Privacy policy
This is an English translation of our privacy policy. In case of any discrepancy, the German version at infusionbar.de/datenschutz prevails.
Name and contact details of the controller pursuant to Article 4(7) GDPR
NWL The Natural Weight Loss Company GmbH
Daniela Elena Laubinger, Managing Partner
Mönckebergstraße 19, 20095 Hamburg, Germany
Scope
This privacy policy applies to all services offered by NWL The Natural Weight Loss Company GmbH, including our brand Infusionbar. This includes in particular our websites gewicht-schnell-abnehmen-hamburg.de, nwl-shop.com and infusionbar.de, our course area on ablefy (myablefy.com/s/nwl-company.com), our online appointment booking, our newsletter, our contact channels by email, phone and WhatsApp, and our profiles on social networks.
I. Security and protection of your personal data
We consider it our primary task to maintain the confidentiality of the personal data you provide and to protect it from unauthorised access. We therefore apply the utmost care and state-of-the-art security standards to ensure maximum protection of your personal data.
As a private company, we are subject to the provisions of the European General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG). We have taken technical and organisational measures to ensure that the data protection regulations are observed both by us and by our external service providers.
II. Definitions
The law requires that personal data be processed lawfully, fairly and in a transparent manner in relation to the data subject ("lawfulness, fairness and transparency"). To ensure this, we inform you about the individual legal definitions that are also used in this privacy policy:
1. Personal data
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "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 factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. Processing
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
3. Restriction of processing
"Restriction of processing" means the marking of stored personal data with the aim of limiting their processing in the future.
4. 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 analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
5. Pseudonymisation
"Pseudonymisation" 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
6. Filing system
"Filing system" means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.
7. 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.
8. Processor
"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
9. Recipient
"Recipient" means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
10. 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 authorised to process personal data.
11. Consent
"Consent" of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
III. Lawfulness of processing
The processing of personal data is only lawful if there is a legal basis for the processing. Pursuant to Article 6(1)(a) to (f) GDPR, the legal basis for processing may in particular be:
1. the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
2. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
3. processing is necessary for compliance with a legal obligation to which the controller is subject;
4. processing is necessary in order to protect the vital interests of the data subject or of another natural person;
5. processing 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;
6. processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
We only process health data and other special categories of personal data (Art. 9 GDPR) with your explicit consent (Art. 9(2)(a) GDPR). For details, please see section XXIII "Health data for the NWL programme, nutritional counselling and infusions".
IV. Information on the collection of personal data
1. In the following, we inform you about the collection of personal data when you use our website. Personal data are, for example, your name, address, email addresses and user behaviour.
2. When you contact us by email or via a contact form, we store the data you provide (your email address and, if applicable, your name and phone number) in order to answer your questions. We delete the data arising in this context once storage is no longer necessary, or we restrict processing if statutory retention obligations apply.
3. You can also reach us via WhatsApp. For details, please see section XXII "Contact via WhatsApp".
4. For our email accounts under nwl-company.com we use Microsoft 365 provided by Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. When you send us an email, your message and your contact details are stored on Microsoft servers. We have concluded a data processing agreement with Microsoft. A transfer to the USA cannot be ruled out; Microsoft is certified under the EU-US Data Privacy Framework. The legal basis is Art. 6(1)(b) GDPR where a contract is concerned, otherwise Art. 6(1)(f) GDPR; our legitimate interest is answering your enquiry.
V. Collection of personal data when you visit our website
If you use the website for information purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. When you view our website, we collect the following data, which are technically necessary for us to display our website to you and to ensure its stability and security (the legal basis is Art. 6(1) sentence 1(f) GDPR):
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Access status/HTTP status code
- Amount of data transferred in each case
- Website from which the request comes
- Browser
- Operating system and its interface
- Language and version of the browser software
Hosting
Our websites gewicht-schnell-abnehmen-hamburg.de and nwl-shop.com are hosted by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. The website infusionbar.de is hosted by Mittwald CM Service GmbH & Co. KG, Königsberger Straße 4-6, 32339 Espelkamp, Germany. The providers process the data listed above on our behalf on servers in Germany. We have concluded a data processing agreement pursuant to Art. 28 GDPR with both providers. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the secure and reliable operation of our websites.
