Kemperplatz 1, 4 OG, 10785 Berlin, Germany
E-mail address: firstname.lastname@example.org
Types of processed data
Inventory data (e.g., person data, names or addresses).
Contact information (e.g., e-mail, phone numbers).
Content data (e.g., text input, photographs, videos).
Usage data (e.g., websites visited, interest in content, access times).
Meta / communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter we refer to the data subjects as “users”).
Purpose of processing
Provision of the online offer, its functions and contents.
Answering contact requests and communicating with users.
Reach Measurement / Marketing
“Personal data” is any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, in case the natural person can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
“Processing” is any process performed with or without the aid of automated procedures or any such process associated with personal data. The term is broad and includes virtually every handling of data.
“Pseudonymisation” is the processing of personal data in such a way that the personal data can no longer be assigned to a specific affected person without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data is not assigned to an identified or identifiable natural person.
“Profiling” is any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to job performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.
“Controller” means the natural or legal person, public authority or other body that decides, alone or in cooperation with others, on the purposes and means of processing personal data.
“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Article 13 GDPR, we inform you about the legal basis of our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, unless the legal basis in the data privacy notice is mentioned, the following applies:
The legal basis for obtaining consent is Article 6 (1) and Article 7 GDPR; The legal basis for the processing for the fulfillment of our services and the execution of contractual measures as well as the answering of inquiries is Article 6 (1) point (b) GDPR; The legal basis for processing to fulfill our legal obligations is Article 6 (1) point (c) GDPR; In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 (1) point (d) GDPR acts as the legal basis. The legal basis for the processing required to perform a task in the public interest or in the exercise of official authority which has been delegated to the controller is Article 6 (1) point (e) GDPR. The legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) point (f) GDPR. The processing of data for purposes other than those to which they have been granted is governed by the provisions of Article 6 (4) GDPR. The processing of special categories of data (according to Article 9 (1) GDPR) is governed by the provisions of Article 9 (2) GDPR.
We will take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing and the different likelihood and severity of the risk to the rights and freedoms of individuals to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, i.e. during selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings.
Collaboration with contract processors, joint controllers and third parties
If, in the course of our processing, we disclose data to other persons and companies (contract processors, joint controllers or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if the data is transmitted to third parties, such as to payment service providers, to fulfill the contract), users have consented to a legal obligation to do so or on the basis of our legitimate interests (e.g. the use of agents, web hosts, etc.).
If we disclose data to other companies in our group, convey it or otherwise grant access to it, this is done in particular for administrative purposes as a legitimate interest and, moreover, based on a legal basis.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or this occurs in the context of the use of third party services or disclosure, or transfer of data to other persons or companies, this will only happen if it is to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only in the presence of legal prerequisites. That is, the processing is e.g. based on specific guarantees, such as the officially recognized EU-equal level of data protection (for example, the US Privacy Shield) or compliance with officially recognized specific contractual obligations.
Rights of data subjects
You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with legal requirements. You have the right, in accordance with the legal requirements, to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with the legal requirements, you have the right to demand that the relevant data be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with the legal requirements. You have the right to request that the data relating to you provided to us in accordance with legal requirements and to request its transmission to other controllers.
They also have the right, in accordance with the legal requirements, to submit a complaint to the competent supervisory authority.
Right of withdrawal
You have the right to withdraw granted consent with effect for the future.
Right of objection
You may object to the future processing of your data in accordance with legal requirements at any time. The objection may in particular be made against processing for direct marketing purposes.
Cookies and right to object in direct marketing
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or a login status are saved. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, this is called “first-party cookies”).
If users do not want cookies stored on their computer, they are asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. Please note that the exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of data
Unless the data is deleted because it is required for other and legitimate purposes, its processing will be restricted. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.
In addition we process
Contract data (e.g., contract subject, term, customer category).
Payment data (e.g., bank details, payment history) of our customers, prospects and business partners for the purpose of providing contractual obligations, service and customer care, marketing, advertising and market research.
When contacting us (for example, by contact form, e-mail, telephone or via social media), the information of the user is processed to handle the contact request and its processing in accordance with Article 6 (1) point (b) (in the context of contractual / pre-contractual relationships), Article 6 (1) point (f) (other requests) GDPR. User information can be stored in a Customer Relationship Management System (“CRM System”) or similar request system.
We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, the legal archiving obligations apply.
CRM system Bitrix24
We use the CRM system “Bitrix24” of the provider Bitrix, Inc., 901 N. Pitt St, Suite 325 Alexandria VA 22314, USA, in order to be able to process inquiries of the users faster and more efficiently (legitimate interest according to Article 6 (1) point (f) GDPR.
Bitrix24 uses users’ data only for the technical processing of inquiries and does not pass them on to third parties. To use Bitrix24 at least the specification of a correct e-mail address is necessary. A pseudonymous use is possible. During the processing of service requests it may be necessary to collect further data (name, address).
If users disagree with data collection and data storage in Bitrix24’s external system, we offer alternative contact options for submitting service requests by e-mail, telephone, fax or post.
Hosting and e-mailing
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security and technical maintenance services, which we use to operate this online service.
We, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer according to Article 6 (1) point (f) GDPR in connection with Article 28 GDPR (conclusion of order processing contract).
Collection of access data and log files
We, or our hosting provider, collect on the basis of our legitimate interests within the scope of Article 6 (1) point (f) GDPR data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Where further retention is required for evidential purposes, data shall be exempted from the cancellation until final clarification of the incident.
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation.
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting of their browser software; Users may also prevent the collection by Google of the data generated by the cookie and related to its use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de
The personal data of users will be deleted or anonymized after 14 months.
Integration of services and contents of third parties
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the scope of Article 6 (1) point (f) GDPR), we make use of content or services offered by third-party providers in order to provide their content and services, e.g. to include videos or fonts (collectively referred to as “content”).
This always presupposes that the third-party providers of this content receive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.
We incorporate the fonts (“Google Fonts”) provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data privacy notice: https://www.google.com/policies/privacy/ Opt-Out: https://adssettings.google.com/authenticated.
We incorporate functions to detect bots, e.g. when entering into online forms (“ReCaptcha”) of the provider Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data privacy notice: https://www.google.com/policies/privacy/ Opt-Out: https://adssettings.google.com/authenticated.
We include maps from the Google Maps service provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, users’ IP addresses and location data, but these are not collected without their consent (usually as part of the settings of their mobile devices). The data can be processed in the USA. Data privacy notice: https://www.google.com/policies/privacy/ Opt-Out: https://adssettings.google.com/authenticated.
The MIT License (MIT)
Permission is hereby granted, free of charge, to any person obtaining a copy of this software and associated documentation files (the "Software"), to deal in the Software without restriction, including without limitation the rights to use, copy, modify, merge, publish, distribute, sublicense, and/or sell copies of the Software, and to permit persons to whom the Software is furnished to do so, subject to the following conditions: The above copyright notice and this permission notice shall be included in all copies or substantial portions of the Software. THE SOFTWARE IS PROVIDED "AS IS", WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO THE WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NONINFRINGEMENT. IN NO EVENT SHALL THE AUTHORS OR COPYRIGHT HOLDERS BE LIABLE FOR ANY CLAIM, DAMAGES OR OTHER LIABILITY, WHETHER IN AN ACTION OF CONTRACT, TORT OR OTHERWISE, ARISING FROM, OUT OF OR IN CONNECTION WITH THE SOFTWARE OR THE USE OR OTHER DEALINGS IN THE SOFTWARE.
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