Data Protection

We are delighted that you have taken an interest in our company. Data protection is a top priority for the management of Verus-Klinik GmbH. In principle, it is possible to use the Verus-Klinik GmbH website without providing any personal data. However, should a data subject wish to make use of specific services offered by our company via our website, the processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally seek the consent of the data subject.

The processing of personal data – such as a data subject’s name, address, email address or telephone number – is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to Verus-Klinik GmbH. Through this privacy policy, our company aims to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, this privacy policy informs data subjects of their rights.

Verus-Klinik GmbH, as the data controller, has implemented numerous technical and organisational measures to ensure the most comprehensive possible protection of the personal data processed via this website. However, internet-based data transmissions may, in principle, be subject to security vulnerabilities, meaning that absolute protection cannot be guaranteed. For this reason, any data subject is free to provide us with personal data via alternative means, such as by telephone.

1. Definitions

Verus-Klinik GmbH’s privacy policy is based on the terminology used by the European legislators and regulators when enacting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used at the outset.

In this privacy policy, we use the following terms, amongst others:

(a) personal data

• Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as the ‘data subject’). A natural person is regarded as identifiable if they 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 one or more specific characteristics that reflect the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

(b) data subject

• A data subject is any identified or identifiable natural person whose personal data is processed by the data controller.

(c) Processing

• Processing means any operation or set of operations which is carried out on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, distribution or any other form of disclosure, the matching or linking, the restriction, erasure or destruction.

(d) Restriction of processing

• Restriction of processing refers to the marking of stored personal data with the aim of restricting its future processing.

(e) Profiling

• Profiling means any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements of that natural person.

(f) Pseudonymisation

• Pseudonymisation 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 such additional information is kept separately and is subject to technical and organisational measures that ensure the personal data cannot be attributed to an identified or identifiable natural person.

(g) Data controller or controller

• The controller 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 laid down by Union law or the law of the Member States, the controller or the specific criteria for its designation may be provided for by Union law or the law of the Member States.

(h) Data processors

• A data processor is a natural or legal person, public authority, agency or other body that processes personal data on behalf of the data controller.

(i) Recipient

• A recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, irrespective of whether or not they are a third party. However, public authorities which may receive personal data in the course of a specific investigation under Union law or the law of the Member States shall not be regarded as recipients.

(j) Third party

• A ‘third party’ means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or the processor.

(k) Consent

• Consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes, expressed in the form of a statement or any other clear affirmative action, by which the data subject indicates that they consent to the processing of their personal data.

2. Name and address of the data controller

The data controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions relating to data protection is:

Verus-Klinik GmbH

Hauptstr. 3

79682 Todtmoos

FRG

Tel.: 07674 9209 110

Email: info@verus-klinik.de

Website: www.verus-klinik-todtmoos.de

3. Name and address of the data protection officer

The data protection officer of the data controller is:

Jörg M. Leuchtner

Solicitor

Freiburger Datenschutzgesellschaft mbH 

Luisenstr. 5

D – 79098 Freiburg

Tel.: + 49 (0) 761 – 21716550 Fax: + 49 (0) 761 – 21716551

Email: info@freiburger-datenschutzgesellschaft.de

Website: www.freiburger-datenschutzgesellschaft.de

Any data subject may contact our Data Protection Officer directly at any time with any questions or suggestions regarding data protection.

4. Cookies and similar tools

When tracking and analysing the usage behaviour of users of our web services using cookies or similar technologies, we process your personal data on the basis of the following legal authorisations:

Article 6(1)(a) of the GDPR, where we are required to ask for your consent to the processing of your personal data,

Article 6(1)(b) of the GDPR, where necessary to fulfil (pre-)contractual obligations towards you,

Article 6(1)(f) of the GDPR, where necessary to fulfil (pre-)contractual obligations with the company or another legal entity that you represent as a contact person for a client, or where appropriate legal authorisations under applicable national laws, where applicable.

