Privacy policy

Responsible person:

Thorsten Seefried
Beethovenstr. 14
63939 Wörth am Main

+49 160 9961 0679
thorsten.seefried@essec.edu

Status: 02.03.2022

Basic information on data processing and legal basis
Types of data processed/categories of data subjects
Security measures
Transfer of data to third parties and third-party providers
Provision of contractual services
Contact us
Webhosting
Cookies & reach measurement
Google Analytics
Facebook social plugins
Reach analysis with Matomo
Newsletter
Integration of videos
Integration of third-party services and content
Rights of the data subject
Deletion of data
Right of objection
Changes to the privacy policy

1. basic information on data processing and legal bases

1.1. This privacy policy clarifies the nature, scope and purpose of the processing of personal data within our online offer and the associated websites, functions and content (hereinafter collectively referred to as “online offer” or “website”). The privacy policy applies regardless of the domains, systems, platforms and devices used (e.g. desktop or mobile) on which the online offer is executed.

1.2. The terms used, e.g. “personal data” or their “processing” refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

2. types of data processed/categories of data subjects

2.1. The personal data of users processed in the context of this online service includes

Inventory data (e.g. names and addresses of customers),
Contact details (e.g. e-mail, telephone numbers),
Communication data,
Contract data (e.g. services utilized, names of processors, payment information),
Usage data (e.g. the websites 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” includes all categories of data subjects affected by data processing. They include our business partners, customers, interested parties and other visitors to our online offering. 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 user data is only processed if legal permission has been granted, in particular if data processing is necessary for the provision of our contractual services (e.g. processing of orders) and online services, or is required by law, if the user has given consent, and on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation and security of our online offer within the meaning of Art. 6 para. 1 lit. f GDPR). 1 lit. f. GDPR, in particular when measuring reach, creating profiles for advertising and marketing purposes, collecting access data and using the services of third-party providers.

2.4. We would like to point out that the legal basis for consent is Art. 6 para. 1 lit. a. and Art. 7 GDPR, the legal basis for the processing for the fulfillment of our services and implementation of contractual measures Art. 6 para. 1 lit. b. GDPR, the legal basis for processing to fulfill our legal obligations Art. 6 para. 1 lit. c. GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f. GDPR is.

2.5. The following persons are affected by the data processing:

Contract and business partners,
Users of our online offer,
Interested parties who are interested in our online offer or contact us for other reasons and
Customers.

3. safety measures

We take appropriate organizational, contractual and technical security measures in accordance with Art 32 GDPR in accordance with the state of the art, taking into account the implementation costs and the nature, scope, circumstances and purposes of the data processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms in order to ensure an adequate level of protection of 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. The 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 the address bar of your browser begins with “https://”. This is a communication protocol with which data can be transmitted tap-proof as part of transport encryption.

4. transfer of data to third parties and third-party providers

4.1. Data will only be passed on to third parties within the framework of legal requirements. We only pass on user data to third parties if, for example, this is necessary to fulfill a contract. on the basis of Art. 6 para. 1 lit. b GDPR is required for contractual purposes or on the basis of legitimate interests pursuant to Art. Art. 6 para. 1 lit. f. GDPR for the economic and effective operation of our business.

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

4.3. If content, tools or other means described in this privacy policy are used by other providers (hereinafter collectively referred to as “third-party providers”), we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect 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 countries in which the third-party provider is based. Data is only transferred to third countries if there is an adequate level of data protection, user consent or other legal permission.

5. provision of contractual services

5.1. We process inventory data (e.g. names and addresses as well as contact data of users), contract data (e.g. services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit b. GDPR. We inform the contractual partners which data is required for the aforementioned purposes before or as part of the data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally. Within the framework of applicable law, we only pass this data on to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations or with your consent (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities).

