Person in Charge

Richard Porstmann
Bachelor of Business Administration | MBA

Lyoner Straße 52D
60528 Frankfurt (Main)
Germany

+49 157 / 78 63 20 77
rp@porstmann.net
www.porstmann.net

Contents

  1. General Information on Data Processing and Legal Bases
  2. Types of Data Processed / Categories of Data Subjects
  3. Safety Measures
  4. Sharing Data with Third Parties and Third-Party Providers
  5. Performance of Contractual Obligations
  6. Contact Us
  7. Web Hosting
  8. Cookies & Audience Measurement
  9. Google Analytics
  10. Facebook Social Plugins
  11. Reach Analysis with Matomo
  12. Newsletter
  13. Embedding Videos
  14. Integration of Third-Party Services and Content
  15. Rights of the Data Subject
  16. Deletion of Data
  17. Right to Object
  18. Changes to the Privacy Policy

1. General Information on Data Processing and Legal Bases

1.1. This Privacy Policy explains the nature, scope, and purpose of the processing of personal data within our online service and the associated websites, features, and content (hereinafter collectively referred to as the “online service” or “website”). This Privacy Policy applies regardless of the domains, systems, platforms, and devices (e.g., desktop or mobile) on which the online service is operated.

1.2. The terms used, such as “personal data” or “processing” of such data, refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

2. Types of Data Processed / Categories of Data Subjects

2.1. The users’ personal data processed as part of this online service includes:

  • Master data (e.g., customer names and addresses),
  • Contact information (e.g., email, phone numbers),
  • Communication data,
  • Contract data (e.g., services used, names of case workers, payment information),
  • Usage data (e.g., the web pages visited on our website, interest in our products)
  • Meta/communication data (e.g., device information, IP addresses) and
  • Content data (e.g., entries in the contact form).

2.2. The term “user” encompasses all categories of individuals affected by data processing. These include our business partners, customers, prospective customers, and other visitors to our website. The terms used are to be understood as gender-neutral.

2.3. We process users’ personal data only in compliance with the relevant data protection regulations. This means that users’ data is processed only when there is legal authorization to do so—in particular, when data processing is necessary for the provision of our contractual services (e.g., processing orders) and online services, or is required by law, or when users have given their consent, or based on our legitimate interests (i.e., our interest in the analysis, optimizing, and ensuring the economic operation and security of our online offering within the meaning of Article 6(1)(f) of the GDPR, particularly in connection with audience measurement, the creation of profiles for advertising and marketing purposes, as well as the collection of access data and the use of third-party services.

2.4. Please note that the legal basis for consent is Article 6(1)(a) and Article 7 of the GDPR; the legal basis for processing to fulfill our services and carry out contractual measures is Article 6(1)(b) of the GDPR; the legal basis for processing to fulfill our legal obligations is Article 6(1)(c) of the GDPR; and the legal basis for processing to protect our legitimate interests is Article 6(1)(f) of the GDPR.

2.5. The following individuals are affected by this data processing:

  • Contract and business partners,
  • Users of our online service,
  • Prospective customers who are interested in our online offerings or who contact us for other reasons and
  • Customers.

3. Safety Measures

In accordance with Article 32 of the GDPR, we implement appropriate organizational, contractual, and technical security measures that reflect the state of the art, taking into account the costs of implementation and the nature, scope, circumstances, and purposes of the data processing, as well as the varying likelihood and severity of the risk to your rights and freedoms, in order to ensure an appropriate level of protection for your data. We hereby ensure compliance with the provisions of data protection laws and protect this data against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.

3.1. These security measures include, in particular, the encrypted transmission of data between your browser and our server. You can recognize such encrypted connections by the fact that the URL in your browser’s address bar begins with “https://.” This is a communication protocol that allows data to be transmitted securely using transport-layer encryption.

4. Disclosure of Data to Third Parties and Third-Party Providers

4.1. Data is disclosed to third parties only in accordance with legal requirements. We will only disclose user data to third parties if this is necessary, for example, for contractual purposes pursuant to Article 6(1)(b) of the GDPR or based on legitimate interests pursuant to Article 6(1)(f) GDPR for the economic and effective operation of our business.

