61191 Rosbach vor der Höhe
Managing Directors: Gerd R. Vössing, Thorsten W. König
Link to the imprint: https://finma.de/en/imprint
Contact Data Protection Officer: firstname.lastname@example.org
Types of processed data
Categories of affected persons
Visitors and users of the online offer (hereinafter we refer to the affected persons as “users”).
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, which 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, are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person. “Processing” means any process performed with or without the aid of automated procedures, or any such process associated with personal data. The term covers a wide range and covers practically every handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject 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 not assigned to an identified or identifiable natural person. “Profiling” means 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 aspects relating to job performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts, or relocation of that natural person. ‘Responsible person’ means the natural or legal person, public authority, body or institution which, alone or in concert with others, decides on the purposes and means of processing personal data. “Processor” means a natural or legal person, public authority, body or institution that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 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), meaning the EU and the EEC, if the legal basis in the data protection declaration is not mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR; The legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 para. 1 lit. b GDPR; The legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c GDPR; In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as legal basis. The legal basis for the processing required to carry out a task in the public interest or in the exercise of official authority which has been delegated to the controller is Article 6 (1) lit. e GDPR. The legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR. The processing of data for purposes other than those for which they were collected is governed by the provisions of Article 6 (4) GDPR. The processing of special categories of data (pursuant to Art. 9 (1) GDPR) is governed by the provisions of Art. 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 disconnection. In addition, we have established procedures to ensure the enjoyment of data subject rights, the erasure of data and the response to data compromise. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings.
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 if this involves the use of third party services or disclosure or transmission of data to other persons or companies, this only occurs 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 express consent or contractually required transmission, we process or disclose the data only in third countries with a recognized level of privacy, including those certified under the Privacy Shield, or on the basis of specific warranties, such as limited liability. contractual obligation by so-called standard protection clauses of the European Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the European Commission).
Rights of data subjects
You have the right to ask for confirmation as to whether such data is being processed and for information about this data, as well as for further information and copy of the data in accordance with legal requirements. You have accordingly. the legal requirements to request the completion of the data concerning you or the correction of the incorrect data concerning you. In accordance with the legal requirements, they 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 statutory provisions. You have the right to request that the data relating to you provided to us be obtained in accordance with the statutory requirements and to request their transmission to other persons responsible. You also have the right, in accordance with the statutory provisions, to submit a complaint to the competent supervisory authority.
You have the right to revoke granted consent with effect for the future-
EU-Kommission (Art. 44 bis 49 DSGVO, Informationsseite der EU-Kommission).
Right of revocation
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 to direct mail
Cookies and right to object to direct mail “Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie serves primarily to sto re 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 are stored in an online shop or a login status.
The data processed by us will be deleted or restricted in accordance with legal requirements. Unless explicitly stated in this privacy statement, the data stored by us will be deleted as soon as they are no longer necessary for their intended purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legally permitted purposes, its processing will be restricted. That means, the data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.
In addition, we process
– contract data (e.g., 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 services, service and customer care, marketing, advertising and market research.
In addition, we process – contract data (e.g., 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 services, service and customer care, marketing, advertising and market research.
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. GDPR in order to provide you with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., Bank details, payment history).
In principle, we do not process special categories of personal data, unless they are part of a commissioned or contractual processing.
We process data that are necessary for the establishment and fulfillment of the contractual services and point out the necessity of their information, if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if required by a contract. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client and the legal requirements.
As part of the use of our online services, we can save the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of the user in the protection against misuse and other unauthorized use. A transfer of this data to third parties is not made, unless it is to pursue our claims acc. Art. 6 para. 1 lit. f. GDPR required or there is a legal obligation acc. Art. 6 para. 1 lit. c. GDPR.
The data is deleted if the data is no longer required for the fulfillment of contractual or legal duties of care and for handling any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; otherwise the statutory storage obligations apply
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks and organization of our business, financial ac counting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in processing lies in administration, financial accounting, office organization, data archiving, that is, tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors, and other fee agents and payment service providers. Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. We generally store this majority of company-related data permanently.
Business analysis and market research
In order to operate our business economically, to be able to recognize market tendencies, wishes of the contractors and users, we analyze the data available to us for business transactions, contracts, inquiries, etc. We process stock data, communication data, contract data, payment data, usage data, metadata on the basis of Art 6 para. 1 lit. f. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer. The analyzes are carried out for the purpose of business analysis, marketing and market research. In doing so, we can provide the profiles of the registered users with information, e.g. take into account their services. The analyzes serve us to increase the user-friendliness, the optimization of our offer and the business economy. The analyzes are for us alone and will not be disclosed externally unless they are anonymous and with aggregated values. If these analyzes or profiles are personal, they will be deleted or anonymized upon termination of the users, otherwise after two years from the conclusion of the contract. Incidentally, the overall business analyzes and general trend provisions are created anonymously if possible.
