A. Sample privacy protection policy according to the GDPR
I. Name and address of the data controller
Draisstraße 19 a-b
is the data controller as defined in the EU General Data Protection Regulation (DSGVO) and the national data privacy laws.
II. Name and address of the data protection officer
The data protection officer of the data controller is: Due to the number of data processing workstations, a data protection officer is not required.
III. General information about data processing
1. The extent to which personal data is processed
We collect and use the personal data of users of our homepage only to the extent that this is necessary for keeping our website, contents and services functioning properly.
Basically, we collect and use our users’ personal data only after they give their consent. An exception to this principle applies in cases where processing the data by statutory provisions is permitted or when obtaining prior consent for actual reasons is not possible.
2. Legal basis for processing personal data
The legal basis for processing personal data is basically based on:
• Art. 6 Section 1 lit. a GDPR upon obtaining the consent of the data subject.
• Art. 6 Section 1 lit. b GDPR for processing operations that serve to fulfill a contract to which the data subject is a party. Included here are processing operations that are necessary to carry out pre-contractual measures.
• Art. 6 Section 1 lit. c GDPR for processing required to fulfill a legal obligation.
• Art. 6 Section 1 lit. d GDPR, if vital interests of the data subject or another natural person require the processing of personal data.
• Art. 6 Section 1 lit. f GDPR, if the processing is necessary to safeguard the legitimate interests of our company or a third party, and the interests, fundamental rights and fundamental freedoms of the data subject do not outweigh the former interest.
3. Data erasure and storage duration
The personal data of users will be deleted or blocked as soon as the purpose of the storage is no longer applicable. Additional storage may be provided for by European or national legislators through EU regulations, laws or other regulations to which the data controller is subject. Blocking or deleting the data also takes place when a storage period prescribed by the standards mentioned expires, unless there is a need for additional storage of the data for concluding a contract or fulfilling the contract.
IV. Use of our website, general information
1. Description and scope of data processing
Every time our website is accessed, our system automatically collects data and information from the user’s computer system. The following information is collected:
(1) Information about the browser type and version used
(2) The user’s operating system
(3) The user’s Internet service provider
(4) The user’s IP address
(5) Date and time of access
(6) Websites the user’s system accesses to get to our website
(7) Websites that the user’s system invokes by accessing our website
The described data are stored in the log files of our system. This data is not stored together with any other personal user data.
2. Purpose and legal basis for data processing
Our system must temporarily store user IP addresses to allow us to deliver our website to the user’s computer.
To do this, the user’s IP address must be stored for the duration of the session.
Storage in log files is done to ensure the functionality of the website. In addition, the data is used to optimize the website and to ensure the security of our information technology systems. This data is not evaluated for marketing purposes in this context.
Collecting your personal data to ensure our web presence and storing this data in log files is essential for operating our website. A contradictory possibility of the user therefore does not exist.
3. Duration of storage
Your data will be deleted as soon as they are no longer necessary for achieving the purpose of the inquiry. Your data will be deleted when the session ends if your data has been collected to ensure the site’s availability.
If your data is stored in log files, it will be deleted after seven days at the latest. Further storage is possible, whereby in this case, the IP addresses of the users are deleted or alienated. This means that it is then no longer possible to assign the client who has accessed our website.
The following data is stored and transmitted:
(1) Language settings
(2) An item placed in a shopping cart
(3) Log-in information
(4) Last viewed items
The legal basis for processing personal data using cookies is defined in Article 6 Section 1 lit. f GDPR. The purpose for using technically required cookies is to simplify the use of our website.
VI. Your rights/rights of the data subject
According to the EU General Data Protection Regulation, as an affected party you have the following rights:
1. The right to receive information
As the data controller, you have the right to receive information from us regarding processing personal data involving you.
In addition, you may request information about the following:
(1) The purpose of the data processing
(2) The categories of personal data that are processed
(3) The recipients or categories of recipients to whom the personal data relating to you have been disclosed or are still being disclosed
(4) The planned duration of the storage of your personal data or, if specific information is not available, the criteria for determining the duration of storage
(5) The existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the data controller or concerned, or a right to object to such processing
(6) The existence of a right of appeal to a supervisory authority
(7) All available information on the source of the data if the personal data are not collected from the data subject
(8) The existence of automated decision-making, including profiling according to Art. 22 Section 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved as well as the scope and the intended effects of such processing on the data subject.
