PRIVACY POLICY

1. Data protection at a glance

General information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. Detailed information on the subject of data protection can be found in our data protection declaration listed below this text.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator’s contact details in the “Information on the controller” section of this privacy policy.

How do we collect your data?

On the one hand, your data is collected when you provide it to us. This may, for example, be data that you enter in a contact form.

Other data is collected automatically or with your consent by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time of page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure that the website is provided without errors. Other data can be used to analyze your user behavior.

What rights do you have with regard to your data?

You have the right to receive information about the origin, recipient and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time if you have further questions on the subject of data protection.

2. 2. General notes and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the Internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

Note on the responsible body

The controller responsible for data processing on this website is:

dhk Daniel ∙ Hagelskamp & Kollegen Rechtsanwälte Steuerberater PartG mbB

(dhk attorneys at law)

Jülicher Str. 215

52070 Aachen

Germany

Phone: 0241/ 9 46 21-0

E-Mail: kanzlei@dhk-law.com

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the deletion will take place after these reasons no longer apply.

General information on the legal basis for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, insofar as special categories of data are processed in accordance with Art. 9 para. 1 GDPR. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or access to information in your end device (e.g. via device fingerprinting), the data processing is also carried out on the basis of Section 25 (1) TTDSG (German Telecommunications-Telemedia Data Protection Act). Consent can be revoked at any time. If your data is required to fulfill the contract or to carry out pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.

Data Protection Officer

We have appointed a data protection officer for our company:

Address details:

DHK Rechtsanwälte Steuerbarater PartG mbB, Datenschutzbeauftragter, Jülicher Str. 215, D-52070 Aachen, Germany

Telefon: 0241/ 9 46 21-0

E-Mail: dataprotection@dhk-law.com

Note on data transfer to the USA and other third countries

Among other things, we use tools from companies based in the USA or other third countries that are not secure under data protection law. If these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that a level of data protection comparable to that in the EU cannot be guaranteed in these countries. For example, US companies are obliged to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for surveillance purposes. We have no influence on these processing activities.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can withdraw your consent at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to the collection of data in special cases and to direct marketing (Art. 21 GDPR)

IF THE DATA PROCESSING IS BASED ON ART. 6 ABS. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21 PARA. 1 GDPR).

IF YOUR PERSONAL DATA ARE PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA 2 GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. The right to lodge a complaint is without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Information, deletion and correction

Within the framework of the applicable legal provisions, you have the right to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, if necessary, a right to correction or deletion of this data at any time. You can contact us at any time if you have further questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time to do this. The right to restriction of processing exists in the following cases:

• If you dispute the accuracy of your personal data stored by us, we generally need time to check this. You have the right to request the restriction of the processing of your personal data for the duration of the review.
• If the processing of your personal data was/is carried out unlawfully, you can request the restriction of data processing instead of erasure.
• If we no longer need your personal data, but you need it for the exercise, defense or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
• If you have lodged an objection pursuant to Art. 21 (1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the establishment, exercise or defense 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 European Union or of a Member State.

3. Data collection on this website

Cookies

Our Internet pages use so-called “cookies”. Cookies are small text files and do not cause any damage to your end device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or they are automatically deleted by your web browser.

In some cases, cookies from third-party companies may also be stored on your device when you visit our website (third-party cookies). These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies are used to evaluate user behavior or display advertising.

Cookies that are required to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 para. 1 lit. f GDPR, unless another legal basis is specified. The website operator has a legitimate interest in the storage of necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG -German Telecommunications-Telemedia Data Protection Act-); the consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.

If cookies are used by third-party companies or for analysis purposes, we will inform you about this separately in this privacy policy and, if necessary, request your consent.

Consent with Borlabs Cookie

Our website uses Borlabs Cookie consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document these in compliance with data protection regulations. The provider of this technology is Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg (hereinafter referred to as Borlabs).

When you enter our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the revocation of these consents are stored. This data is not passed on to the provider of Borlabs Cookie.

The data collected will be stored until you ask us to delete it or delete the Borlabs cookie yourself or until the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. Details on data processing by Borlabs Cookie can be found at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.

Borlabs cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c GDPR.

Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are

• Browser type and browser version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server request
• IP address

This data is not merged with other data sources.

This data is collected on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – the server log files must be recorded for this purpose.

Contact form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We will not pass on this data without your consent.

This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.

We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Request by e-mail, telephone or fax

If you contact us by e-mail, telephone or fax, we will store and process your inquiry, including all personal data (name, inquiry), for the purpose of processing your request. We will not pass on this data without your consent.

This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.

The data you send to us via contact requests will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

4. Social media

Instagram plugin

Functions of the Instagram service are integrated on this website. These functions are offered by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

If you are logged into your Instagram account, you can link the content of this website to your Instagram profile by clicking on the Instagram button. This allows Instagram to associate your visit to this website with your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by Instagram.

The data is stored and analyzed on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the widest possible visibility in social media. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG (German Telecommunications-Telemedia Data Protection Act), insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.

Insofar as personal data is collected on our website using the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its transfer to Facebook or Instagram. The processing carried out by Facebook or Instagram after forwarding is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in an agreement on joint processing. You can find the text of the agreement at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the data protection information when using the Facebook or Instagram tool and for the secure implementation of the tool on our website in accordance with data protection law. Facebook is responsible for the data security of Facebook and Instagram products. You can assert data subject rights (e.g. requests for information) regarding the data processed by Facebook or Instagram directly with Facebook. If you assert your data subject rights with us, we are obliged to forward them to Facebook.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum

https://help.instagram.com/519522125107875

https://de-de.facebook.com/help/566994660333381

You can find more information on this in Instagram’s privacy policy: https://instagram.com/about/legal/privacy/.