We process the applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. The processing of the applicant data takes place in order to fulfill our (pre-) contractual obligations in the context of the application process within the meaning of Art. 6 para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR if the data processing is e.g. is required for us in the context of legal proceedings (in Germany additionally § 26 BDSG applies).
The application process requires applicants to provide us with the applicant data. The necessary applicant data are, as far as we offer an online form marked, otherwise result from the job descriptions and basically include the information on the person, postal and contact addresses and the documents belonging to the application, such as cover letter, CV and the certificates. In addition, applicants can voluntarily provide us with additional information.
Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the context of the application process, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (for example health data, if necessary for the profession).
If provided, applicants can submit their applications via our online form on our website. The data will be encrypted and transmitted to us according to the state of the art.
When contacting us (for example, by contact form, e-mail, telephone or via social media), the information of the user is processed acc. Art. 6 para. 1 lit. b. (in the context of contractual / pre-contractual relationships), Art. 6 para. 1 lit. f. (other inquiries) GDPR processed. User information can be stored in a Customer Relationship Management System (“CRM System”) or comparable request organization system. We delete the requests, if they are no longer required. We check the requirement every two years; Furthermore, the legal archiving obligations apply.
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-mail delivery, security and technical maintenance services we use to operate this online service. Here 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 acc. Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of contract processing contract).
Collection of access data and log files
We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR Data on every access to the server on which this service is located (so-called server log files). The access data includes the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, notification of 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. Data whose further retention is required for evidential purposes are excluded from the erasure until the final clarification of the incident.
Google Tag Manager
Google Tag Manager is a solution that allows us to manage so-called web site tags through one interface (including integrating Google Analytics and other Google marketing services into our online offering). The tag manager itself (which implements the tags) does not process users’ personal data. With regard to the processing of users’ personal data, reference is made to the following information about the Google services. Usage Policy: https://www.google.com/analytics/tag-manager/use-policy/
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation
(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). 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 offering and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous user profiles of the processed data can be created.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the users is 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 their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
The personal data of users will be deleted or anonymized after 14 months.
Google Universal Analytics
We use Google Analytics as “universal analytics”. “Universal Analytics” means a process by Google Analytics, in which the user analysis is based on a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from the use of different devices (so-called “cross-device tracking”).
Google AdWords and conversion measurement
We use the services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4 on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online service within the meaning of Art. 6 (1) lit. GDPR) , Ireland, (“Google”). Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation
(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). We use Google’s online marketing method “AdWords” to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.) to show them to users who have a suspected interest in the ads. This allows us to better target advertisements for and within our online offering so that we only present ads to users that potentially match their interests. If a user e.g. receives ads for products he was looking for on other online offers, this is called remarketing. For these purposes, upon access to our and other websites where the Google Advertising Network is active, Google will immediately execute a code from Google and incorporate so-called (re) marketing tags (invisible graphics or code, also as ” Web beacons “) into the website. With their help, the user is provided with an individual cookie on the device. a small file is saved
(instead of cookies, comparable technologies can be used). In this file it will be noted, which web pages the user visited, what content he is interested in and what offers the user has clicked, as well as technical information about the browser and operating system, referring web pages, visit time and other information on the use of the online offer. Furthermore, we receive an individual “conversion cookie”. The information obtained through the cookie is used by Google to generate conversion statistics for us. However, we only hear about the anonymous total number of users who clicked on our ad and were redirected to a conversion tracking tag page. However, we do not receive information that personally identifies users. The data of the users are pseudonymly processed in the context of the Google advertising network. This means that Google stores and processes e.g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. From the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the United States.
Online presence in social media
We maintain online presence within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services. We point out that data of the users outside the area of the European Union can be processed. This may result in risks to users because, e.g. the enforcement of user rights could be made more difficult. With respect to US providers certified under the Privacy Shield, we point out that they are committed to respecting EU privacy standards. Furthermore, the data of the users are usually processed for market research and advertising purposes. Thus, e.g. user profiles are created from the user behavior and the resulting interests of the users. The usage profiles may in turn be used to e.g. place advertisements inside and outside the platforms that are allegedly in line with users’
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 meaning of Art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to provide their content and services, such as videos or fonts (collectively referred to as “content”). This always presupposes that the third-party providers of this content perceive 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 only 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, time of visit, and other information regarding the use of our online offer.
Short Codes: To give users a better experience, they can use the shortcodes listed here. These shortcodes allow you to change certain behaviors of the site.– allows a user to disable google tracking in his or her browser
– allows a user to disable the use of google webfonts in his or her browser
– allows a user to disable the use of google maps in his or her browser
– allows a user to disable video embeds in his or her browser