Privacy Policy Website

ZREALITY GmbH

We are pleased about your visit to our website and your interest in our company.

In the following, we inform you about the processing of personal data in connection with the services we offer at www.zreality.com, zrealitysphere.com or other websites or apps (hereinafter collectively referred to as “platforms”) that incorporate this privacy policy. Personal data is any information relating to an identified or identifiable natural person (Art. 4 No. 1 DSGVO). This includes information such as your name, e-mail address, postal address or telephone number. Information that is not directly associated with your identity, such as the number of users of an Internet site, does not fall under this category.

We collect and use your personal data exclusively within the framework of the legal data protection regulations. These are, for example, the provisions of the Basic Data Protection Regulation (DSGVO, from 25 May 2018) and the Federal Data Protection Act (BDSG). Our employees and agents are obliged to comply with the provisions of data protection law. In the following we inform you about the type, scope and purpose of the collection and use of personal data as well as your rights. You can access this information at any time on our website.

  1. Responsible body in terms of § 13 para. 1 TMG / § 3 para. 7 BDSG

Responsible office in terms of data protection law is:
ZREALITY GmbH
Zollamtstraße 11
67663 Kaiserslautern
GERMANY

E-Mail: info@zreality.com
Tel: +49 (0) 631 – 34 35 96 80
Fax: +49 (0) 631 – 34 35 96 89

Legal representatives:
Managing Director Michael Neidhöfer, Jan Knieriemen

  1. Name and address of the data protection officer

PROLIANCE GmbH
www.datenschutzexperte.de
Leopoldstr. 21
80802 München

datenschutzbeauftragter@datenschutzexperte.de

III. general information on data processing

  1. scope of the processing of personal data

As a matter of principle, we process personal data of our users only to the extent necessary to provide a functional website and our contents and services. The processing of personal data of our users is regularly only carried out with the consent of the user. An exception is made in cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by law.

  1. legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for processing of personal data, Art. 6 para. 1 lit. a EU Data Protection Basic Regulation (DSGVO) serves as the legal basis.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b DSGVO serves as the legal basis. This also applies to processing operations which are necessary to carry out pre-contractual measures.
Insofar as processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Art. 6 para. 1 lit. c DSGVO serves as the legal basis.
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO serves as the legal basis.
If the processing is necessary to safeguard a legitimate interest of our company or of a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 lit. f DSGVO serves as the legal basis for the processing.

  1. data deletion and storage duration

The personal data of the person concerned will be deleted or blocked as soon as the purpose of the storage no longer applies. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU ordinances, laws or other regulations to which the person responsible is subject. Data will also be blocked or deleted when a storage period prescribed by the above-mentioned standards expires, unless there is a need to continue storing the data for the purpose of concluding or fulfilling a contract.

  1. Provision of the website and creation of log files
  2. description and scope of data processing

Whenever our website is called up, our system automatically collects data and information from the computer system of the calling computer.

The following data is collected:

(1) Information about the browser type and version used
(2) The user’s operating system
(3) The user’s IP address
(4) Date and time of access
(5) Websites from which the user’s system accesses our website. The
data is also stored in the log files of our system. This data is not stored together with other personal data of the user.

  1. legal basis for data processing

The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f DSGVO.

  1. purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.

The storage in log files is done to ensure the functionality of the website. In addition, the data serves us to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes also include our legitimate interest in data processing in accordance with Art. 6 para. 1 lit. f DSGVO.

  1. duration of storage

The data will be deleted as soon as they are no longer necessary for the purpose of their collection. In the case of the collection of data for the provision of the website, this is the case when the respective session is ended.

In the case of data storage in log files, this is the case after seven days at the latest. A storage beyond that is possible. In this case the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.

  1. possibility of objection and removal

The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. There is therefore no possibility of objection on the part of the user.

  1. Use of cookies
  2. description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. If a user calls up a website, a cookie can be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.
The following data is stored and transmitted in the cookies:
(1) Identification token to recognize registered users
(2) Items in a shopping cart
(3) Language settings

We also use cookies on our website, which enable an analysis of the surfing behaviour of the users.
In this way the following data can be transmitted:
A list of the collected data follows. This information may include, for example:
(1) search terms entered
(2) frequency of page views
(3) use of website functions
(4) recognition of users

When calling up our website, the user is informed about the use of cookies for analysis purposes and his consent to the processing of the personal data used in this context is obtained. In this context, reference is also made to this data protection declaration.

