Responsible for data protection
Manuel Vogel
MV Consulting GmbH
Mergenthalerallee 73-75, 65760 Eschborn, Germany
General information on data processing
Scope of the processing of personal data
As a matter of principle, we process personal data of our users only insofar as this is necessary for the provision of a functional website as well as our content and services. The processing of personal data of our users is regularly carried out only with the consent of the user. An exception applies in those cases where obtaining prior consent is not possible for actual reasons and the processing of the data is permitted by legal regulations.
Legal basis for the processing of personal data
In so far as we obtain the consent of the data subject for processing operations involving personal data, Article 6 (1) (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Article 6 (1) (b) of the GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures.Insofar as processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Art. 6 (1) lit. c DSGVO serves as the legal basis.In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the 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 data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may take place beyond this if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.
Provision of the website and creation of log files
Description and scope of data processing
Whenever our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.The following data is collected in this context:
- Information about the browser type and the version used
- The operating system of the user
- The user’s internet service provider
- The anonymized IP address of the user
- The date and time of access
- Websites from which the user’s system accesses our website
- Websites that are accessed by the user’s system via our websiteThe data is also stored in the log files of our system. Not affected by this are the IP addresses of the user or other data that allow the data to be assigned to a user. Storage of this data together with other personal data of the user does not take place.
Legal basis for data processing
The legal basis for the temporary storage of the data and the log files 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 user’s IP address must remain stored for the duration of the session.The storage in log files takes place to ensure the functionality of the website. In addition, we use the data to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.In these purposes also lies our legitimate interest in data processing according to Art. 6 para. 1 lit. f DSGVO.
Duration of storage
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.In the case of the storage of data in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.
Opposition and removal option
The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. Consequently, there is no possibility of objection on the part of the user.
Use of cookies
Description and scope of data processing
Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. When a user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change. The following data is stored and transmitted in the cookies in the process:
- Log-in information
- We also use cookies on our website that enable an analysis of the user’s surfing behavior.In this way, the following data can be transmitted:
- Entered search terms
- Frequency of page views
- Use of website functions
The user data collected in this way is pseudonymized by technical precautions. Therefore, an assignment of the data to the calling user is no longer possible. The data is not stored together with other personal data of the users.When calling up our website, the users are informed by an info banner about the use of cookies for analysis purposes and referred to this data protection declaration. In this context, there is also a reference to how the storage of cookies can be prevented in the browser settings.When calling up our website, the user is informed about the use of cookies for analysis purposes. In this context, there is also a reference to this data protection declaration.
b) Legal basis for data processing
The legal basis for the processing of personal data using cookies is Art. 6 (1) lit. f DSGVO.
c) Purpose of data processing
The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change. We require cookies for the following applications: Remembering search termsThe user data collected by technically necessary cookies are not used to create user profiles.The use of analysis cookies is for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus constantly optimize our offer.In these purposes also lies our legitimate interest in the processing of personal data pursuant to Art. 6 para. 1 lit. f DSGVO.
d) Duration of storage, possibility of objection and elimination
Cookies are stored on the user’s computer and transmitted by it to our site. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.
TLS encryption with https
We use https to transmit data in a tap-proof manner on the Internet (data protection by design of technology Article 25(1) DSGVO). By using TLS (Transport Layer Security), an encryption protocol for secure data transmission on the Internet, we can ensure the protection of confidential data. You can recognize the use of this protection of data transmission by the small lock symbol at the top left of the browser and the use of the scheme https (instead of http) as part of our Internet address.
Google products
Google Fonts
What are Google Fonts?
Google Fonts (formerly Google Web Fonts) is an interactive directory of more than 800 fonts provided for free use by Google LLC.
Many of these fonts are released under the SIL Open Font License, while others are released under the Apache License. Both of these are free software licenses. Thus, we can use them freely without paying any license fees.
Why do we use Google Fonts on our website?
