Thank you for your interest in our web presence and the services we offer on our web pages.
Protecting your personal data (hereinafter referred to as ‘data’) is of great importance to us. We would therefore like to take this opportunity to inform you in detail about the data that is collected when you visit our website and use the offers featured there and how we subsequently process or use this data, as well as the accompanying protective technical and organisational measures we have taken with regard to this data.
2. Data controller/service provider
The controller as defined by Art. 4 GDPR and service provider within the meaning of the German Telemedia Act (TMG) is easySoft. GmbH, Konrad-Zuse-Weg 2, 72555 Metzingen, Germany, tel.+49 7252 5833 0, fax +49 7252 5833 199, email email@example.com.
The controller is represented by the Managing Directors
Andreas Nau, Wilfried Hahn and Friedhelm Seiler, who are jointly responsible according to Section 55 of the Interstate Media Services Agreement.
The Data Protection Officer is
RA Ulrich Emmert, e/s/b Rechtsanwälte, Schockenried Straße 8a, 70565 Stuttgart, tel.: 07114 690580, fax: 07114 69058 99, email: firstname.lastname@example.org
3. Collection and use of your data
We only collect, process and use all personal data you disclose while using our web pages for the purpose stated. We take care to ensure that this is done in accordance with the applicable legal provisions or only with your consent.
Please contact email@example.com or send us your request by post.
Unless you are informed subsequently or directly at the time of data collection about a transfer to third countries, stating the respective legal basis, and, if required, if your consent is requested for this, the data is only processed within the EU and the European Economic Area. The provisions regarding the legal basis for international data transfer and the necessary prerequisites for this are available from us on request.
We make automated individual decisions on the processing of personal data according to the following criteria: none
The extent and type of collection and use of your data differs depending on whether you visit our website only to retrieve information or make use of services offered by us:
a) Informational use
If you use our website for informational purposes only, it is not necessary for you to provide personal data.
Rather, in this case we only collect and use that personal data which your internet browser automatically transmits, such as
date and time of the retrieval of one of our web pages
your browser type
the browser settings
the operating system used
the page you last visited
the amount of data transferred and the access status (file transferred, file not found etc.) as well as
your IP address.
The data is also stored in our system’s log files. This data is not stored together with any other personal data of the user.
The legal basis for the temporary storage of data and log files is Art. 6(1)(f) GDPR.
Temporary storage of the IP address in the system is necessary to enable delivery of the website to the user’s computer. To this end, the user’s IP address must remain stored for the duration of the session.
The storage of data in log files serves to ensure the functionality of the website. The data is also used to optimise the website and to ensure the security of our information technology systems. The data is not evaluated for marketing purposes in this context.
The data is deleted once it is no longer needed to fulfil the purpose for which it was collected. If data is collected to aid provision of the website, this is then carried out when the relevant session has ended.
If the data is stored in log files, this is carried out after seven days at the latest. It is possible that data may be stored beyond this time. In this case, the users’ IP addresses are deleted or distorted to ensure that assignment to the retrieving client is no longer possible.
The collection of data to provide the website and the storage of data in log files are essential for operation of the website. Accordingly, the user has no option to object.
b) Use of offers
If you wish to make use of the services we offer on our website or after contacting us in any other way, it may be necessary for you to provide further data. This data is required for processing in accordance with Art. 6(1)(b) GDPR, otherwise we cannot provide the requested service. Further offers may be listed in Appendix 2.
You can enter additional information voluntarily; we mark entry fields with optional input accordingly.
Your data is collected or used for the purpose of providing the service you have requested. This includes, for example, requests via our contact form.
If the provision of data is required by law, we will inform you accordingly.
If necessary, your data will be passed on to service providers who support us for the aforementioned purpose, and whom we have of course carefully selected and obliged to observe the EU General Data Protection Regulation.
Otherwise, your data will only be passed on to other third parties if this is permitted by law or if we have received your explicit consent.
4. Consent under data protection law
To process your data, we may require your consent to the processing of your data in accordance with Art. 6(1)(a) GDPR. We assure you that we will only process and use the data for the purpose stated at the time of collection.
You may give your consent separately for each individual collection of data. You may subsequently revoke this at any time with future effect.
Consent with regard to newsletters is based on Section 5; for cookies or advertising trackers consent is based on the following Section 6 of this Policy.
To subscribe to our email newsletter service, in addition to your data protection consent pursuant to Art. 6(1)(a) GDPR, we require at least your email address to which the newsletter is to be sent. Any further information is optional and will be used to address you personally and to personalize the content of the newsletter as well as to clarify questions about your email address. We only use this data for the purpose of sending the newsletter.