The Verus-Klinik GmbH website uses cookies. Cookies are text files that are placed and stored on a computer system via a web browser.

Numerous websites and servers use cookies. Many cookies contain what is known as a cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters which enables websites and servers to associate the cookie with the specific web browser in which it was stored. This enables the websites and servers visited to distinguish the data subject’s individual browser from other web browsers that contain different cookies. A specific web browser can be recognised and identified via the unique cookie ID.

By using cookies, Verus-Klinik GmbH is able to provide users of this website with more user-friendly services, which would not be possible without the use of cookies.

Cookies enable us to optimise the information and content on our website to suit the user’s needs. As already mentioned, cookies allow us to recognise 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 login details every time they visit the site, as this is handled by the website and the cookie stored on the user’s computer system. Another example is the shopping basket cookie in an online shop. The online shop uses a cookie to remember the items a customer has placed in their virtual shopping basket.

The data subject may prevent our website from setting cookies at any time by adjusting the settings of their web browser accordingly, thereby permanently objecting to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via a web browser or other software programmes. This is possible in all common web browsers. If the data subject disables the setting of cookies in their web browser, it may not be possible to use all the functions of our website to their full extent.

5. Collection of general data and information

The Verus-Klinik GmbH website collects a range of general data and information each time a data subject or an automated system accesses the website. This general data and information is stored in the server’s log files. The following may be recorded: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (known as the referrer), (4) the sub-pages on our website accessed via an accessing system, (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 used for security purposes in the event of attacks on our information technology systems.

When using this general data and information, Verus-Klinik GmbH does not draw any conclusions about the data subject. Rather, this information is required in order to (1) display the content of our website correctly, (2) to optimise the content of our website and the advertising on it, (3) to ensure the long-term functionality of our IT systems and the technology underpinning our website, and (4) to provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack. This data and information, collected anonymously, is therefore analysed by Verus-Klinik GmbH both for statistical purposes and with the aim of enhancing data protection and data security within our organisation, ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files is stored separately from any personal data provided by a data subject.

6. Contact details on the website

In accordance with statutory provisions, the Verus-Klinik GmbH website contains information that enables users to contact our company quickly by electronic means and to communicate directly with us; this also includes a general electronic mail address (e-mail address). Where a data subject contacts the data controller by email or via a contact form, the personal data transmitted by the data subject is stored automatically. Such personal data, provided voluntarily by a data subject to the data controller, is stored for the purposes of processing the enquiry or contacting the data subject. This personal data is not disclosed to third parties.

7. Routine erasure and restriction of personal data

The data controller shall process and store the data subject’s personal data only for the period necessary to fulfil the purpose of storage, or insofar as this is provided for by the European legislator (in directives and regulations) or by another legislator in laws or regulations to which the data controller is subject.

If the purpose for which the data is stored ceases to apply, or if a retention period prescribed by the European legislator (directives and regulations) or another competent legislative body expires, the personal data will be blocked or deleted as a matter of routine and in accordance with the statutory provisions.

8. Rights of the data subject

(a) Right to confirmation

• Every data subject has the right, as granted by the European legislator, to request confirmation from the controller as to whether personal data relating to them is being processed. If a data subject wishes to exercise this right to confirmation, they may contact a member of staff of the data controller at any time.

(b) Right of access

• Any data subject whose personal data is being processed has the right, as granted by the European legislator, to obtain from the controller, at any time and free of charge, information regarding the personal data stored about them and a copy of that information. Furthermore, the European legislator has granted the data subject the right to be provided with the following information:
  • the purposes of processing
  • the categories of personal data that are processed
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular where recipients are in third countries or are international organisations
  • where possible, the envisaged period for which the personal data will be stored, or, if this is not possible, the criteria used to determine that period
  • the existence of a right to have personal data concerning them rectified or erased, or to have the processing restricted by the controller, or a right to object to such processing
  • the existence of a right to lodge a complaint with a supervisory authority
  • where the personal data are not collected from the data subject: all available information regarding the origin of the data
  • the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the GDPR and — at least in such cases — meaningful information about the logic involved, as well as the scope and intended consequences of such processing for the data subject

  Furthermore, the data subject has the right to be informed as to whether personal data has been transferred to a third country or to an international organisation. Where this is the case, the data subject is also entitled to be informed of the appropriate safeguards in connection with the transfer.