4.2. We use subcontractors to provide our services only if we have taken appropriate legal precautions and implemented corresponding technical and organizational measures to ensure the protection of the personal data being processed in accordance with the relevant legal provisions.

4.3. If content, tools, or other resources described in this Privacy Policy are provided by other providers (hereinafter collectively referred to as “third-party providers”), we comply with legal requirements and, in particular, enter into appropriate agreements or arrangements designed to protect your data with the recipients of your data.

4.4. If we use a third-party provider whose registered office is located in a third country (outside the European Union (EU) or the European Economic Area), it can be assumed that data will be transferred to the third-party provider’s country of incorporation. Data will only be transferred to third countries if an adequate level of data protection is ensured, the user has given consent, or there is some other legal basis for the transfer.

5. Performance of Contractual Obligations

5.1. We process master data (e.g., names, addresses, and contact information of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and providing services in accordance with Article 6(1)(b) of the GDPR. We inform our contractual partners of which data is required for the aforementioned purposes either before or during the data collection process—for example, in online forms, through special markings (e.g., colors) or symbols (e.g., asterisks, etc.), or in person. In accordance with applicable law, we disclose this data to third parties only to the extent necessary for the aforementioned purposes or to fulfill legal obligations, or with your consent (e.g., to relevant telecommunications, transportation, and other support services, as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities).

5.2. We delete the data once statutory warranty obligations and similar obligations have expired, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving purposes (e.g., for tax purposes, typically 10 years). We delete data disclosed to us by the contracting party within the scope of a contractual relationship in accordance with the terms of the contract, generally after the contractual obligations have been fulfilled.

6. Making Contact

6.1. When you contact us (via the contact form or email), your information is processed in accordance with Article 6(1)(b) of the GDPR for the purpose of handling your inquiry and processing it. In doing so, we process only the data we need to address your request.

6.2. User information may be stored in our customer relationship management system (“CRM system”) or a similar system for managing inquiries.

7. Web Hosting

7.1. In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space, and database services, as well as security and technical maintenance services.

7.2. Based on our legitimate interests within the meaning of Article 6(1)(f) of the GDPR, we collect data regarding every access to the server on which this service is hosted (so-called server log files). The access data includes the name of the webpage accessed, the file, the date and time of access, the amount of data transferred, a notification of successful access, the browser type and version, the user’s operating system, the referrer URL (the previously visited page), IP address, and the requesting provider.

7.3. For security reasons (e.g., to investigate cases of misuse or fraud), log file information is stored for a maximum of seven days and then deleted. Data that must be retained for evidentiary purposes is exempt from deletion until the respective incident has been fully resolved.

7.4. The web hosting services also include the sending, receiving, and storage of emails. For these purposes, the addresses of the recipients and senders, as well as additional information regarding email transmission (e.g., the providers involved), including the content of the respective emails, are processed. Even though our email communications are encrypted during transmission, they are not encrypted on the servers from which they are sent and received. The content of email communications is therefore generally susceptible to tampering.

8. Cookies & Audience Measurement

8.1. When you visit our website, information may be stored on your computer in the form of a cookie. Cookies are pieces of information that are transmitted from our web server or third-party web servers to users’ web browsers and stored there for later retrieval. Most browsers are set to automatically accept cookies. We would like to point out that using our online services without cookies is only possible to a limited extent. In particular, you will generally not be able to use your customer account, as the use of cookies is technically essential for this purpose. However, you can also use your browser to prevent only certain cookies from being set (e.g., third-party cookies), for example, if you wish to block web tracking. You can find more detailed information on this in your browser’s help section. Further information on third-party cookies that are set or processed when you visit our website can be found in the privacy policy below, to the extent that we use them. We also include other technologies that perform the same functions as cookies under the term “cookies” (e.g., when user information is stored using pseudonymous online identifiers, also known as “user IDs”).

