Privacy

Person responsible:

Waldherr-Interim e.U.

Ing. Ronald Josef Waldherr BSc.

Weilandgasse 16 Top 13
A-1210 Vienna

+43 676 7 569 568

ronald@waldherr-interim.com
www.waldherr-interim.com

Status: 02.03.2022

Content

Basic information on data processing and legal basis
Types of data processed / categories of data subjects
Security measures
Disclosure of data to third parties and third-party providers
Provision of contractual services
Contact
Web hosting
Cookies & Reach Measurement
Google Analytics
Facebook Social Plugins
Reach analysis with Matomo
Newsletter
Video integration
Integration of third-party services and content
Rights of the data subject
Data deletion
Right of objection
Changes to the privacy policy

1. basic information on data processing and legal basis

1.1. This data protection declaration informs you about the type, scope and purpose of the processing of personal data within our online offer and the websites, functions and content connected to it (hereinafter jointly 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 terminology used, such as e.g. “personal data” or its “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 within the framework of this online offer include:

Inventory data (e.g. names and addresses of customers),
Contact information (e.g., email, phone numbers),
Communication data,
Contractual data (e.g. services used, names of clerks, 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” includes all categories of data subjects. 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 provisions. This means that user data will only be processed with legal permission, in particular if the data processing is necessary for the provision of our contractual services (e.g. processing of orders) and online services, or is required by law, or if the user has given his consent, as well as 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 Article 6 para. 1 lit. f. DSGVO, in particular when measuring reach, creating profiles for advertising and marketing purposes, and collecting access data and using third-party services.

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

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

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

3. security measures

We take appropriate organizational, contractual and technical security measures in the sense of Art 32. DSGVO according to 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 varying likelihood and severity of the risk to the rights and freedoms, in order to ensure an adequate 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 against 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 starts with “https://”. This is a communication protocol with which data can be transmitted in a tap-proof manner as part of transport encryption.

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

4.1. Data is only passed on to third parties within the framework of legal requirements. We only pass on the user’s data to third parties if this is necessary, for example. on the basis of Art. 6 para. 1 lit. b DSGVO is necessary for contractual purposes or on the basis of legitimate interests according to. Art. 6 par. 1 lit. f. DSGVO in 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. Insofar as content, tools or other means described within the scope of this data protection declaration are used by other providers (hereinafter collectively referred to as “third-party providers”), we comply with the legal requirements and, in particular, conclude corresponding contracts or agreements that serve 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 must be assumed that data is transferred to the countries in which the third-party provider is based. The transfer of data to third countries only takes place if there is an adequate level of data protection, user consent or otherwise 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 the German Data Protection Act. Art. 6 par. 1 lit b. DSGVO. We inform the contractual partners which data are required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person. Within the framework of applicable law, we only disclose this data 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 legal 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 specifications of the contract, in principle after fulfillment of the contractual services.

6. contact

6.1. When contacting us (via contact form or e-mail), the information provided by the user will be used to process the contact request and its handling in accordance with the German Data Protection Act. Art. 6 par. 1 lit. b DSGVO processed. Here, we only process the data that we need to process your request.

6.2. User information 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 offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer 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 each 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 security reasons (e.g. for the clarification of abuse or fraud) for a maximum of seven days and then deleted. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.

7.4. The web hosting services also include sending, receiving as well as storing e-mails. For these purposes, the addresses of the recipients and senders, but also further information on the e-mail dispatch (e.g. the providers involved), including contents of the respective e-mails are processed. Even though our email communications have transport path encryption, 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 transmitted from our web server or third-party web servers to users’ web browsers, where they are stored for later retrieval. Most browsers are set to accept cookies automatically. We would like to point out that the use of our online offer 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 mandatory for this. However, you can also use your browser to prevent only certain cookies from being set (e.g. cookies from third-party providers), for example if you want to prevent web tracking. For more information, see the help function of your browser. For more information about third-party cookies that are set or processed when you visit our website, please see the privacy policy below, if we make use of 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 former cookies. We further differentiate between the following cookies.
Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, login status can be saved or preferred content can be displayed directly when the user revisits a website. Likewise, the interests of users used for reach measurement or marketing purposes may be stored in such a cookie.
Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user inputs or for security reasons).
Statistics, marketing and personalization cookies: Furthermore, cookies are generally also used in the context of range measurement and when a user’s interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles serve e.g. to show users content that matches their potential interests. This process is also called “tracking”, i.e., following the potential interests of users. We will inform you separately about the use of “tracking” technologies in our privacy policy or in the context of 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). In a session cookie, a randomly generated unique identification number is stored, a so-called session ID. In addition, a cookie 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 online offer and have logged in, 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 disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser.