  1. legal basis for data processing

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f DSGVO.
The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 lit. a DSGVO if the user has given his consent to this.

  1. purpose of data processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these it is necessary that the browser is recognized even after a page change.
We require cookies for the following applications:
(1) Recognition of registered users
(2) Adoption of language settings
(3) Remembering search terms

The user data collected through technically necessary cookies is not used to create user profiles.

The analysis cookies are used to improve the quality of our website and its contents. The analysis cookies enable us to find out how the website is used and thus to continuously optimize our offer.
For these purposes, our legitimate interest lies in the processing of personal data in accordance with Art. 6 para. 1 lit. f DSGVO.

  1. duration of storage and possibility of objection and removal

Cookies are stored on the user’s computer and transmitted by the user to our site. Therefore you as a user have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Already stored cookies can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it is possible that not all functions of the website can be used to their full extent.

  1. registration
  2. description and scope of data processing

On our website we offer users the possibility to register by providing personal data. The data is entered into an input mask, transmitted to us and stored. The data will not be passed on to third parties. The following data is collected during the registration process:

(1) Email address
(2) First name
(3) Last name

At the time of registration, the following data is also stored:

(1) Internal User ID
(2) Status of consent to send further information
(3) Information on the type of browser and version used
(4) The user’s operating system
(5) The user’s IP address
(6) Date and time of access
(7) Websites from which the user’s system accesses our website

During the registration process, the user’s consent to the processing of this data is obtained.

  1. legal basis for data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.

If the registration serves the fulfilment of a contract to which the user is a party or the implementation of pre-contractual measures, the additional legal basis for the processing of data is Art. 6 para. 1 letter b DPA.

  1. purpose of data processing

User registration is required for the provision of certain contents and services on our website.

ZREALITY Sphere is a cloud platform for easy creation of customized virtual reality applications. Users can choose from a variety of predefined templates and then customize them with their own content.

A registration of the user is required for the fulfillment of a contract with the user or for the implementation of pre-contractual measures.

The collected data is necessary to recognize the user with whom the contract was concluded and to provide him/her with a protected area for his/her uploaded content and personalized virtual reality applications.

  1. duration of storage

The data will be deleted as soon as they are no longer necessary for the purpose of their collection.

This is the case for data collected during the registration process for the purpose of fulfilling a contract or for the implementation of pre-contractual measures if the data is no longer required for the execution of the contract. Even after conclusion of the contract, it may still be necessary to store personal data of the contractual partner in order to comply with contractual or legal obligations.

Continuing obligations require the storage of personal data during the contract period. In addition, warranty periods must be observed and the storage of data for tax purposes. Which storage periods are to be adhered to cannot be determined in a general way, but must be determined for each individual contract and contracting party in each individual case.

  1. possibility of objection and removal

As a user you have the possibility to cancel the registration at any time. You can have the data stored about you changed at any time. To do so, please send an email to support@zrealitysphere.com or datenschutz@zreality.com. For authentication reasons, please make sure that you send this message from the same email address with which you registered.

If the data is required for the fulfilment of a contract or for the implementation of pre-contractual measures, an early deletion of the data is only possible if no contractual or legal obligations prevent a deletion.

VII. contact form and e-mail contact

  1. description and scope of data processing

On our website there is a contact form which can be used for electronic contact. If a user takes advantage of this possibility, the data entered in the input mask is transmitted to us and stored. These data are your name and e-mail address.

At the time the message is sent, the following data is also stored:

(1) Information about the type of browser and version used
(2) The user’s operating system
(3) The user’s IP address
(4) Date and time of access
(5) Websites from which the user’s system accesses our website

For the processing of the data, your consent will be obtained during the sending process and reference will be made to this privacy policy.

Alternatively, it is possible to contact us via the provided e-mail address. In this case, the user’s personal data transmitted with the e-mail will be stored.

In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation.

  1. legal basis of the data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6, Par. 1, letter f, DSGVO. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 letter b DSGVO.

  1. purpose of data processing

The processing of the personal data from the input mask serves us only to process the contact. In the case of contacting us by e-mail, this is also the necessary legitimate interest in the processing of the data.
The other personal data processed during the sending process serves to prevent misuse of the contact form and to ensure the security of our information technology systems.

