Privacy policy
We are very pleased about your interest in our company. Data protection is of a particularly high priority for the management of hey circle GmbH. The use of the Internet pages of the hey circle is possible without any indication of personal data. However, if a data subject wants to use special services of our enterprise via our website, processing of personal data could become necessary. If processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation, and in accordance with the country-specific data protection regulations applicable to the hey circle. By means of this data protection declaration, our enterprise would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this data protection declaration.
As the controller, the hey circle has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can always be subject to security vulnerabilities, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.
1. definitions
The data protection declaration of the hey circle GmbH is based on the notions used by the European Directive and Ordinance when issuing the Data Protection Regulation (DS-GVO). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
We use the following terms, among others, in this privacy policy:
a) personal data
Personal data is any information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject means any identified or identifiable natural person whose personal data are processed by the controller.
c) Processing
Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
e) Profiling
Profiling is any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person's job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
f) Pseudonymization
Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separate and is subject to technical and organizational measures to ensure that the personal data cannot be attributed to an identified or identifiable individual.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
k) Consent
Consent is any voluntary expression of will for a specific case, made by the data subject in an informed and unequivocal manner, in the form of a statement or any other clear affirmative action. Through this, the data subject indicates that they agree to the processing of their personal data concerning them.
2. Name and Address of the Data Controller
The data controller, as defined by the General Data Protection Regulation (GDPR), other data protection laws applicable in the member states of the European Union, and other provisions of a data protection nature, is:
hey circle GmbH
Arcisstraße 32
80799 Munich
Germany
Email: info@heycircle.com
Website: www.heycircle.de
3. Cookies
The websites of hey circle GmbH use cookies. Cookies are text files that are stored on a computer system through an internet browser.
Many websites and servers use cookies. Many cookies contain a unique cookie ID. A cookie ID is a unique identifier of the cookie, consisting of a string through which websites and servers can be associated with the specific internet browser in which the cookie was stored. This allows the visited websites and servers to differentiate the individual browser of the data subject from other internet browsers that may contain other cookies. A specific internet browser can be recognized and identified by the unique cookie ID.
By using cookies, hey circle GmbH can provide users of this website with more user-friendly services that would not be possible without the cookie setting.
Through a cookie, the information and offers on our website can be optimized for the benefit of the user. As mentioned before, cookies allow us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, a user of a website that uses cookies does not have to re-enter their access data each time they visit the website because this is taken over by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a cookie.
The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the used internet browser, not all functions of our website may be fully usable.
4. Collection of General Data and Information
The hey circle website collects a series of general data and information with each visit by a data subject or an automated system. This general data and information are stored in the server's log files. The following information can be recorded: (1) types and versions of browsers used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the subpages accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information that serve to avert dangers in the event of attacks on our information technology systems.
Hey circle does not draw conclusions about the data subject when using this general data and information. Instead, this information is needed to (1) deliver the contents of our website correctly, (2) optimize the content of our website and its advertising, (3) ensure the ongoing functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. This anonymously collected data and information are evaluated by hey circle both statistically and with the aim of increasing data protection and data security in our company, ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files are stored separately from all personal data provided by a data subject.
5. Subscription to Our Newsletter
On the website of hey circle GmbH, users are given the opportunity to subscribe to our company's newsletter. The personal data transmitted to the data controller when ordering the newsletter is determined by the input mask used for this purpose.
hey circle GmbH regularly informs its customers and business partners about the company's offers through a newsletter. The company's newsletter can generally only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject has registered for newsletter delivery. A confirmation email in the double-opt-in procedure is sent to the email address first entered by a data subject for newsletter delivery for legal reasons. This confirmation email serves to verify whether the owner of the email address, as the data subject, has authorized the receipt of the newsletter.
Upon newsletter registration, we also store the IP address assigned by the Internet Service Provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary to be able to trace potential misuse of a data subject's email address at a later date and therefore serves to legally safeguard the data controller.
The personal data collected during newsletter registration is exclusively used for sending our newsletter. Furthermore, newsletter subscribers may be informed by email if this is necessary for the operation of the newsletter service or related registration, such as in the case of changes to the newsletter offering or changes in technical conditions. The personal data collected within the scope of the newsletter service is not disclosed to third parties. The subscription to our newsletter can be terminated by the data subject at any time. The consent to the storage of personal data that the data subject has given us for newsletter delivery can be revoked at any time. A corresponding link can be found in every newsletter for the purpose of revoking consent. Furthermore, there is the option to unsubscribe from the newsletter delivery at any time directly on the website of the data controller or to communicate this to the data controller in another way.
