The Privacy Policy

Data protection declaration according to art. 13 GDPR

The data protection and privacy of the users of our Internet pages are of particular concern to us. We therefore undertake to protect your personal data and to collect, process and use it only in accordance with the Data Protection Basic Regulation (GDPR) and the national data protection regulations. The following data protection declaration explains which of your personal data is collected on our Internet pages and how this data is used. Our data protection declaration is regularly updated in accordance with the legal and technical requirements. Please therefore take note of the current version of our data protection declaration.

The following data protection provisions apply exclusively to the Internet pages of spot9 GmbH on the website: spot9.com/en/

I. Name and address of responsible party

The responsible party within the meaning of the Basic Data Protection Regulation and other national data protection laws as well as other provisions of data protection law is:

  • spot9 GmbH
  • Landsberger Allee 366
  • 12681 Berlin
  • Germany

II. Name and address of the Data Protection Officer

The data protection officer of the responsible party is:

III. General information on data processing

1. Scope of processing of personal data

As a matter of principle, your personal data will only be processed as this is necessary to provide a functioning website as well as our content and services. The processing regularly takes place only after your consent, unless a previous obtaining of consent is not possible for actual reasons and the processing of the data is permitted by legal regulations.

2. Legal basis for the processing of personal data

As legal basis for the processing of personal data we use the facts standardized in Art. 6 para. 1 GDPR as follows:

  • Art. 6 para. 1 lit. a GDPR, provided that we obtain the consent of the person concerned for processing personal data.
  • Art. 6 para. 1 lit. b GDPR if the processing of personal data is necessary for the performance of a contract to which the data subject is a party. This shall also apply to processing operations which are necessary for the implementation of pre-contractual measures.
  • Art. 6 para. 1 lit. c GDPR, if the processing of personal data is necessary to fulfil a legal obligation to which our company is subject.
  • Art. 6 para. 1 lit. d GDPR, insofar as vital interests of the data subject or another natural person necessitate the processing of personal data.
  • Art. 6 para. 1 lit. f GDPR, if the processing is necessary to safeguard a legitimate interest of our company or a third party and this outweighs the interests, fundamental rights and fundamental freedoms of the data subject.

3. Data deletion and storage period

Your personal data will be deleted or blocked as soon as the purpose of storage no longer applies. If the European or national legislator provides for a storage beyond the purpose in Union regulations, laws or other provisions to which the person responsible is subject, this can take place until the expiry of the storage period prescribed by the standards mentioned. Subsequently, the data will also be blocked or deleted, unless it is necessary for further storage of the data for the conclusion of a contract or fulfilment of a contract.

IV. Provision of the website and creation of log files

1. Description and scope of data processing

Our system automatically collects data and information from the computer system of the calling computer each time you visit our website.

The following data is collected here:

  • The user IP address
  • The date and time of access
  • Your Internet provider
  • Information about the type of access browser and the version used
  • Your operating system

With the exception of your IP address or other data which enable the assignment of the data to you, this data is also stored in the log files of our system. These data are not stored together with your other personal data in this case.

2. Legal basis for data processing

Art. 6 para. 1 lit. f GDPR constitutes the necessary legal basis for the temporary storage of data.

3. Purpose of the data processing

The provision of the website to your computer requires the temporary storage of the IP address by the system. For this purpose, your IP address must remain stored for the duration of the session. These purposes also represent our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f GDPR.

4. Duration of storage

If the data collection is no longer necessary to achieve the purpose, the data will be deleted. In the case of data collection for the provision of the website, this shall take place at the end of the respective session.

5. Possibility of objection and removal

There is no possibility for you to object, as the collection and storage of data in log files is mandatory for the provision and operation of the website.

V. Use of cookies

1. Description and scope of data processing

Our website uses so-called "cookies". These are text files that are stored in the Internet browser or by the Internet browser on your computer system. A cookie can be stored on your operating system as soon as it calls a website. This cookie contains a characteristic string that allows the browser to be uniquely identified when the website is reopened.

Cookies are used for the user-friendly design of our website. Because some parts of our website require identification of the browser used even after a page change.

