PRIVACY & COOKIE POLICY – GDPR

We are very pleased about your interest in our company. Data protection is of particular importance to the management of Poloca Surf. The Poloca Surf website can be used without the need to provide any personal data. However, if a data subject wishes to make use of special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as a data subject’s name, address, email address or telephone number, is always in accordance with the General Data Protection Regulation and the country-specific data protection regulations applicable to Poloca Surf. By means of this data protection declaration, our company would like to inform the public about the type, scope and purpose of the personal data collected, used and processed by us. Furthermore, data subjects will be informed of their rights by means of this data protection declaration.

As data controller, Poloca Surf has implemented numerous technical and organisational measures to ensure the most complete protection possible for personal data processed via this website. Nevertheless, Internet-based data transmissions can have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us by alternative means, for example by telephone.

1. DEFINITIONS

The Poloca Surf Privacy Statement is based on the terms used by the European Directive and Regulation Giver in the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be easy to read and understand both for the public and for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this privacy statement we use the following terms, among others:

A) 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;

B) PERSON AFFECTED

Data subject is any identified or identifiable natural person whose personal data are processed by the controller.

C) PROCESSING

Means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

D) LIMITATION OF PROCESSING

Means the marking of stored personal data with the aim of limiting their processing in the future.

E) 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.

F) 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.

G) 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

H) PROCESSOR

Means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

I) RECEPIENT

Means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

J) THIRD PARTY

Means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

K) CONSENT

Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. NAME OF CONTROLLER

Poloca Surf

Owner: Victoria Sadowska

Tel.: +34 678224872

E-mail: vicky@polocasuf.com

Website: www.polocasurf.com

3. COOKIES

In order to be able to offer you the best service through our website, Poloca Surf places small data files called cookies in your browser.

WHAT ARE COOKIES?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

4. ACQUISITION OF GENERAL DATA AND INFORMATION

The Poloca Surf website collects a series of general data and information each time a person or automated system accesses the website. This general data and information is stored in the log files of the server. We may record (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the subwebsites which are accessed via an accessing system on our website, (5) the date and time of access to the Website, (6) an Internet Protocol address (IP address), (7) the Internet service providers of the accessing system, and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.

When using this general data and information Poloca Surf does not draw any conclusions about the person concerned. Rather, this information is required to (1) correctly deliver the contents of our website, (2) optimize the contents of our website and the advertising for it, (3) ensure the permanent functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. These anonymously collected data and information are therefore evaluated by Poloca Surf statistically and with the aim of increasing data protection and data security in our company in order ultimately to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a person concerned.

5. ROUTINE DELETION AND BLOCKING OF PERSONAL DATA

The controller shall process and store the personal data of the data subject only for the time necessary to achieve the data retention purpose or as provided for by the European regulator or other legislator in laws or regulations to which the controller is subject.

If the storage purpose is not fulfilled or if a storage period prescribed by the European Directive and Regulation Giver or another competent legislator expires, the personal data will be blocked or deleted routinely and in accordance with the statutory provisions.

6. RIGHTS OF THE PERSON AFFECTED

A) RIGHT TO CONFIRMATION

Any data subject shall have the right granted by the European legislator to require the controller to confirm whether personal data concerning him/her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may contact our data protection officer or another employee of the data controller at any time.

B) RIGHT TO INFORMATION

Any person concerned by the processing of personal data has the right granted by the European legislator of directives and regulations to obtain, at any time and free of charge, from the controller information on the personal data held concerning him/her and a copy of that information. Furthermore, the European regulator has granted the data subject access to the following information:

the processing purposes

the categories of personal data being processed

the recipients or categories of recipients to whom the personal data have been or are still being disclosed, in particular recipients in third countries or 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 of rectification or deletion of personal data concerning him or of a restriction on processing by the controller or of a right of opposition to such processing

the existence of a right of appeal to a supervisory authority

if the personal data is not collected from the data subject: 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) GDPRs and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject

Furthermore, the data subject has a right of access to information as to whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to obtain information on the appropriate guarantees in connection with the transfer.

If a data subject wishes to exercise this right of access, he/she may contact our data protection officer or another employee of the controller at any time.

C) RIGHT TO CORRECTION

Any person concerned by the processing of personal data has the right granted by the European legislator of directives and regulations to request the immediate correction of inaccurate personal data concerning him/her. Furthermore, taking into account the purposes of the processing, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration.