We generally use a double opt-in procedure for newsletter dispatch, i.e. we will only send you the newsletter if you have confirmed your registration via a link contained in a confirmation email sent to you for this purpose. This is intended to ensure that only you can subscribe to the newsletter as the owner of the email address provided. Your confirmation must be sent as soon as possible after receiving the confirmation email, otherwise your newsletter subscription will be automatically deleted from our database.
If you purchase goods or services from us and enter your email address, we may subsequently use it to send you newsletters. In such a case, only direct advertising for similar goods or services will be sent via the newsletter. The legal basis for the dispatch of the newsletter as a result of the sale of goods or services is Section 7(3) of the German Act Against Unfair Competition (UWG).
You can unsubscribe from one of your newsletters at any time. You can either send us an informal email to firstname.lastname@example.org or cancel your subscription using the link at the bottom of the newsletter.
Analysis cookies or web beacons (small graphics for log evaluation) are used to help improve the quality of our website and its contents as well as to recognise repeat visitors. Analysis cookies help us to learn how the website is used, which enables us to consistently improve our offers.
This information may be passed on to advertising partners under the above conditions. The forwarded data may not be merged with any other data concerning you that may be stored.
This information may also be passed on by advertising partners to their contractual partners under the above conditions. The forwarded data may not be merged with any other data concerning you that may be stored.
The advertising partners or the companies to which the advertising information is forwarded may also be located in countries outside the European Union or the European Economic Area (in compliance with the data transfer requirements of the GDPR pursuant to Art. 44-47, standard contractual clauses of the EU and/or, in the case of the US, the EU-US Privacy Shield)
You can determine whether cookies can be set and retrieved yourself via the settings in your browser. For example, you can completely deactivate the storage of cookies in your browser, restrict it to certain websites or configure your browser so that you are automatically notified as soon as a cookie is about to be set and your feedback is requested. You can also delete cookies from your browser at any time. For our website to function fully, however, it is necessary for technical reasons to allow the session cookies mentioned above.
When using a login area on the homepage, the account name and the correctness of the password entry are logged and a session cookie is transmitted to the user, which is deleted upon logout or expiry of the maximum session duration (within a few hours).
If we allow a login service via an external provider to log in to a protected area, this will be indicated to the user. In this case, the information specified by the provider by default or by the user in the login provider’s settings will be transferred to us, comprising at least the name, email address and date of birth in order to fulfil the obligations required in Art. 8 and 32 GDPR.
7. Right to object
Pursuant to Art. 21 GDPR, you may object to the processing of your data in the cases specified therein, in particular in cases of processing based on Art. 6(1)(e) or Art. 6(1)(f) or in the form of direct advertising or profiling.
8. Data security
We also use technical and organisational security measures to protect any incurred or collected personal data, in particular against accidental or intentional manipulation, loss, destruction or attack by unauthorised persons. We continuously improve our security measures in line with technological developments.
We provide you with various online forms and services which you can use to send personal data to us. These forms are protected against third-party access through the use of TLS encryption. We may store and, following prior agreement, process the data that you enter or transmit to us as a file. If the use and processing requires the consent of the user or third parties, this consent can be revoked at any time without giving reasons. In this case, however, we may be impaired with regard to fulfilment of the contract.
Depending on the service, you may be asked to enter various pieces information to identify or prevent misuse:
(a) The input of a user-defined identifier or other appropriate authentication may be required for identification at the time of delivery of data. The data is protected via SFTP or HTTPS against third-party access in accordance with Art. 32(1)(a) and (b) GDPR, provided that the user makes use of the methods of data transfer recommended by us.
b) To prevent machine intervention, CAPTCHAS may be used in accordance with Art. 32(1)(b) GDPR; these contain images or tasks that cannot be processed by computer scripts.
9. Deletion periods
We store only personal data until the purpose of the data storage no longer applies. This is not the case if the user has voluntarily consented to processing of the data for a longer period or if statutory retention periods or the possible pursuit of legal claims within limitation periods that have not yet expired conflict with the deletion of the data (in the case of conflicting retention or limitation periods, it may be necessary to restrict the processing of the data in accordance with Art. 18 GDPR).
10. Rights of data subjects
Under the applicable laws, you have various rights with respect to your personal data. If you wish to exercise these rights, please send your enquiry by email or by post to the address stated in (2), clearly identifying yourself.