The following data is stored and transmitted in the cookies:

  • Log-in information
  • Language settings
  • Articles in a shopping cart
  • Navigation on the page and function control

2. Prevent the storage of cookies

Depending on the browser you are using, you can set your browser so that cookies are only stored after you have given your consent. If you only want to accept the cookies used by us, but not the cookies of any service providers and partners, you can select the setting in your browser „Block third-party cookies“. As a rule, the help function in the menu bar of your web browser shows you how to reject new cookies and how to deactivate cookies that have already been received. We recommend that you always completely log out of shared computers that are set to accept cookies and flash cookies after they have been completed.

3. Legal basis for data processing

Art. 6 para. 1 lit. f GDPR represents the necessary legal basis for the processing of personal data using cookies.

4. Purpose of the data processing

The use of technically necessary cookies is carried out for the purpose of simplifying the use of our websites for you. Without the use of cookies, various functions of our website cannot be offered, as these require the recognition of the browser after a page change.

The following applications require cookies:

  • Remembering search terms
  • Acceptance of language settings

There is no creation of user profiles by means of technically necessary cookies of collected user data.

These purposes also represent our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f GDPR.

5. Duration of storage, objection and removal possibility

Cookies are stored on your computer. From there they are transmitted to our website. You as the user therefore have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. You can also delete cookies that have already been saved at any time. This can also be done automatically. If you deactivate cookies for our website, this may result in restrictions on the use of the functions of our website.

VI. Newsletter

1. Description and scope of data processing

We offer the possibility of a free newsletter subscription on our website. The data from the input mask provided for this purpose will be transmitted to us when you register for the newsletter.

  • Name, first name
  • Email address
  • Date of birth
  • IP address

The following data is also collected during registration:

  • Date and time of registration
  • IP address of the calling computer

During the registration process, we will obtain your consent to the processing of this data and refer to this Privacy Policy. The data is used exclusively for the newsletter dispatch. A transmission of the data processed for the newsletter dispatch to third does not take place.

2. Legal basis for data processing

For the processing of personal data by the user after registration for the newsletter, the present consent according to Art. 6 para. 1 lit. a GDPR provides the necessary legal basis.

3. Purpose of the data processing

We collect your email address in order to deliver the newsletter.

To prevent misuse of the services or the email address provided, we collect other personal data during the registration process.

4. Duration of storage

If the data collection is no longer necessary to achieve the purpose, the data will be deleted. Thus we store your email address for the duration of the active newsletter subscription.

As a rule, the other personal data collected during the registration process will be deleted after a period of seven days.

5. Possibility of objection and removal

You can cancel your newsletter subscription at any time. You will find a link to this in every newsletter.

You can also use this link to revoke your consent to the storage of any other personal data collected during the registration process.

VII. Registration

1. Description and scope of data processing

You can register on our website by entering personal data. You enter your data into an input mask. This data will then be transmitted to us and be stored. The data will not be passed on to third parties. The following data is collected as part of the registration process:

  • Name
  • Address
  • Email

The following data will also be stored at the time of registration:

  • Your IP address
  • Data protection date and time of your registration

During the registration process, we obtain your consent to the processing of this data.

2. Legal basis for data processing

For the processing of the data, the user’s consent in accordance with Art. 6 para. 1 lit. a GDPR constitutes the necessary legal basis.

In addition, Art. 6 para. 1 lit. b GDPR constitutes the necessary legal basis for the processing of your data insofar as the registration serves the fulfilment of a contract with you or the implementation of pre-contractual measures.

3. Purpose of the data processing

Your personal data will be processed in compliance with the requirements of the GDPR and the BDSG.

  • a) for the fulfilment of a contract (Art. 6 para. 1 b GDPR)

    We process your data only in order to provide you with banking transactions and financial services for the fulfilment of contracts or to carry out pre-contractual measures on request.

    Data processing depends on the specific purpose or the product you have requested. For example, this can be the establishment of a depot, the execution of deposits, the granting of loans, etc.. The purpose may therefore also include the execution of transactions, the determination of requirements, asset analyses, asset management and advice. Further details regarding data processing purposes can be found at any time in the applicable contract documents and terms and conditions.