If a data subject wishes to exercise this right of rectification, he/she may contact our data protection officer or another employee of the controller at any time.

D) RIGHT TO CANCELLATION (RIGHT TO BE FORGOTTEN)

Any person concerned by the processing of personal data shall have the right granted by the European regulator to require the controller to delete personal data concerning him/her immediately, provided that one of the following reasons applies and insofar as processing is not necessary:

Personal data have been collected or otherwise processed for such purposes for which they are no longer necessary.

The data subject withdraws his/her consent on which processing was based under Article 6(1)(a) GDPR or Article 9(2)(a) GDPR and there is no other legal basis for processing.

The data subject opposes processing under Article 21(1) GDPR and there are no overriding legitimate grounds for processing or the data subject opposes processing under Article 21(2) GDPR.

The personal data was processed unlawfully.

The deletion of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the data controller is subject.

Personal data have been collected in relation to information society services provided pursuant to Art. 8 (1) GDPR.

If one of the above reasons applies and a data subject wishes to have the personal data stored by Poloca Surf deleted, he/she may contact our data protection officer or another employee of the data controller at any time. The data protection officer of Poloca Surf or another employee will arrange for the deletion request to be complied with immediately.

If Poloca Surf has made the personal data public and our company is obliged to delete the personal data in accordance with Art. 17 para. 1 GDPR, Poloca Surf will take appropriate measures, including technical measures, taking into account the available technology and implementation costs, to inform other data processors who process the published personal data, that the data subject has requested the deletion of all links to this personal data or of copies or replications of this personal data from these other data processors, insofar as processing is not necessary. The data protection officer of Poloca Surf or another employee will take the necessary steps in individual cases.

E) RIGHT TO LIMITATION OF PROCESSING

Any person data subject to the processing of personal data has the right granted by the European regulator to require the controller to restrict processing if one of the following conditions is met:

The accuracy of the personal data is disputed by the data subject for a period that enables the data controller to verify the accuracy of the personal data.

The processing is unlawful, the data subject refuses to delete the personal data and instead requests a restriction on the use of the personal data.

The data controller no longer needs the personal data for the purposes of the processing, but the data subject needs them to assert, exercise or defend legal claims.

The data subject has lodged an objection to the processing under Article 21(1) GDPR and it has not yet been determined whether the legitimate reasons of the data subject outweigh those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Poloca Surf, he/she may contact our data protection officer or another employee of the controller at any time. Poloca Surf’s data protection officer or another employee will have the processing restricted.

F) RIGHT TO DATA TRANSFERABILITY

Any data subject shall have the right granted by the European legislator to receive in a structured, current and machine-readable format the personal data concerning him/her which have been provided by the data subject to a controller. It shall also have the right to transmit such data to another data controller without obstruction by the controller to whom the personal data have been made available, provided that the processing is based on the consent provided for in Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract in accordance with Article 6(1)(b) GDPR and that the processing is carried out using automated procedures, unless the processing is necessary for the performance of a task in the public interest or in the exercise of public authority conferred on the data controller.

Furthermore, in exercising their right to data transferability under Article 20(1) GDPR, the data subject has the right to have the personal data transferred directly from one data controller to another data controller, provided this is technically feasible and does not affect the rights and freedoms of others.

To assert the right to data transferability, the person concerned may contact the data protection officer appointed by Poloca Surf or another employee at any time.

G) RIGHT OF OBJECTION

Any person data subject to the processing of personal data has the right granted by the European legislator to object at any time, for reasons arising from their particular situation, to the processing of personal data concerning them under Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.

Poloca Surf will no longer process personal data in the event of an objection, unless we can prove compelling grounds for processing that outweigh the interests, rights and freedoms of the data subject or the processing serves to assert, exercise or defend legal claims.

If Poloca Surf processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such advertising purposes. This also applies to profiling insofar as it is connected with such direct advertising. If the data subject objects to Poloca Surf processing for direct marketing purposes, Poloca Surf will no longer process the personal data for these purposes.

In addition, the data subject has the right to object to the processing of personal data concerning him/her carried out by Poloca Surf for scientific or historical research purposes or for statistical purposes in accordance with Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task in the public interest.

