I. Name and address of the responsible person
The responsible person within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is:
Dr. Frühwein & Partner, GF: Dr. Markus Frühwein
Brienner Straße 11
Tel. +49 (0)89 – 223523
Fax. +49 (0)89 – 2283645
II. Name and address of the data protection officer
The data protection officer of the controller is:
Philip Knoll / Knoll IT Consulting
III. General information on data processing
1. scope of the processing of personal data
As a matter of principle, we collect and use personal data of our users only to the extent that this is necessary for the provision of a functional website as well as our content and services. The collection and use of personal data of our users is regularly carried out only with the consent of the user. An exception applies in those cases in which obtaining prior consent is not possible for factual reasons and the processing of the data is permitted by legal regulations.
2. legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) as the legal basis for the processing of personal data.
When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b DSGVO as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.
Insofar as the processing of personal data is necessary for the fulfillment of a legal obligation to which our company is subject, Art. 6 para. 1 lit. c DSGVO as the legal basis.
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as the legal basis.
If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 para. 1 lit. f DSGVO as the legal basis for the processing.
3. data deletion and storage period
The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage ceases to apply. In addition, storage may take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion or fulfillment of a contract.
IV. Provision of the website and creation of log files
1. description and scope of data processing
Each time you visit our website, our system automatically collects data and information from the computer system of the calling computer.
The following data is collected:
(1) Information about the browser type and version used.
(2) The operating system of the user
(3) The Internet service provider of the user
(4) The IP address of the user is stored anonymously
(5) Date and time of access
(6) Websites from which the user’s system accesses our Internet site
The data is also stored in the log files of our system. This does not affect the IP addresses of the user or other data that allow the data to be assigned to a user. This data is not stored together with other personal data of the user.
2. legal basis for data processing
The legal basis for the temporary storage of the data is Art. 6 para. 1 lit. f GDPR.
3. purpose of data processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.
These purposes are also our legitimate interest in data processing according to Art. 6 para. 1 lit. f GDPR.
4. duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
5. possibility of objection and elimination
The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. Consequently, there is no possibility for the user to object.
a) Description and scope of data processing
In the cookies, only language settings are stored and transmitted as data.
In this way, the following data can be transmitted:
(1) Frequency of page views
(2) Country of origin
(3) Operating system
(4) Browser, browser version
(7) Device type
The user data collected in this way is pseudonymized by technical precautions. Therefore, an assignment of the data to the calling user is no longer possible. The data is not stored together with other personal data of the users.
b) Legal basis for data processing
The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.
c) Purpose of the data processing
We need cookies for the following applications:
(1) Google Analytics
(2) Google Maps
(3) Google WebFonts
The user data collected through technically necessary cookies are not used to create user profiles.
The analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus constantly optimize our offer.
This involves counting visits to the website in order to evaluate its success.
In these purposes also lies our legitimate interest in the processing of personal data pursuant to Art. 6 para. 1 lit. f GDPR.
d) Duration of storage, possibility of objection and elimination
VI. contact form and e-mail contact
1. description and scope of data processing
A contact form is available on our website, which can be used for electronic contact. If a user takes advantage of this option, the data entered in the input mask will be transmitted to us and stored. These data are:
(1) Your name
(2) Your e-mail address
(4) Your message
(5) Date and time of shipment
Alternatively, it is possible to contact us via the e-mail address provided. In this case, the user’s personal data transmitted with the e-mail will be stored.
It does not pursue in this context any disclosure of data to third parties. The data will be used exclusively for the processing of the conversation.
2. legal basis for data processing
The legal basis for the processing of the data, if the user has given his consent, is Art. 6 para. 1 lit. a GDPR.
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.
3. purpose of data processing
The processing of personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.
The other personal data processed during the submission process are used to prevent misuse of the contact form and to ensure the security of our information technology systems.
4. duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is ended when the circumstances indicate that the matter in question has been conclusively clarified.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
5. possibility of objection and elimination
The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.
The objection can be made by e-mail or in text form.
All personal data stored in the course of contacting us will be deleted in this case.
VII Google Analytics
(1) This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). The use is made on the basis of Art. 6 para. 1 p. 1 lit. f. GDPR. Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website such as
– Browser type/version,
– operating system used,
– Referrer URL (the previously visited page),
– Host name of the accessing computer (IP address),
– Time of the server request,
are usually transferred to a Google server in the USA and stored there. The IP address transmitted by your browser as part of Google Analytics is not merged with other data from Google. We have also added the code “anonymizeIP” to Google Analytics on this website. This guarantees the masking of your IP address so that all data is collected anonymously. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
(2) For the exceptional cases where personal data is transferred to the US, Google has submitted to the EU-US Privacy Shield – https://www.privacyshield.gov/EU-US-Framework.