VI. Use of cookies
1. In addition to the data mentioned above, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive, assigned to the browser you use, and through which certain information flows to the party that sets the cookie. Cookies cannot run programs or transfer viruses to your computer. They serve to make our website more user-friendly and effective overall.
2. This website uses the following types of cookies, the scope and functioning of which are explained below: transient cookies (see a.) and persistent cookies (see b.).
a. Transient cookies are deleted automatically when you close your browser. These include in particular session cookies. They store a so-called session ID, with which various requests from your browser can be assigned to the same session. This allows your computer to be recognised when you return to our website. Session cookies are deleted when you log out or close your browser.
b. Persistent cookies are deleted automatically after a specified period, which may differ depending on the cookie. You can delete cookies at any time in the security settings of your browser.
c. You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or all cookies. "Third-party cookies" are cookies that have been set by a third party and therefore not by the actual website you are currently visiting. Please note that if you deactivate cookies, you may not be able to use all the functions of this website.
d. We use cookies to identify you on subsequent visits if you have an account with us. Otherwise, you would have to log in again for each visit.
e. We only use cookies and similar technologies that are not strictly necessary for the operation of our websites, for example for Google Analytics, Google Maps or YouTube, with your consent (Section 25(1) TDDDG, Art. 6(1)(a) GDPR). You give your consent via our cookie banner and can change or withdraw it at any time with effect for the future. To do so, click on "Einwilligung verwalten" (manage consent) at the bottom right of every page in our customer shop, or on "Cookie settings" in the footer of infusionbar.de. Without your consent, these services remain blocked; technically necessary cookies, for example for the shopping cart and for logging in to your customer account, are always active. We store your choice in a cookie directly in your browser so that the banner does not reappear on every visit. In our customer shop we use the consent tool Complianz for this and ask again after one year; on infusionbar.de we use the cookie banner of our website system YOOtheme and ask again after one month.
VII. Further functions and services of our website
1. In addition to the purely informational use of our website, we offer various services that you can use if you are interested. To do so, you will generally have to provide further personal data, which we use to provide the respective service and to which the data processing principles set out above apply.
2. In some cases, we use external service providers to process your data. They have been carefully selected and commissioned by us, are bound by our instructions and are checked regularly.
3. Furthermore, we may pass on your personal data to third parties if promotions, competitions, contracts or similar services are offered by us together with partners. You will receive more information about this when you provide your personal data or below in the description of the offer.
VIII. Children
Our services are generally aimed at adults. Persons under the age of 18 should not send us any personal data without the consent of their parents or legal guardians.
IX. Rights of the data subject
1. Withdrawal of consent
If the processing of personal data is based on consent you have given, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. You can contact us at any time to exercise your right of withdrawal.
2. Right to confirmation
You have the right to request confirmation from the controller as to whether we are processing personal data concerning you. You can request this confirmation at any time using the contact details above.
3. Right of access
Where personal data are being processed, you can request access to these personal data and to the following information at any time:
a. the purposes of the processing;
b. the categories of personal data concerned;
c. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
d. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
e. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
f. the right to lodge a complaint with a supervisory authority;
g. where the personal data are not collected from the data subject, any available information as to their source;
h. the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
4. Right to rectification
You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
5. Right to erasure ("right to be forgotten")
You have the right to obtain from the controller the erasure of personal data concerning you without undue delay, and we are obliged to erase personal data without undue delay where one of the following grounds applies:
a. The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
b. The data subject withdraws consent on which the processing is based according to Article 6(1)(a) or Article 9(2)(a) GDPR, and there is no other legal ground for the processing.
c. The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
d. The personal data have been unlawfully processed.
e. The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
f. The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase them, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copies or replications of, those personal data.
The right to erasure ("right to be forgotten") does not apply to the extent that 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 in the area of public health in accordance with Article 9(2)(h) and (i) as well as Article 9(3) GDPR; for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) GDPR in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or for the establishment, exercise or defence of legal claims.
6. Right to restriction of processing
You have the right to obtain from us restriction of processing of your personal data where one of the following applies:
a. 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;
b. the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
c. the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; or
d. the data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
Where processing has been restricted under the above conditions, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence 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.
