Privacy Policy

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as ‘data’) within our online offering and the related web pages, features and content, as well as external online presence, e.g. our social media profile (collectively referred to as the ‘online offering’). With regard to the terminology used, e.g. ‘processing’ or ‘controller’ we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Controller

The person responsible (‘controller”) for implementing the data protection regulations is

Christiane Steinhoff
Steinhoff & Steinhoff IT-Berater GmbH
Kirchhalde 5
71083 Herrenberg
Germany
christiane.steinhoff@steinhoffundsteinhoff.de

Managing Directors: Alfons Steinhoff, Christiane Steinhoff
Imprint

Types of processed data:

  • Inventory data (e.g., names, addresses).
  • contact data (e.g., e-mail, 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 offering (hereinafter collectively referred to as ‘users’).

Purpose of the processing

  • Provision of the online offering, its features and contents.
  • Answering contact requests and communication with users.
  • Safety measures.
  • Reach measurement / marketing.

Definitions

‘personal data’ means any information relating to an identified or identifiable natural person (‘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 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 covers a wide range of actions and covers practically every handling of data.

‘pseudonymisation’ 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 organisational 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 analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

‘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.

Applicable legal bases

In accordance with Art. 13 GDPR, we inform you about the legal bases of our data processing. Unless the legal basis is mentioned in our privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the answer to inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 para. 1 lit. f GDPR. 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 GDPR serves as legal basis.

Security measures

In accordance with Art. 32 GDPR we implement appropriate technical and organizational measures taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing, to ensure adequate level of protection.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. In addition, we have established procedures ensuring the exercise of data subject rights, the erasure of data and the reaction to data compromise. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Art. 25 GDPR).

Collaboration with processors and third parties

If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit them to them or otherwise grant them access to the data, this is done only on the basis of a legal permission (e.g. if a transmission of the data to third parties, as to a payment service provider, is required for the performance of a contract pursuant to Art. 6 para. 1 lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. using agents, webhosters, etc.).

Insofar as we commission third parties to process data on the basis of a so-called ‘commissioned data processing contract’, 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 in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre-) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR are fulfilled; i.e. the processing is based e.g. on specific guarantees, such as the officially accepted declaration of a data protection level equivalent to the EU (e.g. the ‘Privacy Shield’ for the USA) or compliance with officially accepted special contractual obligations (so-called ‘standard contractual clauses’).

Rights of data subjects

You have the right to obtain a confirmation as to whether data concerning you are being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

According to Art. 16 GDPR you have the right to request the completion of data concerning you or to obtain the rectification of inaccurate data concerning you.

According to Art. 17 GDPR, you have the right to obtain the erasure of the data concerning you without undue delay, or, alternatively, to obtain the restriction of processing in accordance with Art. 18 GDPR.

You have the right to receive the data concerning you, which you have provided to us, in accordance with Art. 20 GDPR and to request their transmission to other controllers.

Furthermore, according to Art. 77 GDPR you have the right to lodge a complaint with the competent supervisory authority.

Right of withdrawal

You have the right to withdraw given consents according to. Art. 7 para. 3 GDPR with effect for the future.

Right to object

You may at any time object to the future processing of data concerning you in accordance with Art. 21 GDPR. In particular, the objection may be made against processing for direct marketing purposes.

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 serves primarily to store the information about a user (or the device on which the cookie is stored) during or after his visit of an online offering. Temporary cookies, or ‘session cookies’ or ‘transient cookies’, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart of an online shop or a login status are stored. The term ‘permanent’ or ‘persistent’ refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved in case users visit the site after several days again. Likewise, in such a cookie the interests of the users can be stored, which are used for reach measurement or marketing purposes. A third-party cookie is a cookie offered by a provider other than the controller who runs the online offering (otherwise, if it is only his cookies, they are called first-party cookies).

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

If users do not want cookies stored on their machine, they will be asked to disable the respective option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional restrictions of this online offering.

A general objection to the use of cookies used for online marketing purposes can be declared for a variety 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 avoided by switching them off in the settings of the browser. Please note that then, as the case may be, not all features of this online offering may be used.

Erasure of data

The data processed by us are erased or limited in their processing in accordance with Art. 17 and Art. 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer necessary for their intended purpose and the deletion does not conflict with any legal retention requirements. In case the data is not deleted because it is required for other and legally permitted purposes, its processing will be restricted; i.e. the data is blocked and not processed for other purposes. This applies, for example, for data that must to be retained for commercial or tax reasons.

According to legal requirements in Germany, the retention takes place in particular for 10 years pursuant to §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 German Commercial Code (Handelsgesetzbuch – HGB) (books, records, management reports, accounting documents, trading books, for taxation relevant documents, etc.) and 6 years pursuant to § 257 para. 1 no. 2 and 3, para. 4 German Commercial Code (business letters).

Business related processing

In addition, we process

  • contract data (e.g., subject, term, customer category).
  • payment data (e.g., bank account, payment history)

of our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Agency Services

We process our customers’ data as part of our contractual services that include conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, campaign / process / handling implementation, server administration, data analysis / consulting services, and training services.

In this connection we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text input, photographs, videos), contract data (e.g., subject, term), payment data (e.g., bank account, payment history), usage and meta data (e.g. as part of the evaluation and success measurement of marketing measures). Generally, we do not process special categories of personal data, unless these are components of a commissioned processing. Data subjects include our customers, prospects and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contract services, billing and our customer service. The legal basis for processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data necessary for the establishment and performance of the contractual services and point out the requirement of their specification. Disclosure to externals will only be made if required by an order. In the processing of the data provided to us in the context of an order, we act in accordance with the instructions of the customer as well as the legal requirements of a commissioned data processing according to Art. 28 GDPR and process the data for no other purpose than the order.

We erase the data after expiry of legal warranty and comparable obligations. The requirement of retaining the data is checked every three years; in the case of legal archiving obligations, the erasure takes place after their expiry (6 years, pursuant to § 257 para. 1 German Commercial Code, 10 years, pursuant to § 147 para. 1 AO). In the case of data disclosed to us in the context of an order by the customer, we erase the data according to the specifications of the order, generally after the end of the order.

Administration, financial accounting, office organisation, contact management

We process data in the context of administrative tasks and 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 in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose and our interest in processing lies in administration, financial accounting, office organization, data archiving, thus tasks that serve to maintain our business, perform our duties and provide our services. The erasure of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.

In this connection, we disclose or transmit data to the financial administration, consultants, such as tax consultants or auditors, and other fee agencies and payment service providers.

Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. We generally store these mostly company-related data permanently.

Contacting

When contacting us (e.g., via contact form, e-mail, telephone or via social media), the information of the user for processing and handling the contact request are processed in accordance with Art. 6 para. 1 lit. b GDPR. User information can be stored in a Customer Relationship Management System (‘CRM System’) or comparable request organization.

We delete the requests, if they are no longer required. We check the requirement every two years; furthermore, the legal archiving obligations apply.

Hosting

The hosting services we use are for the purpose of providing the following services: infrastructure and platform services, computing capacity, storage and database services, security and technical maintenance services we use to operate this online offering.

In this connection we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects and visitors of this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering according to Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of commissioned data processing contract).

Collection of access data and logfiles

We, or our hosting provider, collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR data on every access to the server on which this service is located (so-called server log files). The access data include the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then erased. Data whose further retention is required for evidential purposes are excluded from the erasure until the final clarification of the incident.

Interpretation

In case of interpretation questions the German version of this privacy policy shall prevail.