Privacy Policy
This privacy notice explains how we, The Wolf Practice, process personal data in our website as per the General Data Protection Regulation (GDPR) and other relevant data protection and privacy laws applicable to our business.
Your data protection rights
Access and rectification - You may request a copy of the information we process about you and ask us to rectify any incorrect data.
Erasure or restriction - In some circumstances, you may ask us to delete or restrict the processing of your data, but we cannot delete any data we are legally required to process.
Object to processing - In some circumstances, you may ask us to stop processing your data.
Data portability - In some circumstances, you may ask us to transfer your data to you or another organisation.
Also, if you're unhappy about how we process your data, you have a right to complain to a national data authority. We hope, however, that you will contact us first so that we can try to resolve the matter for you in a satisfactory way.
Please get in touch with us if you have any questions about how we handle your data or want to exercise one of your rights. You are entitled to a reply within 30 days.
How we get your personal data
We typically process personal data on potential or existing customers, website visitors and vendors and collaboration partners.
We may process personal data when you -
Contact / communicate with us online (email, video calls, social media, etc.) or on the phone.
Use our services.
Deliver products / services to or enter into a collaboration with us.
It is voluntary to provide us with personal data, but we cannot provide you with our services if you choose not to.
We do not rent, buy or sell personal data from or to others, use automated decisions or profiling in the processing of your personal data, or process any special category data as per the GDPR Article 9.
Purpose, lawful basis and retention periods
We only process your personal data when we have a purpose and a lawful basis for doing so. Under the GDPR Article 6-1, the lawful bases we rely on are -
Your consent.
We have a contractual obligation (contract).
We have a legal obligation.
We have a legitimate interest.
As a rule, we do not process personal data for longer than necessary to fulfil the purpose of processing. To comply with this, we formally assess our data protection and privacy work with the intention to amend, update and, if necessary, delete personal data.
We will only retain data for as long as we are required to as per applicable legal obligations such as accounting, tax, labour laws or any other relevant rules and regulations.
Details on the processing of your personal data
This section describes when and how we process your data, for what purposes and our legal grounds to do so (lawful bases). We also specify the retention periods for the processing.
We process personal data when:
1. You communicate with us
Regardless of your relationship with us, as a potential or existing customer, vendor or other, we process your personal data whenever you communicate with us. This could be when you contact us through email, phone (call, text message) or social media. Depending on where and how you contact us, this may include your name, contact details, IP address and other information you choose to send to us.
The purpose is to be able to respond to your inquiries and, on some occasions, to keep records in case of complaints or legal claims. The lawful basis is f), where our legitimate interest is to respond to your inquiries and, on some occasions, keep records in case of complaints or legal claims.
We review this data at our regular GDPR audits and delete personal data as appropriate. We typically keep this type of personal data for up to two years or six years if we have a legal obligation in accordance with accounting and bookkeeping rules.
2. You receive marketing as an existing customer
If we have an existing customer relationship with you, we may send you emails containing a promotional element (this happens infrequently). The personal data we process is your name and email address. The purpose is to provide you with news and offers related to your subscription. The lawful basis is f), where our legitimate interest is to offer our relevant products and services. The lawful basis could also be a), where you have given us your consent to such marketing.
You can opt-out of marketing emails at any time by clicking the unsubscribe link in any such email. We process the data for as long as we have a customer relationship with you or if the processing is based on your consent until you withdraw it. When you ask us not to send you any promotional materials, your account will be flagged as "unsubscribed from marketing" in our internal database, and you won't receive any further marketing emails from us. We are still required to process data for accountancy, tax and other business purposes if you are our customer.
3. You respond to our surveys
We sometimes send surveys to our customers to improve our service / product. Responding to our surveys is completely voluntary. We process personal data such as your name, contact details and other information you choose to share with us. We do not process any personal data if a survey is anonymous.
The purpose is to gather your feedback to continuously improve our products and services and provide you with better customer service in the future. The lawful basis is a) consent. We review this data at our regular GDPR audits and delete personal data as appropriate; however, no later than two years after responding to the survey.
4. You supply services to or collaborate with us
When you enter into an agreement with us either as a vendor, partner or data processor, we process personal data such as your name, contact details and correspondence. The purpose is to enter into this agreement and communicate with you before, during and after our formal business relationship.
The lawful bases are b) contract, c) legal obligation related to accounting, tax and other business laws we are required to abide by, and f) where our legitimate interest is to be able to communicate with you before, during and after our formal business relationship (described under the paragraph "You communicate with us" above). We store personal data for as long as we have a formal business relationship and then for up to 5 years after, in accordance with our legal obligations for accounting, tax and other business purposes.
5. You use our website
When you use our website, we briefly process your IP address and user agent, which are considered personal data under the GDPR. With DDoS (Distributed Denial of Service) attacks increasing every year, it is necessary to safeguard our website with strong security measures so that it stays safe and works well. For this, we are forced to keep partial access logs. The purposes for this processing are a) to protect against cyberattacks such as the DDoS one and b) to analyze our website traffic to optimize and run our business effectively. The lawful basis is f), where our legitimate interests protect our business against cyberattacks and optimize and run our business effectively.
Whom we share your personal data with
To run our business efficiently and securely, we sometimes will have to share your personal data with other (trusted) parties such as:
IT support (when necessary)
Our accountant
Data processors (providers of various services that process your personal data on our behalf)
Public authorities (when we are obliged to report to them)
Professional advisors from other industries (such as law and finance)
We require that all such recipients secure data in accordance with good information security and as per the requirements of this Privacy notice. We review and quality assure all vendors and data processors and enter into a data processing agreement / addendum whenever necessary.
We use data processors for -
Accounting / bookkeeping
Email, calendar and digital meetings
This website, including online payments providers
Transactional emails to customers
Support ticket system
We don't publish further details (like names) of our data processors to protect our business. If you'd like to know more about our processing and with whom we share your personal data, please get in touch with us. We practice data minimization, so we will only use data suppliers to process your personal data when required (e.g. Stripe for payment processing).
Transfer of personal data outside the EU/EEA
In some cases, your personal data will be transferred to a "third country", i.e. outside the EU / EEA. For example, where we use data processors to manage email services. We only use data processors we trust that are well known, reputable, and have a data processing agreement / addendum.
We have ensured that every data processor in a third country has necessary safeguards in place like the EU adequacy decision, standard contractual clauses (SCC) or binding corporate rules (BCR).
We conduct risk assessments for every data processor we use in our business. We review, in particular, the data processor's technical and organizational security measures, reputation and safeguards for international transfers of personal data.
If you still have any concerns or questions, please get in touch with us.
Information security
We take information security as seriously as privacy, and we will always do our utmost to safeguard your personal data in the best possible way. For example, we use strong passwords, data encryption, two-factor authentication and several other measures to secure our data and prevent unauthorized persons from accessing, altering, deleting, or in any way affecting the data we store, including your personal data.
We only allow others to access or process your personal data in accordance with our instructions and only when strictly necessary.
Accessing and correcting your personal data
You have a right to access your personal data and request a correction if you believe it is inaccurate. If you have submitted Personal Information and would like to have access to it, or if you would like to have it corrected, please get in touch with us using the contact information provided below.
How to contact us
If you have any questions regarding this Privacy Policy or to access your information, please send an email to - mirko@thewolfpractice.net.