  1. duration of storage

The data will be deleted as soon as they are no longer necessary for the purpose of their collection. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is terminated when it can be concluded from the circumstances that the matter in question has been finally clarified.

  1. possibility of objection and removal

The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case the conversation cannot be continued.

If you wish to exercise your right of revocation or objection, simply send an e-mail to datenschutz@zreality.com.

All personal data stored in the course of the contact will be deleted in this case.

VIII. Newsletter

On our website you have the possibility to subscribe to a free newsletter. When registering for the newsletter, the data from the input mask will be transmitted to us.
For this purpose, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and agree to receive the newsletter (IP address and date and time of registration). Further data will not be collected, or only on a voluntary basis. We use these data exclusively for sending the requested information and do not pass them on to third parties.

The data entered in the newsletter registration form will be processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke your consent to the storage of the data, the e-mail address as well as its use for sending the newsletter at any time, e.g. via the “unsubscribe” link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.
The data you have provided us with for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and deleted after you have cancelled your subscription. Data that has been stored by us for other purposes (e.g. e-mail addresses for the member area) remains unaffected.

  1. Engagement of contractors for hosting, platform security, administrative, troubleshooting and support services

For the provision of our services we use contract processors, which are listed below. The legal basis for the use of these contract processors is a legitimate interest according to Art. 6 para. 1 letter f DSGVO. The legitimate interest consists in the pursuit of our business purposes, in particular for the provision of the services otherwise described in this data protection declaration. No conflicting interest is apparent because we have concluded a contract with the respective contractors in accordance with Art. 28 DSGVO.

  1. hosting & platform security

For the purpose of hosting our platforms and back-up services, we use contract processors so that personal data stored on our platforms is transferred to these contract processors. These processors are Amazon Web Services, Inc. 410 Terry Drive Ave North, WA 98109-5210 Seattle, USA, and Telekom Deutschland GmbH, Landgrabenweg 151 53227 Bonn, Germany. These processors will store personal data for as long as the data is stored on our platforms based on the purposes defined in this Privacy Policy. Amazon Web Services Inc. is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law. All data is processed exclusively in Germany (AWS region Frankfurt/Main). Further information on data protection at Amazon Web Services can be found at the following address: https://aws.amazon.com/de/compliance/gdpr-center/.
We have concluded a contract for commissioned data processing with both Amazon Web Services Inc. and Telekom Deutschland GmbH and fully implement the strict requirements of the German data protection authorities when using these services.

  1. administrative, troubleshooting and support services

For administrative, troubleshooting and support services, we use the services of Atlassian Pty Ltd, c/o Atlassian, Inc, 1098 Harrison Street, San Francisco, CA 94103, USA, which may also have access to your personal information. In principle, Atlassian will not store your personal data. Only in exceptional cases will it be stored, for example, if it is necessary in connection with the resolution of technical problems or support requests. In these cases, your personal data will only be stored to the extent and for the duration required. Atlassian Pty Ltd is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law. For more information on data protection at Atlassian, please visit the following address: https://www.atlassian.com/trust/privacy.
We have concluded a contract with Atlassian Pty Ltd for the processing of commissioned data and fully implement the strict requirements of the German data protection authorities when using Atlassian services.

  1. sending emails and other messages

For sending e-mails and messages via other electronic channels, we use the services of Telekom Deutschland GmbH, Landgrabenweg 151, 53227 Bonn, Germany, within the scope of order processing. This company can accordingly receive your personal data within the scope of the order processing existing with us. Your personal data will be stored there for the period of time for which storage for purposes in accordance with this data protection declaration is otherwise lawful, i.e. in particular for contractual communication within the scope of existing contracts with you or for advertising communication. Further information on data protection at Atlassian can be found at the following address: https://cloud.telekom.de/infrastruktur/open-telekom-cloud/compliance/.
We have concluded a contract with Telekom Deutschland GmbH for commissioned data processing and fully implement the strict requirements of the German data protection authorities when using their services.

  1. Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google Analytics uses so-called “cookies”. These are text files which are stored on your computer and which enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there.
The storage of Google Analytics cookies is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in the analysis of user behavior in order to optimize both his web offer and his advertising.

