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Privacy Policy

1. Data Protection at a Glance

General Information

The following information provides a brief overview of what happens to your personal data when you visit this website. Personal data means any data that can be used to identify you personally. Detailed information on data protection can be found in the Privacy Policy set out below.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. The operator’s contact details can be found in the section “Information on the Controller” in this Privacy Policy.

How do we collect your data?

Some data is collected when you provide it to us. This may, for example, include data that you enter into a contact form.

Other data is collected automatically by our IT systems when you visit the website or, where applicable, after you have given your consent. This primarily includes technical data, such as your internet browser, operating system or the time the page was accessed. This data is collected automatically as soon as you access this website.

What do we use your data for?

Some of the data is collected to ensure that the website is provided correctly and without technical errors. Other data may be used to analyse user behaviour. Where contracts can be concluded or initiated through the website, the data submitted may also be processed for quotations, orders or other contractual enquiries.

What rights do you have regarding your data?

You have the right, at any time and free of charge, to obtain information about the origin, recipients and purposes of your stored personal data. You also have the right to request the rectification or erasure of this data. If you have given consent to data processing, you may withdraw that consent at any time with effect for the future. You also have the right, under certain circumstances, to request restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You may contact us at any time if you have any questions regarding data protection or the exercise of your rights.

Analytics Tools and Third-Party Tools

When you visit this website, your browsing behaviour may be statistically analysed. This is primarily carried out using analytics software.

Detailed information about these analytics tools can be found in this Privacy Policy.

2. Hosting

We host the content of our website with the following provider:

Strato

The provider is Strato AG, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany (hereinafter “Strato”). When you visit our website, Strato collects various log files, including your IP address.

For further information, please refer to Strato’s Privacy Policy:
https://www.strato.de/datenschutz/

The use of Strato is based on Art. 6(1)(f) GDPR. We have a legitimate interest in ensuring that our website is displayed as reliably as possible. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG insofar as such consent covers the storage of cookies or access to information on the user’s terminal device, for example through device fingerprinting, within the meaning of the TDDDG. Consent may be withdrawn at any time.

Data Processing Agreement

We have entered into a data processing agreement with the above-mentioned provider for the use of this service. This is an agreement required under data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

3. General Information and Mandatory Disclosures

Data Protection

The operator of this website takes the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with applicable data protection legislation and this Privacy Policy.

When you use this website, various types of personal data are collected. Personal data is any information relating to an identified or identifiable natural person. This Privacy Policy explains what data we collect and what we use it for. It also explains how and for what purposes the processing takes place.

Please note that data transmitted over the internet, for example when communicating by email, may be subject to security vulnerabilities. Complete protection of data against access by third parties cannot be guaranteed.

Information on the Controller

The controller responsible for data processing on this website is:

Tom Florian Graßmann
Tom Graßmann IT+Media
Kümmritz 34
15926 Luckau
Germany

Phone: [Controller’s telephone number]
Email: tom@grassmann-it.de

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data, such as names, email addresses or similar information.

Retention Period

Unless a more specific retention period is stated elsewhere in this Privacy Policy, your personal data will remain with us until the purpose for which it was processed no longer applies.

If you submit a legitimate request for erasure or withdraw your consent to data processing, your data will be erased unless we have other legally permissible grounds for retaining your personal data, such as statutory retention obligations under tax or commercial law. In such cases, the data will be erased once those grounds cease to apply.

General Information on the Legal Bases for Data Processing on This Website

Where you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR where special categories of personal data within the meaning of Art. 9(1) GDPR are processed.

Where you have expressly consented to the transfer of personal data to third countries, processing is also based on Art. 49(1)(a) GDPR.

Where you have consented to the storage of cookies or access to information on your terminal device, for example through device fingerprinting, processing is additionally based on Section 25(1) TDDDG. Consent may be withdrawn at any time.

Where your data is required for the performance of a contract or in order to take steps at your request prior to entering into a contract, we process your data on the basis of Art. 6(1)(b) GDPR.