  If a data subject wishes to exercise this right of access, they may contact a member of staff of the data controller at any time.

(c) Right to rectification

• Any data subject affected by the processing of personal data has the right, as granted by the European legislator, to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right, taking into account the purposes of the processing, to request that incomplete personal data be completed — including by means of a supplementary statement.

  If a data subject wishes to exercise this right to rectification, they may contact a member of staff of the data controller at any time.

(d) Right to erasure (right to be forgotten)

• Any data subject whose personal data is being processed has the right, as granted by European legislation, to request that the controller erase the personal data relating to them without delay, provided that one of the following grounds applies and insofar as the processing is not necessary:
  • The personal data was collected or otherwise processed for purposes for which it is no longer necessary.
  • The data subject withdraws their consent on which the processing was based in accordance with Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing.
  • The data subject objects to the processing in accordance with Article 21(1) of the GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing in accordance with Article 21(2) of the GDPR.
  • The personal data was processed unlawfully.
  • The erasure of personal data is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the controller is subject.
  • Personal data was collected in connection with the information society services offered, in accordance with Article 8(1) of the GDPR.

  If any of the above reasons apply and a data subject wishes to request the erasure of personal data stored by Verus-Klinik GmbH, they may contact a member of staff of the data controller at any time. The member of staff at Verus-Klinik GmbH will ensure that the request for erasure is complied with without delay.

  If personal data has been made public by Verus-Klinik GmbH and our company, as the data controller, is obliged under Article 17(1) of the GDPR to erase the personal data, Verus-Klinik GmbH shall, taking into account the available technology and the costs of implementation, take appropriate measures, including technical measures, to inform other data controllers who are processing the published personal data that the data subject has requested that these other data controllers delete all links to this personal data or any copies or replicas of this personal data, insofar as the processing is not necessary. The employee of Verus-Klinik GmbH will take the necessary steps on a case-by-case basis.

(e) Right to restriction of processing

• Any data subject whose personal data is being processed has the right, granted by the European legislator, to request that the controller restrict the processing where one of the following conditions is met:
  • The data subject disputes the accuracy of the personal data for a period sufficient to enable the controller to verify the accuracy of the personal data.
  • The processing is unlawful; the data subject objects to the erasure of the personal data and instead requests that the use of the personal data be restricted.
  • The data controller no longer requires the personal data for the purposes of processing, but the data subject requires it to establish, exercise or defend legal claims.
  • The data subject has lodged an objection to the processing pursuant to Article 21(1) of the GDPR, and it has not yet been determined whether the legitimate grounds of the controller outweigh those of the data subject.

  Where any of the above conditions are met and a data subject wishes to request the restriction of the processing of personal data held by Verus-Klinik GmbH, they may contact a member of staff of the data controller at any time. The member of staff at Verus-Klinik GmbH will arrange for the processing to be restricted.

(f) Right to data portability

• Any data subject whose personal data is being processed has the right, as granted by the European legislator, to receive the personal data concerning them – which they have 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 whom the personal data was provided, provided that the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the 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, when exercising their right to data portability in accordance with Article 20(1) of the GDPR, the data subject has the right to have their personal data transmitted directly from one controller to another, provided that this is technically feasible and does not adversely affect the rights and freedoms of others.

  To exercise their right to data portability, the data subject may contact a member of staff at Verus-Klinik GmbH 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, on grounds relating to their particular situation, to object at any time to the processing of personal data concerning them carried out on the basis of Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.

