Privacy Policy

Responsible Authority

Isabella von Hobe
Grimnitzstrasse 17C
10318 Berlin
Phone: +49 (0) 30 55 57 37 46
E-mail: moc.lufituaeberasedoclla@asi

Privacy legacy officer

Isabella von Hobe
E-mail: moc.lufituaeberasedoclla@asi
Phone: +49 (0) 30 55 57 37 46

General Information

Pursuant to our statutory obligations, we would like to inform you about the collection and use of your personal data. When you use our website, personal data about you will be collected. This may happen by you entering the data yourself, for example your e-mail address. But our system also collects your data automatically, for example whenever you visit our website. This happens irrespective of the device or the software that you use to visit our website. All data that you enter in our app is provided voluntarily; there are no disadvantages to you if you do not provide data. But without certain data, we are unable to provide services or to conclude contracts. Whenever such information is necessary, we will point it out to you. On this website, the user’s personal data is only collected within the framework of the existing data-protection law, in particular the General Data Protection Regulation (GDPR). The legal terms used in the text are defined in Art. 4 of the GDPR. The GDPR allows data processing in three cases in particular:

  • in accordance with Art. 6 para. 1 (a) and 7 GDPR, when you have consented to us processing your data; in this Privacy Policy and in the cases of consent pursuant to Art. 4 no. 11 GDPR, we will inform you in detail and each time for what purposes and under what circumstances your data will be processed by us;
  • in accordance with Art. 6 para. 1 (b) GDPR, when processing your personal data is necessary for negotiating, concluding or performing a contract;
  • in accordance with Art. 6 para. 1 (f) GDPR, if the balancing of interests leads to the conclusion that the processing is necessary to protect our legitimate interests; this means in particular our interests to analyse, optimise and secure the offers on our website – meaning primarily the analysis of user behaviour, setting up profiles for advertisement purposes and storage of access data as well as the use of third-party providers.

Inventory Data

We collect inventory data as far as it is necessary to establish, negotiate or amend a contract (including one without remuneration) between us and the user. This can be: customer data (for example name, address), contact data (for example e-mail address, phone number), service data (for example services ordered, duration, payment). Upon establishing the user relationship, we will ask you for this data (for example name, address and e-mail address) and will also tell you which of the information is required to establish the user relationship.

Usage Data

We also collect usage data to allow users to use the services on our website. These may consist of: usage information (for example visited websites or parts, duration of visit, interest in services), content data (for example data, text, images, sounds, videos entered or uploaded by you), meta data (for example identity of your device, location, IP address). We will only combine usage data if and insofar as it is necessary for billing purposes. Otherwise, we will only put together usage data pseudonymously and only insofar as you have not objected. You may send this objection to the address indicated in the “About Us” section or the responsible authority indicated in this Privacy Policy at any time. The legal basis for this data processing are our legitimate interests pursuant to Art. 6 para. 1 (f) GDPR in analysing the website and your use, possibly also the statutory permission to store data as part of the negotiation of a contract pursuant to Art. 6 para. 1 (b) GDPR. Furthermore, our provider stores information, the so-called server log files, each time the website is used; this is information which is automatically transferred by your browser. In detail, this data consists of:

  • your IP address
  • type and version of your browser
  • host name
  • time of visit
  • the page from which you came to our page
  • name of the page opened
  • exact time of usage as well as
  • the amount of data transferred

This data will only be used for statistical purposes and do not allow us to identify you as a user.