Where processing is necessary for compliance with a legal obligation to which we are subject, we process your data on the basis of Art. 6(1)(c) GDPR.

Processing may also be carried out on the basis of our legitimate interests pursuant to Art. 6(1)(f) GDPR.

Information on the legal basis applicable in each individual case is provided in the relevant sections of this Privacy Policy.

Recipients of Personal Data

As part of our business activities, we work with various external service providers and other third parties. In some cases, this requires personal data to be disclosed to these parties.

We disclose personal data to external parties only where this is necessary for the performance of a contract, where we are legally required to do so, for example when disclosing information to tax authorities, where we have a legitimate interest in the disclosure pursuant to Art. 6(1)(f) GDPR, or where another legal basis permits the disclosure.

Where we use processors, we disclose our customers’ personal data only on the basis of a valid data processing agreement. In cases of joint controllership, an agreement governing joint processing is concluded.

Withdrawal of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You may withdraw consent that you have previously given at any time.

The lawfulness of processing carried out on the basis of consent before its withdrawal remains unaffected by the withdrawal.

Right to Object to Processing in Specific Cases and to Direct Marketing (Art. 21 GDPR)

WHERE PERSONAL DATA IS PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT, AT ANY TIME AND ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA. THIS ALSO APPLIES TO PROFILING BASED ON THOSE PROVISIONS. THE APPLICABLE LEGAL BASIS FOR PROCESSING CAN BE FOUND IN THIS PRIVACY POLICY.

IF YOU OBJECT, WE WILL NO LONGER PROCESS THE PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR UNLESS THE PROCESSING IS NECESSARY FOR THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (RIGHT TO OBJECT PURSUANT TO ART. 21(1) GDPR).

WHERE YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING.

IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (RIGHT TO OBJECT PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of an infringement of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement.

The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to Data Portability

You have the right to receive personal data which we process by automated means on the basis of your consent or for the performance of a contract, in a commonly used and machine-readable format, and to have that data transmitted to yourself or to a third party.

Where you request the direct transmission of the data to another controller, this will only be carried out where technically feasible.

Right of Access, Rectification and Erasure

Within the scope of applicable law, you have the right at any time and free of charge to obtain information about your stored personal data, its origin and recipients, and the purposes for which it is processed.

You may also have the right to request rectification or erasure of this data.

You may contact us at any time regarding these rights or any other questions concerning personal data.

Right to Restriction of Processing

You have the right to request restriction of the processing of your personal data. You may contact us at any time for this purpose.

The right to restriction of processing applies in the following circumstances:

Where processing of your personal data has been restricted, such data may, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

SSL/TLS Encryption

For security purposes and to protect the transmission of confidential content, such as orders or enquiries that you submit to us as the website operator, this website uses SSL/TLS encryption.

You can recognise an encrypted connection by the fact that the browser’s address bar changes from “http://” to “https://” and by the padlock icon displayed in your browser.

When SSL/TLS encryption is enabled, the data you transmit to us cannot be read by third parties while in transit.

4. Data Collection on This Website

Server Log Files

The website provider automatically collects and stores information in server log files which your browser automatically transmits. This information includes:

This data is not combined with data from other sources.

The collection of this data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in ensuring the technically correct presentation and optimisation of the website. The collection of server log files is necessary for this purpose.

Contact Form

If you submit an enquiry to us via the contact form, the information you provide in the form, including the contact details you enter there, will be stored by us for the purpose of processing your enquiry and responding to any follow-up questions.

We do not disclose this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR where your enquiry relates to the performance of a contract or is necessary in order to take steps prior to entering into a contract.

In all other cases, processing is based on our legitimate interest in efficiently handling enquiries addressed to us pursuant to Art. 6(1)(f) GDPR or, where consent has been requested, on your consent pursuant to Art. 6(1)(a) GDPR. Consent may be withdrawn at any time.

The data you enter into the contact form will remain with us until you request its erasure, withdraw your consent to its storage, or the purpose for storing the data no longer applies, for example once your enquiry has been fully processed.