  Verus-Klinik GmbH will no longer process personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing is necessary for the establishment, exercise or defence of legal claims.

  Where Verus-Klinik GmbH processes personal data for the purposes of direct marketing, the data subject has the right to object at any time to the processing of their personal data for the purposes of such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to Verus-Klinik GmbH processing their personal data for the purposes of direct marketing, Verus-Klinik GmbH will no longer process the personal data for these purposes.

  Furthermore, the data subject has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them carried out by Verus-Klinik GmbH for scientific or historical research purposes or for statistical purposes in accordance with Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

  To exercise the right to object, the data subject may contact any member of staff at Verus-Klinik GmbH or another member of staff directly. The data subject is also free, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise their right to object by means of automated procedures using technical specifications.

(h) Automated individual decision-making, including profiling

• Any 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 authorised by Union or Member State law to which the controller is subject, and that law provides for appropriate measures to safeguard the data subject’s rights and freedoms as well as their legitimate interests; or (3) is based on the data subject’s explicit consent.

  If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is made with the data subject’s explicit consent, Verus-Klinik GmbH shall take appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, which shall include, at a minimum, the right to have a person from the controller intervene, to state their own point of view and to challenge the decision.

  If the data subject wishes to exercise their rights in relation to automated decision-making, they may contact a member of staff of the data controller at any time.

(i) Right to withdraw consent under data protection law

• Any data subject whose personal data is being processed has the right, granted by the European legislator, to withdraw their consent to the processing of personal data at any time.

  If the data subject wishes to exercise their right to withdraw consent, they may contact a member of staff of the data controller at any time.

9. Data protection in relation to job applications and the recruitment process

The data controller collects and processes applicants’ personal data for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case where an applicant submits the relevant application documents to the data controller electronically, for example by email or via a web form on the website. If the data controller enters into an employment contract with an applicant, the data provided will be stored for the purpose of managing the employment relationship in accordance with the relevant legal provisions. If the data controller does not enter into an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the data controller preclude such deletion. Other legitimate interests in this context include, for example, the burden of proof in proceedings under the General Equal Treatment Act (AGG).

10. Privacy policy regarding the use of Google Analytics (with anonymisation feature)

The data controller has integrated the Google Analytics component (with anonymisation function) into this website. Google Analytics is a web analytics service. Web analytics refers to the collection, gathering and analysis of data relating to the behaviour of website visitors. Among other things, a web analytics service records data on which website a data subject came from (known as a ‘referrer’), which sub-pages of the website were accessed, and how often and for how long a sub-page was viewed. Web analytics is primarily used to optimise a website and to carry out a cost-benefit analysis of online advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The data controller uses the parameter “_gat._anonymizeIp” for web analytics via Google Analytics. This parameter ensures that the IP address of the data subject’s internet connection is truncated and anonymised by Google when our website is accessed from a Member State of the European Union or from another State party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse visitor traffic on our website. Google uses the data and information collected, amongst other things, to analyse the use of our website, to compile online reports for us showing activity on our website, and to provide other services relating to the use of our website.

Google Analytics places a cookie on the data subject’s IT system. What cookies are has already been explained above. Once the cookie is set, Google is able to analyse the use of our website. Each time a user accesses one of the individual pages of this website – which is operated by the data controller and on which a Google Analytics component has been integrated – the web browser on the data subject’s IT system is automatically prompted by the relevant Google Analytics component to to transmit data to Google for the purposes of online analysis. As part of this technical process, Google obtains personal data, such as the data subject’s IP address, which Google uses, amongst other things, to trace the origin of visitors and clicks and, consequently, to facilitate commission settlements.

Cookies are used to store personal information, such as the time of access, the location from which access was made and the frequency of visits to our website by the data subject. Each time our website is visited, this personal data – including the IP address of the internet connection used by the data subject – 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, pass on this personal data, collected via the technical process, to third parties.