To exercise the right of objection, the person concerned may contact Poloca Surf or another employee directly. The data subject shall also be free to exercise his right of opposition in relation to the use of information society services by means of automated procedures using technical specifications, notwithstanding Directive 2002/58/EC.

H) AUTOMATED DECISIONS IN INDIVIDUAL CASES INCLUDING PROFILING

Any data subject to the processing of personal data shall have the right granted by the European legislator of directives and regulations not to be subject to a decision based exclusively on automated processing, including profiling, which has legal effect or similarly significantly affects him or her, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the data controller, or (2) is admissible under Union or Member State law to which the data controller is subject and that such law contains appropriate measures to safeguard the rights, freedoms and legitimate interests of the data subject, or (3) with the express consent of the data subject.

If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the data controller or (2) if it is made with the data subject’s express consent, Poloca Surf shall take appropriate measures to safeguard the rights, freedoms and legitimate interests of the data subject, including at least the right to obtain the intervention of a person by the data controller, to state his own position and to challenge the decision.

If the data subject wishes to assert rights relating to automated decisions, he/she may contact our data protection officer or another employee of the controller at any time.

I) RIGHT TO REVOKE CONSENT UNDER DATA PROTECTION LAW

Any person concerned by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise his/her right to revoke his/her consent, he/she may contact our data protection officer or another employee of the controller at any time.

7. PRIVACY POLICY REGARDING THE USE AND APPLICATION OF FACEBOOK

The controller has integrated components of the company Facebook on this website. Facebook is a social network.

A social network is an Internet-based social meeting place, an online community that usually allows users to communicate with each other and interact in virtual space. A social network can serve as a platform for the exchange of opinions and experiences or enables the Internet community to provide personal or company-related information. Facebook enables social network users to create private profiles, upload photos and network via friendship requests, among other things.

Facebook is operated by Facebook, Inc, 1 Hacker Way, Menlo Park, CA 94025, USA. The person responsible for the processing of personal data if a data subject lives outside the USA or Canada is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time one of the individual pages of this website is accessed, which is operated by the controller and on which a Facebook component (Facebook plug-in) has been integrated, the Internet browser on the information technology system of the person concerned is automatically prompted by the respective Facebook component to download a representation of the corresponding Facebook component of Facebook. An overview of all Facebook plug-ins can be found at https://developers.facebook.com/docs/plugins/. As part of this technical process, Facebook is informed about which specific subpage of our website is visited by the person concerned.

If the person concerned is logged on to Facebook at the same time, Facebook recognizes which specific subpage of our website the person concerned visits each time the person accesses our website and for the entire duration of the respective stay on our website. This information is collected by the Facebook component and assigned by Facebook to the respective Facebook account of the person concerned. If the person concerned clicks one of the Facebook buttons integrated on our website, for example the “Like” button, or the person concerned makes a comment, Facebook assigns this information to the personal Facebook user account of the person concerned and stores this personal data.

Facebook always receives information via the Facebook component that the person concerned has visited our website if the person concerned is logged on to Facebook at the same time as accessing our website; this takes place regardless of whether the person concerned clicks on the Facebook component or not. If the person concerned does not want this information to be transmitted to Facebook, they can prevent it from being transmitted by logging out of their Facebook account before accessing our website.

The data policy published by Facebook, available at https://facebook.com/about/privacy/, provides information about Facebook’s collection, processing and use of personal data. It also explains what setting options Facebook offers to protect the privacy of the person concerned. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by the person concerned to suppress data transmission to Facebook.

8. PRIVACY POLICY REGARDING THE USE AND APPLICATION OF GOOGLE ANALYTICS (WITH ANONYMIZATION FUNCTION)

The controller has integrated the component Google Analytics (with anonymisation function) on this website. Google Analytics is a web analytics service. Web analysis is the collection, collection and evaluation of data on the behaviour of visitors to websites. A web analysis service collects, among other things, data on which website a person concerned came to a website from (so-called referrer), which subpages of the website were accessed or how often and for how long a subpage was viewed. A web analysis is mainly used to optimize a website and for cost-benefit analysis of Internet advertising.

The Google Analytics component is operated by Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The data controller uses the suffix “_gat._anonymizeIp” for the web analysis via Google Analytics. By means of this addition, Google shortens and anonymizes the IP address of the Internet connection of the person concerned when accessing our website from a member state of the European Union or from another state party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the flow of visitors to our website. Google uses the data and information collected to evaluate the use of our website, among other things, to compile online reports for us that show the activities on our websites and to provide other services in connection with the use of our website.