  • b) within the scope of balancing interests (Art. 6 para. 1 f GDPR)

    Beyond the fulfilment of the contract, we only process your data insofar as this is unavoidable to safeguard the legitimate interests of us or third parties. Examples:

    • Prevention and clarification of criminal offences
    • Assertion of legal claims and defense in legal disputes
    • Inquiry and data exchange with credit agencies (e.g. SCHUFA) for the analysis of creditworthiness and default risks in credit business
    • Measures for building and plant security (e.g. access controls)
    • Examination and optimization of procedures for business management and further development of services and products
    • Video surveillance to ensure the right of residence and to collect evidence in cases of robbery and fraud
  • c) based on your consent (Art. 6 para. 1 a GDPR)

    For one or more specific purposes, you can give us permission to process personal data (for example, to receive the newsletter or to evaluate traffic data for advertising purposes). In this case, the processing of your data based on your consent is lawful. You can revoke your consent at any time - including such a declaration as you made before 25 May 2018 before the GDPR came into force. The revocation of a consent only takes effect for the future and does not affect the legality of the data processed until the revocation.

  • d) based on legal obligations (Art. 6 para. 1 c GDPR) or in the public interest (Art. 6 para. 1 e GDPR)

    As a financial services provider, we are also subject to many national and European legal requirements. The purposes include, among others, identity and age verification, compliance with tax control and reporting obligations as well as fraud and money laundering prevention.

4. Duration of storage

If the data collection is no longer necessary to achieve the purpose, the data will be deleted.

This applies to the data collected during the registration process if the registration on our website is cancelled or changed.

5. Possibility of objection and removal

You can cancel the registration at any time or have the data stored about you changed at any time.

VIII. Contact form and email contact

1. Description and scope of data processing

For electronic contact we offer a contact form on our website. For its use you enter your data in the input mask. This data is then transmitted to us and stored. The following data will be collected:

  • Name, first name
  • Address
  • Email

The following data is also stored at the time the message is sent:

  • Your IP address
  • Data protection date and time of your registration

During the sending process, we obtain your consent to the processing of this data and refer to this data protection declaration.

In addition, you can contact us via the email address provided. Your personal data transmitted with the email will be stored.

The data will be used exclusively for the processing of the communication. The data processed for communication will not be passed on to third parties.

2. Legal basis for data processing

For the processing of the data, the user’s consent in accordance with Art. 6 para. 1 lit. a GDPR constitutes the necessary legal basis.

The necessary legal basis for the processing of the data is the user’s consent in accordance with Art. 6 para. 1 lit. a GDPR. If the personal data is transmitted by email, Art. 6 para. 1 lit. f GDPR constitutes the necessary legal basis for the processing of the data. If the conclusion of a contract is also intended with this establishment of contact, Art. 6 para. 1 lit. b GDPR also constitutes the necessary legal basis for the processing.

3. Purpose of the data processing

We process the personal data collected via the input mask exclusively for the purpose of processing the establishment of contact. If you contact us by email, this is also the necessary legitimate interest in the processing of the data.

In order to prevent misuse of the contact form and to secure our IT systems, we use other personal data processed during the sending process.

4. Duration of storage

If the data collection is no longer necessary to achieve the purpose, the data will be deleted. This applies to the personal data from the input mask of the contact form and those sent by email when the respective communication with you has ended. This is the case if the circumstances indicate that the facts in question have been conclusively clarified.

After a period of seven days at the latest, the other personal data additionally collected during the sending process will be deleted.

5. Possibility of objection and removal

You can revoke your consent to the processing of your personal data at any time. If you contact us by email, you can object to the storage of your personal data at any time. Please note that in this case further communication with you can no longer be continued.

To revoke your consent and to revoke the storage, please send an informal email or a postal letter to the contact person.

Personal data stored for the purpose of establishing contact will be completely deleted in this case.

IX. Passing on your data to third parties

In order to make our website as pleasant and convenient as possible for you as a user, we occasionally use the services of external service providers. Below you have the opportunity to inform yourself about the data protection regulations for the use and application of the services and functions used, in order to possibly also exercise your rights with these service providers.

1. Google Analytics

Google Analytics is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA („Google“). Google Analytics uses „cookies“, which are text files placed on your computer, to help the website analyse how users use the site. The information collected by the cookie about the use of our website (including your IP address) is generally transmitted to a Google server in the USA and stored there.

At our request, Google will only record your IP address in abbreviated form, which guarantees anonymisation and does not allow any conclusions to be drawn about your identity. If IP anonymization is activated on our websites, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

Google will use this information to evaluate your use of our websites, to compile reports on website activity for us and to provide us with other services associated with the use of websites and the Internet. The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google. A transfer of this data by Google to third parties only takes place due to legal regulations or in the context of order processing. Under no circumstances will Google combine your data with other data collected by Google.

