3 General information on data processing
3.1 Scope of the processing of personal data
As a matter of principle, we process your personal data only insofar as this is necessary for the provision of a functional website as well as our contents and offered services, and regularly only after obtaining your consent. An exception applies in those cases where obtaining prior consent is not possible for actual reasons and the processing of the data is permitted by legal regulations.
3.2 Legal basis for the processing of personal data
The legal basis for consent for processing operations of personal data is Art. 6 para. 1 lit. a DSGVO.
In the case of processing of personal data which is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) (b) DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.
Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which our company is subject, Art. 6 (1) c DSGVO serves as the legal basis.
In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) (d) DSGVO serves as the legal basis.
If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 (1) lit. f DSGVO serves as the legal basis for the processing.
3.3 Data deletion and storage period
Your personal data will be deleted or blocked as soon as the purpose of the storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a necessity for the continued storage of the data for the conclusion or fulfilment of a contract.
4. provision of the website and creation of log files
4.1 Description and scope of data processing
Each time our website is accessed, our system automatically collects data and information from the computer system of the calling end device.
The following data is collected:
- IP address of the requesting computer (anonymised),
- Date and time of access,
- name and URL of the file accessed,
- website from which access was made (referrer URL),
- the browser used and, if applicable, the operating system of your computer as well as the name of your access provider.
This data is also stored in the log files of our system. This data is not stored together with other personal data.
4.2 Legal basis for data processing
The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f DSGVO.
4.3 Purpose of data processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to your computer. For this purpose, your IP address must remain stored for the duration of the session.
The storage in log files is done to ensure the functionality of our website. In addition, we use the data to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes or to draw conclusions about your person does not take place in this context.
These purposes are also our legitimate interest in data processing according to Art. 6 Para. 1 lit. f DSGVO.
4.4 Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
In the case of storage of data in log files, this is the case after 30 days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.
4.5 Possibility of objection and removal
The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. Consequently, the user has no possibility to object.
5 Contact form and e-mail contact
5.1 Description and scope of data processing
A contact form is available on our website, which can be used for electronic contact. If you make use of this option, both the contents of the mandatory fields and the optional contents are transmitted to us and stored.
For the processing of the data, your consent is obtained during the sending process and reference is made to this data protection declaration.
Alternatively, it is possible to contact us via the e-mail address provided. In this case, your personal data transmitted with the e-mail will be stored.
In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation.
5.2 Legal basis for data processing
The legal basis for the processing of data is Art. 6 para. 1 lit. a DSGVO if you have given your consent.
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f DSGVO. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO.
5.3 Purpose of the data processing
The processing of the personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.
5.4 Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with you has ended. The conversation is ended when the circumstances indicate that the matter in question has been conclusively clarified.
5.5 Possibility of objection and removal
You have the option to revoke your consent to the processing of personal data at any time. If you contact us by e-mail, you can object to the storage of your personal data at any time. In such a case, the conversation can no longer be continued.
You can declare to us the revocation of consent and the objection to storage via the e-mail address given in the imprint or by telephone via the telephone number given.
All personal data stored in the course of contacting us will be deleted in this case.
6. plugins and tools
6.1 WP Statistics
a) Description and scope of data processing
We use the WP Statistics tool on our website to statistically evaluate visitor access. The provider is Veronalabs, ARENCO Tower, 27th Floor, Dubai Media City, Dubai, Dubai 23816, UAE (https://veronalabs.com).
In doing so, we record, among other things
- IP address of the requesting computer (anonymised)
- Website from which the access is made (referrer URL)
- browser used
- search engine used
- actions of the visitors (e.g. clicks and views)
b) Legal basis for data processing
WP Statistics data is stored on the basis of Art. 6 (1) lit. f DSGVO.
c) Purpose of data processing
There is a legitimate interest in the anonymised analysis of user behaviour in order to constantly optimise the website for the visitor. In no case do we use the collected data for the purpose of drawing conclusions about your person.
d) Type and duration of storage
The data collected is stored exclusively locally on the web server until it is no longer used for the purposes listed. The data will not be passed on to third parties.