5.2. We delete the data after the expiry of statutory warranty and comparable obligations, 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 reasons (e.g. for tax purposes, generally 10 years). We delete data disclosed to us by the contractual partner within the scope of a contractual relationship in accordance with the provisions of the contract, generally after fulfillment of the contractual services.

6. making contact

6.1. When contacting us (via contact form or e-mail), the user’s details are used to process the contact request and its handling in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit. b GDPR is processed. We only process the data that we need to process your request.

6.2. User data may be stored in our Customer Relationship Management System (“CRM System”) or comparable inquiry organization.

7. web hosting

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

7.2. We collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

7.3. Log file information is stored for a maximum of seven days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

7.4. The web hosting services also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders, but also other information on the sending of e-mails (e.g. the providers involved), including the content of the respective e-mails, are processed. Even though our e-mail communications are encrypted in transit, they are not encrypted on the servers from which they are sent and received. The content of e-mail communication is therefore fundamentally susceptible to manipulation.

8. cookies & reach 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 transferred from our web server or third-party web servers to the user’s web browser and stored there for later retrieval. Most browsers are set to accept cookies automatically. We would like to point out that the use of our website without cookies is only possible to a limited extent. In particular, the use of your customer account is generally not possible, as the use of cookies is technically necessary for this. However, you can also use your browser to prevent the setting of certain cookies (e.g. third-party cookies), for example if you want to prevent web tracking. You can find more information on this in the help function of your browser. Further information on third-party cookies that are set or processed when you visit our website can be found in the following privacy policy, insofar as we use them. The term “cookies” also includes other technologies that perform the same functions as 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-party providers (also known as “third-party cookies”). We only have technical control over the first-mentioned cookies. We also differentiate between the following cookies.
Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their browser.
Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users who are used for reach measurement or marketing purposes can also be stored in such a cookie.
Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user input or for security reasons).
Statistical, marketing and personalization cookies: Cookies are also generally used to measure reach and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example to show users content that matches their potential interests. This process is also referred to as “tracking”, i.e. tracking the potential interests of users. We will inform you separately about the use of “tracking” technologies in our privacy policy or when obtaining consent.

8.2. We use “session cookies”, which are only stored for the duration of the current visit to our online presence (e.g. to enable the storage of your login status or the shopping cart function and thus the use of our online offer at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our website and have logged out, for example. log out or close the browser.

8.3. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Saved cookies can be deleted in the system settings of the browser.

8.4. The legal basis on which we process your personal data with the help of 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 the processing of your data is your declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer 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 permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies (“opt-out”). You can first declare your opt-out using the settings of your browser by objecting to the setting of cookies in the system settings of your browser. An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. You can also receive further information on how to object in the context of the information on the service providers and cookies used.

Before we process or have data processed in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has not been given, cookies that are necessary for the operation of our online offer may be used. They are used on the basis of our interest and the interest of users in the expected functionality of our online offering. This includes usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses). Users of our online offer are affected by this processing. Processing is carried out on the legal basis of consent (Art. 6 para. 1 sentence 1 lit. a GDPR) or legitimate interests within the meaning of Art. 6 para. 1 sentence 1 lit. a GDPR). Art. 6 para. 1 p. 1 lit. f. GDPR.

9. google analytics

9.1. We use Google Analytics, a web analysis service of Google Ireland Limited Gordon House, Barrow Street Dublin 4, Ireland (“Google”) on the basis of your consent for the analysis, optimization and economic operation of our online offer. Google uses permanent third-party cookies. The resulting information is processed exclusively in our interest.

9.2. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.

9.3. We have agreed so-called standard contractual clauses with Google in order to be able to guarantee an appropriate level of data protection. Google thereby offers a guarantee of compliance with European data protection law.

9.4. 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 associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

9.5. We only use Google Analytics with activated IP anonymization. This means that the IP address of the user 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 transmitted to a Google server in the USA and shortened there.

9.6. The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

9.7. You can find further information on data use by Google, setting and objection options on the Google websites: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google 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 information that Google uses to show you advertising”).

