Privacy Policy
1. An overview of data protection
General information
The following information will provide you with an easy to navigate overview of what will happen with your
personal data when you visit this website. The term “personal data” comprises all data that can be used to
personally identify you. For detailed information about the subject matter of data protection, please consult
our Data Protection Declaration, which we have included beneath this copy.
Data recording on this website
Who is the responsible party for the recording of data on this website (i.e., the “controller”)?
The data on this website is processed by the operator of the website, whose contact information is available
under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this
Privacy Policy.
How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information
you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during
your website visit. This data comprises primarily technical information (e.g., web browser, operating system,
or time the site was accessed). This information is recorded automatically when you access this website.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data
may be used to analyze your user patterns.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived
personal data at any time without having to pay a fee for such disclosures. You also have the right to demand
that your data are rectified or eradicated. If you have consented to data processing, you have the option to
revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to
demand that the processing of your data be restricted under certain circumstances. Furthermore, you have
the right to log a complaint with the competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about this or any other data protection
related issues.
2. Hosting and Content Delivery Networks (CDN)
External Hosting
This website is hosted by an external service provider (host). Personal data collected on this website are
stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests,
metadata and communications, contract information, contact information, names, web page access, and
other data generated through a web site.
The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art.
6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a
professional provider (Art. 6(1)(f) GDPR).
Our host will only process your data to the extent necessary to fulfil its performance obligations and to
follow our instructions with respect to such data.
We are using the following host:
Strato AG
Pascalstraße 10
10587 Berlin
Execution of a contract data processing agreement
In order to guarantee processing in compliance with data protection regulations, we have concluded an
order processing contract with our host.
3. General information and mandatory information
Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence,
we handle your personal data as confidential information and in compliance with the statutory data
protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises
data that can be used to personally identify you. This Data Protection Declaration explains which data we
collect as well as the purposes we use this data for. It also explains how, and for which purpose the
information is collected.
We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications)
may be prone to security gaps. It is not possible to completely protect data against third-party access.
Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
Dirk-Andrè Clevert
Leharstraße 13
82166 Gräfelfing
Phone: +49-173 3637322
E-mail: Clevert(at)web.de
The controller is the natural person or legal entity that single-handedly or jointly with others makes
decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail
addresses, etc.).
Storage duration
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain
with us until the purpose for which it was collected no longer applies. If you assert a justified request for
deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally
permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the
latter case, the deletion will take place after these reasons cease to apply.
Information on data transfer to the USA and other non-EU countries
Among other things, tools of companies domiciled in the United States or other from a data protection
perspective non-secure non-EU countries, are integrated into our website. If these tools are active, your
personal data may potentially be transferred to these non-EU countries and may be processed there. We
must point out that in these countries, a data protection level that is comparable to that in the EU cannot be
guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security
agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it
cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently
archive your personal data for surveillance purposes. We have no control over these processing activities.
Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also
revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness
of any data collection that occurred prior to your revocation.
Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE
THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON
GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED
ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS
BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE
WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO
PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA,
THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE
PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION
PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING,
YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR
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THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE
EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL
DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES
(OBJECTION PURSUANT TO ART. 21(2) GDPR).
Right to log a complaint with the competent supervisory agency
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory
agency, in particular in the member state where they usually maintain their domicile, place of work or at the
place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other
administrative or court proceedings available as legal recourses.
Right to data portability
You have the right to demand that we hand over any data we automatically process on the basis of your
consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine
readable format. If you should demand the direct transfer of the data to another controller, this will be done
only if it is technically feasible.
SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or
inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption
program. You can recognize an encrypted connection by checking whether the address line of the browser
switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you have the right to at any time demand
information about your archived personal data, their source and recipients as well as the purpose of the
processing of your data. You may also have a right to have your data rectified or eradicated. If you have
questions about this subject matter or any other questions about personal data, please do not hesitate to
contact us at any time.
Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is
concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in
the following cases:
- In the event that you should dispute the correctness of your data archived by us, we will usually need
some time to verify this claim. During the time that this investigation is ongoing, you have the right to
demand that we restrict the processing of your personal data. - If the processing of your personal data was/is conducted in an unlawful manner, you have the option to
demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
If we do not need your personal data any longer and you need it to exercise, defend or claim legal
entitlements, you have the right to demand the restriction of the processing of your personal data instead
of its eradication.
If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be
weighed against each other. As long as it has not been determined whose interests prevail, you have the
right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data – with the exception of their archiving
– may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to
protect the rights of other natural persons or legal entities or for important public interest reasons cited by
the European Union or a member state of the EU.
Rejection of unsolicited e-mails
We herewith object to the use of contact information published in conjunction with the mandatory
information to be provided in our Site Notice to send us promotional and information material that we have
not expressly requested. The operators of this website and its pages reserve the express right to take legal
action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.