6.2 Wordfence Security
a) Description and scope of data processing
To secure our website, we use the “Wordfence Security” service, which is operated by Defiant Inc, 800 5th Ave, Suite 4100, Seattle, WA 98104, USA.
The website uses the service to protect against viruses and malware and to defend against attacks by computer criminals. For the purpose of protection against brute force and DDoS attacks or comment spam, IP addresses are stored on the Wordfence servers. IP addresses classified as harmless are placed on a white list.
b) Legal basis for data processing
The data collection is based on our legitimate interests as defined in Art. 6 (1) f) DSGVO.
c) Purpose of data processing
Wordfence Security secures our website and thus protects visitors to the website from viruses and malware. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO.
Further information on the collection and use of data by Wordfence Security can be found in Defiant’s data protection information: https://www.wordfence.com/privacy-policy/.
7. rights of the data subject
If personal data of yours is processed, you are a data subject within the meaning of the GDPR and you have the following rights against the controller:
7.1 Right of access
You may request confirmation from the controller as to whether personal data concerning you is being processed by us. If there is such processing, you may request information from the controller about the following:
- (1) the purposes for which the personal data are processed;
- (2) the categories of personal data which are processed;
- (3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
- (4) the envisaged duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
- (5) the existence of a right to obtain the rectification or erasure of personal data concerning you, a right to obtain the restriction of processing by the controller or a right to object to such processing;
- (6) the existence of a right of appeal to a supervisory authority;
- (7) any available information on the origin of the data, if the personal data are not collected from the data subject;
- (8) the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information on whether personal data concerning you are transferred to a third country or to an international organisation. In this context, you may request to be informed about the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer.
7.2 Right to rectification
You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you are inaccurate or incomplete. The controller must make the rectification without undue delay.
7.3 Right to restriction of processing
You may request the restriction of the processing of personal data concerning you under the following conditions:
- (1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
- (2) the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
- (3) the controller no longer needs the personal data for the purposes of the processing but you need it for the establishment, exercise or defence of legal claims; or
- (4) if you have objected to the processing pursuant to Article 21(1) DSGVO and it is not yet clear whether the controller’s legitimate grounds override your grounds.
Where the processing of personal data relating to you has been restricted, such data may only be processed – apart from being stored – with your 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 substantial public interest of the Union or a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
7.4 Right to erasure
a) Obligation to delete
You may request the controller to erase the personal data concerning you without undue delay and the controller is obliged to erase such data without undue delay if one of the following reasons applies:
- (1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
- (2) You revoke your consent on which the processing was based pursuant to Art. 6(1)(a) or Art. 9(2)(a) DSGVO and there is no other legal basis for the processing.
- (3) You object to the processing pursuant to Art. 21(1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21(2) DSGVO.
- (4) The personal data concerning you have been processed unlawfully.
- (5) The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
- (6) The personal data concerning you has been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.
b) Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers that process the personal data that you, as the data subject, have requested them to erase all links to, or copies or replications of, that personal data.
The right to erasure does not apply insofar as the processing is necessary to.
- (1) for the exercise of the right to freedom of expression and information;
- (2) for compliance with a legal obligation which 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;
- (3) 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;
- (4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, insofar as the right referred to in section (a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
- (5) for the assertion, exercise or defence of legal claims.
7.5 Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right to be informed of these recipients by the controller.
7.6 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, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data has been provided, provided that
- (1) the processing is based on consent pursuant to Art. 6 (1) lit. a DSGVO or Art. 9 (2) lit. a DSGVO or on a contract pursuant to Art. 6 (1) lit. b DSGVO and
- (2) the processing is carried out with the aid of automated procedures.
In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another controller, insofar as this is technically feasible. This must not affect the freedoms and rights of other persons.
The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7.7 Right of objection
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.
If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.
7.8 Right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
7.9 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 – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
- (1) is necessary for the conclusion or performance of a contract between you and the controller,
- (2) is permissible on the basis of legal provisions of the Union or the Member States to which the controller is subject and these legal provisions contain appropriate measures to safeguard your rights and freedoms as well as your legitimate interests; or
- (3) is made with your express consent.
However, these decisions must 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) of the GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.
With regard to the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person on the part of the controller, to express your point of view and to contest the decision.
7.10. Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.