As explained above, the data subject may at any time prevent our website from setting cookies by adjusting the settings of their web browser accordingly, thereby permanently objecting to the setting of cookies. Adjusting the settings of the web browser in this way would also prevent Google from setting a cookie on the data subject’s IT system. Furthermore, any cookie already set by Google Analytics can be deleted at any time via the web browser or other software programmes.

Furthermore, the data subject has the option to object to the collection of data generated by Google Analytics relating to the use of this website, as well as to the processing of such data by Google, and to prevent this from taking place. To do so, the data subject must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on uses JavaScript to inform Google Analytics that no data or information regarding visits to websites may be transmitted to Google Analytics. Google regards the installation of the browser add-on as an objection. If the data subject’s IT system is subsequently deleted, formatted or reinstalled, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or by another person within their control, it is possible to reinstall or reactivate the browser add-on.

Further information and Google’s applicable privacy policy can be found at https://www.google.de/intl/de/policies/privacy/ and at www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link: https://www.google.com/intl/de_de/analytics/.

HUBSPOT

We use HubSpot on our website for marketing activities. HubSpot is a US-based software company with one branch:

HubSpot Ireland Limited in

2nd Floor, 30 North Wall Quay

Dublin 1, Ireland

We use this integrated software solution for our own marketing, lead generation and customer service purposes. This includes, amongst other things, email marketing, which manages the sending of newsletters and automated mailings; social media publishing and reporting; contact management, such as user segmentation and CRM; landing pages; and contact forms.

HubSpot uses cookies, which are small text files stored locally in your web browser’s cache on your device, enabling us to analyse your use of the website. HubSpot analyses the information collected (e.g. IP address, geographical location, browser type, duration of the visit and pages viewed) on our behalf, so that we can generate reports on the visit and the pages visited.

Information collected via HubSpot, as well as the content of our website, is stored on servers belonging to HubSpot’s service providers. Where you have given your consent in accordance with Article 6(1)(a) of the GDPR, processing on this website is carried out for the purpose of website analytics.

As HubSpot may transfer personal data to affiliated companies and sub-processors in countries outside the EU and the EEA, further safeguards are required to ensure a level of data protection in line with the GDPR. For the USA, there is an adequacy decision by the European Commission pursuant to Article 45(1) of the GDPR in respect of companies certified under the EU-US Data Privacy Framework. HubSpot, Inc. is certified under the EU-US Data Privacy Framework and is therefore committed to complying with appropriate data protection standards, which can be viewed at the following link: www.dataprivacyframework.gov/s/participant-search. For potential transfers to other third countries outside the EU and the EEA for which no adequacy decision has been issued by the European Commission, standard data protection clauses in accordance with Article 46(2)(c) of the GDPR are also agreed. These oblige the recipient of the data in the third country to process the data in accordance with the level of protection applicable in Europe.

The data will be deleted as soon as it is no longer required to fulfil the purpose for which it was collected.

You can permanently object to HubSpot collecting data and setting cookies by disabling cookies via your browser settings. You may object to the processing of your personal data at any time, with effect for the future.

11. Privacy Policy on the Use of Google AdWords

The data controller has integrated Google AdWords into this website. Google AdWords is an online advertising service that allows advertisers to place adverts both in Google’s search engine results and on the Google Display Network. Google AdWords enables an advertiser to specify certain keywords in advance, so that an advert is displayed in Google’s search engine results only when a user enters a search query containing those keywords. Within the Google Display Network, adverts are distributed across thematically relevant websites using an automated algorithm and in accordance with the pre-defined keywords.

The operator of the Google AdWords services is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google AdWords is to promote our website by displaying adverts relevant to users’ interests on third-party websites and in Google’s search results, and by displaying third-party adverts on our website.

