Objective and Responsibility
- This Data Privacy Statement is to inform you about the nature, scope and purpose of the processing of personal data related to our online service and the related websites, features and contents (hereinafter collectively referred to as "online service" or "website").
- The online service is provided by VIER PFOTEN, European Policy Office / Pierre Sultana | powered by WordPress | Theme: Edin by WordPress.com – hereinafter referred to as "provider", "we" or "us" – who is also legally responsible under the data protection law.
- Our online service is hosted by One.com.
- You can reach out to our Data Protection Officer under the E-Mail address email@example.com
- The term "user" encompasses all customers, interested people, employees and visitors of our online service.
We collect and process personal data based on the following legal grounds:
- Consent in accordance with Article 6 paragraph 1 (a) General Data Protection Regulation (GDPR). Consent meaning any freely given, specific, informed and unambiguous indication of agreement, which could be in the form of a statement or any other unambiguous confirmatory act, given by the data’s subject consenting to the processing of personal data relating to him or her.
- Necessity for the performance of a contract or in order to take steps prior to entering into a contract according to Article 6 paragraph 1 (b) GDPR, meaning the data is required in order for us to fulfil our contractual obligations towards you or to prepare the conclusion of a contract with you.
- Processing to fulfil a legal obligation in accordance with Article 6 paragraph 1 (c) GDPR, meaning that e.g. the processing of data is required by law or other provisions.
- Processing in order to protect legitimate interests in accordance with Article 6 paragraph 1 (f) GDPR, meaning that the processing is necessary to protect legitimate interests pursued by us or by a third party, unless such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal data.
Data Subject Rights
You have the following rights with regards to the processing of your data through us:
- The right to lodge a complaint with a supervisory authority in accordance with Article 13 paragraph 2 (d) GDPR and Article 14 paragraph 2 (e) GDPR.
- Right of access in accordance with Article 15 GDPR
- Right to rectification in accordance with Article 16 GDPR
- Right to erasure („right to be forgotten“) in accordance with Article 17 GDPR
- Right to restriction of processing in accordance with Article 18 GDPR
- Right to data portability in accordance with Article 20 GDPR
- Right to objection in accordance with Article 21 GDPR
Notice: Users may object to the processing of their personal data in accordance with legal allowances at any time with effect for the future. The objection may in particular be made against processing for the purposes of direct marketing.
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.
Data Erasure and Duration of Storage
The personal data of the data subject will be erased or blocked as soon as the purpose of the storage is inapplicable. Storage of data beyond that may occur if such storage is required by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Blocking or erasure of data also takes place when a retention period mandated by the standards mentioned expires, unless the continued storage of data is required for the conclusion of a contract or the fulfilment of contractual obligations.
Security of Processing
- We have implemented appropriate and state-of-the-art technical and organisational security measures (TOMs). Thus, the data that is processed by us is protected against accidental or intentional manipulation, loss, destruction and unauthorized access.
- These security measures include in particular the encrypted transfer of data between your browser and our server.
Transfer of Data to Third Parties, Subcontractors and Third Party Providers
- A transfer of personal data to third parties only occurs within the framework of legal requirements. We only disclose personal data of users to third parties, if this is required e.g. for billing purposes or other purposes, if the disclosure is necessary to ensure the fulfilment of contractual obligations towards the users.
- If we engage subcontractors for our online service, we have made appropriate contractual arrangements as well as adequate technical and organizational measures with these companies.
- If we use content, tools or other means from other companies (hereinafter collectively referred to as "third party providers") whose registered offices are located in a third country, it is assumed that a transfer of data to the home countries of these third party providers occurs. The transfer of personal data to third countries takes place exclusively only, if an adequate level of data protection, the user’s consent or another legal permission is present.
Concrete Data Processing
Contact Form and Contacting via Email
- When contacting us (via online form or e-mail), the data provided by the user will be processed exclusively for processing the inquiry and its handling.
- Any other use of the data will only take place based on the given consent from the user.
- The users' data will be stored in our Customer Relationship Management System ("CRM System") or a comparable software/database. The legal retention periods for business letters apply.
- With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter you agree to the receipt and the described procedures.
double opt-in and logging
As part of the registration for our newsletter, the so-called double opt-in procedure is carried out; i.e. after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that no one can log in with other e-mail addresses. The registrations for the newsletter are recorded for the fulfilment of legal obligations of proof. This includes the storage of the time of registration and confirmation as well as the IP address.
shipping service provider
The newsletter is sent out by our subcontractor Growing Minds (Wibautstraat 135-139, 1097 DN Amsterdam) – hereinafter referred to as "dispatch service provider". The data protection regulations of the shipping service provider can be viewed here: https://www.cleverreach.com/de/datensicherheit/.
