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This privacy policy informs you about the type, scope, and purpose of the processing of personal data (hereinafter referred to as “Data”) within our online offering and the associated websites, functions, content, and external online presences, such as our social media profiles (hereinafter collectively referred to as “Online Offering”). Regarding the terminology used, such as “processing” or “controller,” we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Controller
CTR Löbtauer GmbH
Ostra-Allee 13 D-01067 Dresden
Email: sales@ctrgroup.de
Types of processed data:
Categories of data subjects
Visitors and users of the online offering (Hereinafter, we also refer to the data subjects collectively as “Users”).
Purpose of processing
Terminology used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.
“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. Unless the legal basis is stated in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR, the legal basis for processing for the performance of our services and implementation of contractual measures as well as responding to inquiries is Art. 6(1)(b) GDPR, the legal basis for processing to comply with our legal obligations is Art. 6(1)(c) GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6(1)(f) GDPR. If vital interests of the data subject or another natural person require processing of personal data, Art. 6(1)(d) GDPR serves as the legal basis.
Security measures
In accordance with Art. 32 GDPR, we take appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons. The measures include ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, assurance of availability and separation thereof. Furthermore, we have established procedures that ensure the exercise of data subject rights, deletion of data, and responses to data threats. Furthermore, we already consider the protection of personal data during the development and selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default (Art. 25 GDPR).
Cooperation with Processors and Third Parties
If we disclose data to other persons and companies (processors or third parties) within the scope of our processing, transmit it to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e.g., if a transfer of data to third parties, such as payment service providers, is necessary for the performance of the contract pursuant to Art. 6 (1) (b) GDPR), you have consented, a legal obligation provides for this, or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.).
If we commission third parties to process data based on a so-called “data processing agreement”, this is done on the basis of Art. 28 GDPR.
Transfers to Third Countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this will only occur if it is necessary for the fulfillment of our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the data to be processed in a third country only if the special conditions of Art. 44 et seq. GDPR are met. This means the processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
Storage Duration
Unless a more specific storage period has been specified within this privacy policy, your personal data will remain with us until the purpose for the processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods). However, this data will also be deleted once these reasons no longer apply.
Rights of Data Subjects
You have the right to request confirmation as to whether data in question is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with Art. 15 GDPR.
You have the right, in accordance with Art. 16 GDPR, to request the completion of the data concerning you or the rectification of incorrect data concerning you.
You have the right, in accordance with Art. 17 GDPR, to demand that relevant data be erased immediately, or, alternatively, to demand a restriction on the processing of the data in accordance with Art. 18 GDPR.
You have the right to request that the data concerning you, which you have provided for us, be received in accordance with Art. 20 GDPR and to demand its transmission to other controllers.
You have the right to receive information free of charge about the purpose, origin, and recipient of your stored personal data.
You also have the right, pursuant to Art. 77 GDPR, to lodge a complaint with the competent supervisory authority (Saxon Data Protection and Transparency Commissioner).
Right of Revocation
You have the right to revoke any consent given pursuant to Art. 7 (3) GDPR with effect for the future. The lawfulness of the processing carried out based on consent until its revocation remains unaffected.
Right to Object
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection may be made in particular against processing for direct marketing purposes pursuant to Art. 21 (2) GDPR.
Cookies and Right to Object to Direct Marketing
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit within an online offering. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes their browser. For example, the contents of a shopping cart in an online shop or a login status can be stored in such a cookie. “Permanent” or “persistent” cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. Likewise, user interests can be stored in such a cookie, which are used for range measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online offering (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and provide information on this in our privacy policy.
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 from the system settings of the browser. The exclusion of cookies can lead to functional restrictions on this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by disabling them in the browser settings. Please note that in this case, not all functions of this online offering may be available.
Deletion of Data
The data processed by us will be deleted or its processing restricted in accordance with Articles 17 and 18 GDPR. Unless explicitly stated within this privacy policy, 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. If the data is not deleted because it is necessary for other and legally permissible purposes, its processing will be restricted. That is, the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
According to legal requirements in Germany, storage is carried out in particular for 10 years in accordance with §§ 147 (1) AO, 257 (1) nos. 1 and 4, (4) HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and for 6 years in accordance with § 257 (1) nos. 2 and 3, (4) HGB (commercial letters).
According to legal requirements in Austria, storage is carried out in particular for 7 years according to § 132 (1) BAO (accounting documents, receipts/invoices, accounts, vouchers, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
External Payment Service Providers
We use external payment service providers, through whose platforms users and we can conduct payment transactions (e.g., each with a link to the privacy policy, Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html)
Within the framework of fulfilling contracts, we use the payment service providers based on Art. 6 (1) (b) GDPR. Otherwise, we use external payment service providers based on our legitimate interests pursuant to Art. 6 (1) (f) GDPR to offer our users effective and secure payment options.
The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. For this purpose, we refer to the terms and conditions and data protection information of the payment service providers.