10. facebook social plugins

10.1 On the basis of your consent, we use social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), in the interest of optimizing and economically operating our online offer. The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are recognizable by one of the Facebook logos or are marked with the addition “Facebook Social Plugin”.

10.2. When a user accesses a function of this online offering that contains such a plugin, a direct connection to the Facebook servers is only established when the user interacts with the plugins. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offering. User profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.

10.3. By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to their Facebook account. When users interact with the plugins, for example by clicking the Like button or leaving a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out and store their IP address. According to Facebook, only an anonymized IP address is stored in Germany.

10.4. The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as the related rights and setting options to protect the privacy of users can be found in Facebook’s data protection information: 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 via this online service and link it to their membership data stored on Facebook, they must log out of Facebook and delete their cookies before using our online service. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

11. reach analysis with Matomo

11.1. On the basis of your consent, we use Matomo, an open source software for the statistical evaluation of user access, to analyze, optimize and economically operate our online offer. The user’s IP address is shortened before it is saved. However, Matomo uses first party cookies, which are stored on the user’s computer and which enable an analysis of the use of this online offer by the user. Pseudonymous user profiles can be created from the processed data.

11.2. The information generated by the cookie about your use of this online offer is stored on our server and not passed on to third parties.

12th Newsletter

12.1. The following information explains the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

12.2. We only send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user’s consent. Our newsletters also contain information about our products, offers, promotions and our company.

12.3. Registration for our newsletter takes place in a so-called double opt-in procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that no one can log in with other people’s e-mail addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the shipping service provider are also logged.

12.4. The newsletter is sent by CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, hereinafter referred to as the “shipping service provider”. You can view the data protection provisions of the shipping service provider here: https://www.cleverreach.com/de/datenschutz/.

12.5. The newsletter is sent using “MailChimp”, a newsletter distribution platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the data protection provisions of the shipping service provider here: https://mailchimp.com/legal/privacy/. Standard contractual clauses have been agreed to ensure an appropriate level of data protection.

12.6. Furthermore, the shipping service provider may, according to its own information, use this data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the sending and presentation of the newsletter or for statistical purposes to determine from which countries the recipients come. However, the mailing service provider does not use the data of our newsletter recipients to write to them itself or pass it on to third parties.

12.7. Registration data: To subscribe to the newsletter, simply enter your e-mail address. Optionally, we ask you to enter a name so that we can address you personally in the newsletter.

12.8. The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the server of the mailing service provider when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the shipping service provider to monitor individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

12.9. The use of the shipping service provider, the performance of statistical surveys and analyses and the logging of the registration process are based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit. f GDPR. We are interested in using a user-friendly and secure newsletter system that serves both our business interests and the expectations of users.

12.10. You can unsubscribe from our newsletter at any time, i.e. revoke your consent. At the same time, your consent to its dispatch by the dispatch service provider and the statistical analyses will expire. A separate revocation of the dispatch by the dispatch service provider or the statistical evaluation is unfortunately not possible. You will find a link to unsubscribe from the newsletter at the end of each newsletter. If users have only registered for the newsletter and have canceled this registration, their personal data will be deleted.

13. integration of videos

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

13.2. By integrating the videos, the provider’s servers are called up. For the associated use of data, we refer to the respective data protection information of the provider. Vimeo’s privacy policy is available at the following link: https://vimeo.com/privacy.

13.3. The legal basis for the integration of the videos and the associated transmission of personal data for registered users of our website is Art. 6 para. 1 lit. b GDPR. The integration is necessary because there is currently no comparable video solution available to provide protected videos.

13.4. For non-registered users, the legal basis for the transfer of personal data is Art. 6 para. 1 lit f. GDPR.

13.5. In order to ensure an adequate level of data protection when transferring data to the USA, we have concluded the so-called standard contractual clauses with the provider of Vimeo. As a further protective measure, we always integrate videos in the “Do Not Track” variant, so that the amount of personal data transmitted is reduced to a minimum.