First Contact through Electronic Request

If you contact us in electronic form (for example by mail, fax, phone, messenger, etc.), we store and process the data which you have given us (for example name, contact information, content of the request). This is based on our legitimate interest in an effective communication with customers in accordance with Article 6 para. 1 (a) GDPR and, as far as it concerns a request to enter into or to perform a contract, also with Article 6 para. 1 (b) GDPR.
We will only pass on this data to third parties as far as required for the performance of the contract (in accordance with Article 6 para. 1 (b) GDPR), by the overwhelming interest in effective services (in accordance with Article 6 para. 1 (f) GDPR) or based on your consent (in accordance with Article 6 para. 1 (a) GDPR) or if there is another legal permission or obligation.
You may ask us at any time and without any cost to provide information about the purpose of the processing, the origin and the recipient, if any, of your data. You may also request that we correct, delete or limit the processing of your personal data. You may object against the (further) processing of your data at any time and you have a right for the data to be made transferable as well as the right to file a complaint with the competent supervisory agency.
In general, your data will only remain stored as long as required by the purpose of the respective data processing. A longer storage is an option, in particular when required in order to pursue our rights, for other legitimate interests of ours or when there is a statutory duty to keep the data longer (for example record-keeping under tax law, statute of limitations).

Consent

Whenever we ask you for your consent for the processing of your data, we will inform you in clear language and in an easily accessible way about the cases for which you will be granting your consent. Any consent that we ask you for is voluntary. Any advantage that you wish to gain by granting consent is also available without consent; simply ask us.

Regarding any consent, you have the right to revoke any consent given to us for the processing of your personal data at any time. You just need to contact us without any particular formal requirement, for example through our contact form, an e-mail to the e-mail address indicated in the “About Us” section or a link to unsubscribe (if offered by us). Your withdrawal has no effect on the legality of the data processing carried out up to that point.

Storage Period

Generally, your data will only remain stored as long as required by the purpose of the respective data processing. Storage beyond that is possible in particular if it is still required for pursuing our rights or for other legitimate interests of ours.
For your inventory data which were necessary to perform a contract (including one without remuneration), this means that we store this data until the complete performance or termination of the contractual relationship plus the limitation period (which is generally 2 or 3 years) plus an adequate extra time for potential interruptions of the limitation period.
For your usage data which was collected in the course of your use of the website, this means that we will store it only for the time still required for the proper functionality of our website and as long as we still have a legitimate interest. Statistical information will be primarily stored by us in pseudonymous form.
Beyond that, we still store your data for as long as we are required to do so by law. This concerns in particular the tax-law requirements to keep records, usually for 6 or even 10 years.

Users‘ Rights

You may request us anytime to provide information about the personal data stored about you free of charge. To avoid misuse, this will require personal identification.

Deletion, Correction, Limitation

You may at any time demand from us that we correct (or complete) incorrect data as well as a limitation of the processing of data or deletion of your data. This applies in particular if the reason for processing the data is no longer valid, if a required consent has been revoked and there is no other legal basis or if our data processing is unlawful. We will then correct, block or even delete your personal data without delay as far as permitted by law.

Objection

The right to object to advertisement is governed by our text regarding consent:

Data Transfer

You may request us to transfer the data stored about you in machine-readable form.

Complaint

If you feel that our data processing has violated any of your rights, you may file a complaint with the competent regulatory agency (here you find a list of the agencies).

Changes to the Privacy Policy

If and when factual or legal reasons will compel us to amend the Privacy Policy, we will update this page accordingly. This will not change the consent provided by the user.

Data Entry

Encryption of Data Entry

When you enter data on our website, whether in a contact form, during the registration process, when you log in or for payment purposes, the website, where you enter the data, is encrypted. Thus, third parties can not read what you enter. You will recognise the encryption by the lock symbol in your browser and by the URL beginning with “https“ instead of “http“.

Contact Forms

General contact form

When you fill out a contact form or when you send us an e-mail or another electronic message, your information will be stored for the processing of the request, for possible follow-up questions or for other related questions and will only be used to follow up with the request.

Your data will be transferred in an encrypted manner, preventing third parties from reading your data while it is being entered.

Basis for this storage is your consent pursuant to Art. 6 para. 1 (a) GDPR, which you grant us by filling in the contact form or by your other requests. You may revoke this consent at any time, you just need to contact us without any particular formal requirement (for example in the contact form or by e-mail). This withdrawal has no effect on the legality of the data processing that has occurred up to that point.