  • A distinction must be made between cookies that are set by the website operator when you visit a website (also known as “first-party cookies”) and cookies that are set by third parties (also known as “third-party cookies”). We have technical control only over the former. We further distinguish between the following types of cookies.
  • Temporary cookies (also known as session cookies): Temporary cookies are deleted at the latest after a user leaves a website and closes their browser.
  • Persistent cookies: Persistent cookies remain stored even after the browser is closed. For example, this allows the login status to be saved or preferred content to be displayed immediately when the user visits a website again. Similarly, users’ interests—which are used for audience measurement or marketing purposes—can be stored in such a cookie.
  • Necessary (also: essential or strictly required) cookies: Cookies may be strictly necessary for the operation of a website (e.g., to store logins or other user input, or for security reasons).
  • Statistics, Marketing, and Personalization Cookies: Cookies are also generally used for audience measurement and when a user’s interests or behavior (e.g., viewing certain content, using certain features, etc.) on individual web pages are stored in a user profile. Such profiles are used, for example, to display content to users that matches their potential interests. This process is also referred to as “tracking,” i.e., tracking users’ potential interests. We provide separate information about the use of “tracking” technologies in our Privacy Policy or when obtaining consent.

8.2. We use “session cookies,” which are stored only for the duration of your current visit to our website (for example, to save your login status or the shopping cart function, thereby enabling you to use our online services at all). A session cookie stores a randomly generated unique identification number, known as a session ID. In addition, a cookie contains information about its origin and storage period. These cookies cannot store any other data. Session cookies are deleted once you have finished using our online service—for example, when you log out or close your browser.

8.3. If users do not want cookies to be stored on their computers, they are asked to disable the corresponding option in their browser’s settings. Stored cookies can be deleted in the browser’s settings.

8.4. The legal basis on which we process your personal data using cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your explicit consent. Otherwise, the data processed using cookies is processed based on our legitimate interests (e.g., in the business operation of our online service and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Depending on whether the processing is based on consent or legal authorization, you have the option at any time to withdraw your consent or object to the processing of your data through cookie technologies (“opt-out”). You can initially opt out by adjusting your browser settings to prevent cookies from being set. You can also object to the use of cookies for online marketing purposes—particularly in the case of tracking—through a variety of services available on the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can find further information on how to opt out in the details provided about the service providers and cookies used.

Before we process data or have data processed in connection with the use of cookies, we ask users for their consent, which may be revoked at any time. Until consent is given, we may use only those cookies that are necessary for the operation of our online service. Their use is based on our interest and the users’ interest in the expected functionality of our online service. This includes usage data (e.g., webpages visited, interest in content, access times) and meta/communication data (e.g., device information, IP addresses). Users of our online service are affected by this processing. The processing is based on the legal grounds of consent (Art. 6(1)(a) GDPR) or legitimate interests within the meaning of Art. 6(1)(f) GDPR.

9. Google Analytics

9.1. Based on your consent, we use Google Analytics—a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”)—to analyze, optimize, and ensure the efficient operation of our online services. Google uses persistent third-party cookies. The information collected through these cookies is processed exclusively in our interest.

9.2. The information generated by the cookie regarding users’ use of the online service is generally transmitted to a Google server in the United States and stored there.

9.3. We have agreed to so-called standard contractual clauses with Google in order to ensure an adequate level of data protection. Through these clauses, Google guarantees compliance with European data protection law.

9.4. Google will use this information on our behalf to evaluate how users use our online service, to compile reports on activity within this online service, and to provide us with other services related to the use of this online service and Internet usage. In doing so, pseudonymous user profiles may be created from the processed data.

9.5. We use Google Analytics only with IP anonymization enabled. This means that Google truncates users’ IP addresses within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the United States and truncated there.

9.6. The IP address transmitted by the user’s browser is not combined with any other data held by Google. Users can prevent the storage of cookies by adjusting their browser settings accordingly; users can also prevent Google from collecting the data generated by the cookie and related to their use of the online service, as well as from processing this data, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

9.7. For more information about Google’s use of data, as well as options for settings and opting out, please visit Google’s websites: https://www.google.com/intl/de/policies/privacy/partners (“Google’s use of data when you use our partners’ websites or apps”), http://www.google.com/policies/technologies/ads (“Data Use for Advertising Purposes”), http://www.google.de/settings/ads (“Manage the information Google uses to show you ads”).

10. Facebook Social Plugins

10.1. Based on your consent and in the interest of optimizing and ensuring the efficient operation of our online service, we use social plugins (“plugins”) from the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins may display interactive elements or content (e.g., videos, graphics, or text posts) and can be identified by one of the Facebook logos or by the label “Facebook Social Plugin.”