To exercise the right to restriction of processing, the data subject may contact us at any time using the contact details given above.
7. Right to data portability
You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
a. the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR; and
b. the processing is carried out by automated means.
In exercising your right to data portability pursuant to paragraph 1, you have the right to have the personal data transmitted directly from one controller to another, where technically feasible. The exercise of the right to data portability is without prejudice to the right to erasure ("right to be forgotten"). That right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
8. 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, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
Where personal data are 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, which includes profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data will no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
You can exercise your right to object at any time by contacting the respective controller.
Processing of personal data in the withdrawal procedure
If you exercise your right of withdrawal for the online courses (https://myablefy.com/s/nwl-company.com) via the withdrawal button provided, we process the personal data you provide exclusively to handle your notice of withdrawal and to fulfil our legal obligations in connection with the reversal of the contract. We process the following data: your first and last name, your email address, the order ID or invoice number, the type of right of withdrawal exercised, as well as the time stamp and the system-generated withdrawal ID. If you use the optional free-text field, we also process the information contained therein. The legal basis for the processing is Art. 6(1)(b) GDPR insofar as the processing is necessary for the reversal of the contract, and Art. 6(1)(c) GDPR insofar as we comply with legal obligations, in particular the obligation to confirm receipt of the withdrawal on a durable medium pursuant to Section 356 of the German Civil Code (BGB). Your data are passed on to our payment service provider to process the refund and to our email service provider to send the confirmation email. No further disclosure to third parties takes place. We store your data for the duration of the statutory retention periods, generally ten years from receipt of the notice of withdrawal. The withdrawal log is stored unalterably and cannot subsequently be deleted or changed.
9. Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision:
a. is necessary for entering into, or performance of, a contract between the data subject and the controller;
b. is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
c. is based on the data subject's explicit consent.
The controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
The data subject may exercise this right at any time by contacting the respective controller.
10. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you also 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 responsible for us is the Hamburg Commissioner for Data Protection and Freedom of Information (Hamburgischer Beauftragter für Datenschutz und Informationsfreiheit), Ludwig-Erhard-Straße 22, 20459 Hamburg, Germany.
11. Right to an effective judicial remedy
Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to Article 77 GDPR, you have the right to an effective judicial remedy if you consider that your rights under the GDPR have been infringed as a result of the processing of your personal data in non-compliance with the GDPR.
X. Registration on our website
You have the option of registering on our website by providing personal data. The personal data transmitted to us in this process are determined by the respective input form used for registration. The personal data you enter are collected and stored exclusively for internal use by the controller and for its own purposes. The registration of the data subject, with the voluntary provision of personal data, enables the controller to offer the data subject content or services that, by their nature, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have them completely deleted from the controller's database. The controller will provide any data subject at any time upon request with information about which personal data concerning the data subject are stored. Furthermore, the controller will correct or delete personal data at the request or notification of the data subject, provided that this does not conflict with any statutory retention obligations. All employees of the controller are available to the data subject as contact persons in this context.
XI. Use of Google Analytics and Jetpack statistics
1. Our websites use Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google Analytics is only loaded if you have given your consent via our cookie banner.
2. Google Analytics uses cookies and similar technologies to analyse the use of our websites, for example pages visited, time spent, approximate location, device and browser. IP addresses are not stored in Google Analytics 4. The information may be transferred to servers of Google LLC in the USA. Google LLC is certified under the EU-US Data Privacy Framework; in addition, the Standard Contractual Clauses of the European Commission apply.
3. We use Google Analytics to understand how our websites are used and to improve our services. The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). You can withdraw your consent at any time with effect for the future via the cookie banner.
4. We have concluded a data processing agreement with Google. Google Analytics automatically deletes event data (for example individual page views) after 2 months and user-related data after 14 months without new activity.