Browser Plugin

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

Opposition to data collection

You can prevent the collection of your data by Google Analytics by clicking on the following link An opt-out cookie will be set to prevent the collection of your information on future visits to this site: Disable Google Analytics. For
more information on how Google Analytics handles user data, please see the Google privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

Contract data processing

We have concluded a contract with Google for commissioned data processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Demographic characteristics in Google Analytics

This website uses the “demographic features” feature of Google Analytics. This allows reports to be generated that contain information about the age, gender and interests of the site visitors. This data comes from interest-based advertising by Google as well as from visitor data from third parties. This data cannot be assigned to a specific person. You can disable this feature at any time in the ad settings in your Google Account or generally prohibit the collection of your data by Google Analytics as described in the “Opting out of data collection” section.

  1. Google Analytics Remarketing

Our websites use the features of Google Analytics Remarketing in conjunction with the cross-device capabilities of Google AdWords and Google DoubleClick. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
This feature allows advertising target groups created with Google Analytics Remarketing to be linked to the cross-device capabilities of Google AdWords and Google DoubleClick. In this way, interest-based, personalized advertising messages that have been adapted to you on one device (e.g. cell phone) can also be displayed on another of your devices (e.g. tablet or PC) depending on your previous usage and surfing behavior on that device.
If you have given your consent, Google will link your web and app browsing history to your Google Account for
this purpose. In this way, the same personalized advertising messages can be displayed on any device you sign in with your Google Account.
To support this feature, Google Analytics collects Google-authenticated user IDs that are temporarily linked to our Google Analytics data to define and create audiences for cross-device advertising.
You can opt-out of cross-device remarketing/targeting permanently by deactivating personalized advertising in your Google Account, following this link: https://www.google.com/settings/ads/onweb/.

The summary of the data collected in your Google Account is based solely on your consent, which you can give or withdraw to Google (Art. 6 para. 1 lit. a DSGVO). For data collection processes that are not merged into your Google Account (e.g. because you do not have a Google Account or have objected to the merging), the collection of data is based on Art. 6 para. 1 lit. f DSGVO. The legitimate interest arises from the fact that the website operator has an interest in the anonymized analysis of website visitors for advertising purposes.
Further information and the data protection regulations can be found in the Google data protection declaration at: https://www.google.com/policies/technologies/ads/.

XII. Google AdWords and Google Conversion Tracking

This website uses Google AdWords. AdWords is an online advertising program of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).
In the context of Google AdWords we use the so-called conversion tracking. When you click on an ad placed by Google, a cookie is set for conversion tracking. Cookies are small text files that the Internet browser stores on the user’s computer. These cookies expire after 30 days and are not used to personally identify users. If the user visits certain pages of this website and the cookie has not expired, Google and we can recognize that the user clicked on the ad and was redirected to that page.
Each Google AdWords customer receives a different cookie. The cookies cannot be tracked through the websites of AdWords customers. The information collected through the conversion cookie is used to compile conversion statistics for AdWords customers who have opted in to conversion tracking. The customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive information that personally identifies users. If you do not wish to participate in tracking, you can opt-out of this use by slightly disabling the Google conversion tracking cookie on your web browser under User Preferences. You will then not be included in the conversion tracking statistics.
The storage of “conversion cookies” is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in the analysis of user behavior in order to optimize both his website and his advertising.
More information on Google AdWords and Google Conversion Tracking can be found in the Google data protection regulations: https://www.google.de/policies/privacy/.

You can set your browser to inform you about the setting of cookies and to allow cookies only in individual cases, to exclude the acceptance of cookies for certain cases or in general, and to activate the automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of this website may be limited.

XIII Facebook Pixel

Our website uses the visitor action pixel of Facebook, Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) to measure conversion.

This allows the behavior of site visitors to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This allows the effectiveness of Facebook ads to be evaluated for statistical and market research purposes and future advertising campaigns to be optimized.

The collected data is anonymous for us as the operator of this website, we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, in accordance with the Facebook Data Usage Policy. This allows Facebook to enable the placement of advertisements on pages of Facebook and outside of Facebook. This use of the data cannot be influenced by us as a site operator.

You can find further information on the protection of your privacy in the Facebook privacy statement: https://www.facebook.com/about/privacy/.

You can also disable the remarketing feature “Custom Audiences” in the Advertising Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. You must be logged in to Facebook to do this.

If you do not have a Facebook account, you can disable usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website: http://www.youronlinechoices.com/de/praferenzmanagement/.