10.2. When a user accesses a feature of this online service that contains such a plugin, a direct connection to Facebook’s servers is established only when the user interacts with the plugins. The content of the plugin is transmitted directly from Facebook to the user’s device and integrated into the online service. In the process, user profiles may be created based on the processed data. We therefore have no influence over the scope of the data that Facebook collects using this plugin and are providing this information to users based on our current understanding.

10.3. When the plugins are integrated, Facebook receives information that a user has accessed the corresponding page of the website. If the user is logged into Facebook, Facebook can associate the visit with the user’s Facebook account. When users interact with the plugins—for example, by clicking the “Like” button or posting a comment—the corresponding information is transmitted directly from your device to Facebook and stored there. Even if a user is not a Facebook member, there is still a possibility that Facebook may obtain and store their IP address. According to Facebook, only an anonymized IP address is stored in Germany.

10.4. Users can find information on the purpose and scope of data collection, as well as the further processing and use of data by Facebook, and their related rights and privacy settings, in Facebook’s Privacy Policy: https://www.facebook.com/about/privacy/.

10.5. If a user is a Facebook member and does not want Facebook to collect data about them through this website and link it to their Facebook account information, they must log out of Facebook and delete their cookies before using our website. Additional settings and the option to opt out of the use of data for advertising purposes are available in the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the U.S. site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. These settings apply across all platforms, meaning they are applied to all devices, such as desktop computers or mobile devices.

11. Reach Analysis with Matomo

11.1. Based on your consent, we use Matomo—an open-source software tool for statistical analysis of user traffic—to analyze, optimize, and ensure the efficient operation of our online service. Users’ IP addresses are truncated before being stored. However, Matomo uses first-party cookies that are stored on users’ computers and enable an analysis of how users interact with this online service. Pseudonymous user profiles may be created from the processed data.

11.2. The information generated by the cookie regarding your use of this website is stored on our server and is not shared with third parties.

12th Newsletter

12.1. The following information explains the content of our newsletter, as well as our subscription, distribution, and statistical analysis procedures, and your rights to object. By subscribing to our newsletter, you agree to receive it and to the procedures described herein.

12.2. We send newsletters, emails, and other electronic notifications containing promotional information (hereinafter “newsletters”) only with the recipients’ consent or when permitted by law. If the content of the newsletter is specifically described during the subscription process, that description is decisive for the user’s consent. In addition, our newsletters contain information about our products, offers, promotions, and our company.

12.3. Subscription to our newsletter is handled via a so-called double opt-in process. This means that after you subscribe, you will receive an email asking you to confirm your subscription. This confirmation is necessary to ensure that no one can subscribe using someone else’s email address. Newsletter sign-ups are logged to provide proof of the sign-up process in accordance with legal requirements. This includes storing the time of sign-up and confirmation, as well as the IP address. Changes to your data stored with the email service provider are also logged.

12.4. The newsletters are sent via CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, hereinafter referred to as the “mailing service provider.” You can view the mailing service provider’s privacy policy here: https://www.cleverreach.com/de/datenschutz/.

12.5. The newsletter is sent via “MailChimp,” a newsletter distribution platform provided by the U.S. company Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the mailing service provider’s privacy policy here: https://mailchimp.com/legal/privacy/. Standard contractual clauses have been agreed upon to ensure an adequate level of data protection.

12.6. Furthermore, according to the shipping service provider’s own information, it may use this data in pseudonymous form, i.e., without linking it to a specific user, to optimize or improve its own services—for example, to technically optimize the delivery and presentation of the newsletter or for statistical purposes to determine which countries the recipients are from. However, the mailing service provider does not use the data of our newsletter recipients to contact them directly or to share it with third parties.

12.7. Subscription Information: To subscribe to the newsletter, simply enter your email address. Optionally, we ask that you provide a name so we can address you personally in the newsletter.

12.8. The newsletters contain a so-called “web beacon,” which is a pixel-sized file that is retrieved from the mailing service provider’s server when the newsletter is opened. As part of this retrieval, technical information—such as details about your browser and system—as well as your IP address and the time of retrieval are collected. This information is used to improve the services technically based on the technical data, or to analyze target groups and their reading behavior based on their access locations (which can be determined using the IP address) or access times. The statistical analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. Although this information can be traced back to individual newsletter recipients for technical reasons, it is neither our intention nor that of the email service provider to monitor individual users. Rather, these analyses help us identify our users’ reading habits so that we can tailor our content to them or send different content based on our users’ interests.