Finally, you also have the right to request information about whether your personal information is being transferred to a third country or to an international organization. In this case, you can obtain information about the appropriate guarantees in accordance with Art. 46 GDPR regarding such transfer.
You can claim your right to information under: firstname.lastname@example.org
2. The right to rectification
If we process your personal data incorrectly or in an incomplete manner, then you have a right for it to be corrected/completed. The correction will be made immediately.
3. Right to restriction
The right to limit the processing of your personal data may be asserted in the following cases:
(1) The accuracy of the personal data is contested for a period of time, enabling the data controller to verify the accuracy of the personal data.
(2) The processing is unlawful and deleting the personal data is rejected, whereby the restriction of the use of personal data is required.
(3) The data controller no longer needs the personal data for purposes of processing, but the data subject needs them to assert, exercise or defend legal claims, or
(4) The data subject filed an objection to the processing pursuant to Art. 21 Section 1 GDPR and it is not yet clear whether the legitimate reasons of the data controller outweighed those of the data subject.
If processing personal data concerning you has been restricted, such data—viewed separately from your data storage—may be stored only with your consent or for the purposes of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or important public interest of the Union or of a Member State.
If there is a processing restriction in accordance with the principles outlined, you will be informed by us before the restriction is lifted.
4. The right to delete
You can request that your personal data be deleted immediately if you can show the following reasons: The data controller is obligated to delete this data immediately. These reasons include:
(1) Your personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) The processing is based on a consent according to Art. 6 Section 1 lit. a or Art. 9 Section 2 lit. a GDPR protected and you revoke the consent. Another condition is that there is no other legal basis for the processing.
(3) You object to the processing (Art. 21 Section 1 GDPR) and there are no legitimate reasons for the processing. Another possibility is that you have a protest against the processing pursuant to Art. 21 Section 2 GDPR.
(4) The processing of your personal data is unlawful.
(5) Deleting personal data concerning you is required to fulfill a legal obligation under Union law or the law of the Member States to which the data controller is subject.
(6) The personal data concerning you were collected in relation to information society services offered pursuant to Art. 8 Section 1 GDPR.
If we have made personal data concerning you public and we are obligated to delete them according to Art. 17 Section 1 of the GDPR, then we shall take appropriate measures, while also taking the available technology, implementation costs and the available technology into account, to inform data controllers who process the personal data that you, as the data subject, have requested the deletion of all links to such personal data or of copies or replications of such personal data.
We would like to point out that the right to delete does not exist to the extent that processing is required:
(1) to exercise the right to freedom of expression and information
(2) to fulfill a legal obligation required by the law of the Union or of the Member States to which the controller is subject, or to carry out a task of public interest or to exercise the official authority conferred on the controller
(3) for reasons of public interest in the field of public health pursuant to Art. 9 Section 2 lit. h and i and Art. 9 (3) GDPR
(4) for archival purposes of public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 Section 1 GDPR, to the extent that the law referred to in Section (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or
(5) to assert, exercise or defend legal claims.
5. Right to information
If you have asserted the right to rectify, delete or restrict the processing, we are obligated to notify all recipients to whom your personal data have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves to be impossible or is associated with a disproportionate amount of effort. You also have the right to be informed about these recipients.
6. Right to data portability
According to the GDPR, you also have the right to obtain the personal data provided to us and to receive it in a structured, understandable and machine-readable format. Furthermore, you have the right to transfer this data to another data controller without hindrance by the data controller for providing the personal data, provided that
• the processing is based on consent as defined in Art. 6 Section 1 lit. a GDPR or Art. 9 Section 2 lit. a GDPR or on a contract acc. Art. 6 Section 1 lit. b GDPR
• and the processing is done using automated procedures.