 

XV Matomo

 

Our products ZREALITY Grids (https://grids.zreality.com, https://gridslight.zreality.com, (https://my.zrealitysphere.com) use the open source software tool Matomo to analyze the surfing behavior of our users.

The software runs exclusively on servers operated by us; this data is only stored there and is not transmitted to Matomo or other third parties. The software is set in such a way that IP addresses are not stored in full, but the last two bytes of the IP address are masked (e.g.: 192.168.xxx.xxx). In this way, it is no longer possible to assign the shortened IP address to the calling computer.

No other personal data is collected. Also, no methods of user recognition (e.g. cookies) are used for analysis purposes.

If you still do not agree to the use of Matomo, you can deactivate the tracking for all ZREALITY services via the following link (opt-out).

 

XVI Youtube Videos

For integration and display of video content, our website uses plugins from YouTube. Provider of the video portal is YouTube, LLC headquarters in 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is represented by Google Inc. with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

When a page with integrated YouTube plugin is called, a connection to the YouTube servers is established. This tells YouTube which of our pages you have visited.

If you are logged into YouTube as a member, YouTube will associate this information with your personal account. If you use the plugin, e.g. clicking the start button of a video, this information is also assigned to your user account.

YouTube is used in the interest of an attractive presentation of our online offers. This represents a legitimate interest in the sense of Art. 6 para. 1 lit. f DSGVO.

You can prevent this association by logging out of your YouTube user account and other user accounts of the companies YouTube LLC and Google Inc. before using our website and deleting the corresponding cookies of the companies.

For details on the handling of user data, please refer to the YouTube privacy policy at: https://www.google.de/intl/de/policies/privacy.

Further attitudes and contradictions to the use of data by Youtube are possible by the Opt Out function: https://adssettings.google.com/authenticated.

XVII Use of Google Maps

This website incorporates maps from the “Google Maps” service of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, to visually display geographic information.
When using Google Maps, Google also collects, processes and uses data on the use of the map functions by visitors. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually in the context of the settings of their mobile devices). The data may be processed in the USA.
You can find more information about data processing by Google in the corresponding data protection declaration: https:
//www.google.com/policies/privacy/,Dort. You can also change your personal data protection settings in the data protection center. Instructions on how to manage your own data in connection with Google products can be found here.
XVIII. Facebook plugin

On our websites, social plugins of the company Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are used.
The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white “f” on blue tile or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of the Facebook Social Plugins can be viewed here:
https://developers.facebook.com/docs/plugins/.

The basis for the data processing is our legitimate interest, i.e. interest in the analysis, optimization and economic operation of our online offer according to Art. 6 para.1 lit. f. DSGVO.

By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the offer. If the user is logged in to Facebook, Facebook can assign the visit to his or her Facebook account. When users interact with the plugins, for example, by pressing the Like button or posting a comment, the corresponding information is transmitted directly from your browser to Facebook and stored there. We do not know what data Facebook links to the personal data received and for what purposes Facebook uses this data. You can find more information on this in the Facebook privacy policy (https://www.facebook.com/about/privacy/).

If a user is not a member of Facebook, it is still possible for Facebook to find out his or her IP address and store it. According to Facebook, only an anonymized IP address is stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the relevant rights and setting options to protect the privacy of users, can be found in the Facebook privacy policy:
https://www.facebook.com/about/privacy/.

If you do not want Facebook to associate your visit to our website with your Facebook account, please log out of your Facebook account, delete your corresponding cookies and block the execution of script content from Facebook in your browser, e.g. with the script blockers of www.noscript.net or www.ghostery.com.

Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

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.

XIX XING Plugin

Our website uses functions of the network XING. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany.
When a page with integrated Xing functions is called up, a connection to the Xing servers is established. To the best of our knowledge, no personal data is stored. IP addresses are not stored, nor is there any evaluation of user behavior.
If the users are members of the Xing platform, Xing can assign the call of the above mentioned contents and functions to the profiles of the users there.
Details on data protection and the XING Share button can be found in the XING Privacy Policy:
https://www.xing.com/app/share?op=data_protection.

  1. LinkedIn

Within our online offer functions and contents of the service LinkedIn, Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, can be integrated. This can include content such as images, videos or text and buttons that allow users to express their favorites regarding the content, to tell the authors of the content or to subscribe to our contributions.

If the Users are members of the LinkedIn platform, LinkedIn may assign the access to the above-mentioned contents and functions to the User’s profiles there.