Mandatory statutory provisions, in particular statutory retention periods, remain unaffected.

Enquiries by Email, Telephone or Fax

If you contact us by email, telephone or fax, your enquiry, including any personal data arising from it, such as your name and the content of your enquiry, will be stored and processed by us for the purpose of handling your request.

We do not disclose this data without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR where your enquiry relates to the performance of a contract or is necessary in order to take steps prior to entering into a contract.

In all other cases, processing is based on our legitimate interest in efficiently handling enquiries addressed to us pursuant to Art. 6(1)(f) GDPR or, where consent has been requested, on your consent pursuant to Art. 6(1)(a) GDPR. Consent may be withdrawn at any time.

The data you provide to us in connection with enquiries will remain with us until you request its erasure, withdraw your consent to its storage, or the purpose for storing the data no longer applies, for example once your enquiry has been fully processed.

Mandatory statutory provisions, in particular statutory retention periods, remain unaffected.

5. Analytics Tools and Advertising

Matomo

This website uses the open-source web analytics service Matomo.

Matomo enables us to collect and analyse data regarding how visitors use our website. Among other things, this allows us to determine when particular pages were accessed and the geographical region from which they were accessed.

We also collect various log data, such as IP addresses, referrers, browsers used and operating systems, and may measure whether website visitors perform certain actions, such as clicks, purchases or similar interactions.

The use of this analytics tool is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both the website and its advertising activities.

Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG insofar as such consent covers the storage of cookies or access to information on the user’s terminal device, for example through device fingerprinting, within the meaning of the TDDDG. Consent may be withdrawn at any time.

Cookie-Free Analytics

We have configured Matomo so that it does not store cookies in your browser.

Hosting

We host Matomo exclusively on our own servers. As a result, all analytics data remains with us and is not disclosed to third parties.

6. Plugins and Tools

Cloudflare Turnstile

We use Cloudflare Turnstile (hereinafter “Turnstile”) on this website. The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter “Cloudflare”).

Turnstile is used to determine whether data entered on this website, for example through a contact form, is being submitted by a human user or by an automated program. For this purpose, Turnstile analyses the behaviour of website visitors based on various characteristics.

This analysis begins automatically as soon as a website visitor accesses a page on which Turnstile is enabled. For the purposes of this analysis, Turnstile evaluates various information, such as the IP address, the amount of time the website visitor spends on the website or mouse movements made by the user. The data collected during the analysis is transmitted to Cloudflare.

The storage and analysis of this data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting its online services against abusive automated access, automated data collection and spam.

Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG insofar as such consent covers the storage of cookies or access to information on the user’s terminal device, for example through device fingerprinting, within the meaning of the TDDDG. Consent may be withdrawn at any time.

The processing of data is based on the Standard Contractual Clauses. These are available at:
https://www.cloudflare.com/cloudflare-customer-scc/

Further information about Cloudflare Turnstile can be found in Cloudflare’s data protection documentation at:
https://www.cloudflare.com/cloudflare-customer-dpa/

Cloudflare is certified under the EU-U.S. Data Privacy Framework (DPF). The DPF is an arrangement between the European Union and the United States intended to ensure compliance with European data protection standards when personal data is processed in the United States. Companies certified under the DPF undertake to comply with these data protection standards.

Further information is available from the provider at:
https://www.dataprivacyframework.gov/participant/5666

Ninja Firewall

We use Ninja Firewall on this website. The provider is NinTechNet Limited, Unit 1603, 16th Floor, The L. Plaza, 367–375 Queen’s Road Central, Sheung Wan, Hong Kong (hereinafter “Ninja Firewall”).

Ninja Firewall is used to protect our website against unauthorised access and malicious cyberattacks. For this purpose, Ninja Firewall collects the IP address, request data, referrer information and the time at which the website is accessed.

Ninja Firewall is installed on our own servers and does not transmit personal data to the provider of the tool or to any other third party.

The use of Ninja Firewall is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting the website against cyberattacks as effectively as possible.

Source: https://www.e-recht24.de