You will find an overview of your rights below.
a) Right to confirmation and information
the purposes of processing;
the categories of personal data being processed;
the recipients or categories of recipients to whom the personal data has been disclosed or is yet to be disclosed, in particular to recipients in third countries or to international organisations;
if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration;
the existence of a right to rectification or deletion of the data subject’s personal data, or to limitation of processing by the controller, or to of a right to objection to such processing;
the existence of the right to appeal to a supervisory authority;
if the personal data is not collected from you, all available information about the origin of the data;
the existence of automated decision-making including profiling in accordance with Article 22 (1) and (4) GDPR and, at least in these cases, meaningful data about the involved logic, scope and intended impact of such processing on you.
Where personal data is transferred to a third country or to an international organisation, you have the right to be informed of the appropriate safeguards in relation to the transfer pursuant to Art. 46 GDPR.
b) Right to rectification
You have the right to request us to immediately rectify any incorrect personal data concerning you. Taking into account the purposes of processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary statement.
c) Right to deletion (“right to be forgotten”)
You have the right to request that we delete any personal information concerning you immediately, and we are obligated to delete any personal information immediately if any of the following reasons apply:
The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
You revoke your consent, upon which the processing was based under the provisions of Article 6(1)(a) GDPR or Article 9(2)(a) GDPR and no other legal basis for the processing exists.
You submit an objection to the processing pursuant to Art. 21(1) GDPR, and there are no legitimate reasons for the processing, or you object to the processing pursuant to Art. 21(2) GDPR.
The personal data was processed unlawfully.
The deletion of personal data is necessary to fulfil a legal obligation under Union or national law to which we are subject.
The personal data was collected in relation to information society services pursuant to Art. 8(1) GDPR.
The right to deletion does not exist if the processing is necessary
1. for the exercise of freedom of expression and information;
2. to fulfil a legal obligation which requires the processing under the law of the Union or of the Member States to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
3. for reasons of public interest in the field of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) GDPR;
4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89(1) GDPR in so far as the right referred to in paragraph a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
5. for the assertion, exercise or defence of legal claims.
Where we have made your personal data public and are obliged to delete it pursuant to Art. 17(1) GDPR, we, taking account of available technology and the cost of implementation, must take reasonable steps, including technical measures, to inform other controllers that process that personal data of your request for such controllers to delete any links to, or any copy or replications of this personal data.
d) Right to restriction of processing
You have the right to request us to restrict processing if one of the following conditions applies:
you contest the accuracy of the personal data, for a period of time that enables us to verify the accuracy of the personal data.
the processing is unlawful and you refused to delete the personal data and instead requested the restriction of the use of the personal data;
we no longer require the personal data for the purposes of processing, but you require the data to assert, exercise or defend legal claims; or
you have lodged an objection against the processing pursuant to Art. 21(1) GDPR, unless it has been established that our company’s legitimate reasons outweigh yours.
Where, with the exception of its storage, the processing of your personal data has been restricted, such data may not be processed without your consent or for the purpose of asserting, exercising or defending legal claims or protecting the legal claims of another natural or legal person or for reasons of an important public interest of the Union or of a Member State.
e) Right to data portability
You have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format, and you have the right to transfer such data to another controller without interference by us, provided that
the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR, and
the processing is carried out using automated procedures.
Furthermore, in exercising your right to data portability under (1), you have the right to ensure that the personal data is transferred directly from one controller to another if technically feasible.
The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
f) Right to object
You have the right to object, on grounds relating to your particular situation, at any time to to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. We will no longer process your personal data unless we can establish compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or unless the processing is for the purposes of asserting, exercising or defending legal claims.
Where personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of you personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.
You have the right, for reasons arising from your particular situation, to object to the processing of your personal data for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) GDPR, unless such processing is necessary to fulfil a task carried out in the public interest.
g) Automated decisions including profiling
You have the right not to be subject to any decision based solely on automated processing, including profiling, that has any legal effect on you or significantly affects you in a similar way.
h) Right to revoke consent given in accordance with data protection law
You have the right to revoke your consent to the processing of personal data at any time.
i) Right to complain to a supervisory authority
You have the right to complain to a supervisory authority, in particular in the Member State where you reside, where your place of work is based or where the alleged infringement took place, if you consider that the processing of your personal data is unlawful.
j) Right of rectification
If you have exercised your right of rectification, deletion of restriction of the processing of your personal data vis-à-vis the controller, the latter is obliged to notify all recipients to whom the personal data concerning you has been disclosed of such rectification, deletion or restriction, unless this proves impossible or involves a disproportionate effort.
You have the right vis-à-vis the controller to be informed of such recipients.
We may use the services of third parties who transfer information in accordance with (6) above. We use the following services on the homepage:
Statistical tools Log data analysis services
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Social media tools Services for interaction with social networks
If a login has been made to the relevant network, the social network provider may be able to identify the user if they retrieve a page or click on a social media button.
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