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 the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies is 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 any consent given or to object to the processing of your data by cookie technologies (“opt-out”). You can initially declare your opt-out by means of your browser settings 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 may also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further instructions on how to object within the scope of the information on the service providers and cookies used.

Before we process or have data processed within the scope of the use of cookies, we ask users for consent that can be revoked at any time. Before the consent has not been expressed, cookies are used at most, which are necessary for the operation of our online offer. Their use is based on 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. The processing is carried out on the legal basis of consent (Art. 6 para. 1 p. 1 lit. a DSGVO) or legitimate interests iSd. Art. 6 par. 1 p. 1 lit. f. GDPR.

9. google analytics

9.1. We use Google Analytics, a web analytics service provided by Google Ireland Limited Gordon House, Barrow Street Dublin 4. Ireland (“Google”), based on 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 on 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 for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.

9.5. We use Google Analytics only with IP anonymization enabled. 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 is the full IP address 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 data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

9.7. For more information about Google’s data use, settings and opt-out options, please visit Google’s 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 Google uses to serve you ads”).

10. Facebook Social Plugins

10.1 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”), based on your consent in the interest of optimizing and economically operating our online offer. The plugins can represent 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 calls up a function of this online offer that contains such a plugin, a direct connection to Facebook’s 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 by the user into the online offer. In the process, usage profiles of the users 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 into Facebook, Facebook can assign the visit to his Facebook account. When users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to obtain and store his or her 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 settings options for protecting the privacy of users, can be found in the privacy policy of Facebook: https://www.facebook.com/about/privacy/.

10.5. If a user is a Facebook member and does not want Facebook to collect data about him or her via this online offering and link it to his or her membership data stored with Facebook, he or she must log out of Facebook and delete his or her cookies before using our online offering. 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 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 for statistical evaluation of user access, for the analysis, optimization and economic operation of our online offer. The IP address of the users is shortened before it is stored. 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. In doing so, pseudonymous usage profiles of the users 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.

12. newsletter

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

12.2. We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the course of registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our products, offers, promotions and our company.

12.3. The registration for our newsletter takes place in a so-called double opt-in process. I.e. after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can log in with foreign e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the subscription process in accordance with legal requirements. This includes the storage of the login and confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider are logged.

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

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

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

12.7. Registration data: To register for the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to enter a name for the purpose of personal address 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 dispatch service provider when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the 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. Statistical surveys also include determining whether 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, as well as logging of the registration process, are carried out on the basis of our legitimate interests in accordance with the German Data Protection Act. Art. 6 par. 1 lit. f GDPR. Our interest is directed towards the use of a user-friendly as well as secure newsletter system that serves our business interests as well as meets the expectations of the users.

12.10. You can cancel the receipt of our newsletter at any time, i.e. revoke your consents. 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 cancel the newsletter at the end of each newsletter. If users have only subscribed to the newsletter and cancelled this subscription, their personal data will be deleted.

13. integration of videos

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

13.2. The integration of the videos results in a call to the provider’s servers. 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 is for registered users of our offer 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 transmission of personal data is Art. 6 para. 1 lit f. DSGVO.

13.5. In order to ensure an appropriate 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 include 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 of the platform “YouTube” of the third party provider Google. Here, the video is embedded in our website, but still hosted on the platform of Youtube. When the video is played, a connection with YouTube is established. 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 services and contents of third parties

14.1. Within our online offer, we use content or service offers of third party providers 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) or on the basis of your consent (Art. 6 para. 1 lit. a DSGVO). DSGVO) or on the basis of your consent (Art. 6 para. 1 lit. a DSGVO), we use content or services offered by third party providers in order to provide 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 assumes that the third-party providers of this content are aware of the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known 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 third-party cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be combined with such information from other sources.