5. For more information, please see Google's privacy policy: https://policies.google.com/privacy
6. In our customer shop we also use the statistics function of Jetpack and WooCommerce, services provided by Automattic Inc., San Francisco, USA. It analyses which pages and products are viewed. These statistics are also only loaded if you have consented to "Statistics" via the cookie banner (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). The data are processed on Automattic servers in the USA; Automattic is certified under the EU-US Data Privacy Framework. More information: https://automattic.com/privacy/
XII. Newsletter and emails with ActiveCampaign
To send our newsletter and other emails and to manage contact data, we use ActiveCampaign, a service of ActiveCampaign, LLC, 1 North Dearborn Street, 5th Floor, Chicago, IL 60602, USA. We obtain the service via Wild Audience S.L., Ronda Sant Pere 52, 08010 Barcelona, Spain. We have concluded a data processing agreement with Wild Audience S.L. pursuant to Art. 28 GDPR, in which ActiveCampaign is included as a sub-processor. Your contact data are stored in ActiveCampaign data centres in the USA.
In doing so, we process your name, your email address, information on how you joined our mailing list (for example newsletter sign-up, free guide or purchased online course), and information on your use of our emails. If you purchase an online course or request a free guide via ablefy, ablefy automatically transmits your name, your email address and the product to ActiveCampaign. We do not store any health data in ActiveCampaign.
The transfer of data to the USA is based on ActiveCampaign's certification under the EU-US Data Privacy Framework (adequacy decision of the European Commission, Art. 45 GDPR). In addition, where necessary, the Standard Contractual Clauses of the European Commission apply (Art. 46 GDPR).
ActiveCampaign enables us to analyse our email campaigns. When you open an email sent with ActiveCampaign, a connection to ActiveCampaign's servers is established via a so-called tracking pixel (web beacon). This makes it possible to determine whether a message has been opened and which links, if any, have been clicked. Technical information may also be recorded (e.g. time of retrieval, IP address, browser type and operating system). We use these data to better tailor our content and offers to the interests of our recipients.
The data processing is based on your consent (Art. 6(1)(a) GDPR). If you have already purchased from us, we also send you information about our own similar offers by email on the basis of our legitimate interest in direct marketing (Art. 6(1)(f) GDPR in conjunction with Section 7(3) of the German Act against Unfair Competition, UWG). You can object to this at any time without incurring any costs other than the transmission costs according to the basic rates.
You can unsubscribe from our emails at any time. Every email contains an unsubscribe link for this purpose. Alternatively, you can send your withdrawal or objection by email to
We store the data stored with us for the purpose of receiving emails until you unsubscribe and then delete them from our mailing list and from ActiveCampaign. Data stored with us for other purposes remain unaffected.
For more information on data protection at ActiveCampaign, please see https://www.activecampaign.com/legal/privacy-policy
XIII. Links to social networks
We currently use various links to different social media platforms, such as Facebook, Instagram, TikTok and Pinterest. These are not social media plugins, but merely links. If you click on one of the links, you will be taken to the website of the respective provider and your IP address will be transmitted. If you are logged in to the respective social media account at the same time, further data may be collected by the respective provider.
XIV. Our profiles on social networks
We maintain our own profiles on Instagram and Facebook (Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland), TikTok (TikTok Technology Limited, 10 Earlsfort Terrace, Dublin 2, Ireland) and Pinterest (Pinterest Europe Ltd., Palmerston House, Fenian Street, Dublin 2, Ireland). When you visit our profiles, interact with posts or send us messages, we process the data you provide to us there. The networks also process your data for their own purposes, for example for advertising, and may transfer them to the USA.
We are jointly responsible with Meta for the page statistics ("Insights") of our profiles on Instagram and Facebook (Art. 26 GDPR). Meta has undertaken in an agreement to assume the essential obligations; you can assert your rights directly with Meta. The legal basis is our legitimate interest in up-to-date communication with you (Art. 6(1)(f) GDPR).
For more information, please see the privacy policies of the networks: https://privacycenter.instagram.com/policy, https://www.facebook.com/privacy/policy, https://www.tiktok.com/legal/privacy-policy-eea, https://policy.pinterest.com/en/privacy-policy
XV. Use of Google Maps
1. On our websites we embed maps from the Google Maps service, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. This allows you to see our location on Mönckebergstraße directly on the page.
2. The map is only loaded once you have given your consent via the cookie banner or have actively loaded the map. In particular, your IP address and information about which page you visited are transmitted to Google, including to servers of Google LLC in the USA (EU-US Data Privacy Framework). If you are logged in to Google, Google can assign the data to your account.