By using this website, you consent to the processing of data about you by Google and the manner of data processing described above as well as the stated purpose. You can prevent the storage of cookies by setting your browser software accordingly. However, we would like to point out that in this case you may not be able to use all the functions of our website to their full extent.

Further information on Google Analytics and data protection can be found at https://policies.google.com/privacy?hl=de&gl=en.

2. Google-AdWords

Diese Website nutzt das Online-Werbeprogramm "Google AdWords" und im Rahmen dessen das Conversion-Tracking. Das Cookie für Conversion-Tracking wird gesetzt, wenn ein Nutzer auf eine von Google geschaltete Anzeige klickt. Diese Cookies verlieren nach 30 Tagen ihre Gültigkeit und dienen nicht der persönlichen Identifizierung. Besucht der Nutzer bestimmte Seiten dieser Website und das Cookie ist noch nicht abgelaufen, können wir und Google erkennen, dass der Nutzer auf die Anzeige geklickt hat und zu dieser Seite weitergeleitet wurde. Jeder Google AdWords-Kunde erhält ein anderes Cookie. Cookies können somit nicht über die Websites von AdWords-Kunden nachverfolgt werden.

The information collected using the conversion cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. Customers will know the total number of users who clicked on their ad and were directed to a page tagged with a conversion tracking tag. However, they will not receive information that personally identifies users. Users who do not wish to participate in tracking can easily disable the Google Conversion Tracking cookie from their Internet browser under User Preferences. These users are not included in the conversion tracking statistics. Learn more about the Google Privacy Policy on https://policies.google.com/privacy?hl=de&gl=en

3. Google Maps

Our web pages use Google Maps to display maps and to create directions. Google Maps is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. By using this website, you consent to the collection, processing and use of the data automatically collected and entered by you by Google, one of its agents or third parties. The terms of use for Google Maps can be found in the google.de Privacy Center: Transparency and Choices as well as the Privacy Policy. https://policies.google.com/privacy?hl=de&gl=en

4. Social Media Plugins

Our website uses social media plugins („plugins“) from various social networks. With the help of these plugins you can, for example, share content or recommend products. The plugins are deactivated by default on our websites and therefore do not send any data. You can activate the plugins by clicking on the „Activate social media“ button. The plugins can of course be deactivated with one click.

If these plugins are activated, your browser establishes a direct connection with the servers of the respective social network as soon as they call up a website of our Internet presence. The content of the plugin is transmitted directly from the social network to your browser and integrated into the website by it.

By integrating the plugins, the social network receives the information that you have accessed the corresponding page of our website. If you are logged in to the social network, it can assign the visit to your account. If you interact with the plugins, for example by pressing the Facebook „Like“ button or making a comment, the corresponding information is transmitted directly from your browser to the social network and stored there.

The purpose and scope of the data collection and the further processing and use of the data by social networks as well as your rights in this regard and setting options for the protection of your privacy can be found in the data protection information of the respective networks or websites. You will find the relevant links below.

Even if you are not registered with the social networks, websites with active social plugins can send data to the networks. An active plugin sets a cookie with an identifier each time the website is accessed. Since your browser sends this cookie each time you connect to a network server without being asked, the network could in principle use it to create a profile of which web pages the user belonging to the identifier has called up. And it would then also be quite possible to assign this identifier to a person again later - for example when logging on to the social network later.

We use the following plugins on our websites:

5. Google Fonts

On our website we use external fonts of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA („Google“). We have taken the greatest possible care to ensure that personal data is not passed on to Google. Nevertheless, we would like to offer you the opportunity to inform yourself about the handling of personal data in Google’s data protection regulations and to provide an opt-out link deposited by Google. https://policies.google.com/privacy?hl=de&gl=en

6. MailChimp

The newsletter is sent via "MailChimp", a newsletter distribution platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.

The e-mail addresses of our newsletter recipients, as well as their other data described in the context of this notice, are stored on the servers of MailChimp in the USA. MailChimp uses this information to send and evaluate newsletters on our behalf. Furthermore, according to its own information, MailChimp may use this data to optimise or improve its own services, e.g. for the technical optimisation of the dispatch and presentation of the newsletter or for economic purposes in order to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them or pass them on to third parties.