LinkedIn is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active).

The purpose and extent of data collection and the further processing and use of data by LinkedIn, as well as your rights and preferences in this regard, can be found in LinkedIn’s Privacy Policy: https://www.linkedin.com/legal/privacy-policy.

Further settings and objections to the use of data by LinkedIn are possible by using the opt-out function: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

XXI. rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the DSGVO and you are entitled to the following rights vis-à-vis the person responsible:

  1. right of information

You may request confirmation from the person responsible as to whether personal data concerning you is being processed by us.

Where such processing is carried out, you may request from the controller information on:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data processed;
(3) the recipients or recipients of the data; (4) the purposes for which the data are processed; (5) the purposes for which the data are processed; (6) the purposes for which the data are processed; (7) the purposes for which the data are processed; (8) the purposes for which the data are processed; (9) the purposes for which the data are processed; (9) the purposes for which the data are processed; (9) the purposes for which the data are processed; (9) the purposes for which the data are processed; (9) the purposes for which the data are processed; (9) the purposes for which the data are processed; (9) the purposes for which the data are processed; (9) the purposes for which the data are processed; (9) the purposes for which the data are processed; (10) the purposes for which the data are processed. (3) the recipients or the categories of recipients to whom the personal data concerning you have been or will be disclosed;
(4) the envisaged duration of the storage of the personal data concerning you or, if it is not possible to give specific details, criteria for determining the duration of storage;
(5) the existence of a right of rectification or erasure of personal data concerning you, a right to have the processing limited by the controller or a right to object to such processing;
(6) the existence of a right of appeal to a supervisory authority;
(7) any available information on the origin of the data when the personal data are not collected from the data subject;
(8) the existence of automated decision making, including profiling, in accordance with Art. 22 (1) and (4) DPA and – at least in these cases – meaningful information on the logic involved and the scope and intended effects of such processing on the data subject.
You have the right to request information as to whether the personal data concerning you are being transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 DPA in connection with the transfer.

  1. right of rectification

You have the right to ask the data controller to correct and/or complete the data if the personal data processed concerning you is incorrect or incomplete. The data controller must make the correction without delay.

  1. right to limit processing

You may request the restriction of the processing of personal data concerning you under the following conditions:
(1) if you dispute the accuracy of the personal data concerning you for a period of time which allows the controller to verify the accuracy of the personal data;
(2) if the processing is unlawful and you object to the deletion of the personal data and instead request the restriction of the use of the personal data;
(3) if the controller no longer needs the personal data for the purposes of the processing but you need them for the purpose of exercising, exercising or defending legal claims; or
(4) if you object to the processing pursuant to Art. 21 paragraph 1 DSGVO and it is not yet clear whether the legitimate reasons of the controller outweigh your reasons.
If the processing of personal data relating to you has been restricted, such data – apart from being stored – may only be processed with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of an important public interest of the Union or a Member State.
If the restriction on processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

  1. right of deletion
  2. a) Duty to delete

You may request the controller to delete the personal data concerning you without delay and the controller is obliged to delete such data without delay if one of the following reasons applies:
(1) the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed
(2) you revoke your consent on which the processing was based pursuant to Art. 6 para. 1 letter a or Art. 9 para. 2 letter a FADP, and there is no other legal basis for the processing.
(3) You lodge an objection to the processing pursuant to Art. 21 para. 1 DSGVO and there are no legitimate reasons for the processing, or you lodge an objection to the processing pursuant to Art. 21 para. 2 DSGVO.
(4) The personal data concerning you have been processed unlawfully.
(5) The deletion of personal data concerning you is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
(6) The personal data concerning you have been collected in relation to information society services offered in accordance with Article 8(1) of the DPA.

  1. b) Information to third parties

If the data controller has made public the personal data concerning you and is obliged to delete them in accordance with Art. 17 para. 1 DPA, he shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform data controllers who process the personal data that you, as a data subject, have requested them to delete all links to this personal data or copies or replications of this personal data.

  1. c) Exceptions

The right to deletion does not exist insofar as the processing is necessary

(1) to exercise the right to freedom of expression and information;
(2) to comply with a legal obligation requiring processing under Union or national law 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 relating to public health pursuant to Art. 9 para. 2 lit. h and i as well as Art. 9 para. 3 DSGVO;
(4) for archiving, scientific or historical research purposes in the public interest or for statistical purposes pursuant to Art. 89 para. 1 DSGVO, insofar as the right referred to in section a) is likely to render impossible or seriously harm the achievement of the objectives of such processing, or
(5) for the assertion, exercise or defence of legal claims.