The terms and conditions and data protection notices of the respective payment service providers apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to these for further information and assertion of revocation, information and other data subject rights.
Administration, Financial Accounting, Office Organization, Contact Management
We process data as part of administrative tasks and the organization of our business, financial accounting, and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process while providing our contractual services. The processing bases are Art. 6 (1) (c) GDPR, Art. 6 (1) (f) GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving data, i.e., tasks that serve to maintain our business activities, perform our duties and provide our services. The deletion of data regarding contractual services and contractual communication corresponds to the information mentioned in these processing activities.
We disclose or transmit data to the tax authorities, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers.
Furthermore, based on our business interests, we store information on suppliers, organizers and other business partners, e.g., for the purpose of contacting them later. We generally store this predominantly company-related data permanently.
Business Analyses and Market Research
In order to operate our business economically, to identify market trends, and the wishes of contractual partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata based on Art. 6 (1) (f) GDPR, whereby the persons affected include contractual partners, interested parties, customers, visitors and users of our online offering.
The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may consider the profiles of registered users with information, e.g., on the services they have used. The analysis serves us to increase user-friendliness, optimize our offer and business efficiency. The analyses are for our use only and are not disclosed externally unless they are anonymous analyses with summarized values.
If these analyses or profiles are personal, they are deleted or anonymized upon termination of the user, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyses and general trend determinations are created anonymously wherever possible.
Contacting Us
When contacting us (e.g., via contact form, email, telephone, or via social media), the user’s details are processed for the purpose of handling the contact request and its execution pursuant to Art. 6 (1) (b) GDPR. The user’s details may be stored in a Customer Relationship Management System (“CRM System”) or comparable inquiry organization.
We delete the requests if they are no longer necessary. We review the necessity every two years; furthermore, the legal archiving obligations apply.
Hosting and Email Dispatch
This website is hosted by an external service provider. The personal data collected on this website is stored on the host’s servers. The hosting services we use are used to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services and technical maintenance services that we use for the purpose of operating this online offering.
In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering pursuant to Art. 6 (1) (f) GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).
We use the following hoster:
WEDOS Internet, a.s.
Masarykova 1230
373 41 Hluboká nad Vltavou
Czech republic
Company ID: 28115708
VATIN: CZ28115708
Data box ID: dc6iqnh
https://www.wedos.com/contacts
Collection of Access Data and Log Files
We, or our hosting provider, collect data based on our legitimate interests within the meaning of Art. 6 (1) (f) GDPR on every access to the server on which this service is located (so-called server log files). The access data includes the name of the 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.
Log file information is stored for a maximum of 7 days for security reasons (e.g., to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
If you have given your consent in accordance with Art. 6 (1) (a) GDPR, we use Google Analytics – a web analytics service provided by Google Ireland Limited (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in Ireland and stored there.
Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering, and to provide us with other services related to the use of this online offering and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
We use Google Analytics only with IP anonymization enabled. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in Ireland and shortened there.
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 as well as the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
Further information on Google’s use of data, settings and objection options can be found in Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
The personal data of users will be deleted or anonymized after 14 months. As an alternative to the browser plugin, you can prevent the collection by Google Analytics on this website by clicking on the following link when you first visit our site. An opt-out cookie will be set on your device. If you delete your cookies, you will be asked to give your consent again.
Google AdWords and Conversion Measurement
If you have given your consent in accordance with Art. 6 (1) (a) GDPR, we use the services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, (“Google”).
We use the online marketing method Google “AdWords” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our online offering in a more targeted manner to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she was interested on other online offers, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google advertising network is active are called up, a code from Google is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e., a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user has visited, which content he is interested in and which offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, visit time and other information on the use of the online offer.
Furthermore, we receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a conversion tracking tag. We do not receive any information that can be used to personally identify users.
The users’ data is processed pseudonymously within the Google advertising network. That is, Google does not store and process, for example, the name or email address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. This means that from Google’s perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in Ireland.
Further information on Google’s use of data, settings and objection options can be found in Google’s privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Online Presence in Social Media
We maintain online presences within social networks and platforms to communicate with the customers, prospects and users active there and to inform them about our services there. When calling up the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process users’ data if they communicate with us within the social networks and platforms, e.g., write posts on our online presences or send us messages.
Integration of Third-Party Services and Content
Within our online offering, we use content or service offerings from third-party providers on the basis of our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 (1) (f) GDPR) in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “Content”).
This always requires that the third-party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore necessary for the display of this content. We endeavor to use only content whose respective providers use the IP address solely 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 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 offering, as well as be linked to such information from other sources.
Youtube
We integrate the videos of the platform “YouTube” of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google Fonts
We integrate the fonts (“Google Fonts”) of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google Maps
We integrate the maps of the service “Google Maps” of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually as part of the settings of their mobile devices). The data may be processed in Ireland. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Created with datenschutz-generator.de by Lawyer Dr. Thomas Schwenke
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