Last updated: 26 February 2026

1. Controller (Who We Are)
The controller within the meaning of the General Data Protection Regulation (GDPR) is:
Joanna Furgał
The MirrorWings – Collective
Member (employed member) of:
SMartDE e.G.
Wilhelmstraße 150
10963 Berlin
Germany
Cooperative register: GnR 791B
Register court: Berlin Local Court (Charlottenburg)
Represented by: Magdalena Ziomek, Alicja Möltner
Email: hi@themirrorwings.com
Website: https://www.themirrorwings.com
Unless otherwise stated, Joanna Furgał is responsible for data processing related to The MirrorWings programmes and services.

2. What Personal Data We Collect
We collect and process the following categories of personal data:
a) When you contact us or express interest in our programmes:

• Name

• Email address

• Telephone number

• Organisation / type of organisation

• Any additional information you voluntarily provide in your enquiry

• Information relevant to participation in programmes, workshops, or events (where necessary to assess suitability and ensure a good programme fit)

b) When you register for a programme:

• All of the above

• Billing and invoicing information (processed via SMartDE e.G.)

c) When you visit our website:

• IP address

• Browser type and version

• Device information

• Pages visited and interaction data

• Date and time of access

• Referrer URL

• Analytics data via Wix Analytics and Google Analytics

• Marketing tracking technologies (if consented), such as Meta Pixel, TikTok Pixel, and Microsoft Advertising
   

3. Purposes of Processing
We process your personal data for the following purposes:
Programme administration

• Communication regarding programmes, workshops, and events

• Registration confirmation

• Delivery of materials

• Organisational coordination

Invoicing and payments

• Billing and financial administration

• Processed via SMartDE e.G. in accordance with applicable tax regulations (including § 4 Nr. 21 UStG, where applicable)

Communication

• Responding to enquiries

• Sending relevant updates about programmes you have registered for

Marketing (only with consent)

• Sending newsletters or information about future programmes

• Online advertising and remarketing via tracking tools

Website improvement and analytics

• Understanding website usage

• Improving user experience

• Ensuring website security and functionality
   

4. Legal Basis for Processing (Art. 6 GDPR)
We process your data based on:

• Art. 6(1)(b) GDPR (Contract performance):
  For delivering programmes and services you register for.

• Art. 6(1)(f) GDPR (Legitimate interest):
  For responding to enquiries, improving services, ensuring website security, and internal administration.

• Art. 6(1)(a) GDPR (Consent):
  For newsletter subscriptions, marketing communications, and non-essential cookies (analytics and marketing tracking).

You may withdraw consent at any time with effect for the future.

5. Data Sharing and Third-Party Processors
We share personal data only where necessary and in compliance with GDPR.
SMartDE e.G.
Your billing and invoicing data is processed by SMartDE e.G., which acts as our administrative and billing partner. Data processing is carried out in accordance with their own data protection policies and applicable legal requirements.
Wix.com Ltd.
This website is hosted by Wix.com Ltd. Data may be stored on Wix servers. Wix may process technical website data on our behalf as a data processor.
Analytics and Marketing Providers (only with consent)

• Google Analytics

• Wix Analytics

• Meta (Facebook/Instagram) Pixel

• TikTok Pixel

• Microsoft Advertising

These providers may process data as independent controllers. Data processing may include transfers outside the EU/EEA. In such cases, appropriate safeguards (e.g., Standard Contractual Clauses) are used in accordance with Chapter V GDPR.
We do not sell, rent, or trade personal data to third parties for marketing purposes.

6. Data Retention
We retain personal data only as long as necessary:

• Programme participant data: Duration of the programme plus 3 years for administrative purposes

• Enquiry data: Up to 2 years unless earlier deletion is requested

• Financial records: 10 years in accordance with German tax and commercial law (§147 AO, §257 HGB)

• Marketing consent data: Until consent is withdrawn
   

7. Your Rights Under GDPR
You have the following rights:

• Access (Art. 15 GDPR)

• Rectification (Art. 16 GDPR)

• Erasure (Art. 17 GDPR)

• Restriction of processing (Art. 18 GDPR)

• Data portability (Art. 20 GDPR)

• Objection (Art. 21 GDPR)

• Withdrawal of consent (Art. 7(3) GDPR)

To exercise your rights, contact:
hi@themirrorwings.com
You also have the right to lodge a complaint with a supervisory authority.

8. Cookies and Website Analytics
Cookie Policy
We use cookies and similar technologies to operate and improve our website.
Essential Cookies
Required for website functionality, security, and basic operations.
Analytics Cookies (only with consent)
Used to understand user behaviour and improve performance (Google Analytics, Wix Analytics).
Marketing Cookies (only with consent)
Used for advertising and remarketing (Meta Pixel, TikTok Pixel, Microsoft Advertising).
You can manage or withdraw cookie consent at any time through our cookie banner or via your browser settings. Disabling certain cookies may limit website functionality.

9. Data Security
We implement appropriate technical and organisational measures in accordance with Art. 32 GDPR to protect personal data against loss, misuse, unauthorised access, or disclosure.
However, no internet transmission is completely secure, and absolute security cannot be guaranteed.

10. International Data Transfers
Data is primarily processed within the European Economic Area (EEA).
If personal data is transferred outside the EEA, we ensure appropriate safeguards in accordance with Chapter V GDPR, such as:

• EU Standard Contractual Clauses (SCCs)

• Adequacy decisions of the European Commission
   

11. Children’s Privacy
Our services are not directed at individuals under the age of 16. We do not knowingly collect personal data from children.

12. Changes to This Privacy Policy
We may update this Privacy Policy to reflect legal, technical, or operational changes. The updated version will always be published on this page with the revised date.

13. Questions and Complaints
If you have questions about this Privacy Policy or how we handle personal data, please contact:
hi@themirrorwings.com
You also have the right to lodge a complaint with the competent supervisory authority:
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Friedrichstr. 219
10969 Berlin
Germany
Phone: +49 30 13889-0
Email: mailbox@datenschutz-berlin.de
Website: https://www.datenschutz-berlin.de