Your data remains stored for as long as the processing of the request requires, in particular as long as the storage is still necessary to perform the contract, to pursue our rights or for our other legitimate interests or we are compelled by law to keep your data stored (for example based on tax-law requirements to maintain files).

Offer

On our website, you find a contact form, through which you may request a specific offer for our goods and services. We will ask for for the necessary data as in the form, so we can prepare the offer.
Your data will be entered in an encrypted manner, so that third parties cannot read your data while being entered.
The legal basis for this storage is our legitimate interest in communication with interested users in accordance with Art. 6 para. 1 (f) GDPR and in case of contractual requests also the storage of contractual data in accordance with Art. 6 para. 1 (b) GDPR.
These data remain saved until you will terminate your access by sending an e-mail to the e-mail address listed in the “About Us” section. After that, they will remain stored in connection with the necessary performance of the contract (see the section on user/contract data).

Return Call

On our service page, you can ask for a call from one of our customer service agents.
We will ask for
– your first name, because we like to address your personally,
– your phone number, so we can call you, and
– your e-mail address, because we will e-mail you to confirm your request.

Your data will be entered in an encrypted manner, so that third parties cannot read your data while being entered.

The legal basis for this storage is our legitimate interest in communication with interested users in accordance with Art. 6 para. 1 (f) GDPR and in case of contractual requests also the storage of contractual data in accordance with Art. 6 para. 1 (b) GDPR.

We will only use this data for your specific request and will save it for 6 months after the request has been completed, so we can refer to the results already achieved in the case of subsequent service requests.

Social Media

We refer with links to our social media presences. When you follow any such link to the social media site, your data will be broadcasted to that site. The social media site will normally store a cookie in your browser and to your account information there, especially, if you are logged into your social media account on the site. The social media site can analyse your use of the platform and your browsing habits and will use these for targeting advertisements based on your interests. That can lead to ads being shown to you when browsing in- and outside of the social media site. Please inform yourself about the use of your data on these sites and use them only, when you agree to that use of your data, that happens on that social media site, in particular, when you are not using that social media site for the first time. We have added links to all the privacy policies of the social media site for your information.

Our website uses links to our presence in the social network of Facebook by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland. It is just a normal link. Thus, when you open our site, Facebook will not learn of your visit to our website. But once you click on the link, you will be led to Facebook, allowing Facebook to learn that you have visited out site.
Your data will be forwarded by Facebook Ireland on the base of the standard contractual clauses to Facebook USA.
The collection and use of your data which is possibly carried out by Facebook after clicking on the link is beyond our knowledge or control. You may find further information in Facebook’s privacy policy at https://en-gb.facebook.com/policy.php.

Our page uses links to our presence on the social network LinkedIn, provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, as a subsidiary of LinkedIn Corporation, 2029 Stierlin Ct. Ste. 200 Mountain View, CA 94043, USA.

It is just a normal link, which means that upon opening our page, LinkedIn won’t learn anything of your visit to our website. But when you click on the link, you will be taken to LinkedIn, and then LinkedIn will also learn that you visited our page.

Thus, your data may be forwarded to the USA.

We have neither knowledge of, nor any influence on the possible collection and processing of your data by LinkedIn after clicking on the link. Further information can be found in LinkedIn’s privacy policy at https://www.LinkedIn.com/legal/privacy-policy?_l=de_DE.

