Data Protection Information –
SPARRKS & CGM Integration

1. Purpose of this document
While Sparrks already provides detailed information about the processing of personal data on its own behalf and on behalf of the coach (see “Consent or declaration of consent under data protection law for the use of personal data by SPARRKS Service GmbH” and “Consent or declaration of consent under data protection law for the use of personal data by the coach”), this additional statement clarifies the data interface between Sparrks and CGM in the context of the Coaching @CGM program. It does not replace the existing declarations but complements them for CGM-specific data flows.

2. What Sparrks does not do
No integration with CGM-internal systems (e.g., CGM Alice or Workday) exists. No automated synchronization, data import/export, or API-based transmission takes place.

Sparrks does not collect or process HR metadata from CGM (e.g., job urgency, organizational unit, internal classifications).

Sparrks does not conduct long-term or follow-up surveys (e.g., 6 or 12 months post-coaching). Feedback is collected only directly after the coaching ends, with prior consent.

3. Data exchange between Sparrks and CGM

a) Personal data (only with consent)

Sparrks may transmit the following participant data to CGM HR for program management purposes, only if the participant has given informed consent:

• First and last name
• E-mail address
• Coaching language and topic
• Booking and participation status
• Coaching start and completion date

This exchange enables CGM to confirm enrollment and coordinate internal processes (e.g., HR development tracking). No content of coaching conversations, personal notes, or individual evaluations are shared.

b) Aggregated, non-identifying data

Sparrks may provide CGM with high-level, anonymized and aggregated information to support internal evaluation and quality improvement. This may include:

• General status updates across all participants (e.g., „80% have completed at least
  3 sessions“)
• Aggregated topic selections (e.g., „Most frequently selected themes: Leadership,
  Communication“;
• Summarized feedback results (e.g., „Average capability improvement across
  participants“)

This data is stripped of personal identifiers and cannot be traced back to individual coachees. Its sole purpose is to support CGM in evaluating the impact and relevance of the coaching offering.

4. Responsibilities & Hosting
Sparrks is the data controller for all information processed via its platform (app.sparrks.io and coachee.sparrks.io), including coaching operations and related communications. Data is hosted on secure servers located in Germany (Google Cloud, Frankfurt region).
CGM remains responsible for any additional HR data processed within its internal tools and platforms. No shared processing or joint controllership exists between CGM and Sparrks.

5. Contact
If you have any questions regarding data protection in the context of this cooperation, please contact:

Sparrks Service GmbH
Data Protection Officer
Prof. Dr. Reinhold Mauer
Email: datenschutz@sparrks.de

CompuGroup Medical SE & Co. KGaA
Data Protection Officer
Hans Josef Gerlitz
Email: HansJosef.Gerlitz@CGM.com