Finally, where technically feasible and without harm to the freedoms and rights of others and as part of exercising the right of data transferability, you have the right to obtain that personal data related to you that has been transmitted directly from one controller to another.
The right to data portability does not apply to processing that personal data necessary for performing a task in the public interest or for exercising the official authority that has been delegated to the data controller.
7. Right to revoke the declaration of consent to data protection
You have the right to revoke your data protection declaration at any time. Please note that revoking consent does not affect the lawfulness of the processing carried out based on the consent until the revocation goes into effect.
8. Right to objection
Furthermore, for reasons based on your particular situation, you have the right at any time to file an objection to the processing of personal data relating to you, as it is defined in Art. 6 Section 1 lit. e or f GDPR. The right of objection also applies to profiling based on these provisions.
The data controller will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and liberties, or the processing is for enforcing, exercising or defending legal claims.
If the personal data related to you are processed for advertising purposes, then you have the right to object at any time to your personal data being processed for such advertising. This also applies to profiling, as far as it is associated with such direct marketing. Your personal data will no longer be processed for direct marketing purposes if you object to your data being used for such purposes.
You also have the option of discussing the use of information society services (despite Directive 2002/58/EC).
Exercise your right to object by using automated procedures that use technical specifications.
9. Automated decision on an individual basis, including profiling
Under the EU General Data Protection Regulation, you remain entitled not to be subjected to a decision based solely on automated processing – including profiling – which would have legal effect or would affect you in a similar manner. An exception to this principle, however, is when the decision
(1) is required for concluding or fulfilling a contract between you and the data controller,
(2) and is permissible based on Union or Member State legislation to which the controller is subject, and that legislation contains adequate measures to safeguard your rights and freedoms and your legitimate interests, or
(3) is with your express consent.
If the processing is carried out in accordance with the cases mentioned in Section 1 and 3, then the data controller shall take appropriate measures to safeguard your rights and freedoms as well as your legitimate interests. This includes at least the right to obtain the intervention of a person on the part of the data controller to state his own position and to contest the decision.
The ruling under (1) – (3) may not be based on special categories of personal data pursuant to Art. 9 Section 1 GDPR, unless Art. 9 Section 2 lit. a or g and reasonable measures have been taken to protect the rights and freedoms and your legitimate interests.
10. Right to complain to a supervisory authority
Finally, if you believe that the processing of personal data concerning you is contrary to the GDPR, you have the right to complain to a supervisory authority, in the Member State of its place of residence, employment or the location of the alleged infringement.
You can subscribe to a free newsletter on our homepage that we use to inform you about our current interesting offers. The advertised goods and services are named in the declaration of consent.
The data you enter in the online registration form will be transmitted to us.
We collect the following data based on the consent obtained during the registration process: Last name, first name, email address, The IP address of the invoking computer, the date and the hour of the registration.
Your data will not be forwarded as part of data processing involved in sending newsletters. The data will be used exclusively for sending the newsletter.
2. Double opt-in and logging
Registration for our newsletter takes place in a so-called double-opt-in procedure. After registration, you will receive an email asking you to confirm your registration. This confirmation is necessary so that nobody can register using external email addresses.
The registration for the newsletter will be logged to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address.
3. Legal basis
Legal basis for processing the data is once the consent of the user Art. 6 Section 1 lit. a GDPR has been submitted. Collecting the user’s email address aids in delivering the newsletter.
4. Cancellation, revocation and opposition
Your data will be deleted as soon as they are no longer necessary for achieving the purpose of the inquiry. Your email address will therefore be saved as long as the subscription to the newsletter is active. You may terminate subscription to the newsletter at any time by revoking your consent. There is a corresponding link in each newsletter to do this.
We would like to further point out that at any time, you are free to cancel any future processing of your personal data in accordance with the statutory requirements. pursuant to Art. 21 GDPR. You are free to object to your data being processed for direct marketing purposes.
5. Statistical survey
We would like to point out that we evaluate your user behavior when sending the newsletter. For this evaluation, the emails sent include so-called web beacons or tracking pixels that represent one-pixel image files stored on our website. For the evaluations, we link the data mentioned under Point 1 and the web beacons with your email address and an individual ID.