Videoconferences, Webinare and Onlinemeetings

Skype

We use external communication providers (external providers or platforms for our video conferences, audio conferences, webinars or other online meetings and online communication), in this case the provider Skype, the Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA. This is based either
- on our contractual or pre-contractual legal relationship in accordance with Art. 6 para. 1 (b) GDPR,
- on your consent if we have obtained that before (for example for a recording) in accordance with Art. 6 para. 1 (a) GDPR or
- on our legitimate interest in a technologically perfect online offering and its design and optimisation in an economically efficient manner pursuant to Art. 6 para. 1 (f) GDPR.
Each time you use our external communication provider, any data that you enter, indicate or show during the communication (in particular contractual data like name and e-mail, usage data like the browse used, visited websites, duration of the visit, referrer URL and your IP address, content data like audio and video communication and/or recordings, chat protocols, shared screen content) will be transmitted to the external communication provider and stored by them. We use settings that guarantee as much privacy as possible, and you can be careful about your privacy as well. For example, you can register with alias names or with one-time e-mail addresses or (partially) deactivate your transfer of audio and video.
This means that your data will be transmitted to the USA. We have concluded a data processing agreement with the external communication provider, according to which they will only process your data in accordance with our instructions.
Your data will remain stored as long as necessary for the purposes of your consent, for performing the contract, to pursue our legal rights or for other legitimate interests of ours or as long as we are required by law to keep your information.
Neither we nor the external communication provider will pass on your data to third parties. Exceptions may be made for analysing the user date for service and security purposes as well as for marketing purposes of the external communication provider. Regarding the further processing of your data by the external communication provider, we refer you to the provider’s privacy policy.
https://privacy.microsoft.com/de-de/privacystatement
and the corresponding additional security information
https://www.microsoft.com/de-de/trust-center.
If the external communication providers place cookies or other trackers on your computer, we refer you to our general information about dealing with cookies and deactivating them in this privacy policy.

Zoom

We use external communication providers (external providers or platforms for our video conferences, audio conferences, webinars or other online meetings and online communication), in this case the provider ZOOM Video Communications Inc., San Jose Office, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. This is based either
- on our contractual or pre-contractual legal relationship in accordance with Art. 6 para. 1 (b) GDPR,
- on your consent if we have obtained that before (for example for a recording) in accordance with Art. 6 para. 1 (a) GDPR or
- on our legitimate interest in a technologically perfect online offering and its design and optimisation in an economically efficient manner pursuant to Art. 6 para. 1 (f) GDPR.
Each time you use our external communication provider, any data that you enter, indicate or show during the communication (in particular contractual data like name and e-mail, usage data like the browse used, visited websites, duration of the visit, referrer URL and your IP address, content data like audio and video communication and/or recordings, chat protocols, shared screen content) will be transmitted to the external communication provider and stored by them. We use settings that guarantee as much privacy as possible, and you can be careful about your privacy as well. For example, you can register with alias names or with one-time e-mail addresses or (partially) deactivate your transfer of audio and video.
This means that your data will be transmitted to the USA. We have a contract according to the EU standard contractual clauses with our external communication provider, in which he guarantees to protect your data in compliance with the GDPR. Additionally we have concluded a data processing agreement with the external communication provider, according to which they will only process your data in accordance with our instructions.
Your data will remain stored as long as necessary for the purposes of your consent, for performing the contract, to pursue our legal rights or for other legitimate interests of ours or as long as we are required by law to keep your information.
Neither we nor the external communication provider will pass on your data to third parties. Exceptions may be made for analysing the user date for service and security purposes as well as for marketing purposes of the external communication provider. For the further use of your data by the external communication provider, we refer you to their terms and conditions https://zoom.us/terms and the associated privacy policy https://zoom.us/privacy
Insofar as external communication providers store cookies or other trackers on your device, we refer you to our general information about dealing with cookies and deactivating them in this privacy policy.

Our Social Media Fan Page(s) - General Information

Beside our website, we also use fan page(s) on social media platforms. Above, we have already informed you about the data processing on our website and we have in particular made sure that the fact alone that you access our website is not yet forwarded to the social media platform. Following the ECJ ruling dated 5 June 2018 about social media presences, we want to inform you about the data processing during your visit to our social media fan page(s):

On the basis of our legitimate interest in a timely customer communication pursuant to Art. 6 para. 1 (f) GDPR as well as for advertising and public relations purposes, we present ourselves and our offers on social media fan page(s).

Our social media fan page(s) usually can be accessed online independently of you having a user account with the relevant platform or not. But in either case, your data will be processed by the social media platform.

Each time the social media platform is accessed, your IP address will be collected and stored. Usually, a cookie will also be placed on your page, which will save your visit and further data about your visit to the social media platform.