(4) You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de. As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent the collection by Google Analytics by clicking here Click here to opt-out of Google Analytics. An opt-out cookie is set that prevents future collection of your data when visiting this website. The opt-out cookie is only valid in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.
(5) We continue to use Google Analytics to analyze data from Double-Click-Cookies and also AdWords for statistical purposes. If you do not want this, you can deactivate it via the Ads Preferences Manager (http://www.google.com/settings/ads/onweb/?hl=de).
VIII Use of Google Maps
We use the component “Google Maps” of the company Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter “Google”, on our website.
With each individual call of the “Google Maps” component, a cookie is set by Google in order to process user settings and data when displaying the page on which the “Google Maps” component is integrated. This cookie is usually not deleted by closing the browser, but expires after a certain time, unless you delete it manually beforehand.
If you do not agree with this processing of your data, you have the option of deactivating the “Google Maps” service and thus preventing the transfer of data to Google. To do this, you must disable the Java Script function in your browser. However, we would like to point out that in this case you will not be able to use “Google Maps” or only to a limited extent.
and the additional terms and conditions for “Google Maps
IX. Google Web Fonts
This site uses so-called web fonts provided by Google for the uniform display of fonts.
When you call up a page, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly.
For this purpose, the browser you use must connect to Google’s servers.
This gives Google knowledge that our website was accessed via your IP address.
Google Web Fonts are used in the interest of a uniform and appealing presentation of our online offers.
This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.
If your browser does not support web fonts, a default font is used by your computer.
X. Rights of the data subject
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
1. right to information
You may request confirmation from the controller as to whether personal data concerning you is being processed by us.
If there is such processing, you can request information from the controller about the following:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data which are processed;
(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
(4) the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage duration;
(5) the existence of a right to rectify or erase the personal data concerning you, a right to have the controller restrict the processing, or a right to object to such processing;
(6) the existence of a right of appeal to a supervisory authority;
(7) any available information on the origin of the data, if the personal data are not collected from the data subject;
(8) the existence of automated decision making including profiling pursuant to Art. 22 para. 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information on whether personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to. Article 46 of the GDPR in connection with the transfer.
2. right to rectification
You have a right to rectification and/or completion vis-à-vis the data controller, insofar as the personal data processed concerning you are inaccurate or incomplete. The responsible party shall make the correction without undue delay.
3. right to restriction of processing
Under the following conditions, you may request the restriction of the processing of personal data concerning you:
(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
(3) the controller no longer needs the personal data for the purposes of processing, but you need them for the assertion, exercise or defense of legal claims; or
(4) if you object to the processing pursuant to Art. 21 para. 1 DSGVO and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.
Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of their storage, only with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
4. right to deletion
a) Obligation to delete
You may request the controller to delete the personal data concerning you without undue delay, and the controller is obliged to delete such data without undue delay, if one of the following reasons applies:
(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You revoke your consent on which the processing according to. Art. 6 par. 1 lit. a or Art. 9 para. 2 lit. a GDPR and there is no other legal basis for the processing.
(3) They shall lay down in accordance with Art. 21 par. 1 DSGVO and there are no overriding legitimate grounds for the processing, or you lodge an objection to the processing pursuant to Art. Art. 21 par. 2 DSGVO to object to the processing.
(4) The personal data concerning you have been processed unlawfully.
(5) The deletion of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
(6) The personal data concerning you have been processed in relation to information society services offered pursuant to Art. 8 para. 1 DSGVO collected.
b) Information to third parties
If the controller has made the personal data concerning you public and is responsible pursuant to. Art. 17 par. 1 DSGVO to erase them, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers processing the personal data that you, as data subject, have requested erasure of all links to or copies or replications of such personal data.
The right to erasure does not exist insofar as the processing is necessary to
(1) to exercise the right to freedom of expression and information;
(2) for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the field of public health pursuant to Art. 9 par. 2 lit. h and i and Art. 9 para. 3 GDPR;
(4) for archival purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to. Art. 89 par. 1 GDPR, insofar as the right referred to in Section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
(5) to assert, exercise or defend legal claims.
5. right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right to be informed about these recipients by the data controller.
6. right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that
(1) the processing is based on consent pursuant to. Art. 6 par. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to. Art. 6 par. 1 lit. b DSGVO is based and
(2) the processing is carried out with the aid of automated procedures.
In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.
The right to data portability does not apply to 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.
7. right of objection
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.
If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures using technical specifications.
8. right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
9. automated decision in individual cases including profiling
You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
(1) is necessary for the conclusion or performance of a contract between you and the controller,
(2) is permitted by legislation of the Union or the Member States to which the controller is subject and that legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests; or
(3) is done with your express consent.
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 DSGVO, unless Art. 9 para. 2 lit. a or g applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.
With regard to the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms of, and the legitimate interests of, the data subject, which shall include, at least, the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.
10. right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.