I Name and address of the person responsible
The person responsible within the meaning of the Basic Data Protection Regulation and other national data protection laws of the member states as well as other data protection provisions is:
Dr. Frühwein & Partner, GF: Dr. Markus Frühwein
Brienner Strasse 11
80333 Munich, Germany
Phone: +49 (0)89 – 223523
Fax. +49 (0)89 – 2283645
II. Name and address of the Data Protection Officer
The data protection officer of the person responsible is still to be appointed.
III General information on data processing
scope of processing of personal data
We collect and use the personal data of our users only to the extent necessary to provide a functional website and our content and services. The collection and use of personal data of our users takes place regularly only with the consent of the user. An exception applies in those cases in which it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by statutory provisions.
- legal basis for the processing of personal data
Where we obtain the consent of the data subject for the processing of personal data, Article 6(1)(a) of the EU Basic Data Protection Regulation (DSGVO) serves as the legal basis for the processing of personal data.
Art. 6 para. 1 lit. b DSGVO serves as the legal basis for the processing of personal data required for the performance of a contract to which the data subject is a party. This also applies to processing operations that are necessary for the implementation of pre-contractual measures.
Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c DSGVO serves as the legal basis.
Art. 6 para. 1 lit. d DSGVO serves as a legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data.
If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and fundamental freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f DSGVO serves as the legal basis for the processing.
- data deletion and storage period
The personal data of the person concerned will be deleted or blocked as soon as the purpose of storage no longer applies. In addition, the data may be stored if the European or national legislator has provided for this in EU regulations, laws or other provisions to which the person responsible is subject. The data shall also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless it is necessary for further storage of the data for the conclusion or performance of a contract.
IV Provision of the website and creation of log files
- description and scope of data processing
Each time you access our website, our system automatically collects data and information from the computer system of the accessing computer.
The following data is collected:
(1) Information about the browser type and the version used
(2) The user’s operating system
(3) The User’s Internet Service Provider
(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 Website
The data is also stored in the log files of our system. This does not affect the user’s IP address or other data that enables the data to be assigned to a user. These data are not stored together with other personal data of the user.
- legal basis for data processing
The legal basis for the temporary storage of data is Art. 6 para. 1 lit. f DSGVO.
- 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 IP address of the user must remain stored for the duration of the session.
These purposes also include our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f DSGVO.
- duration of storage
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data to provide the website, this is the case when the session in question has ended.
- possibility of objection and removal
The collection of data for the provision of the Website and
- possibility of objection and removal
The collection of data for the provision of the website and the storage of 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
Only language settings are stored and transmitted as data in the cookies.
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 pseudonymised by technical precautions. It is therefore no longer possible to assign the data to the calling user. The data are not stored together with other personal data of the user.
- b) Legal basis for data processing
The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f DSGVO.
- c) Purpose of data processing
We need cookies for the following applications:
(1) Google Analytics
(2) Google Maps
(3) Google WebFonts
The user data collected by 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. The analysis cookies tell us how the website is used and enable us to continually optimise our services.
Visits to the website are counted in order to evaluate the success of the website.
Our legitimate interest in the processing of personal data pursuant to Art. 6 Para. 1 lit. f DSGVO also lies in these purposes.
- d) Duration of storage, objection and removal options
- contact form and e-mail contact
- 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 this opportunity, the data entered in the input mask will be transmitted to us and stored. These data are:
(1) Your name
(2) Your e-mail adress
(4) Your message
(5) Date and time of dispatch
Your consent will be obtained for the processing of the data as part of the sending process and reference will be made to this data protection declaration.
Alternatively, you can contact us via the e-mail address, provided. In this case the personal data of the user transmitted with the e-mail will be stored.
In this context, it does not pursue the passing on of data to third parties. The data will be used exclusively for the processing of the conversation.
- legal basis for the data processing
The legal basis for the processing of the data is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f DSGVO. If the purpose of the e-mail contact is to conclude a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO.
3 Purpose of data processing
The processing of the personal data from the input mask serves us exclusively for the processing of the establishment of contact. If you contact us by e-mail, this is also the necessary legitimate interest in the processing of the data.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
- duration of storage
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were 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 terminated when it can be inferred from the circumstances that the relevant facts have been conclusively clarified.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
- possibility of objection and removal
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 analysis service provided by Google Inc. (“Google”). It is used on the basis of Art. 6 Para. 1 S. 1 lit. f. DSGVO. 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 combined 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 in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield – https://www.privacyshield.gov/EU-US-Framework.
(4) You can also prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) as well as Google from processing this data by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en. As an alternative to browser add-ons, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting this data by clicking here to opt-out of Google Analytics. An opt-out cookie is set to prevent your data from being collected in the future when you visit 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 evaluate data from double-click cookies and AdWords for statistical purposes. If you do not wish this to happen, you can deactivate it using the ad preferences manager (http://www.google.com/settings/ads/onweb/?hl=en).
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 referred to as “Google”, on our site.
Google sets a cookie each time the “Google Maps” component is called up in order to process user settings and data when the page on which the “Google Maps” component is integrated is displayed. As a rule, this cookie is not deleted when you close your browser, but expires after a certain period of time unless you delete it manually beforehand.
If you do not agree with this processing of your data, it is possible to deactivate the “Google Maps” service and thus prevent the transmission of data to Google. To do this, you must deactivate the Java Script function in your browser. However, we would like to point out that in this case you cannot use “Google Maps” or can only use it to a limited extent.
and the additional terms and conditions for Google Maps.