Google Analytics places a cookie on the information technology system of the person concerned. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyse the use of our website. Each time one of the individual pages of this website is called up, which is operated by the data controller and on which a Google Analytics component has been integrated, the Internet browser on the information technology system of the person concerned is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the person concerned, which serves Google, among other things, to trace the origin of visitors and clicks and subsequently enable commission statements.

The cookie stores personal information, such as access time, the location from which access came and the frequency of visits to our website by the person concerned. Whenever you visit our website, this personal data, including the IP address of the Internet connection used by the person concerned, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may disclose personal data collected through the technical process to third parties.

The person concerned can prevent the setting of cookies by our website at any time, as already described above, by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a cookie on the information technology system of the person concerned. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, it is possible for the person concerned to object to and prevent the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google. To do this, the person concerned must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout This browser add-on informs Google Analytics via JavaScript that no data and information on visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered a contradiction by Google. If the person’s information technology system is deleted, formatted or reinstalled at a later time, the person concerned must reinstall the browser add-on to disable Google Analytics. If the browser add-on is uninstalled or deactivated by the person concerned or another person within their control, it is possible to reinstall or reactivate the browser add-on.

More information and Google’s current privacy policy can be found at https://www.google.com/policies/privacy/ and http://www.google.com/analytics/terms/ Google Analytics will be explained in more detail under this link https://www.google.com/analytics/.

9. PRIVACY POLICY REGARDING THE USE AND APPLICATION OF INSTAGRAM

The controller has integrated components of the Instagram service on this web page. Instagram is a service that can be qualified as an audiovisual platform that allows users to share photos and videos and to redistribute such data on other social networks.

Instagram’s service provider is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, USA.

Each time you access one of the individual pages of this Web page operated by the controller and on which an Instagram component (Insta button) has been integrated, the Internet browser on the person’s information technology system is automatically prompted by the respective Instagram component to download a representation of the corresponding Instagram component. As part of this technical process, Instagram is informed about which specific subpage of our website is visited by the person concerned.

If the person concerned is logged in to Instagram at the same time, each time the person accesses our website and for the entire duration of their stay on our website, Instagram will recognize which specific subpage the person concerned is visiting. This information is collected by the Instagram component and assigned to the person’s Instagram account by Instagram. If the person concerned presses one of the Instagram buttons integrated on our website, the data and information thus transmitted will be assigned to the personal Instagram user account of the person concerned and stored and processed by Instagram.

Instagram receives information via the Instagram component that the person concerned has visited our website whenever the person concerned is logged in to Instagram at the same time as accessing our website, regardless of whether or not the person concerned clicks on the Instagram component. If the person concerned does not want such information to be transmitted to Instagram, the person concerned may prevent the transmission by logging out of their Instagram account before accessing our website.

For more information and Instagram’s current privacy policy, please visit https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/

10. PRIVACY POLICY REGARDING THE USE AND APPLICATION OF TWITTER

Processor has integrated components of Twitter on this website. Twitter is a multilingual public microblogging service on which users can publish and distribute so-called tweets, i.e. short messages limited to 140 characters. These short messages are available to everyone, including people who are not registered on Twitter. The tweets are also displayed to the so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter makes it possible to address a broad audience via hashtags, links or retweets.

Twitter is operated by Twitter, Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

Every time one of the individual pages of this website is called up, which is operated by the person responsible for processing and on which a Twitter component (Twitter button) has been integrated, the Internet browser on the person’s information technology system is automatically prompted by the respective Twitter component to download a representation of the corresponding Twitter component from Twitter. Further information on the Twitter buttons can be found at https://about.twitter.com/de/resources/buttons As part of this technical process, Twitter is informed about which specific subpage of our website is visited by the person concerned. The purpose of integrating the Twitter component is to enable our users to disseminate the content of this website, to make this website known in the digital world and to increase our visitor numbers.