12.9. The use of the shipping service provider, the conduct of statistical surveys and analyses, and the logging of the registration process are based on our legitimate interests pursuant to Article 6(1)(f) of the GDPR. Our interest is in using a user-friendly and secure newsletter system that serves both our business interests and meets users’ expectations.

12.10. You can unsubscribe from our newsletter at any time, i.e., revoke your consent. This will simultaneously revoke your consent to the newsletter’s distribution by the mailing service provider and to statistical analysis. Unfortunately, it is not possible to revoke consent separately for the mailing service provider’s distribution or for statistical analysis. You will find a link to unsubscribe from the newsletter at the end of each newsletter. If users have only subscribed to the newsletter and have canceled that subscription, their personal data will be deleted.

13. Embedding Videos

13.1. We use videos to display the submitted entries. Since hosting videos locally is not efficient enough, we rely on external video providers. We use the services of Vimeo, Inc., West 18th Street, New York 10011, USA (“Vimeo”).

13.2. Embedding the videos results in a request being sent to the provider’s servers. For information regarding the associated use of data, please refer to the provider’s respective privacy policy. Vimeo’s privacy policy is available at the following link: https://vimeo.com/privacy.

13.3. The legal basis for embedding the videos and the associated transfer of personal data for registered users of our service is Article 6(1)(b) of the GDPR. Embedding is necessary because there is currently no comparable video solution available for providing protected videos.

13.4. For unregistered users, the legal basis for the transfer of personal data is Article 6(1)(f) of the GDPR.

13.5. To ensure an adequate level of data protection when transferring data to the United States, we have entered into the so-called Standard Contractual Clauses with the provider of Vimeo. As an additional safeguard, we always embed videos using the “Do Not Track” option, thereby minimizing the amount of personal data transferred.

13.6. Alternatively, we can also use the YouTube service. These are videos from the “YouTube” platform provided by the third-party provider Google. In this case, the video is embedded on our website but continues to be hosted on the YouTube platform. When the video is played, a connection is established with YouTube. The privacy policy is available here: https://www.google.com/policies/privacy/, and you can opt out here: https://www.google.com/settings/ads/. We have entered into an agreement with Google

14. Integration of Third-Party Services and Content

14.1. Within our online offering, we incorporate content or services from third-party providers based on our legitimate interests (i.e., our interest in analyzing, optimizing, and ensuring the economic operation of our online offering within the meaning of Art. 6(1)(f) GDPR) or based on your consent (Art. 6(1)(a) GDPR) to integrate content or services from third-party providers, such as videos or fonts (hereinafter collectively referred to as “Content”). This is done to provide our online service and to enhance its user-friendliness. This always requires that the third-party providers of this content collect users’ IP addresses, as they would be unable to send the content to users’ browsers without the IP address. The IP address is therefore necessary for the display of this content. We make every effort to use only such content whose respective providers use the IP address solely for the purpose of delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. These “pixel tags” allow information—such as visitor traffic on the pages of this website—to be analyzed. This pseudonymous information may also be stored in third-party cookies on the user’s device and may include, among other things, technical information about the browser and operating system, referring websites, time of visit, and other details regarding the use of our online service; it may also be linked to such information from other sources.

14.2. The following list provides an overview of third-party providers and their content, along with links to their privacy policies, which contain further information on data processing and—as mentioned in some cases above—options to object (so-called “opt-out” options):