According to its own information, the shipping service provider can use this data in pseudonymous form – i.e. without allocation to a user, to optimise or improve its own services, e.g. to technically optimise the dispatch and presentation of the newsletter or for statistical purposes in order to determine from which countries the recipients come. However, the shipping service does not use the data of our newsletter recipients to write them down itself or to pass the data on to third parties.
To register for the newsletter, you must enter your gender, email address, first name, surname and country of residence.
statistical survey and analyses
The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file which is retrieved from the server of the shipping service when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are initially collected. This information is used to technically improve the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or access times.
The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is not our intention, nor that of the shipping service provider, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
The use of the shipping service provider, the performance of statistical surveys and analyses as well as the logging of the registration process shall be based on our legitimate interests in accordance with Article 6 (1) (f) DSGVO. We are interested in using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of our users.
You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. If the users have cancelled the newsletter reception, the personal data of the users processed for its dispatch will be deleted.
Google Tag Manager
- This website uses the Google Tag Manager. This service allows website tags to be managed through an interface. The Google Tool Manager only implements tags, does not set cookies and does not collect any personal data. The Google Tag Manager triggers other tags that may collect personal information. However, the Google Tag Manager does not access this data.
- If deactivated at domain or cookie level, it will remain valid for all tracking tags implemented with Google Tag Manager.
- If a so-called "Facebook Connect Button" is placed on this website, you have the possibility to log in to our website with your Facebook user data. In addition, Facebook Connect can automatically include information about your activities on our website in your Facebook profile. In this respect, when you activate the button, you will be given both the opportunity to expressly consent to access your Facebook user data and to publish information and activities in your Facebook profile. The use of further data (e.g. contact via your email address) only takes place with prior express consent.
- Please note that Facebook receives information about the application or website via Facebook Connect, including what you are doing. To personalize the connection process, Facebook may in some cases receive a limited amount of information prior to authorizing the application or website.
- The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as your rights in this regard and setting options for the protection of your privacy can be found in the data protection declaration at: http://www.facebook.com/policy.php.
- Our online service uses Google Analytics, a web analysis service of Google Inc. ("Google").
Google remarketing or "similar target groups”
- This website uses the remarketing or "similar target group" function of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States ("Google").
- You can be targeted with advertising by placing personalised and interest-based ads when you visit other websites in the so-called "Google Display Network". "Google Remarketing" or the function "Similar target groups" uses so-called "cookies", text files which are stored on your computer and which enable an analysis of your use of the website. These text files are used to record your visits and anonymous data about the use of the website. Personal data will not be stored. If you visit another website in the so-called "Google Display Network", you may see advertisements that most likely take into account product and information areas previously accessed on our website.
Google AdWords Conversion Tracking
- This website uses the "Google AdWords Conversion Tracking" function of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States ("Google").
- Google AdWords Conversion Tracking uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site when they click on a Google ad. The cookies are valid for a maximum of 90 days. Personal data will not be stored. As long as the cookie is valid, Google and we as website operators can recognize that you clicked on an ad and reached a specific target page (e.g. order confirmation page, newsletter registration). These cookies cannot be tracked across multiple websites by different AdWords participants. The cookie creates conversion statistics in "Google AdWords". These statistics record the number of users who clicked on one of our ads. It also counts how many users have reached a target page that has been provided with a "conversion tag". However, the statistics do not contain any data with which you can be identified.
- You can prevent cookies from being stored on your hard disk by selecting "do not accept cookies" in your browser settings (in MS Internet Explorer under "Tools > Internet Options > Privacy > Settings"; in Firefox under "Tools > Settings > Privacy > Cookies"); however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent.
- By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
- We use YouTube for the integration of videos. The videos were embedded in the extended data protection mode.
- By using YouTube, a connection is established with the Google DoubleClick network. Starting the video could trigger further data processing. We have no influence on that.
- Doubleclick by Google is a service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").
- By using our website, you consent to the processing of data about you by Google and the manner of data processing described above as well as the named purpose.
- For more information about DoubleClick by Google and privacy, please visit: https://policies.google.com/technologies/ads?hl=en
Facebook Custom Audience
- We use on our website Facebook Website Custom Audiences and have integrated the so-called Facebook pixel.
- This pixel is used to collect pseudonymous information about the use of this website (e.g. information about viewed content). The transmitted data of the pixel can be used to target you on Facebook with individualized advertising, provided you have a Facebook account.
- Cookies are information transmitted by our web server or third-party web servers to the users' web browsers where they are stored for later retrieval. Cookies can be in the form of small files or any other types of information storage.
- In the case that users do not want that cookies are stored on their computer, they will be asked to disable the corresponding option in their browser's system settings. Saved cookies may be deleted in the system settings of the browser. The exclusion of cookies can lead to functional impairments of this online service.
- deactivation page of the Network Advertising Initiative: http://optout.networkadvertising.org/
- the US-American website: http://www.aboutads.info/choices
- the European website http://www.youronlinechoices.com/uk/your-ad-choices/