  1. right to information

If you have asserted the right to rectification, erasure or limitation of processing vis-à-vis the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification, erasure or limitation of processing, unless this proves impossible or involves a disproportionate effort.

You have the right to be informed about these recipients.

  1. right to data transferability

You have the right to receive the personal data concerning you that you have provided to the data controller in a structured, common and machine-readable format. You also have the right to have this data communicated to another person in charge without interference from the person in charge to whom the personal data has been communicated, provided that

(1) the processing is based on a consent pursuant to Art. 6 para. 1 letter a DSGVO or Art. 9 para. 2 letter a DSGVO or on a contract pursuant to Art. 6 para. 1 letter b DSGVO and

(2) the processing is carried out by means 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 person in charge to another, as far as this is technically feasible. The freedoms and rights of other persons may not be affected by this.

The right to data transferability shall not apply to processing of personal data which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

  1. right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you that is carried out pursuant to art. 6, paragraph 1, letter e or f of the DPA; this also applies to profiling based on these provisions.

The person responsible will no longer process the personal data concerning you, unless he/she can demonstrate compelling reasons for processing which are worthy of protection and which outweigh your interests, rights and freedoms, or unless the processing serves to assert, exercise or defend legal claims.

If the personal data concerning you are 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, including profiling, insofar as it relates 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 may exercise your right of objection in connection with the use of information society services, without prejudice to Directive 2002/58/EC, by means of automated procedures involving technical specifications.

  1. right to revoke the declaration of consent under data protection law

You have the right to revoke your data protection declaration of consent at any time. Revocation of your consent does not affect the legality of the processing that has taken place on the basis of your consent until revocation.

  1. 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 has legal effect on you or which significantly affects you in a similar way. This shall not apply if the decision

(1) is necessary for the conclusion or fulfillment of a contract between you and the person responsible,

(2) is authorised by Union law or the law of the Member States to which the person responsible is subject and that law contains appropriate measures to safeguard your rights and freedoms and your legitimate interests; or

(3) with your express consent.

However, these decisions may not be based on special categories of personal data according to Art. 9 para. 1 DSGVO, unless Art. 9 para. 2 lit. a or g DSGVO applies and appropriate measures have been taken to protect rights and freedoms and your legitimate interests.
With regard to the cases referred to in (1) and (3), the data controller shall take reasonable measures to protect the rights and freedoms and your legitimate interests, which shall include at least the right to obtain the intervention of a person from the data controller, to express his point of view and to challenge the decision.

  1. right of appeal 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 in which you are resident, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you is in breach of the DPA.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and the results of the complaint, including the possibility of a judicial remedy under Art. 78 DSGVO.

Specifications for the addition of further elementsThe
addition of further elements to the model data protection declaration must specify the type, scope, purpose, duration and revocation options of the respective data processing. The structure could be as follows:

  1. scope of the processing of personal data

This describes in as much detail as possible which personal data on the website is processed by whom and in what way.

  1. legal basis for the processing of personal data

Here the legal basis for the processing of personal data is mentioned. As a rule, this will be taken from the catalog of Art. 6 para. 1 DSGVO.

  1. purpose of data processing

Here it is described in detail which purposes the website operator has in mind when processing personal data. If the processing is based on the norm of Art. 6 para. 1 lit. f DSGVO, this will usually also indicate the legitimate interest in the processing. In this case, however, it must always be examined whether there are also milder means of achieving the purpose which are less detrimental to the interests of users in the protection of their personal data.

  1. duration of storage

In principle, data is deleted as soon as the purpose for which it was collected has been fulfilled. However, it must be specified in each individual case when this is the case for the specific application. If it is not possible to give exact details, at least criteria should be given which make it easier for the user to determine the time of deletion.

  1. possibility of objection and removal

For each data processing, the user must be provided with information on how the processing of the data can be prevented or data already processed can be deleted prematurely. If the user has given his consent to processing, it must be possible to revoke this consent at any time. The revocation must not be more difficult than the giving of consent. The procedure for submitting the revocation must be described.

 

Status 2018