  • If our customers use third-party payment services (such as PayPal or Sofortüberweisung), the terms and conditions and privacy policies of the respective third-party providers—which are available on their respective websites or within the transaction applications—apply.
  • External fonts from Google Ireland, https://www.google.com/fonts (“Google Fonts”). Google Fonts are integrated via a server request to Google (usually in the U.S.). Privacy Policy: https://www.google.com/policies/privacy/. You can opt out here: https://www.google.com/settings/ads/.
  • Maps from the “Google Maps” service provided by the third-party provider Google. The privacy policy is available here: https://www.google.com/policies/privacy/. You can opt out here: https://www.google.com/settings/ads/
  • Our website uses features from the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Every time you visit one of our pages that contains LinkedIn features, a connection is established with LinkedIn’s servers. LinkedIn is notified that you have visited our website using your IP address. If you click the LinkedIn “Recommend” button while logged into your LinkedIn account, LinkedIn can associate your visit to our website with you and your user account. Please note that, as the provider of these pages, we have no knowledge of the content of the data transmitted or how it is used by LinkedIn. The privacy policy is available here: https://www.linkedin.com/legal/privacy-policy, and you can opt out here: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Our website may incorporate features from the Twitter service. These features are provided by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland. When you use Twitter and the “Retweet” feature, the websites you visit are linked to your Twitter account and made known to other users. Data is also transmitted to Twitter in the process. Please note that, as the provider of these pages, we have no knowledge of the content of the transmitted data or how Twitter uses it. Twitter’s privacy policy is available at http://twitter.com/privacy. You can change your privacy settings on Twitter in your account settings at http://twitter.com/account/settins.
  • We use features provided by the XING network. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Each time one of our pages that contains XING features is accessed, a connection is established to XING’s servers. To the best of our knowledge, no personal data is stored in this process. In particular, IP addresses are not stored, nor is user behavior analyzed. Privacy Policy: https://www.xing.com/app/share?op=data_protection.

15. Rights of the Data Subject

If your personal data is processed, you are a data subject within the meaning of the GDPR, and you have the following rights with respect to the controller:

15.1. Right of Access
You may request confirmation from the data controller as to whether we are processing personal data concerning you.

If such processing is taking place, you may request the following information from the controller:

  • the purposes for which the personal data is processed;
  • the categories of personal data that are processed;
  • the recipients or categories of recipients to whom your personal data has been or will be disclosed;
  • the planned duration of the storage of your personal data or, if specific details cannot be provided, the criteria used to determine the storage period;
  • the existence of a right to have personal data concerning you rectified or erased, a right to restrict processing by the controller, or a right to object to such processing;
  • the existence of a right to file a complaint with a supervisory authority;
  • all available information regarding the source of the data, if the personal data is not collected directly from the data subject;
  • the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR; and—at least in such cases—meaningful information about the logic involved, as well as the scope and intended effects of such processing on the data subject.

You have the right to request information regarding whether your personal data will be transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer.

15.2. Right to Rectification
You have the right to request that the controller rectify and/or complete your personal data if the processed personal data concerning you is inaccurate or incomplete. The controller must carry out the rectification without delay.

15.3. Right to Restriction of Processing
Under the following conditions, you may request that the processing of your personal data be restricted:

  • if you contest the accuracy of the personal data concerning you for a period that allows the controller to verify the accuracy of the personal data;
  • the processing is unlawful, and you object to the erasure of the personal data and instead request that the use of the personal data be restricted;
  • the controller no longer needs the personal data for the purposes of processing, but you need it to assert, exercise, or defend legal claims, or
  • if you have objected to the processing pursuant to Article 21(1) of the GDPR and it has not yet been determined whether the controller’s legitimate grounds override your grounds.

If the processing of your personal data has been restricted, such data—with the exception of its storage—may be processed only with your consent or for the purpose of asserting, exercise, or defense of legal claims; to protect the rights of another natural or legal person; or for reasons of a substantial public interest of the Union or a Member State.

If the restriction on processing has been imposed in accordance with the above conditions, the controller will notify you before the restriction is lifted.

15.4. Right to Erasure
a) Obligation to Erase
You may request that the controller immediately erase the personal data concerning you, and the controller is obligated to erase such data immediately if any of the following grounds apply:

  • The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
  • You withdraw your consent on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing.
  • You object to the processing pursuant to Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data concerning you was processed unlawfully.
  • The erasure of your personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
  • The personal data concerning you was collected in connection with the information society services offered, in accordance with Article 8(1) of the GDPR.

b) Notification to Third Parties
If the controller has made your personal data public and is obligated to erase it pursuant to Article 17(1) of the GDPR, the controller shall take reasonable measures, taking into account available technology and the costs of implementation, including technical measures, to inform other controllers processing the personal data that you, as the data subject, have requested that they erase all links to such personal data or any copies or replicas thereof.

c) Exceptions
The right to erasure does not apply to the extent that the processing is necessary

  • to exercise the right to freedom of expression and information;
  • to comply with a legal obligation that requires processing under 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 pursuant to Article 9(2)(h) and (i) and Article 9(3) of the GDPR;
  • for archiving purposes in the public interest, scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, to the extent that the right referred to in subsection (a) is likely to render impossible or seriously impair the achievement of the purposes of such processing, or
  • to assert, exercise, or defend legal claims.