6. Newsletter Tracking
The newsletters of hey circle GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in emails sent in HTML format to enable log file recording and analysis. This allows for a statistical evaluation of the success or failure of online marketing campaigns. Through the embedded tracking pixel, hey circle GmbH can recognize whether and when an email from a data subject was opened and which links contained in the email were accessed by the data subject.
Personal data collected through such tracking pixels in the newsletters are stored and analyzed by the data controller to optimize newsletter delivery and better tailor the content of future newsletters to the interests of the data subject. This personal data is not disclosed to third parties. Data subjects are at all times entitled to revoke their separate consent given through the double-opt-in procedure. After revocation, this personal data will be deleted by the data controller. Unsubscribing from receiving the newsletter is automatically considered a revocation by hey circle GmbH.
7. Contact Option via the Website
The website of hey circle includes, due to legal requirements, information that enables quick electronic contact with our company and direct communication with us, including a general email address (electronic mail address). If a data subject contacts the data controller via email or through a contact form, the personal data transmitted by the data subject is automatically stored. Personal data voluntarily provided by a data subject to the data controller is stored for the purpose of processing or communicating with the data subject. There is no disclosure of this personal data to third parties.
8. Routine Erasure and Blocking of Personal Data
The data controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or as stipulated by the European legislator or another competent legislator in laws or regulations to which the data controller is subject.
Once the purpose of storage is no longer applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely and in accordance with legal regulations blocked or deleted.
9. Rights of the Data Subject
a) Right to Confirmation
Every data subject has the right, as granted by the European legislator, to obtain confirmation from the data controller as to whether or not personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they can contact an employee of the data controller at any time.
b) Right to Information
Every data subject affected by the processing of personal data has the right, as granted by the European legislator, to obtain free information from the data controller at any time about the personal data stored about them and a copy of this information. Furthermore, the European legislator has granted the data subject the right to information about the following:
Additionally, the data subject has the right to know whether personal data has been transferred to a third country or an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards related to the transfer.
If a data subject wishes to exercise this right to information, they can contact an employee of the data controller at any time.
c) Right to Rectification
Every data subject affected by the processing of personal data has the right, as granted by the European legislator, to demand the immediate correction of inaccurate personal data concerning them. The data subject also has the right, taking into account the purposes of processing, to request the completion of incomplete personal data — even by means of a supplementary statement.
If a data subject wishes to exercise this right to rectification, they can contact an employee of the data controller at any time.
d) Right to Erasure (Right to be Forgotten)
The data subject revokes their consent on which the processing according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR was based, and there is no other legal basis for the processing.
The data subject objects to the processing according to Art. 21(1) GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing according to Art. 21(2) GDPR.
The personal data has been unlawfully processed.
The erasure of personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
The personal data has been collected in relation to the offer of information society services according to Art. 8(1) GDPR.
Any data subject affected by the processing of personal data has the right, granted by the European legislator, to demand from the controller the immediate erasure of personal data concerning them if one of the following reasons applies and the processing is not necessary:
If one of the above-mentioned reasons applies, and a data subject wishes to request the erasure of personal data stored by hey circle, they can contact an employee of the data controller at any time. The employee of hey circle will arrange for the request to be promptly complied with.
If hey circle has made the personal data public and is obligated, as the controller according to Art. 17(1) GDPR, to erase the personal data, hey circle, taking into account available technology and implementation costs, will take reasonable steps, including technical measures, to inform other data controllers processing the published personal data that the data subject has requested the erasure of all links to this personal data or copies or replications of this personal data, to the extent that processing is not required. The employee of hey circle will arrange for the necessary measures on a case-by-case basis.
e) Right to Restriction of Processing
Any data subject affected by the processing of personal data has the right, granted by the European legislator, to demand from the controller the restriction of processing if one of the following conditions is met:
If one of the above-mentioned conditions is met, and a data subject wishes to request the restriction of personal data stored by hey circle, they can contact an employee of the data controller at any time. The employee of hey circle will arrange for the restriction of processing.
The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful, and the data subject opposes the erasure of the personal data and requests instead the restriction of its use.