Google Fonts allows us to use fonts on our own website, and not have to upload them to our own server. Google Fonts is an important component to keep the quality of our website high. All Google Fonts are automatically optimized for the web and this saves data volume and is a great advantage especially for mobile use. When you visit our site, the low file size ensures a fast loading time. Furthermore, Google Fonts are so-called secure web fonts. Different image synthesis systems (rendering) in different browsers, operating systems and mobile devices can lead to errors. Such errors can sometimes visually distort texts or entire web pages. Thanks to the fast Content Delivery Network (CDN), there are no cross-platform problems with Google Fonts. Google Fonts supports all major browsers (Google Chrome, Mozilla Firefox, Apple Safari, Opera) and works reliably on most modern mobile operating systems, including Android 2.2+ and iOS 4.2+ (iPhone, iPad, iPod).
We therefore use the Google Fonts so that we can present our entire online service as beautifully and consistently as possible. According to the Art. 6 para. 1 f lit. F DSGVO, this already constitutes a “legitimate interest” in the processing of personal data. Legitimate interest" in this case means both legal and economic or ideal interests recognized by the legal system.
What data is stored by Google?
When you visit our website, the fonts are reloaded via a Google server. Through this external call, data is transmitted to the Google servers. In this way, Google also recognizes that you or your IP address is visiting our website. The Google Fonts API was developed to reduce the collection, storage, and use of end-user data to what is necessary for efficient font delivery. API, by the way, stands for “Application Programming Interface” and is used, among other things, as a data transmitter in software.
Google Fonts stores CSS and font requests securely at Google and is therefore protected. Through the collected usage figures, Google can determine the popularity of the fonts. Google publishes the results on internal analysis pages, such as Google Analytics. In addition, Google also uses data from its own web crawler to determine which websites are using Google fonts. This data is published in the Google Fonts BigQuery database. BigQuery is a web service from Google for companies that want to move and analyze large amounts of data.
It should be noted, however, that each Google Font request also automatically transmits information such as IP address, language settings, browser screen resolution, browser version and browser name to the Google servers. Whether this data is also stored cannot be clearly determined or is not clearly communicated by Google.
How long and where is the data stored?
Google stores requests for CSS assets for one day on your servers, which are mainly located outside the EU. This allows us to use fonts with the help of a Google stylesheet. A stylesheet is a format template that can be used to easily and quickly change the design or font of a website, for example.
The font files are stored by Google for one year. Google thus pursues the goal of fundamentally improving the loading time of web pages. If millions of web pages refer to the same fonts, they are cached after the first visit and immediately reappear on all other web pages visited later. Sometimes Google updates font files to reduce file size, increase language coverage, and improve design.
How can I delete my data or prevent data storage?
The data that Google stores for one day or one year cannot simply be deleted. The data is automatically transmitted to Google when the page is called up. To delete this data prematurely, you need to contact Google support at this link. Data storage you prevent in this case only if you do not visit our site.
Unlike other web fonts, Google allows us unlimited access to all fonts. So we can have unlimited access to a sea of fonts and get the most out of our website. You can find out more about Google Fonts and other issues at this link. While Google addresses privacy-related issues there, it doesn’t really include detailed information about data storage. It is relatively difficult (almost impossible) to get really precise information from Google about stored data.
You can also read about which data is basically collected by Google and what this data is used for at this link.
Google Analytics
We use Google Analytics, a web analytics service provided by Google LLC (“Google”), on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. DSGVO) Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by users is usually transmitted to a Google server in the U.S. and stored there.Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law. Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and Internet use. In doing so, pseudonymous user profiles can be created from the processed data.We only use Google Analytics with IP anonymization activated. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.The IP address transmitted by the user’s browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available at the this link. For more information on data usage by Google, setting and objection options, please refer to Google’s privacy policy as well as the settings for the display of advertisements by Google.The users’ personal data will be deleted after 14 months. Created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke.
Hotjar
We use Hotjar to better understand the needs of our users and to optimize the experience on this website. Using Hotjar’s technology, we get a better understanding of our users’ experiences (e.g., how much time users spend on which pages, which links they click, what they like and don’t like, etc.) and this helps us tailor our offerings to our users’ feedback. Hotjar works with cookies and other technologies to collect information about our users’ behavior and about their devices (in particular, IP address of the device (collected and stored only in anonymized form), screen size, device type (unique device identifiers), information about the browser used, location (country only), language preferred to view our website). Hotjar stores this information in a pseudonymized user profile. The information is not used by Hotjar or us to identify individual users or merged with other data about individual users. For more information, please see Hotjar’s privacy policy here.