- Google Web Fonts
This page 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 are using, must connect to Google’s servers.
This enables Google to know that your IP address has been used to access our website.
The use of Google Web Fonts is in the interest of a uniform and appealing presentation of our online services.
This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO.
If your browser does not support web fonts, a standard font will be used by your computer.
- Legitime Rights of data subjects
If personal data is processed by you, you are the data subject within the meaning of the DSGVO and you are entitled to the following rights vis-à-vis the person responsible:
- right to information
You can request confirmation from the person responsible as to whether personal data relating to you will be processed by us.
In the event of such processing, you may request the following information from the data controller:
(1) the purposes for which the personal data will be processed;
(2) the categories of personal data processed;
(3) the recipients or categories of recipients to whom the personal data relating to you has been or will be disclosed;
(4) the planned duration of the retention of the personal data relating to you or, if it is not possible to provide specific information in this regard, criteria for determining the retention period;
(5) the existence of a right to rectify or delete personal data concerning you, a right to limit the processing by the controller 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 origin of the data, if the personal data are not collected from the data subject;
(8) the existence of automated decision-making including profiling in accordance with Art. 22 (1) and (4) DSGVO 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 have the right to request information, as to whether the personal data concerning you will be transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 DSGVO in connection with the transfer of your personal data.
- right to rectification
You have the right to have your personal data corrected and/or completed by the data controller if the personal data processed concerning you is inaccurate or incomplete. The data controller must carry out the rectification immediately.
- the right to limit the processing
Under the following conditions, you may request that the processing of your personal data be restricted:
(1) if you dispute the accuracy of the personal data concerning you for a period of time which allows the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you refuse to erase the personal data and instead request that the use of the personal data be restricted;
(3) the controller no longer needs the personal data for the purposes of the processing, but you need them for the assertion, exercise or defence of legal claims, or
(4) if you have objected to the processing pursuant to Art. 21 para. 1 DSGVO and it has not yet been established whether the legitimate reasons of the data controller outweigh your reasons.
If the processing of personal data concerning you has been restricted, such data – apart from their storage – may only be processed with your consent or for the assertion, exercise or defence of legal claims 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 a Member State.
If the processing restriction has been limited in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
- right to cancellation
(a) Duty to delete
You may request 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:
1) Personal data relating to you shall no longer be necessary for the purposes for which they were collected or otherwise processed.
(2) You revoke your consent on which the processing pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a DSGVO was based and there is no other legal basis for the processing.
(3) You object to the processing pursuant to Art. 21 para. 1 DSGVO and there are no overriding legitimate reasons for the processing or you object to the processing pursuant to Art. 21 para. 2 DSGVO.
(4) The personal data concerning you have been processed unlawfully.
(5) 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.
(6) The personal data relating to you have been collected in relation to information society services offered pursuant to Article 8(1) DSGVO.
- b) Information to third parties
If the person responsible has made the personal data concerning you public and is obliged to delete them in accordance with Art. 17 (1) DSGVO, he shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform the persons responsible for data processing who process the personal data that you, as the person concerned, have requested them to delete all links to this personal data or copies or replications of this personal data.
- c) Exceptions
The right to deletion does not exist if the processing is necessary.
(1) the exercise of freedom of expression and information;
(2) to fulfil a legal obligation which processing is subject to 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;
(3) 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 DSGVO;
(4) for archive purposes in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 DSGVO, insofar as the law referred to under a) is likely to make it impossible or seriously impair the attainment of the objectives of such processing, or
(5) to assert, exercise or defend legal claims.
- right to information
Do you have the right to rectify, cancel or limit the processing in relation to the data subject?
- right to information
If you have exercised your right to rectify, cancel or limit the processing of your personal data against the controller, the latter is obliged to notify all recipients to whom the personal data concerning you have been disclosed of such rectification, cancellation or limitation, unless this proves impossible or involves a disproportionate effort.
You have the right to be informed of such recipients by the data controller.
6 Right to data transfer
You have the right to receive the personal data concerning you that you have provided to the responsible person in a structured, common and machine-readable format. In addition, you have the right to communicate these data to another data controller without being hindered by the controller to whom the personal data was provided, provided that
(1) the processing is based on a consent pursuant to Art. 6 para. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to Art. 6 para. 1 lit. b DSGVO and
(2) the processing is carried out by automated means.
In exercising this right, you also have the right to request that the personal data concerning you be transferred directly from one responsible person to another responsible person, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.
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.
- 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 DSGVO; this also applies to profiling based on these provisions.
The person responsible will no longer process the personal data concerning you 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 the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is connected with such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes.
You have the possibility to exercise your right of objection through automated procedures using technical specifications in connection with the use of Information Society services, notwithstanding Directive 2002/58/EC.
- 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 your consent does not affect the legality of the processing carried out on the basis of 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
(1) is necessary for the conclusion or performance of a contract between you and the person responsible,
(2) 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
(3) 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 as well as your legitimate interests.
With regard to the cases mentioned in (1) and (3), the person responsible shall take appropriate measures to protect the rights and freedoms as well as your legitimate interests, which shall at least include the right to obtain the intervention of a person on the part of the person responsible, to state his or her own position and to contest the decision.
- right of appeal to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of presumed infringement, if you consider that the processing of your personal data is in breach of the DSGVO.
The supervisory authority with which the complaint was lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 DSGVO.