If the person concerned is logged in to Twitter at the same time, every time the person concerned visits our website and for the entire duration of their stay on our website, Twitter will recognize which specific subpage of our website the person concerned is visiting. This information is collected by the Twitter component and assigned to the respective Twitter account of the person concerned by Twitter. If the person concerned presses one of the Twitter buttons integrated on our website, the data and information thus transmitted will be assigned to the personal Twitter user account of the person concerned and stored and processed by Twitter.

Twitter always receives information via the Twitter component that the person concerned has visited our website if the person concerned is logged on to Twitter at the same time as accessing our website; this happens regardless of whether the person concerned clicks on the Twitter component or not. If the person concerned does not want such information to be transmitted to Twitter, they can prevent the transmission by logging out of their Twitter account before accessing our website.

The current privacy policy of Twitter is available at https://twitter.com/privacy?lang=en.

11. PRIVACY POLICY REGARDING THE USE AND APPLICATION OF YOUTUBE

The controller has integrated components from YouTube on this website. YouTube is an Internet video portal that allows video publishers to post video clips and other users to view, rate and comment on them free of charge. YouTube allows the publication of all types of videos, which is why complete film and television programmes, music videos, trailers or videos produced by users themselves can be called up via the Internet portal.

YouTube is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Each time a YouTube (YouTube video) component is integrated into one of the individual pages of this website operated by the data controller, the Internet browser on the person’s information technology system is automatically prompted by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. More information about YouTube can be found at https://www.youtube.com/yt/about/ As part of this technical process, YouTube and Google are informed which specific subpage of our website is visited by the person concerned.

If the person is logged in to YouTube at the same time, YouTube recognizes which specific subpage of our website the person is visiting by calling a subpage that contains a YouTube video. This information is collected by YouTube and Google and assigned to the respective YouTube account of the person concerned.

YouTube and Google are informed via the YouTube component that the person concerned has visited our website whenever the person concerned is logged on to YouTube at the same time as accessing our website, regardless of whether or not the person concerned clicks on a YouTube video. If such a transmission of this information to YouTube and Google is not desired by the person concerned, this can prevent the transmission by logging out of their YouTube account before calling up our website.

The privacy policies published by YouTube, available at https://www.google.de/policies/privacy/, provide information about the collection, processing and use of personal information by YouTube and Google.

12. LEGAL BASIS OF PROCESSING

Article 6 I lit. a GDPR serves our company as a legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case for example with processing operations necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing processes that are necessary to carry out pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, for example to fulfil tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may become necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information had to be passed on to a doctor, a hospital or other third parties. The processing would then be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. Such processing procedures are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the person concerned is a customer of the person responsible (recital 47, second sentence, GDPR).

13. LEGITIMATE INTERESTS IN THE PROCESSING PURSUED BY THE CONTROLLER OR A THIRD PARTY

If the processing of personal data is based on Article 6 I lit. f GDPR, it is in our legitimate interest to conduct our business for the well-being of all our employees and our shareholders.

14. DURATION FOR WHICH THE PERSONAL DATA WILL BE STORED

The criterion for the duration of the storage of personal data is the respective legal retention period. After the expiry of this period, the corresponding data will be routinely deleted, provided that it is no longer necessary for the fulfilment or initiation of the contract.

15. LEGAL OR CONTRACTUAL PROVISIONS FOR THE PROVISION OF PERSONAL DATA; NECESSITY FOR THE CONCLUSION OF THE CONTRACT; OBLIGATION OF THE DATA SUBJECT TO PROVIDE THE PERSONAL DATA; POSSIBLE CONSEQUENCES OF FAILURE TO PROVIDE

We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). In some cases, it may be necessary for a contract to be concluded if a data subject provides us with personal data which must subsequently be processed by us. For example, the person concerned is obliged to provide us with personal data if our company enters into a contract with him/her. Failure to provide personal data would mean that the contract with the data subject could not be concluded. Prior to the provision of personal data by the data subject, the data subject must contact our data protection officer. Our data protection officer will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or required for the conclusion of the contract, whether there is an obligation to provide the personal data and what consequences the failure to provide the personal data would have.

16. EXISTENCE OF AUTOMATED DECISION MAKING

As a responsible company, we refrain from automatic decision making or profiling.

COMPLETE EU GENERAL DATA PROTECTION REGULATION (EU-GDPR)

The complete EU General Data Protection Regulation (EU-GDPR) including the 99 articles and 173 recitals you find here – http://www.privacy-regulation.eu/en/index.htm