13.6. Alternatively, we can also use the service provider YouTube. Videos from the “YouTube” platform of the third-party provider Google. In this case, the video is integrated into our website, but is still 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 an opt-out can be found here: https://www.google.com/settings/ads/. With Google we have

14. integration of third-party services and content

14.1. We use within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO. GDPR) or on the basis of your consent (Art. 6 para. 1 lit. a GDPR), we use content or service offers from third-party providers in order to make their content and services, such as e.g. videos or fonts (hereinafter uniformly referred to as “content”). This is done to provide our online offer and to create a user-friendly online offer. This always presupposes that the third-party providers of this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in third-party cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offer, as well as being linked to such information from other sources.

14.2. The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, options for objection (so-called opt-out):

If our customers use third-party payment services (e.g. PayPal or Sofortüberweisung), the terms and conditions and data protection notices of the respective third-party providers apply, which can be accessed on the respective websites or transaction applications.
External fonts from Google Ireland, https://www.google.com/fonts (“Google Fonts”). Google Fonts are integrated by accessing a Google server (usually in the USA). Privacy policy: https://www.google.com/policies/privacy/. An opt-out: can be found here https://www.google.com/settings/ads/.
Maps from the “Google Maps” service of the third-party provider Google. The privacy policy is available here: https://www.google.com/policies/privacy/, You can find an opt-out option here: https://www.google.com/settings/ads/
Our online services use functions of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Each time one of our pages containing LinkedIn functions is accessed, a connection to LinkedIn servers is established. LinkedIn is informed that you have visited our website with your IP address. If you click on LinkedIn’s “Recommend button” and are logged into your LinkedIn account, LinkedIn is able to associate your visit to our website with you and your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by LinkedIn. The privacy policy is available here: https://www.linkedin.com/legal/privacy-policy and an opt-out is available here: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Functions of the Twitter service may be integrated into our online offering. These functions are offered by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland. By using Twitter and the “Re-Tweet” function, the websites you visit are linked to your Twitter account and made known to other users. Data is also transmitted to Twitter. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Twitter. Twitter’s privacy policy at http://twitter.com/privacy. You can change your data protection settings on Twitter in the account settings at http://twitter.com/account/settins.
We use functions of the XING network. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. Each time one of our pages containing Xing functions is accessed, a connection to Xing servers is established. As far as we are aware, no personal data is stored in the process. In particular, no IP addresses are stored or usage behavior evaluated. 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 vis-à-vis the controller:

15.1.
Auskunftsrecht
Sie können von dem Verantwortlichen eine Bestätigung darüber verlangen, ob personenbezogene Daten, die Sie betreffen, von uns verarbeitet werden.

If such processing has taken place, you can request the following information from the controller:

the purposes for which the personal data are processed;
the categories of personal data that are processed;
the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
the planned duration of storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the duration of storage;
the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
the existence of a right of appeal to a supervisory authority;
all available information on the origin of the data if the personal data are not collected from the data subject;
the existence of automated decision-making, including profiling, in accordance with Art. 22 para. 1 and 4 GDPR and – at least in these cases – meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you can request to be informed about the appropriate guarantees in accordance with Art. Art. 46 GDPR in connection with the transfer.

15.2.
Recht auf Berichtigung
Sie haben ein Recht auf Berichtigung und/oder Vervollständigung gegenüber dem Verantwortlichen, sofern die verarbeiteten personenbezogenen Daten, die Sie betreffen, unrichtig oder unvollständig sind. The controller must make the correction immediately.

15.3.
Recht auf Einschränkung der Verarbeitung
Unter den folgenden Voraussetzungen können Sie die Einschränkung der Verarbeitung der Sie betreffenden personenbezogenen Daten verlangen:

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;
the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims, or
if you object to the processing pursuant to Art. 21 para. 1 GDPR and it has not yet been established whether the legitimate reasons of the controller outweigh your reasons.