3. The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG), which you can withdraw at any time. More information: https://policies.google.com/privacy
XVI. Videos from YouTube and Vimeo
On some pages we embed videos from YouTube, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. We use the enhanced privacy mode (youtube-nocookie.com). A connection to YouTube's servers is only established when you play a video. In particular, your IP address and information about your use of the video are transmitted, including to servers of Google LLC in the USA (EU-US Data Privacy Framework).
The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG), which you give via the cookie banner and can withdraw at any time. More information: https://policies.google.com/privacy
On infusionbar.de we also embed a video from the Vimeo service (Vimeo.com, Inc., USA). Here, too, a connection to Vimeo's servers is only established once you have given your consent via the cookie banner or clicked "Play video" in the video window. We use Vimeo's setting that switches off viewer tracking. In particular, your IP address and information about your use of the video are transmitted, including to the USA. The legal basis is your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). More information: https://vimeo.com/privacy
XVII. Transfer of information to transport service providers / shipping partners
For the purpose of delivering ordered goods, we work with logistics service providers, transport companies and/or shipping partners. The following data may be transmitted to them for the purpose of delivering the ordered goods or announcing the shipment: first name, last name, postal address and, if applicable, email address and phone number. The legal basis for the processing is Art. 6(1)(b) GDPR.
We currently ship with DHL (Deutsche Post AG, Charles-de-Gaulle-Straße 20, 53113 Bonn, Germany).
XVIII. Transfer of information to payment service providers
On this website we offer, among other things, payment via PayPal. The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). If you choose to pay via PayPal, the payment data you enter are transmitted to PayPal. The transmission of your data to PayPal is based on Art. 6(1)(a) GDPR (consent) and Art. 6(1)(b) GDPR (processing for the performance of a contract). You have the option to withdraw your consent to data processing at any time. A withdrawal does not affect the validity of data processing operations carried out in the past.
In our course area on ablefy, further payment methods are available (for example credit card, SEPA direct debit, purchase on account, Apple Pay and Google Pay). ablefy processes the payment with its payment service providers; for details, please see section XIX.
XIX. Online courses and course area on ablefy
We offer our online courses, for example the NWL Signature programme, as well as free guides via the ablefy platform of ablefy GmbH, Potsdamer Straße 125, 10783 Berlin, Germany. When you purchase a course or request a guide there, ablefy processes your name, your email address, your billing address, your payment data and information on your course access and course progress. Your contractual partner is exclusively NWL (see our Terms and Conditions, Section 23); ablefy provides the technical platform and payment processing and processes your data on our behalf pursuant to Art. 28 GDPR; the data processing agreement is part of our contract with ablefy.
The legal basis is the performance of the contract with you (Art. 6(1)(b) GDPR) and compliance with statutory retention obligations (Art. 6(1)(c) GDPR). How your data are transferred to ActiveCampaign is described in section XII. For more information, please see ablefy's privacy policy.
XX. Orders in our customer shop
When you place an order in our customer shop (nwl-shop.com) or create a customer account, we store the information from the order form and your customer account, i.e. name, address, email address, phone number, orders and invoices. We use these data to process your order, to issue invoices and to contact you if you have questions about your order. The legal basis is Art. 6(1)(b) GDPR. We retain invoices and accounting records for ten years. This is based on the statutory retention obligations (Art. 6(1)(c) GDPR, Section 147 of the German Fiscal Code (AO), Section 257 of the German Commercial Code (HGB)); where the statutory period is shorter, the retention is based on our legitimate interest in complete records (Art. 6(1)(f) GDPR).