4. Recording of data on this website
Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not
cause any damage to your device. They are either stored temporarily for the duration of a session (session
cookies) or they are permanently archived on your device (permanent cookies). Session cookies are
automatically deleted once you terminate your visit. Permanent cookies remain archived on your device
until you actively delete them, or they are automatically eradicated by your web browser.
In some cases, it is possible that third-party cookies are stored on your device once you enter our site (thirdparty
cookies). These cookies enable you or us to take advantage of certain services offered by the third
party (e.g., cookies for the processing of payment services).
Cookies have a variety of functions. Many cookies are technically essential since certain website functions
would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The
purpose of other cookies may be the analysis of user patterns or the display of promotional messages.
Cookies, which are required for the performance of electronic communication transactions (required
cookies) or for the provision of certain functions you want to use (functional cookies, e.g., for the shopping
cart function) or those that are necessary for the optimization of the website (e.g., cookies that provide
measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a
different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to
ensure the technically error free and optimized provision of the operator’s services. If your consent to the
storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the
consent obtained (Art. 6(1)(a) GDPR); this consent may be revoked at any time.
You have the option to set up your browser in such a manner that you will be notified any time cookies are
placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of
cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies
when the browser closes. If cookies are deactivated, the functions of this website may be limited.
In the event that third-party cookies are used or if cookies are used for analytical purposes, we will
separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.
Server log files
The provider of this website and its pages automatically collects and stores information in so-called server
log files, which your browser communicates to us automatically. The information comprises:
- The type and version of browser used
- The used operating system
- Referrer URL
- The hostname of the accessing computer
- The time of the server inquiry
- The IP address
This data is not merged with other data sources.
This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest
in the technically error free depiction and the optimization of the operator’s website. In order to achieve this,
server log files must be recorded.
Contact form
If you submit inquiries to us via our contact form, the information provided in the contact form as well as any
contact information provided therein will be stored by us in order to handle your inquiry and in the event
that we have further questions. We will not share this information without your consent.
The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a
contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based
on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or
on your agreement (Art. 6(1)(a) GDPR) if this has been requested.
The information you have entered into the contact form shall remain with us until you ask us to eradicate the
data, revoke your consent to the archiving of data or if the purpose for which the information is being
archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without
prejudice to any mandatory legal provisions, in particular retention periods.
Request by e-mail, telephone, or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name,
request) will be stored and processed by us for the purpose of processing your request. We do not pass these
data on without your consent.
These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a
contract or is required for the performance of pre-contractual measures. In all other cases, the data are
processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art.
6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your
consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request).
Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
5. Plug-ins and Tools
Google Web Fonts
To ensure that fonts used on this website are uniform, this website uses so-called Web Fonts provided by
Google. When you access a page on our website, your browser will load the required web fonts into your
browser cache to correctly display text and fonts.
To do this, the browser you use will have to establish a connection with Google’s servers. As a result, Google
will learn that your IP address was used to access this website. The use of Google Web Fonts is based on Art.
6(1)(f) GDPR. The website operator has a legitimate interest in a uniform presentation of the font on the
operator’s website. If a respective declaration of consent has been obtained (e.g., consent to the archiving of
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cookies), the data will be processed exclusively on the basis of Art. 6(1)(a) GDPR. Any such consent may be
revoked at any time.
If your browser should not support Web Fonts, a standard font installed on your computer will be used.
For more information on Google Web Fonts, please follow this link:
https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under:
https://policies.google.com/privacy?hl=en.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is
Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of reCAPTCHA is to determine whether data entered on this website (e.g., information entered
into a contact form) is being provided by a human user or by an automated program. To determine this,
reCAPTCHA analyzes the behavior of the website visitors based on a variety of parameters. This analysis is
triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA
evaluates a variety of data (e.g., IP address, time the website visitor spent on the site or cursor movements
initiated by the user). The data tracked during such analyses are forwarded to Google.
reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is
underway.
Data are stored and analyzed on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate
interest in the protection of the operator’s websites against abusive automated spying and against SPAM. If
a respective declaration of consent has been obtained, the data will be processed exclusively on the basis of
Art. 6(1)(a) GDPR. Any such consent may be revoked at any time.
For more information about Google reCAPTCHA please refer to the Google Data Privacy Declaration and
Terms Of Use under the following links:
https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en.
6. eCommerce and payment service providers
Processing of data (customer and contract data)
We collect, process, and use personal data only to the extent necessary for the establishment, content
organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art.
6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual
actions. We collect, process, and use personal data concerning the use of this website (usage data) only to
the extent that this is necessary to make it possible for users to utilize the services and to bill for them.
The collected customer data shall be eradicated upon completion of the order or the termination of the
business relationship. This shall be without prejudice to any statutory retention mandates.
Data transfer upon closing of contracts for services and digital content
We share personal data with third parties only if this is necessary in conjunction with the handling of the
contract; for instance, with the financial institution tasked with the processing of payments.
Any further transfer of data shall not occur or shall only occur if you have expressly consented to the
transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for
advertising purposes, shall not occur.
The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the
fulfilment of a contract or for pre-contractual actions.
Source: eRecht24