15.5. Right to Be Informed
If you have exercised your right to rectification, erasure, or restriction of processing with the controller, the controller is obligated to notify all recipients to whom your personal data has been disclosed of such rectification, erasure, or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to request information from the controller regarding these recipients.

15.6. Right to Data Portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that

  • the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, or on a contract pursuant to Article 6(1)(b) of the GDPR, and
  • the processing is carried out using automated means.

In exercising this right, you also have the right to have your personal data transferred directly from one controller to another, provided that this is technically feasible. This must not infringe upon the freedoms and rights of others.

The right to data portability does not apply to the processing of personal data that 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.

15.7. Right to Object
You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data carried out pursuant to Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions.

The controller will no longer process your personal data unless it can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.

If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for such marketing purposes; this also applies to profiling to the extent that it is related to such direct marketing.

If you object to the processing of your personal data for direct marketing purposes, your personal data will no longer be processed for those purposes.

In connection with the use of information society services—notwithstanding Directive 2002/58/EC—you have the option to exercise your right to object through automated procedures that use technical specifications.

15.8. Right to Withdraw Consent Under Data Protection Law
You have the right to withdraw your consent under data protection law at any time. Withdrawing your consent does not affect the lawfulness of the processing carried out on the basis of your consent prior to its withdrawal.

15.9. Automated decision-making in individual cases, including profiling
You have the right not to be subject to a decision based solely on automated processing—including profiling—that produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

  • is necessary for the conclusion or performance of a contract between you and the data controller,
  • is permitted under Union or Member State law to which the controller is subject, and such law provides for appropriate safeguards to protect your rights, freedoms, and legitimate interests; or
  • is done with your express consent.

However, these decisions may not be based on special categories of personal data as defined in Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) applies and appropriate measures have been taken to protect your rights and freedoms as well as your legitimate interests.

With respect to the cases referred to in (1) and (3), the controller shall take appropriate measures to safeguard your rights and freedoms as well as your legitimate interests, including, at a minimum, the right to request that the controller involve a person, to present your own point of view, and to challenge the decision.

15.10. Right to File a Complaint with a Supervisory Authority
Without prejudice to any other administrative or judicial remedy, you have the right to file a complaint with a supervisory authority, in particular in the Member State where you reside, where you work, or where the alleged infringement occurred, if you believe that the processing of your personal data violates the GDPR.

The supervisory authority to which the complaint was submitted shall inform the complainant of the status and outcome of the complaint, including the possibility of seeking judicial remedy under Article 78 of the GDPR.

16. Deletion of Data

16.1. The data we store is deleted as soon as it is no longer necessary for its intended purpose and there are no legal retention requirements preventing its deletion. In particular, deletion also occurs when other grounds for processing no longer apply. If user data is not deleted because it is required for other, legally permissible purposes, its processing is restricted—that is, the data is blocked and not processed for any other purposes. This applies, for example, to user data that must be retained for commercial or tax law reasons.

16.2. In accordance with legal requirements, records must be retained for 6 years pursuant to Section 257(1) of the German Commercial Code (HGB) (commercial ledgers, inventories, opening balance sheets, annual financial statements, business correspondence, accounting documents, etc.) and for 10 years pursuant to Section 147(1) of the German Tax Code (AO) (books, records, management reports, accounting vouchers, business and commercial correspondence, documents relevant for taxation, etc.).

17. Right to Object

Users may object at any time to the future processing of their personal data in accordance with legal requirements. In particular, they may object to the processing of their personal data for direct marketing purposes.

18. Changes to the Privacy Policy

18.1. We reserve the right to amend the Privacy Policy to adapt it to changes in the legal landscape or to changes in the service and data processing. However, this applies only with respect to statements regarding data processing. If user consent is required, or if parts of the Privacy Policy contain provisions governing the contractual relationship with users, changes will be made only with the users’ consent.

18.2. Users are asked to review the contents of the Privacy Policy on a regular basis.

Scroll to Top