If the processing of personal data concerning you has been restricted, such data may only be processed – apart from being stored – with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of 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.

15.4.
Recht auf Löschung
a) Löschungspflicht
Sie können von dem Verantwortlichen verlangen, dass die Sie betreffenden personenbezogenen Daten unverzüglich gelöscht werden, und der Verantwortliche ist verpflichtet, diese Daten unverzüglich zu löschen, sofern einer der folgenden Gründe zutrifft:

The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
You revoke your consent on which the processing is based in accordance with. Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR and there is no other legal basis for the processing.
You create acc. Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 6(1) GDPR. Art. 21 para. 2 GDPR to object to the processing.
The personal data concerning you has been processed unlawfully.
The deletion of personal data concerning you is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.
The personal data concerning you have been collected in relation to the offer of information society services referred to in Art. 8 (1) GDPR. 1 GDPR collected.

b) Information to third parties
If the controller has made the personal data concerning you public and is obliged to do so in accordance with Art. Art. 17 para. Where the controller has made the personal data public and is obliged pursuant to Article 1 GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

c) Exceptions
The right to erasure does not exist if the processing is necessary

to exercise the right to freedom of expression and information;
for compliance with a legal obligation which requires processing by 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 Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;
for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Art. 6 para. 1 lit. a GDPR. Art. 89 para. 1 GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
for the assertion, exercise or defense of legal claims.

15.5.
Recht auf Unterrichtung
Haben Sie das Recht auf Berichtigung, Löschung oder Einschränkung der Verarbeitung gegenüber dem Verantwortlichen geltend gemacht, ist dieser verpflichtet, allen Empfängern, denen die Sie betreffenden personenbezogenen Daten offengelegt wurden, diese Berichtigung oder Löschung der Daten oder Einschränkung der Verarbeitung mitzuteilen, es sei denn, dies erweist sich als unmöglich oder ist mit einem unverhältnismäßigen Aufwand verbunden. You have the right to be informed about these recipients by the controller.

15.6.
Recht auf Datenübertragbarkeit
Sie haben das Recht, die Sie betreffenden personenbezogenen Daten, die Sie dem Verantwortlichen bereitgestellt haben, in einem strukturierten, gängigen und maschinenlesbaren Format zu erhalten. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where

the processing is based on consent pursuant to Art. Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. Art. 6 para. 1 lit. b GDPR is based and
the processing is carried out using automated procedures.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The freedoms and rights of other persons must not be impaired by this.

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.

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

The controller will no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

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

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

Notwithstanding Directive 2002/58/EC, you have the option of exercising your right to object in connection with the use of information society services by means of automated procedures using technical specifications.

15.8. 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 withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

15.9. Automated individual decision-making, 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

is necessary for the conclusion or performance of a contract between you and the controller,
is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

In the cases referred to in (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

15.10. Right to lodge a complaint with 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 habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with 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 pursuant to Art. 78 GDPR.

16. deletion of data

16.1. The data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. Deletion shall also take place in particular if other permissions cease to apply. If the user’s data is not deleted because it is required for other and legally permissible purposes, its processing is restricted, i.e. the data is blocked and not processed for other purposes. This applies, for example, to for user data that must be retained for commercial or tax law reasons.

16.2. According to legal requirements, the data is stored for 6 years in accordance with § 257 para. 1 HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).

17. right of objection

Users can object to the future processing of their personal data in accordance with the legal requirements at any time. The objection may be made in particular against processing for direct marketing purposes.

18. changes to the privacy policy

18.1. We reserve the right to amend the data protection declaration in order to adapt it to changed legal situations or in the event of changes to the service and data processing. However, this only applies with regard to declarations on data processing. If user consent is required or components of the privacy policy contain provisions of the contractual relationship with the users, the changes will only be made with the consent of the users.

18.2. Users are requested to inform themselves regularly about the content of the privacy policy.