5. 5. Analysis tools and advertising

Google Ads

The website operator uses Google Ads. Google Ads is an online advertising program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters certain search terms on Google (keyword targeting). Furthermore, targeted advertisements can be displayed based on the user data available at Google (e.g. location data and interests) (target group targeting). As the website operator, we can evaluate this data quantitatively by analyzing, for example, which search terms led to the display of our advertisements and how many advertisements led to corresponding clicks.

The use of Google Ads is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in marketing its products and services as effectively as possible.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.

6. Newsletter

Newsletter data

If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.

The data entered in the newsletter registration form is processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You can revoke your consent to the storage of the data, the e-mail address and its use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter. The legality of the data processing operations that have already taken place remains unaffected by the revocation.

The data you provide us with for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose no longer applies. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR.
Data stored by us for other purposes remains unaffected by this.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist if this is necessary to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

7. Plugins and tools

Google Web Fonts (local hosting)

This site uses so-called web fonts provided by Google for the uniform display of fonts. The Google fonts are installed locally. There is no connection to Google servers.

Further information on Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=de.

Font Awesome (local hosting)

This site uses Font Awesome for the uniform display of fonts. Font Awesome is installed locally. There is no connection to the servers of Fonticons, Inc.

Further information about Font Awesome can be found in the Font Awesome privacy policy at: https://fontawesome.com/privacy.

8. Audio and video conferencing

Data processing

We use online conferencing tools, among others, to communicate with our customers. The individual tools we use are listed below. If you communicate with us by video or audio conference via the internet, your personal data will be collected and processed by us and the provider of the respective conference tool.

The conference tools collect all data that you provide/enter to use the tools (e-mail address and/or your telephone number). The conference tools also process the duration of the conference, the start and end (time) of participation in the conference, the number of participants and other “context information” in connection with the communication process (metadata).

Furthermore, the provider of the tool processes all technical data that is required to process the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

If content is exchanged, uploaded or provided in any other way within the tool, it is also stored on the tool provider’s servers. Such content includes, in particular, cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared while using the service.

Please note that we do not have full control over the data processing procedures of the tools used. Our options are largely determined by the company policy of the respective provider. Further information on data processing by the conference tools can be found in the privacy policies of the tools used, which we have listed below this text.

Purpose and legal basis

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 lit. b GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). If consent has been requested, the tools in question are used on the basis of this consent; consent can be withdrawn at any time with effect for the future.

Storage duration

The data collected directly by us via the video and conference tools will be deleted from our systems as soon as you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Stored cookies remain on your end device until you delete them. Mandatory statutory retention periods remain unaffected.

We have no influence on the storage period of your data, which is stored by the operators of the conference tools for their own purposes. For details, please contact the operators of the conference tools directly.

Conference tools used

We use the following conference tools:

Zoom

We use Zoom. The provider of this service is Zoom Communications Inc, San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. Details on data processing can be found in Zoom’s privacy policy: https://zoom.us/de-de/privacy.html.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://zoom.us/de-de/privacy.html.

Order processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract prescribed by data protection law, which ensures that the provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Details on data processing can be found in the Microsoft Teams privacy policy: https://privacy.microsoft.com/de-de/privacystatement.

Order processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract prescribed by data protection law, which ensures that the provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

Webex

We use Webex. The provider of this service is Webex Communications Deutschland GmbH, Hansaallee 249 c/o Cisco Systems GmbH, 40549 Düsseldorf, Germany.

It cannot be ruled out that the data processed with WebEx will be transferred to third countries (e.g. the USA). Webex has Binding Corporate Rules (BCR) that have been approved by Dutch, Polish, Spanish and other relevant European data protection regulatory authorities. These are binding corporate rules that legitimize internal data transfers to third countries outside the EU and EEA. Details can be found here: https://www.cisco.com/c/de_de/about/trust-center/data-protection-and-privacy-policy.html and https://konferenzen.telekom.de/fileadmin/Redaktion/conference/cisco-webex/Webex_Compliance_Deutsch_V1.0.pdf.

Details on data processing can be found in Webex’s privacy policy: https://www.cisco.com/c/de_de/about/legal/privacy-full.html.

Order processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract prescribed by data protection law, which ensures that the provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

9. Own services

Handling applicant data

We offer you the opportunity to apply to us (e.g. by e-mail, post or via the online application form). In the following, we inform you about the scope, purpose and use of your personal data collected as part of the application process. We assure you that your data will be collected, processed and used in accordance with applicable data protection law and all other statutory provisions and that your data will be treated in strict confidence.

Scope and purpose of data collection

If you send us an application, we process your associated personal data (e.g. contact and communication data, application documents, notes taken during job interviews, etc.) insofar as this is necessary to decide on the establishment of an employment relationship. The legal basis for this is § 26 BDSG (German Data Protectin Law) under German law (initiation of an employment relationship), Art. 6 para. 1 lit. b GDPR (general contract initiation) and – if you have given your consent – Art. 6 para. 1 lit. a GDPR. Consent can be revoked at any time. Your personal data will only be passed on within our company to persons who are involved in processing your application.

If the application is successful, the data submitted by you will be stored in our data processing systems on the basis of § 26 BDSG and Art. 6 para. 1 lit. b GDPR for the purpose of implementing the employment relationship.

Data retention period

If we are unable to make you a job offer, you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR) for up to 6 months from the end of the application process (rejection or withdrawal of the application). The data will then be deleted and the physical application documents destroyed. The retention serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g. due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Data may also be stored for longer if you have given your consent (Art. 6 para. 1 lit. a GDPR) or if statutory retention obligations prevent deletion.