XXI. Online appointment booking with Zeeg
For online appointment booking we use the service "Zeeg". The provider is Zeeg GmbH, Schlesische Straße 26, 10997 Berlin, Germany. Zeeg is cloud-based software for online appointment booking and appointment management. You can book appointments with us via a corresponding link or an embedded booking form. The data you enter are transmitted to Zeeg and processed there. Depending on the appointment, these are in particular the following data: name, email address, phone number, booked appointment (date, time, type of appointment) and optional information you provide in the free-text field. For appointments in our Infusionbar, your address, your date of birth, whether this is your first visit with us, and the health information you provide in the registration form are added (see section XXIII). We use these data exclusively for the purpose of scheduling, confirming, carrying out and, if necessary, cancelling the appointment. The data processing is carried out to take pre-contractual steps or to perform a contract within the meaning of Art. 6(1)(b) GDPR (appointment for consultation/treatment). Insofar as we collect additional information for analysis or marketing purposes, this is done on the basis of your consent pursuant to Art. 6(1)(a) GDPR, which you can withdraw at any time with effect for the future. Zeeg stores and processes all data exclusively on servers in Germany and thus within the European Economic Area (EEA). No transfer to third countries takes place. We have concluded a data processing agreement with Zeeg pursuant to Art. 28 GDPR, in which Zeeg undertakes to comply with European data protection requirements. The data you provide when booking an appointment are only stored for as long as is necessary to handle the appointment and to comply with statutory retention obligations. Otherwise, the general deletion periods stated in this privacy policy apply.
Via Zeeg you book appointments with NWL and in our Infusionbar. For more information on data protection at Zeeg, please see the provider's privacy policy: https://zeeg.me/en/legal/privacy
We need your date of birth for your infusion: we order the infusion from a pharmacy with a prescription in your name, which must state your name and date of birth. For this purpose, we pass these details on to the pharmacy. The legal basis is the performance of your treatment contract (Art. 6(1)(b) GDPR) and, since a prescription allows conclusions to be drawn about your health, Art. 9(2)(h) GDPR. The pharmacy is itself bound by professional confidentiality.
XXII. Contact via WhatsApp
You can also reach NWL and our Infusionbar via WhatsApp, a service of WhatsApp Ireland Limited, Merrion Road, Dublin 4, Ireland. When you write to us, we process your phone number, your name and the content of your message in order to answer your enquiry or arrange appointments. The legal basis is Art. 6(1)(b) GDPR where a contract or its initiation is concerned, otherwise our legitimate interest in fast communication (Art. 6(1)(f) GDPR).
The messages are end-to-end encrypted. However, WhatsApp receives metadata (for example who communicates with whom and when) and may also transfer these to the USA (EU-US Data Privacy Framework). Please do not send us detailed health information via WhatsApp; please use our registration form for this or speak to us in person. The use of WhatsApp is voluntary; you can always reach us by phone or email as well. More information: https://www.whatsapp.com/legal/privacy-policy-eea
XXIII. Health data for the NWL programme, nutritional counselling and infusions
For the NWL programme, nutritional counselling and the infusions in our Infusionbar, we need information about your health, for example about previous illnesses, medication, allergies, weight and diet. We only process these special categories of personal data with your explicit consent (Art. 9(2)(a) GDPR), which you give in the registration form or before treatment. You can withdraw your consent at any time with effect for the future; however, support or treatment is then not possible without this information.
We keep your client file, the treatment contract, the registration form and our consultation notes in lucar, software provided by Alsen Ventures UG (haftungsbeschränkt), Hellkamp 58D, 20255 Hamburg, Germany. You fill in the registration form yourself online via a link from lucar; your details go directly into your file. lucar stores the data on servers in Germany (Düsseldorf). We have concluded a data processing agreement with lucar pursuant to Art. 28 GDPR.
For infusions in our Infusionbar, you fill in the registration form when booking online via Zeeg (section XXI). Zeeg stores the information on servers in Germany; we have also concluded a data processing agreement with Zeeg.
Until the changeover has been completed, expected by the end of November 2026, older client files are still held at vcita (vcita Inc., 200 Central Ave, St. Petersburg, FL 33701, USA), which stores the data in data centres in the USA, and older registration forms at Microsoft Forms (Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland). Once the data have been transferred to lucar, we will delete them there, at the latest when our contract with vcita ends in January 2027. We have concluded a data processing agreement with both providers; the transfer to the USA is based on the Standard Contractual Clauses of the European Commission or the EU-US Data Privacy Framework.
Your health data are only seen by us and, insofar as necessary for organisational purposes, by our employee. They are not passed on to ActiveCampaign or used for advertising. We retain the documentation of your support and treatment for ten years after its completion (Section 630f(3) BGB) and then delete it, unless other obligations apply.
As of October 2026