MailChimp's privacy policy can be found here: https://mailchimp.com/legal/privacy

Statistical survey and analysis

The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file that is retrieved from the MailChimp server when the newsletter is opened. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are first collected. This information is used to technically improve the services on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or access times.

The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our nor MailChimp's aim to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.

7. Salesforce

We use Salesforce.com (San Francisco, California, United States) as our customer contact information management system, which enables ADP to record customer and prospective customer contact information. A limited number of authorized users have access to the database as necessary to search for business information about customers and prospective new customers. Your information is hosted by SalesForce.com in the United States. Salesforce.com complies with U.S. and EU Safe Harbor principles. This means that Salesforce.com protects personal information about affected users that it receives in the United States in accordance with Safe Harbor regulations. For more information about Safe Harbor, visit the U.S. Department of Commerce's Web site at: https://www.export.gov/safeharbor/

8. YouTube

Our website uses plugins from the YouTube site operated by Google. The site is operated by YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. When you visit one of our pages equipped with a YouTube plug-in, a connection is established to YouTube’s servers. This will tell the YouTube server which of our pages you have visited. If you are logged in to your YouTube account, you allow YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account. Please see YouTube’s Privacy Policy for more information on how we handle user information. https://policies.google.com/privacy?hl=de&gl=en

  • Facebook
  • Twitter
  • XING
  • LinkedIn
  • Instagram

If you don’t want social networks to collect information about you through active plug-ins, you can either disable the social plug-ins simply by clicking on them on our websites or select the „Block third-party cookies“ function in your browser settings. Then the browser will not send cookies to the server for embedded content from other providers. With this setting, however, other functions than the plug-ins may no longer work under certain circumstances.

a) Facebook

We use plugins from the social network facebook.com, which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). The link to Facebook's Privacy Policy can be found here: Facebook Privacy Policy.

b) Twitter

We use plugins from the Twitter social network operated by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA ("Twitter"). The link to the privacy policy of Twitter can be found here: Twitter Privacy Policy.

c) Instagram

On our website we use functions of the social media network Instagram of the company Instagram LLC, 1601 Willow Rd, Menlo Park CA 94025, USA. With the functions for embedding Instagram content (Embed function) we can display pictures and videos. By accessing pages that use such functions, data (IP address, browser data, date, time, cookies) is transmitted to Instagram, stored and evaluated. If you have an Instagram account and are logged in, this information will be associated with your personal account and the information stored in it. The privacy policy about what information Instagram collects and how you use it can be found at https://help.instagram.com/519522125107875

d) XING

We use plugins of the social network XING, which is operated by XING SE, Dammtorstraße 30, 20354 Hamburg, Germany ("XING"). The link to XING's privacy policy can be found here: XING Privacy Policy.

e) LinkedIn

We use LinkedIn social networking plugins operated by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ("LinkedIn"). LinkedIn link to LinkedIn privacy policy: LinkedIn privacy notices

X. Rights of the data subject

If personal data is processed by you, you are the data subject in the sense of the GDPR. You are thus entitled to the following rights vis-à-vis the person responsible:

1. Right to information

You may request confirmation from the person responsible as to whether we process personal data relating to you.

In the event of such processing, you may request the controller to provide you with the following information:

  • the purposes of the processing;
  • the categories of personal data processed;
  • the recipients or categories of recipients to whom the personal data relating to you has been or will be disclosed;
  • if possible, the planned duration for which your personal data will be stored or, if this is not possible, the criteria for determining this duration;
  • the existence of a right to rectify or erase personal data concerning you or to have the processing limited by the controller or to object to such processing;
  • the existence of a right of appeal to a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to the source of the data;
  • the existence of automated decision-making including profiling pursuant to Art. 22 (1) and (4) GDPR 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 may also request information as to whether the personal data concerning you will be transferred to a third country or to an international organisation. If this is the case, you can request information on the appropriate guarantees in connection with the transfer in accordance with Art. 46 GDPR.

2. Right to rectification

You may request the person in charge to correct any incorrect personal data concerning you. You may also request the completion of incomplete personal data - also by means of a supplementary declaration - taking into account the purposes of the processing. The person responsible must carry out the requested correction immediately.

