This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services as well as within our online offer and the websites, functions and content associated with it as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Responsible
Ambra Andrei
10245 Berlin
Types of data processed
- Inventory data (e.g., person master data, names or addresses).
- Contact data (e.g., email, phone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., web pages visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter, we also refer to the data subjects collectively as “users”).
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 upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data.
“Pseudonymization” means the processing of personal data in such a way 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, which ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
“Controller” means 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.
Purpose of the processing
- Making available the online offer, its functions and content.
- Responding to contact requests and communicating with users.
- Security measures.
- Reach measurement/marketing
Relevant legal basis
In accordance with Art. 13 DSGVO, we inform you of the legal basis for our data processing. For users from the area of application of the General Data Protection Regulation (DSGVO), i.e. the EU and the EEC, the following applies, unless the legal basis is stated in the privacy policy:
- The legal basis for obtaining consent 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 as well as answering inquiries is Art. 6 (1) lit. b DSGVO;
- The legal basis for processing to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO;
- In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.
- The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 (1) lit. e DSGVO.
- The legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f DSGVO.
- The processing of data for purposes other than those for which they were collected is determined in accordance with the requirements of Art. 6 (4) DSGVO.
- The processing of special categories of data (in accordance with Art. 9 (1) DSGVO) is determined in accordance with the requirements of Art. 9 (2) DSGVO.
Security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, deletion of data, and response to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.
Cooperation with processors, joint controllers and third parties
If, in the course of our processing, we disclose data to other persons and companies (order processors, jointly responsible persons or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract), users 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 disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis that complies with the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of the use of third-party services or disclosure, or transfer of data to other persons or companies, this will only occur if it is done 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 leave the data in a third country only if the legal requirements are met. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations.