Data protection

With this data protection notice, we inform you (also referred to as "user" or "data subject" in the following text) in a general way about data processing in our consultancy and in a special way about data processing when you visit our website, contact us via our website contact form, contact us by e-mail or telephone and register to receive our newsletter. We also inform you about our online presence in social media and about your rights with regard to the processing of your data. The term "data processing" always refers to the processing of personal data.

Responsible in the sense of the data protection laws

Dr Hartmut Frenzel
Fuhlrottstraße 15,
42119 Wuppertal
Germany
Phone +49-202-2541472
E-mail frenzel@dr-frenzel.com

1. general information on data processing

1.1 Categories of personal data

We process the following categories of personal data:

Inventory data (e.g. names, addresses, functions, organisational affiliation, etc.)
Contact details (e.g. e-mail, telephone/fax numbers, etc.)

1.2 Recipients or categories of recipients of personal data

If we disclose data to other persons and companies such as web hosts, contract processors or third parties as part of our processing, transfer it to them or otherwise grant them access to the data, this is done on the basis of legal permission (e.g. if the transfer of data to third parties is necessary for the fulfilment of a contract pursuant to Art. 6 para. 1 subpara. 1 lit. b GDPR), if the data subjects have given their consent or if a legal obligation provides for this.

1.3 Duration of storage of personal data

The criterion for the duration of the storage of personal data is the respective statutory retention period. After this period has expired, the corresponding data will be deleted if it is no longer required to achieve the purpose, fulfil the contract or initiate a contract.

1.4 Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of the use of third-party services or the disclosure or transfer of data to third parties, this will only take place if it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of a legal obligation.

We use the service provider EQUINOXE GmbH, Bismarckallee 9, 79098 Freiburg, https://www.equinoxe.com, to provide you with encrypted communication.

We would like to point out that you use the functions on your own responsibility.

Please read the privacy policy.

on the basis of our legitimate interests. Subject to legal or contractual authorisations, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR, i.e. the processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to the EU or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").

2. data processing in the context of visiting our website

Every time a data subject accesses our website, general data and information is stored in our system's log files:

Date and time of retrieval (timestamp)
Request details and destination address (protocol version, HTTP method, referrer, user agent string)
Name of the retrieved file and amount of data transferred (requested URL incl. query string, size in bytes)
Message as to whether the request was successful (HTTP status code)

2.1 Log files

When using this general data and information, we do not draw any conclusions about the data subject. There is no personalised analysis or evaluation of the data for marketing purposes or profiling. The IP address is not stored in this context.

The legal basis for the temporary storage of data is Art. 6 para. 1 subpara.1 lit. f GDPR. The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the secure operation of our website. Consequently, the data subject has no option to object.

2.2 Malware detection and log data analysis

We collect log data that is generated during the operation of our consultancy's communication technology and analyse it automatically, insofar as this is necessary to detect, limit or eliminate malfunctions or errors in the communication technology or to defend against attacks on our information technology or to detect and defend against malware.

The legal basis for the temporary storage and analysis of the data is Art. 6 para. 1 subpara. 1 lit. f GDPR. The storage and analysis of the data is absolutely necessary for the provision of the website and for its secure operation. Consequently, the data subject has no option to object.

2.3 Hosting

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating our website.

In doing so, we or our processors process inventory data, contact data, content data, contract data, usage data as well as meta and communication data of users of our website on the basis of our legitimate interests in the efficient and secure provision of this online offer in accordance with Art. 6 para. 1 subpara. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a contract for order processing).

Hosting service provider:
Raidboxes GmbH
Harbour road 32
48153 Münster
Germany
Raidboxes privacy policy: https://raidboxes.io/legal/privacy/

2.4 Content Delivery Network (CDN)

We use the "RocketCDN" service. The provider is WP MEDIA, 47 Rue Duquesne, 69006 - Lyon, France (hereinafter referred to as "RocketCDN").

RocketCDN offers a globally distributed content delivery network with DNS. Technically, the information transfer between your browser and our website is routed via the RocketCDN network. This enables RocketCDN to analyse the data traffic between your browser and our website and to act as a filter between our servers and potentially malicious data traffic from the Internet. RocketCDN may also use cookies for this purpose, but these are used solely for the purpose described here.

Further information on security and data protection at RocketCDN can be found here: https://docs.wp-rocket.me/article/1307-rocketcdn

3. data processing in the context of establishing contact

3.1 Contact by e-mail and letter

You can contact our company by e-mail using the e-mail addresses published on our website.

If you use this contact channel, the data you provide (e.g. surname, first name, address), but at least the e-mail address and the information contained in the e-mail, as well as the personal data you provide, will be stored for the purpose of contacting you and processing your request. The following data is also collected by our system:

IP address of the calling computer;
Date and time of the e-mail.

The legal basis for the processing of personal data in the context of e-mails sent to us is Art. 6 para. 1 subpara. 1 lit. b or lit. f GDPR.

If you send us a letter, the data you provide (e.g. surname, first name, address) and the information contained in the letter, together with the personal data you provide, will be stored for the purpose of contacting you and processing your request.

The legal basis for the processing of personal data in the context of letters sent to us is Art. 6 para. 1 subpara. 1 lit. b or lit. f GDPR.

3.2 Data processing when subscribing to our newsletter

Your consent is obtained for the processing of the data as part of the registration process and reference is made to this privacy policy. The data is processed on the basis of your consent in accordance with Art. 6 para. 1 subpara. 1 lit. a GDPR and within the scope of the legitimate interest in accordance with Art. 6 para. 1 subpara. 1 lit. f GDPR.

We use this data exclusively for sending the newsletter. We do not pass on your data to third parties and do not use it for any other purposes of our own.

When you register, your data will be saved. A message with a link to confirm your registration will then be generated and sent to the e-mail address you provided (so-called double opt-in procedure). If you do not confirm your registration by clicking on the link in this e-mail, the data will be deleted after 24 hours. Only when you confirm the link in the email will your data for sending the newsletter be stored for the duration of your use of our website. This ensures that the newsletter was requested by you and not by a third party.

If you no longer agree to the storage of your data for this purpose and therefore no longer wish to use our services, you can unsubscribe from our newsletter at any time. There is a corresponding link for this purpose in every newsletter. The personal data you have provided to subscribe to the newsletter will then be deleted.

Service provider newsletter:
CleverReach GmbH & Co. KG
Schafjückenweg 2
26180 Rastede
Germany
CleverReach privacy policy https://www.cleverreach.com/de-de/datenschutz/

3.3 Content Delivery Network from RocketCDN

On this website we use a so-called Content Delivery Network ("CDN") of the technology service provider SAS WP MEDIA, 8 Rue Tronchet, 69006 Lyon, France (hereinafter "RocketCDN"). A content delivery network is an online service that is used to deliver large media files (such as graphics, page content or scripts) through a network of regionally distributed servers connected via the Internet. The use of RocketCDN helps to optimise the loading speed of the website.

The processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of my legitimate interest in the secure and efficient provision and improvement of the stability and functionality of the website.

Further information on security and data protection at RocketCDN can be found here: https://docs.wp-rocket.me/article/1307-rocketcdn/

4. evaluation platforms

4.1 ProvenExpert

Proven Expert is a platform for customer reviews. The Proven Expert widget shows how the provider of this website has been rated by customers on Proven Expert. No cookies in the technical sense are set on the client device of the user, but technical and personal data such as the IP address are transferred from the client to the server of the service provider to enable the use of the service.