With the data obtained in this way, we create a user profile to tailor the newsletter to your individual interests. In doing so, we record when you read our newsletters, which links you click and from this find out what your personal interests are. We link this data with actions you have taken on our website.
You can object to this tracking at any time by clicking on the separate link provided in each email or informing us via another means of contact. Your information will be stored as long as you are subscribed to the newsletter. After logging out, we store the data purely statistically and anonymously.
VIII. Electronic contact
You will find a contact form on our homepage that you can use to contact us electronically. The data entered into the input mask are transmitted to us and stored. These data include:
The following data is also stored once the message has been sent:
(1) The user’s IP address
(2) Date and time of registration
(4) Name of Company
(5) E-Mail Address
(7) Your message
It is also possible to contact us via our provided email address. In this case, the user’s personal data transmitted by email will be stored.
A transfer of your data to third parties will not take place in this context; this data will be used exclusively for processing the communication record.
The legal basis for processing the data is in submitting user consent as defined in Art. 6 Section 1 lit. a GDPR. The legal basis for processing the data transmitted while sending an email is Article 6 Section 1 lit. f GDPR. If the email contact aims to conclude a contract, then additional legal basis for the processing is Art. 6 Section 1 lit. b GDPR.
Processing personal data in this context is solely for processing the contact. In the case of contact via email, this also includes the required legitimate interest in processing the data.
If further personal data are processed during the sending process, then they serve only to prevent misuse of the contact form and to ensure the security of our information technology systems.
Your data will be deleted as soon as they are no longer necessary for achieving the purpose of the inquiry. Regarding the personal data from the input form on the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the relevant facts have been finally clarified.
The additional personal data collected during the sending process will be deleted at the latest after a period of seven days.
You will have the opportunity to revoke your consent to the processing of personal data at any time. Even when contacting us by email, you can object to the storage of your personal data at any time. However, we would like to point out that in such a case, the conversation cannot continue.
All personal data stored while contacting will be deleted in this cas
IX. Social Media
1. Social media presence
We maintain fan pages within various social networks and platforms for communicating with customers, prospects and users who are active there and for informing them about our services.
We would like to point out that your personal data may be processed outside the European Union, which may pose risks to you (e.g. in enforcing your rights under European/German law). Please note that some US providers are certified under the Privacy Shield and are committed to respecting EU privacy standards.
These users’ data are usually processed for market research and advertising purposes. Thus, for example, user profiles are created based on the user’s behavior and interests. These usage profiles can in turn be used to do such things as place advertisements inside and outside the platforms that are allegedly in line with users’ interests. For these purposes, cookies are usually stored on the user’s computer where the user’s behavior and the user’s interests are stored. Furthermore, in the usage profiles, data can also be stored independently of the devices that the users use (this is especially true if the users are members of the respective platforms and are logged in to them).
Processing personal user data is based on our legitimate interests in an effective user information and communication with users in accordance with. Art. 6 Section 1 lit. f. GDPR. The legal basis for processing user info is Art. 6 Section a., Art. 7 GDPR, and this entails the respective providers asking users to consent to data processing (that is, that they declare their agreement, for example, by ticking a check box or clicking on a button to confirm).
Additional information about processing your personal data as well as your revocation options can be found under the links for the respective providers listed below. The assertion of information and further rights of the data subjects can likewise take place opposite the offerers, who then have only the direct access to the data of the users and have appropriate information. Of course, we are available for questions and support if you need help. Providers:
Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com
Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA Data Protection Policy: https://twitter.com/de/privacy
Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland
PrivacyShield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&s tatus=Active
XING AG, Dammtorstraße 29-32, 20354 Hamburg, Deutschland
XVI. Integration of Google Fonts
XVII. Borlabs Cookie
This website uses a Borlabs Cookie, which sets a technically necessary cookie (borlabs-cookie) to store your cookie preferences.
Borlabs Cookie does not collect any personal data.
The borlabs-cookie cookie stores the consent you have given when you entered the website. If you wish to revoke these consents, simply delete the cookie from your browser. If you re-enter/reload the website, you will be asked again for your cookie consent.