If a data subject accesses our website via a Google advert, Google places a so-called conversion cookie on the data subject’s IT system. What cookies are has already been explained above. A conversion cookie expires after thirty days and is not used to identify the data subject. Provided the cookie has not yet expired, the conversion cookie is used to track whether certain sub-pages – for example, the shopping basket in an online shop system – have been accessed on our website. The conversion cookie enables both us and Google to determine whether a data subject who arrived at our website via an AdWords advert generated a sale – that is, whether they completed or abandoned a purchase.

The data and information collected through the use of the conversion cookie are used by Google to compile visitor statistics for our website. We, in turn, use these visitor statistics to determine the total number of users who were referred to us via AdWords adverts, i.e. to assess the success or failure of the respective AdWords advert and to optimise our AdWords adverts for the future. Neither our company nor other Google AdWords advertisers receive any information from Google that could be used to identify the data subject.

The conversion cookie is used to store personal information, such as the web pages visited by the data subject. Consequently, each time our website is visited, personal data – including the IP address of the internet connection used by the data subject – 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, pass on this personal data – collected via the technical process – to third parties.

As explained above, the data subject may at any time prevent our website from setting cookies by adjusting the settings of the web browser they are using, thereby permanently objecting to the setting of cookies. Adjusting the settings of the web browser in this way would also prevent Google from setting a conversion cookie on the data subject’s IT system. Furthermore, any cookie already set by Google AdWords can be deleted at any time via the web browser or other software programmes.

Furthermore, the data subject has the option to opt out of interest-based advertising by Google. To do so, the data subject must access the link www.google.de/settings/ads from each of the web browsers they use and configure the desired settings there.

Further information and Google’s applicable privacy policy can be found at https://www.google.de/intl/de/policies/privacy/.

12. Legal basis for processing

Article 6(1)(a) of the GDPR serves as the legal basis for our company’s processing operations where we obtain consent for a specific purpose of processing. 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 required for the delivery of goods or the provision of other services or consideration – the processing is based on Article 6(1)(b) of the GDPR. The same applies to processing operations necessary for the implementation of pre-contractual measures, such as in cases of enquiries regarding our products or services. Where our company is subject to a legal obligation which necessitates the processing of personal data, such as to fulfil tax obligations, the processing is based on Article 6(1)(c) of the 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 to be injured on our premises and their name, age, health insurance details or other vital information subsequently had to be disclosed to a doctor, a hospital or other third parties. In such cases, the processing would be based on Article 6(1)(d) of the GDPR. Finally, processing operations may be based on Article 6(1)(f) of the GDPR. This legal basis applies to processing operations not covered by any of the aforementioned legal bases, where 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 take precedence. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this regard, the legislator took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, second sentence, of the GDPR).

13. Legitimate interests in processing pursued by the data controller or a third party

Where the processing of personal data is based on Article 6(1)(f) of the GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and our shareholders.

14. The period for which personal data is stored

The criterion for the duration of the storage of personal data is the relevant statutory retention period. Once this period has expired, the relevant data is routinely deleted, provided it is no longer required for the performance of a contract or for entering into a contract.

15. Legal or contractual requirements regarding the provision of personal data; necessity for the conclusion of the contract; the data subject’s obligation to provide personal data; possible consequences of failure to provide such data

We would like to inform you that the provision of personal data is, in some cases, required by law (e.g. tax regulations) or may also arise from contractual provisions (e.g. details of the contracting party). In some cases, it may be necessary for a data subject to provide us with personal data in order to conclude a contract, which we must then process. For example, the data subject is obliged to provide us with personal data when our company enters into a contract with them. Failure to provide personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact one of our staff members. Our staff member will explain to the data subject, on a case-by-case basis, whether the provision of personal data is required by law or under a contract, or is necessary for the conclusion of a contract; whether there is an obligation to provide the personal data; and what the consequences would be if the personal data were not provided.

16. The existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

This privacy policy was drawn up using the privacy policy generator provided by DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as an external data protection officer in Frankfurt am Main, in collaboration with Christian Solmecke, a data protection lawyer based in Cologne.