Company: Expert Systems AG, Quedlinburger Str. 1, 10589 Berlin, Germany

Privacy policy of the provider: https://www.provenexpert.com/de-de/datenschutzbestimmungen/

4.2 Trust index

Trustindex.io allows us to display reviews from clients submitted on Google or Facebook. No cookies in the technical sense are set on the user's client device, but technical and personal data such as the IP address are transferred from the client to the server of the service provider to enable the use of the service.

Company: Trustindex Informatikai Kft, Széchenyi utca 21, 3593 Hejőbába, Hungary

Privacy policy of the provider: https://www.trustindex.io/terms-and-conditions-and-privacy-policy/

5. cookie

We use the "Real Cookie Banner" consent tool to manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents. You can find details on how "Real Cookie Banner" works at https://devowl.io/de/rcb/datenverarbeitung/.

The legal basis for the processing of personal data in this context is Art. 6 para. 1 lit. c GDPR and Art. 6 para. 1 lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

6. your rights

As a data subject, you have the following rights in the context of the processing of your personal data:

6.1 Right to information pursuant to Art. 15 GDPR

(1) The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

a) the purposes of the processing

b) the categories of personal data that are processed;

c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations

d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period

e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing

f) the existence of a right of appeal to a supervisory authority

(g) where the personal data are not collected from the data subject, any available information as to their source

h) the existence of automated decision-making, including profiling in accordance with Art. 22 (1) and (4) GDPR and - at least in these cases - meaningful information on the logic involved and the scope and intended effects of such processing for the data subject

(2) Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR in the context of the transfer.

6.2 Right to rectification pursuant to Art. 16 GDPR

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

6.3 Right to erasure pursuant to Art. 17 GDPR

(1) The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

a) The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

b) The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing.

c) The data subject objects to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.

d) The personal data have been processed unlawfully.

e) The deletion of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.

f) The personal data was collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.

(2) Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

(3) Paragraphs 1 and 2 shall not apply if the processing is necessary

a) to exercise the right to freedom of expression and information;

b) for compliance with a legal obligation which requires processing by 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;

c) for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h) and i) and Art. 9 para. 3 GDPR;

(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

e) for the assertion, exercise or defence of legal claims.

6.4 Right to restriction of processing pursuant to Art. 18 GDPR

(1) The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

a) 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,

b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims, or

d) 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.

(2. Where processing has been restricted pursuant to paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of 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 of a Member State.

6.5 Right to data portability pursuant to Art. 20 GDPR

(1) The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where

a) the processing is based on consent pursuant to Art. 6 para. 1 lit. a) or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR and

b) the processing is carried out by automated means.

(2) In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of other persons.

This right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

6.6 Right to object pursuant to Art. 21 GDPR

The data subject has the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

6.7 Right of cancellation pursuant to Art. 7 para. 3 GDPR

The data subject has the right to withdraw their declaration of consent under data protection law at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

6.8 Right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR

Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

7. ContactMeCard

We use the service provider Contact Me Solutions GmbH, Taunus Tor 3, 60310 Frankfurt am Main, https://contactmecard.com/ to provide you with the contact details of all employees digitally via ContactMeCard.

We would like to point out that you use the functions on your own responsibility. This applies in particular to the use of interactive functions (download, ...). When you visit our websites, the providers of the social media platforms collect, among other things, your IP address and other information that is stored on your end device in the form of cookies. This information is used to provide us, as the operator of the accounts, with statistical information about the interaction with us.

8. cryptshare.express

We use the service provider EQUINOXE GmbH, Bismarckallee 9, 79098 Freiburg, https://www.equinoxe.com, to provide you with encrypted communication.

We would like to point out that you use the functions on your own responsibility.

Please read the privacy policy.

9. lexoffice

We use the cloud-based accounting software "lexoffice" from Haufe-Lexware GmbH & Co. KG, Munzinger Straße 9, 79111 Freiburg, Germany.

Lexoffice processes incoming and outgoing invoices and, where applicable, our company's bank transactions in order to automatically record invoices, match them to the transactions and create the financial accounts from this in a semi-automated process.