14.2. The following presentation provides an overview of third-party providers and their content, along with links to their privacy statements, which contain further information on the processing of data and, in part already mentioned here, opt-out options:

If our customers use the payment services of third parties (e.g. PayPal or Sofortüberweisung), the terms and conditions and the privacy policy of the respective third party providers apply, which are available within the respective websites or transaction applications.
External fonts from Google Ireland., https://www.google.com/fonts (“Google Fonts”). The integration of Google Fonts is done by a server call at Google (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 of the service “Google Maps” of the third party provider Google. The privacy policy is available here: https://www.google.com/policies/privacy/, An opt-out option can be found here: https://www.google.com/settings/ads/
Our online offer uses functions of the network LinkedIn. 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 web pages with your IP address. If you click on the “Recommend Button”” of LinkedIn and are logged into your account at LinkedIn, it is possible for LinkedIn to assign your visit to our website to you and your user account. We would like to point out that we, as the provider of the pages, 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.
Within our online offer, functions of the service Twitter can be integrated. 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 transferred to Twitter in the process. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Twitter. Twitter privacy policy at http://twitter.com/privacy. You can change your Twitter privacy settings in your 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. Right to information
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 can request information from the controller about the following:

the purposes for which the personal data are processed;
the categories of personal data which 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 the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage duration;
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;
any 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 pursuant to Art. 22 para. 1 and 4 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 is 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 a right to rectification and/or completion vis-à-vis the data controller, insofar as the personal data processed concerning you are inaccurate or incomplete. The responsible party shall make the correction without undue delay.

15.3. Right to restriction of processing
Under the following conditions, you may request the restriction of the processing of personal data concerning you:

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 object to the erasure of the personal data and request instead the restriction of the use of the personal data;
the controller no longer needs the personal data for the purposes of processing, but you need them for the assertion, exercise or defense of legal claims, or
if you object to the processing pursuant to Art. 21 para. 1 DSGVO and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.

Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of their storage, only 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 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. Right to deletion
a) Obligation to delete
You may request the controller to delete the personal data concerning you without undue delay, and the controller is obliged to delete such data without undue delay, if one of the following reasons applies:

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 according to. Art. 6 par. 1 lit. a or Art. 9 para. 2 lit. a GDPR and there is no other legal basis for the processing.
They lay out acc. Art. 21 par. 1 DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. Art. 21 par. 2 DSGVO to object to the processing.
The personal data concerning you have been processed unlawfully.
The deletion 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.
The personal data concerning you has been processed in relation to information society services offered pursuant to Art. 8 para. 1 DSGVO collected.

b) Information to third parties
If the controller has made the personal data concerning you public and is responsible pursuant to. Art. 17 par. 1 DSGVO to erase them, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers processing the personal data that you, as data subject, have requested erasure of all links to or copies or replications of such personal data.

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

to exercise the right to freedom of expression and information;
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;
for reasons of public interest in the field 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. 89 par. 1 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
for the assertion, exercise or defense of legal claims.

15.5. Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify 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 about these recipients by the data controller.

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, common 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. Art. 6 par. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to. Art. 6 par. 1 lit. b DSGVO is based and
the processing is carried out with the help of automated procedures.

In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to 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 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 Art. 6 para. 1 lit. 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 for the establishment, exercise or defense of legal claims.

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

If you object to 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.

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 revocation of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

15.9. Automated decision 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

is necessary for the conclusion or fulfillment of a contract between you and the responsible party,
is permitted by legislation of the Union or the Member States to which the controller is subject and that legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests, or
is done with your express consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 DSGVO, unless Art. 9 para. 2 lit. a or g applies and appropriate measures have been taken to protect the 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 of, and the legitimate interests of, the data subject, which shall include, at least, the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.

15.10. 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, workplace 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.

16. deletion of data

16.1. The data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. Deletion shall also take place, in particular, if other permissible circumstances cease to apply. If the users’ 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 e.g. for user data that must be retained for commercial or tax law reasons.

16.2. According to legal requirements, the storage takes place for 6 years in accordance with § 257 para. 1 HGB (commercial books, inventories, opening balances, 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 may object to the future processing of their personal data in accordance with the legal requirements at any time. The objection can be made in particular against processing for purposes of direct advertising.

18. changes to the privacy policy

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