If you are logged in with the social media platform, your visit will also be spotted by a cookie or through other technological means and will be attributed to your user account. Thus, the social media platform is usually able to analyse your user behaviour. In this process, a user profile with your interests is generated, which the social media platform will use to provide you with a user experience tailored to your interests, in particular advertisement tailored to your interests within and outside of the social media platform – even across different devices, if applicable. Your data may also be used for market research. For the details, we refer you to the following privacy policies of the social media platform(s) used by us.

We can usually also use the data of the social media platform in order to allow you to use our fan page in accordance with your interests or to approach you with advertising.

When you interact with our fan page and if you are logged in with the relevant social media platform, according to the social media page’s terms of use, we can usually also recognise your user profile and see your content.
If you do not want this, we point you to our explanations about cookies above, with general information about cookies and their deactivation. There, we have laid out in general terms how you can prevent or limit cookies being stored on your devices. Further information about the respective social media platform can be found hereinafter.

According to the aforementioned ECJ ruling dated 5 June 2018, we are always jointly responsible for our social media fan page(s) together with the relevant social media platform. This means that you may also exercise your general rights, which we have listed in detail above under the heading “Users’ Rights”, against us. To that purpose, we refer you to our contact details at the beginning of this Privacy Policy. Please keep in mind, though, that we have no conclusive knowledge of the exact scope of the processing of your data by the social media platform and have even less influence on it. Therefore, we kindly ask you to contact the relevant social media platform in the first place regarding your rights.

We generally leave your data on the social media platform and do not import it onto our server. But if that should occur, our general information regarding the storage period will apply.

Further information about the processing of your data and the storage period on the social media platform can be found in the respective privacy policy of the social media platform, which we have listed hereinafter.

Facebook

We present ourselves on the social media platform Facebook.

Joint Responsibility
Facebook Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour
Dublin 2 Ireland
Contact
Contact Data Protection Officer

If you open our fan page on Facebook, your data will be forwarded to the USA.

Facebook has concluded an agreement with us https://www.facebook.com/legal/controller_addendum about our shared responsibility for processing the data, in which it recognises its primary responsibility and guarantees in particular that you can exercise your right to information, as described in the general part. You may obtain more information from Facebook’s privacy policy at: https://www.facebook.com/about/privacy. Your data will be forwarded by Facebook Ireland on the base of the standard contractual clauses to Facebook USA.

Facebook also provides us with statistics as part of “Facebook Insights” for the purpose of targeted advertising. These are created without our participation and then provided to us. The data include information like interaction with our page, such as likes, page activities, video views, reach of our posts, comments, sharing of content, clicks on offers or further information on our fan page as well as statistical data about those interacting, such as gender, origin by country, city and language. The same applies to groups which we may manage.

When you are logged in, you can influence the processing of your data by Facebook considerably and in different ways.

Here you can make changes to your timeline, i.e. what can be seen about you and your page.

And you can change your advertisement preferences here.

LinkedIn

We have a presence on the social media platform LinkedIn.

Jointly Responsible
LinkedIn Ireland Limited Company,
Wilton Place,
Dublin 2,
Ireland

Contact

If you open our profile on LinkedIn, your data may be forwarded to the USA.

We have neither knowledge of, nor any influence on the possible collection and processing of your data by LinkedIn. Further information can be found in LinkedIn’s privacy policy at
https://www.LinkedIn.com/legal/privacy-policy.

LinkedIn also provides us with statistics. These are created without our participation and then provided to us. The data will include interactions, for example, as well as statistical data.

When you are logged in, you can influence the processing of your data by LinkedIn considerably and in different ways.

For your privacy settings with LinkedIn, LinkedIn refers you to several options that you can read about in their privacy policy.

The LinkedIn advertising cookie can be turned off here (opt-out):
https://www.LinkedIn.com/psettings/guest-controls/retargeting-opt-out

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This is our current valid privacy policy from 12.04.2021