Privacy Policy

This privacy policy informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and the websites, functions and content connected with it as well as external online presences, such as our social media profiles (hereinafter jointly referred to as “online offering”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Controller

Anna Luise Kiss
10405 Berlin
Germany

(link behind)

to the Imprint with a note on the address disclosure

Types of processed data:

– Inventory data (e.g. names, addresses).
– Contact data (e.g. e-mail, telephone numbers).
– Content data (e.g. text entries, photographs, videos).
– Usage data (e.g. websites visited, interest in content, access times).
– Meta/communication data (e.g. device information, IP addresses).

Categories of data subjects

Visitors and users of the online offering (hereinafter we also refer to the data subjects collectively as “users”).

Purpose of processing

– Provision of the online offering, its functions and content.
– Answering contact requests and communicating with users.
– Security measures.
– Reach measurement/marketing

Terms used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.

“Pseudonymisation” means the processing of personal data in such a manner 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 to ensure that the personal data are not attributed to an identified or identifiable natural person.

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

“Controller” means 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.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. If the legal basis is not stated in this privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR; the legal basis for processing to fulfil our services and carry out contractual measures as well as answering enquiries is Art. 6 (1) (b) GDPR; the legal basis for processing to fulfil our legal obligations is Art. 6 (1) (c) GDPR; and the legal basis for processing to safeguard our legitimate interests is Art. 6 (1) (f) GDPR. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) (d) GDPR serves as the legal basis.

Security measures

In accordance with Art. 32 GDPR and taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data as well as the access, input, disclosure, availability and separation relating to them. Furthermore, we have set up procedures that ensure the exercise of data subjects’ rights, the deletion of data and a response to threats to the data. In addition, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default (Art. 25 GDPR).

Cooperation with processors and third parties

If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e.g. if the transmission of data to third parties, such as payment service providers, is necessary for the performance of a contract pursuant to Art. 6 (1) (b) GDPR), you have consented, a legal obligation provides for it, or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called “order-processing agreement”, this is done on the basis of Art. 28 GDPR.

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 happens in the context of using third-party services or disclosing or transmitting data to third parties, this only takes place if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 ff. GDPR are met. This means that 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 that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).

Rights of data subjects

You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as to further information and a copy of the data in accordance with Art. 15 GDPR.

In accordance with Art. 16 GDPR, you have the right to request the completion of the data concerning you or the rectification of inaccurate data concerning you.

In accordance with Art. 17 GDPR, you have the right to request that data in question be deleted without delay, or, alternatively, in accordance with Art. 18 GDPR, to request a restriction of the processing of the data.

You have the right to request that the data concerning you which you have provided to us be received in accordance with Art. 20 GDPR and to request its transmission to other controllers.

You also have the right, in accordance with Art. 77 GDPR, to lodge a complaint with the competent supervisory authority.

Right of withdrawal

You have the right to withdraw consent granted in accordance with Art. 7 (3) GDPR with effect for the future.

Right to object

You can object to the future processing of the data concerning you at any time in accordance with Art. 21 GDPR. The objection may in particular be made against processing for the purposes of direct marketing.

Cookies and right to object to direct marketing

“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or after their visit within an online offering. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offering and closes their browser. In such a cookie, for example, the content of a shopping cart in an online shop or a login status can be stored. Cookies are referred to as “permanent” or “persistent” if they remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. Likewise, the interests of users that are used for reach measurement or marketing purposes can be stored in such a cookie. A “third-party cookie” refers to cookies that are offered by providers other than the controller who operates the online offering (otherwise, if they are only its cookies, one speaks of “first-party cookies”).

We may use temporary and permanent cookies and clarify this in the context of our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the relevant option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser.

The exclusion of cookies can lead to functional restrictions of this online offering.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US-American site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that in this case not all functions of this online offering may be usable.

Deletion of data

The data processed by us is deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated within this privacy policy, the data stored by us is deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

In accordance with the legal requirements in Germany, retention takes place in particular for 10 years pursuant to Sec. 147 (1) AO, 257 (1) nos. 1 and 4, (4) HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years pursuant to Sec. 257 (1) nos. 2 and 3, (4) HGB (commercial letters).

In accordance with the legal requirements in Austria, retention takes place in particular for 7 years pursuant to Sec. 132 (1) BAO (accounting documents, receipts/invoices, accounts, vouchers, business papers, statement of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically supplied services, telecommunications, radio and television services that are provided to non-entrepreneurs in EU member states and for which the Mini One Stop Shop (MOSS) is used.

Making contact

When making contact with us (e.g. via contact form, e-mail, telephone or via social media), the user’s details are processed for the purpose of handling the contact request and its processing pursuant to Art. 6 (1) (b) (in the context of contractual/pre-contractual relationships), Art. 6 (1) (f) (other requests) GDPR. The users’ details can be stored in a customer relationship management system (“CRM system”) or comparable request organisation.

We delete the requests if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.

Hosting and e-mail dispatch

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services as well as technical maintenance services that we use for the purpose of operating this online offering.

In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors of this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering pursuant to Art. 6 (1) (f) GDPR in conjunction with Art. 28 GDPR (conclusion of an order-processing agreement).

Collection of access data and log files

We, or our hosting provider, collect data on the basis of our legitimate interests within the meaning of Art. 6 (1) (f) GDPR about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to clarify acts of abuse or fraud) for a maximum period of 7 days and then deleted. Data whose further retention is required for evidentiary purposes is exempt from deletion until the respective incident has been finally clarified.