If personal data is also processed in this context, the processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in the efficient organisation and documentation of our business processes.

You can find more information about lexoffice, the automated processing of data and the data protection provisions at https://www.lexoffice.de/datenschutz/

The authorised tax consultant has access to the data.

10. edudip

You can register for our web seminars on our website. The data collected for registration for the web seminar (first name, surname, email address) are collected and stored in accordance with Art. 6 para. 1 lit. b GDPR exclusively for your participation, implementation and issue of a training certificate for the respective web seminar. We use the services of edudip GmbH, Jülicher Straße 306, 52070 Aachen ("edudip"), which processes your data collected for the organisation of the seminar on our behalf in order to provide the technical infrastructure and manage participation authorisations. For this purpose, we have concluded an order processing contract with edudip, in which we oblige edudip to protect our customers' data and not to pass it on to third parties. To confirm your registration for a web seminar, you will receive an invitation link by e-mail. After clicking on the invitation link, a connection to the Edudip servers is established. For the purpose of clearly assigning the web seminar access and thus for checking and guaranteeing individual participant admission, Edudip collects information on our behalf about the websites visited on our site as well as your IP address in accordance with Art. 6 para. 1 lit. b GDPR.

Further information on the handling of user data can be found in Edudip's privacy policy at: https://www.edudip.com/datenschutz

11 Our presence on social networks

(1) We have various presences on social media platforms. We operate these presences with the following providers: LinkedIn, https://de.linkedin.com/legal/privacy-policy.

(2) We use the technical platform and services of the providers for these information services. We would like to point out that you use our presence on social media platforms and their functions on your own responsibility. This applies in particular to the use of interactive functions (e.g. commenting, sharing, rating). When you visit our websites, the providers of the social media platforms collect, among other things, your IP address and other information that is stored on your device in the form of cookies. This information is used to provide us, as the operator of the accounts, with statistical information about the interaction with us.

(3) The data collected about you in this context is processed by the platforms and may be transferred to countries outside the European Union, in particular the USA. According to their own statements, all of the aforementioned providers maintain an adequate level of data protection that corresponds to that of the former EU-US Privacy Shield and we have concluded the standard data protection clauses with the companies (with the exception of Xing, as this provider is based within the EU). We do not know how the social media platforms use the data from your visit to our account and interaction with our posts for their own purposes, how long this data is stored and whether data is passed on to third parties. Data processing may differ depending on whether you are registered and logged in to the social network or whether you visit the site as a non-registered and/or non-logged-in user. When you access a post or the account, the IP address assigned to your end device is transmitted to the provider of the social media platform. If you are currently logged in as a user, a cookie on your device can be used to track how you have moved around the network. Buttons integrated into websites enable the platforms to record your visits to these websites and assign them to your respective profile. This data can be used to offer you customised content or advertising. If you want to avoid this, you should log out or deactivate the "stay logged in" function, delete the cookies on your device and restart your browser.

(4) As the provider of the information service, we also only process the data from your use of our service that you provide to us and that requires interaction. For example, if you ask a question that we can only answer by email, we will store your information in accordance with the general principles of our data processing, which we describe in this privacy policy. The legal basis for the processing of your data on the social media platform is Art. 6 para. 1 sentence 1 lit. f GDPR.

(5) To exercise your rights as a data subject, you can contact us or the provider of the social media platform. If one party is not responsible for responding or must receive the information from the other party, we or the provider will then forward your enquiry to the respective partner. Please contact the operator of the social media platform directly for questions about profiling and the processing of your data when using the website. If you have any questions about the processing of your interaction with us on our site, please write to the contact details we have provided above.

(6) What information the social media platform receives and how it is used is described by the providers in their privacy policies (see link in the table above). There you will also find information about contact options and the setting options for adverts. Further information on social networks and how you can protect your data can also be found at www.youngdata.de

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