You can object to the storage of a user profile and information about your visit to our website by Hotjar as well as to the setting of Hotjar tracking cookies on other websites by clicking on this Opt-Out-Link
Contact form and e-mail contact
Description and scope of data processing
Our website contains a contact form that can be used for electronic contact. If a user takes advantage of this option, the data entered in the input mask is transmitted to us and stored. These data are:
- name
- E-mail address
- Message
At the time the message is sent, the following data is also stored:
- Date and time of registration
- For the processing of the data, your consent is obtained during the sending process and reference is made to this privacy policy.
- Alternatively, it is possible to 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.There will be no disclosure of data to third parties in this context. The data will be used exclusively for processing the conversation.
Legal basis for data processing
The legal basis for the processing of 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 e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO.
Purpose of data processing
The processing of personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data.The other personal data processed during the 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 is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is terminated when the circumstances indicate that the matter in question has been conclusively clarified.The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
Possibility of objection and removal
The user has the option 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.All personal data stored in the course of contacting us will be deleted in this case.
Rights of the data subject
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
Right of information
You may request confirmation from the controller as to whether personal data concerning you are being processed by us.If such processing is taking place, you may request information from the controller about the following:
- The purposes for which the personal data are being processed
- The categories of personal data being processed
- The recipients or categories of recipients to whom the personal data relating to you have been or will be disclosed
- The planned duration of the storage of the personal data relating to you or, if specific information on this is not possible, criteria for determining the storage period
- The existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing
- The existence of a right to lodge a complaint with a supervisory authority
- Any available information about the origin of the data if the personal data are not collected from the data subject
You have the right to request information about whether the personal data concerning you are transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 DSGVO in connection with the transfer.
Right to rectification
You have a right of rectification and/or completion vis-à-vis the data controller if the personal data processed concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
Right to restriction of processing
Under the following conditions, you may request the restriction of the processing of personal data concerning you:
- If you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data
- the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data
- the controller no longer needs the personal data for the purposes of the processing, but you need it for the assertion, exercise or defense of legal claims or
- if you object to the processing pursuant to Art. 21 (1) DSGVO and it has not yet been determined whether the legitimate grounds of the controller override your grounds.
If the processing of personal data concerning you has been restricted, such data may - apart from being stored - only be processed with your consent or for the purpose of asserting, exercising or defending legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State. If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
Right to erasure
Right to erasureYou may request the controller to erase the personal data concerning you without undue delay, and the controller is obliged to erase such data without undue delay, if one of the following reasons applies:
- The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
- You revoke your consent on which the processing was based pursuant to Art. 6(1)(a) or Art. 9(2)(a) DSGVO and there is no other legal basis for the processing.
- You object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO.
- The personal data concerning you have been processed unlawfully.
- The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
- The personal data concerning you was collected in relation to information society services offered pursuant to Art. 8(1) DSGVO.
Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17 (1) of the GDPR, the controller shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.
Exceptions
The right to erasure does not apply insofar as processing is necessary
- for the exercise of the right to freedom of expression and information
- for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
- For reasons of public interest in the area of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the GDPR
- For archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing or
- For the establishment, exercise or defense of legal claims.
Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.You have the right against the controller to be informed about these recipients.
Right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to transfer this data to another controller without hindrance by the controller to whom the personal data was provided, provided that
- the processing is based on 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 (1) (b) DSGVO and
- the processing is carried out with the aid of automated procedures.In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. The right to data portability 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 to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions.The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to processing of the personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.You have the possibility, in connection with the use of information society services - notwithstanding Directive 2002/58/EC - to exercise your right to object by means of automated procedures using technical specifications.
Right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
Automated decision in individual cases including profiling.
You have the right not to be subject to a decision based solely on automated processing - including profiling - which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
- is necessary for the conclusion or performance of a contract between you and the controller,
- is permitted by Union or Member State law to which the controller is subject and that law contains adequate measures to safeguard your rights and freedoms and your legitimate interests, or
- is made with your explicit consent.However, these decisions must not be based on special categories of personal data pursuant to Art. 9(1) of the GDPR, unless Art. 9(2)(a) or (g) of the GDPR applies, and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.With regard to the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person on the part of the controller, to express his or her point of view and to contest the decision.
Right to lodge a complaint with a supervisory authority.
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.