The controller no longer needs the personal data for the purposes of processing, but the data subject requires them for the establishment, exercise, or defense of legal claims.
The data subject has objected to processing pursuant to Art. 21(1) GDPR, pending the verification whether the legitimate grounds of the controller override those of the data subject.
f) Right to Data Portability
Any data subject affected by the processing of personal data has the right, granted by the European legislator, to receive the personal data concerning them, which was provided to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to which the personal data was provided, as long as the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising their right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
To exercise the right to data portability, the data subject can contact an employee of hey circle at any time.
g) Right to Object
Any data subject affected by the processing of personal data has the right, granted by the European legislator, to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them based on Art. 6(1)(e) or (f) GDPR, including profiling based on those provisions.
hey circle will no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.
If hey circle processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing. If the data subject objects to hey circle processing for direct marketing purposes, hey circle will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them by hey circle for scientific or historical research purposes, or for statistical purposes pursuant to Art. 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the data subject can directly contact any employee of hey circle or another employee. The data subject is also free, in the context of the use of information society services, notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Every data subject affected by the processing of personal data has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is made with the explicit consent of the data subject.
If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) it is made with the explicit consent of the data subject, hey circle shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.
If a data subject wants to assert rights relating to automated decisions, they can contact an employee of the data controller at any time.
i) Right to withdraw consent for data protection
Every data subject affected by the processing of personal data has the right, granted by the European legislator, to withdraw consent to the processing of personal data at any time.
If a data subject wants to exercise their right to withdraw consent, they can contact an employee of the data controller at any time.
10. Data protection in job applications and in the application process
The data controller collects and processes the personal data of applicants for the purpose of handling the application process. The processing can also be carried out electronically. This is particularly the case if an applicant submits corresponding application documents electronically, for example, by email or through a web form on the website, to the data controller. If the data controller concludes an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the data controller, the application documents will be automatically deleted two months after the announcement of the rejection decision, provided that no other legitimate interests of the data controller stand in the way of deletion. Other legitimate interest in this sense is, for example, a duty of proof in proceedings under the General Equal Treatment Act (AGG).
11. Data protection provisions on the use and application of Google Analytics (with anonymization function)
The data controller has integrated the Google Analytics component (with anonymization function) into this website. Google Analytics is a web analytics service. Web analytics involves the collection, gathering, and evaluation of data about the behavior of visitors to websites. A web analytics service collects, among other things, data on which website a data subject has come to a website from (so-called referrers), which subpages of the website were accessed, or how often and for what duration a subpage was viewed. Web analytics is mainly used for the optimization of a website and the cost-benefit analysis of internet advertising.
The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The data controller uses the "_gat._anonymizeIp" addition for web analytics via Google Analytics. By means of this addition, the IP address of the data subject's internet connection is truncated and anonymized by Google when accessing our websites from a member state of the European Union or another signatory state to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, among other things, to evaluate the use of our website, to provide us with online reports that show the activities on our websites, and to provide other services related to the use of our website.
Google Analytics sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyze the use of our website. Each time one of the individual pages of this website, which is operated by the data controller and on which a Google Analytics component is integrated, is called up, the internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google gains knowledge of personal data, such as the IP address of the data subject, which serves Google, among other things, to trace the origin of visitors and clicks and subsequently enable commission settlements.
Using the cookie, personal information, such as the access time, the place from which access originated, and the frequency of visits to our website by the data subject, is stored. Each time our websites are visited, this personal data, including the IP address of the data subject's internet connection, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may, under certain circumstances, disclose this personally identifiable information collected through the technical process to third parties.
The data subject can prevent the setting of cookies by our website, as described above, at any time by adjusting the settings of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from placing a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.
Furthermore, the data subject has the option to object to the collection of data generated by Google Analytics related to the use of this website and the processing of this data by Google, and to prevent such. To do this, the data subject must download and install a browser add-on available at the following link: https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information about visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered a contradiction by Google. If the information technology system of the data subject is deleted, formatted, or reinstalled at a later time, the data subject must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their control, there is the option of reinstalling or reactivating the browser add-on.
Further information and the applicable privacy policies of Google can be accessed at https://www.google.de/intl/de/policies/privacy/ and http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail under this link: https://www.google.com/intl/de_de/analytics/.
12. Data protection provisions for the use of Instagram
The data controller has integrated components of the Instagram service on this website. Instagram is a service that qualifies as an audiovisual platform, allowing users to share photos and videos and further distribute such data on other social networks.
