Online accompaniment for a clear, subtle way of being with the horse

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

Larissa Dorrer
Sachsendorf 24
3474 Sachsendorf
Austria

Email: gut@ulmenbruendl.at

For any data protection–related inquiries, you may contact me at the email address listed above.

There is no legal obligation to appoint a data protection officer; therefore, no data protection officer has been designated.

2. Subject of Data Processing

These privacy notices apply to the online accompaniment program “Connected”, which consists of:

• a non-binding introductory call,

• four online sessions of 60 minutes each (via WhatsApp video call),

• accompanying communication via WhatsApp during the program period,

• digital working materials (PDFs).

3. Processed Personal Data

Within the scope of Connected, the following personal data may in particular be processed:

• first and last name

• email address

• phone number

• communication content (e.g. text, voice, or video messages via WhatsApp)

• scheduling and organizational data

• voluntarily shared information about the horse, housing, training, and personal experiences in working with the horse

No special categories of personal data (e.g. health data in the medical sense) are intentionally collected or processed.
Participants are not required to disclose sensitive or health-related data. Such information is not necessary for the execution of the program.

4. Purpose and Legal Basis of Processing

Personal data are processed for the following purposes:

• conducting the introductory call

• carrying out the online accompaniment and agreed sessions

• professional accompaniment within the scope of the program

• scheduling and communication

• provision of working materials

• invoicing and accounting

The legal bases for processing are:

• Art. 6(1)(b) GDPR (performance of a contract or pre-contractual measures)

• Art. 6(1)(c) GDPR (compliance with legal obligations, e.g. tax law retention requirements)

5. Communication via WhatsApp

The online sessions and accompanying communication take place via WhatsApp (WhatsApp Ireland Limited).

Due to technical reasons, personal data may be processed by WhatsApp. WhatsApp acts as an independent controller within the meaning of the GDPR.
The provider has no influence on the nature or scope of data processing carried out by WhatsApp.

The use of WhatsApp is voluntary and serves the uncomplicated execution of the accompaniment.

The privacy policy of WhatsApp applies in addition.

6. Storage and Retention

Personal data are stored only for as long as necessary to carry out the program and fulfill the respective purposes.

Contractual and communication data are stored for the duration of the accompaniment.

Invoice and accounting records are retained for 7 years in accordance with statutory requirements.

After the purpose of processing ceases to apply or statutory retention periods expire, the data are deleted or anonymized.

Appropriate technical and organizational security measures in accordance with Art. 32 GDPR are implemented to protect personal data against loss, misuse, or unauthorized access.

7. Disclosure of Data

Personal data are not disclosed, except:

• where this is necessary for contract performance (e.g. accounting, tax advisory services), or

• where a legal obligation exists.

No further disclosure to third parties takes place.

8. Transfers to Third Countries

When using communication services such as WhatsApp, it may be technically necessary to transfer personal data to third countries (e.g. the United States).

In such cases, data transfers are carried out on the basis of appropriate safeguards pursuant to Art. 46 GDPR, in particular through the conclusion of Standard Contractual Clauses.

9. Rights of Data Subjects

Data subjects have the following rights under the GDPR at any time:

• right of access to processed personal data

• right to rectification of inaccurate or incomplete data

• right to erasure (“right to be forgotten”), insofar as no statutory retention obligations apply

• right to restriction of processing

• right to data portability

• right to object to the processing of personal data

The right to object applies insofar as processing is not strictly necessary for contract performance or required by law.

To exercise these rights, contact may be made at any time using the email address provided above.

In addition, data subjects have the right to lodge a complaint with the competent supervisory authority.
In Austria, this is the Austrian Data Protection Authority.

10. Confidentiality

All content shared within the scope of the accompaniment is treated confidentially.

Online sessions are not recorded unless expressly agreed otherwise.

11. Scope of Application

These privacy notices apply exclusively to the online accompaniment program “Connected.”

Separate privacy notices apply to other offerings (e.g. digital products or additional programs).