA and Australia. Data processing is carried out on the basis of the data processing agreement pursuant to Art. 28 GDPR and appropriate safeguards in the form of EU standard data protection clauses, Art. 46 (2) (c) GDPR. A copy of the EU standard data protection clauses can be requested from us.
6. Duration of storage of your personal data
Your personal data will be deleted as soon as the purposes for its storage specified under “Purposes and legal bases of data processing” no longer apply, you object to the use of your personal data (see section 9 below) or you revoke your previously given consent (see section 8 below). However, your personal data may also be stored beyond this, in particular in the following cases:
if there are still outstanding obligations arising from the contractual relationship
if deletion is prevented by contractual, statutory (e.g., up to 10 years in accordance with Section 257 of the German Commercial Code (HGB) and Section 147 of the German Fiscal Code (AO)) or statutory retention periods
to assert
, exercising or defending legal claims
if this is necessary under European or national law to fulfill a legal obligation to which we are subject.
7. Right of revocation of consent
You have the right to revoke your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. You can send your withdrawal by mail to Babette Kucinski, Pärnu mnt. 139b, Tallinn, 11317 Estonia or by email to: b@babettekucinski.com.
8. Right to object to certain data processing pursuant to Art. 21 GDPR
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 Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. You can send your objection at any time by mail to Babette Kucinski, Xuliganka Holding OÜ, Pärnu mnt. 139b, Tallinn, 11317
Estonia or by email to b@babettekucinski.com.
In the event of an objection, the controller will no longer process your personal data unless it can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims.
If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing purposes; this also applies to profiling insofar as it is related to such direct marketing.
If you object to processing for direct marketing purposes, your personal data will no longer be processed for these purposes.
9. Your rights as a data subject
With regard to your rights that you can assert against us, we refer you to Section IV. “Rights of the data subject” of this privacy policy.