The operator of Instagram services is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.
With each visit to one of the individual pages of this website operated by the data controller and on which an Instagram component (Insta button) has been integrated, the internet browser on the data subject's information technology system is automatically prompted by the respective Instagram component to download a representation of the corresponding Instagram component. As part of this technical process, Instagram becomes aware of which specific subpage of our website is visited by the data subject.
If the data subject is simultaneously logged into Instagram, Instagram recognizes with each visit to our website by the data subject and throughout the duration of their stay on our website which specific subpage the data subject is visiting. This information is collected by the Instagram component and assigned to the respective Instagram account of the data subject by Instagram. If the data subject clicks on one of the integrated Instagram buttons on our website, the data and information transferred with it are assigned to the personal Instagram user account of the data subject and stored and processed by Instagram.
Instagram always receives information via the Instagram component when the data subject has visited our website if the data subject is logged into Instagram at the time of visiting our website; this happens regardless of whether the data subject clicks on the Instagram component or not. If the data subject does not want such information to be transmitted to Instagram, they can prevent the transmission by logging out of their Instagram account before visiting our website.
Further information and the applicable privacy policies of Instagram can be found at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.
13. Data protection provisions for the use of LinkedIn
The data controller has integrated components of LinkedIn Corporation on this website. LinkedIn is an internet-based social network that allows users to connect with existing business contacts and establish new business contacts. Over 400 million registered individuals use LinkedIn in more than 200 countries. LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.
The operator of LinkedIn is the LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA. For data protection matters outside the USA, LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.
With each individual access to our website, which is equipped with a LinkedIn component (LinkedIn plug-in), this component causes the browser used by the data subject to download a corresponding display of the LinkedIn component. Further information on LinkedIn plug-ins can be found at https://developer.linkedin.com/plugins. As part of this technical process, LinkedIn becomes aware of which specific subpage of our website is visited by the data subject.
If the data subject is simultaneously logged into LinkedIn, LinkedIn recognizes with each access to our website by the data subject and throughout the duration of their stay on our website which specific subpage of our website the data subject is visiting. This information is collected by the LinkedIn component and assigned to the respective LinkedIn account of the data subject by LinkedIn. If the data subject clicks on one of the LinkedIn buttons integrated on our website, LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores and processes this personal data.
LinkedIn always receives information via the LinkedIn component when the data subject has visited our website if the data subject is logged into LinkedIn at the time of accessing our website; this happens regardless of whether the data subject clicks on the LinkedIn component or not. If the data subject does not want such information to be transmitted to LinkedIn, they can prevent the transmission by logging out of their LinkedIn account before visiting our website.
LinkedIn offers the option to unsubscribe from email messages, SMS messages, and targeted ads, as well as manage ad settings, at https://www.linkedin.com/psettings/guest-controls. LinkedIn also uses partners such as Quantcast, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame, which may set cookies. Such cookies can be rejected at https://www.linkedin.com/legal/cookie-policy. The applicable privacy policies of LinkedIn can be found at https://www.linkedin.com/legal/privacy-policy. The LinkedIn cookie policy is available at https://www.linkedin.com/legal/cookie-policy.
14. Legal basis for processing
Art. 6 I lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary for carrying out pre-contractual measures, for example, in the case of inquiries about our products or services. If our company is subject to a legal obligation requiring the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data, or other vital information had to be passed on to a doctor, hospital, or other third party. Then the processing would be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject do not prevail. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a customer of the data controller (Recital 47 Sentence 2 GDPR).
15. Legitimate interests in processing pursued by the controller or a third party
If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and shareholders.
16. Duration for which the personal data is stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After the expiration of the period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfillment or initiation of a contract.
17. Legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision
We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual regulations (e.g., information on the contractual partner). Sometimes it may be necessary for a data subject to provide us with personal data that must subsequently be processed by us.
The data subject, for example, is obligated to provide us with personal data if our company enters into a contract with them. Failure to provide personal data would result in the contract with the data subject not being concluded. Before providing personal data, the data subject must contact one of our employees. Our employee informs the data subject on a case-by-case basis whether the provision of personal data is legally or contractually required, whether there is an obligation to provide personal data, and what consequences the failure to provide personal data would have.
18. Existence of automated decision-making
As a responsible company, we refrain from automated decision-making or profiling.