3. Right to cancellation („right to be forgotten“)

You may ask the data controller to delete the personal data concerning you immediately and the data controller is obliged to delete this data immediately if one of the following reasons applies:

  • Your personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
  • You revoke your consent on which the processing pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR was based and there is no other legal basis for the processing.
  • You object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate reasons for the processing or you object to the processing pursuant to Art. 21 para. 2 GDPR.
  • Your personal data have been processed unlawfully.
  • The deletion of your personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.
  • Your personal data have been collected in relation to information society services offered pursuant to Art. 8 para. 1 GDPR.

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

However, the right to deletion does not exist if the processing is required as follows

  • for the exercise of freedom of expression and information;
  • to fulfil a legal obligation which requires processing under the law of the Union or of the Member States 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;
  • for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i as well as Art. 9 para. 3 GDPR;
  • for archival purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the right of deletion described above is likely to make it impossible or seriously impair the attainment of the objectives of such processing, or
  • to assert, exercise or defend legal claims.

4. Right to limit the processing

You may request the data controller to restrict the processing of your personal data if one of the following conditions applies:

  • you have contested the accuracy of your personal data for a period of time which allows the data controller to verify the accuracy of your personal data;
  • the processing is unlawful and you refuse to delete the personal data and instead request that the use of your personal data be restricted;
  • the controller no longer needs your personal data for the purposes of processing, but you do need them for the assertion, exercise or defence of legal claims, or
  • You have objected to the processing pursuant to Art. 21 para. 1 GDPR and it is not yet clear whether the legitimate reasons of the data controller outweigh your own.

If the processing of your personal data has been restricted, such personal data may be processed only with your consent or for the purpose of asserting, exercising or defending legal rights or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the Union or of a Member State, with the exception of their storage.

If you have obtained a restriction on processing in accordance with the above conditions, you shall be informed by the controller before the restriction is lifted.

5. Right to information

If you have asserted the aforementioned rights of rectification, cancellation or limitation of processing to the data controller, the data controller must notify all recipients to whom your personal data have been disclosed of this rectification or cancellation or limitation of processing, unless this proves impossible or involves disproportionate effort.

At your request, the person responsible must inform you of these recipients.

6. 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 communicate this data to another data controller without being hindered by the controller to whom the personal data was provided, provided that

  • the processing is based on a consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and
  • processing is carried out using automated procedures.

In exercising this right, you also have the right to obtain that your personal data be transferred directly from one responsible party to another responsible party, insofar as this is technically feasible.

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

Similarly, the right to data transfer must not affect the rights and freedoms of other persons.

7. Right of objection

You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions.

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

If your personal data are processed for the purpose of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is connected with such direct advertising.

If you object to the processing for purposes of direct marketing, your personal data will no longer be processed for these purposes.

Notwithstanding Directive 2002/58/EC, you may exercise your right to object to the use of Information Society services by means of automated procedures using technical specifications.

8. Right to revoke the declaration of consent under data protection law

You can revoke your declaration of consent under data protection law at any time. The revocation of your consent does not affect the legality of the processing carried out based on your consent until you revoke it.

9. Automated decision in individual cases including profiling

You have the right not to be subject to any decision based solely on automated processing, including profiling, that has any legal effect on you or similarly significantly affects you.

This does not apply if the decision

  • is necessary for the conclusion or performance of a contract between you and the person responsible,
  • is authorised by legislation of the Union or of the Member States to which the person responsible is subject and contains appropriate measures to safeguard your rights and freedoms and your legitimate interests; or
  • is made with your express consent.

In the cases mentioned under a) and c), the person responsible shall take appropriate measures to protect your rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person on the part of the person responsible, to state his own position and to challenge the decision.

The decisions pursuant to a) to c) may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR unless Art. 9 para. 2 lit. a or g GDPR applies and appropriate measures have been taken to protect your rights and freedoms as well as your legitimate interests.

10. Right of complaint to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to complain to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of presumed infringement, if you consider that the processing of your personal data is contrary to the GDPR.

The supervisory authority to which the complaint was submitted shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.

XI. Timeliness and amendment of this data protection declaration

This data protection declaration is currently valid and as of September 2018.

The further development of our website and its offers or changed legal provisions or issued jurisdiction or official requirements may make it necessary to amend this privacy statement.

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