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Data Privacy Statement in accordance with the GDPR

I. Name and address of the controller

The controller, within the meaning of the General Data Protection Regulation and other national data protection laws of the member states, as well as other data protection provisions, is:

PDS Peripherie. Daten. Systeme. Entwicklungs- und Service GmbH Ettore-Bugatti-Str. 35 51149 Cologne Germany Tel.: +49 2203 18 88 0 e-mail: info@circlon.de Website: https://circlon.de/pds

II. Name and address of the data protection officer

The controller’s data protection officer is:

Athanasios Stoikos
Ettore-Bugatti-Str. 35
51149 Cologne
Germany
Tel.: +49 2203 18880
e-mail: Athanasios.stoikos@circlon.de

III. General information on data processing

Scope of processing of personal data

As a general rule, we only process personal data relating to our users if this is necessary to provide a functional website as well as our content and services. In general, personal data relating to our users is only processed after the user has granted his/her consent. An exception applies in those cases in which prior consent cannot be obtained for practical reasons and the processing of the data is permitted by statutory provisions.

Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 (1a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

In respect of the processing of personal data required for the performance of an agreement to which the data subject is party, Art. 6 (1b) GDPR serves as the legal basis. This also applies to processing operations that are necessary to perform pre-contractual measures.

Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 (1c) GDPR serves as the legal basis.

In the event that the vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1d) GDPR serves as the legal basis.

If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh these legitimate interests, Art. 6 (1f) GDPR serves as the legal basis for processing.

Data erasure and storage period

The personal data relating to the data subject will be erased or blocked as soon as the purpose of storage ceases to apply. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. The data will also be blocked or erased if a storage period set out by the aforementioned standards expires, unless there is a need for the further storage of the data for the conclusion or performance of an agreement.

IV. Provision of the website and creation of log files

Description and scope of data processing

Every time you visit our website, our system automatically collects data and information from the computer system of the accessing computer.

The following data is collected:

  • 1. Information on the browser type and version used
  • 2. The user's operating system
  • 3. The user's Internet service provider
  • 4. The user's IP address
  • 5. Date and time of access
  • 6. Websites from which the user's system accesses our website
  • 7. Websites accessed by the user's system via our website

The legal basis for the temporary storage of the data and log files is Art. 6 (1f) GDPR.

Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the website to be displayed on the user's computer. This means that the user’s IP address has to remain stored for the duration of the session.

The data is stored in log files to ensure the functionality of the website. In addition, the data helps us to optimise the website and to ensure the security of our information technology systems. The data is not analysed for marketing purposes within this context.

Our legitimate interest in data processing in accordance with Art. 6 (1f) GDPR also lies in these purposes.

Duration of storage

The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. Regarding the data collected for the provision of the website, this is the case when the session in question has ended.

For data stored in log files, this is the case after seven days at the latest. Further storage is possible. In such cases, the user IP addresses will be erased or masked so that they can no longer be assigned to the accessing client.

Options for objections and elimination

The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. As a result, users have no rights to object.

V. Use of cookies

Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser/by the Internet browser on the user's computer system. If a user visits a website, a cookie may be stored on the user's operating system. This cookie contains a character string that enables the unique identification of the browser when the website is accessed again.

We use cookies to make our website more user-friendly. Some elements of our website require the accessing browser to be identified even after a page change.

The following data is stored and transmitted in the cookies: Language settings,

We also use cookies on our website which enable an analysis of the user's surfing behaviour. This means that the following data can be transmitted: Search terms entered, frequency of page views, use of website functions

The user data collected in this way is pseudonymised using technical precautions. This means that the data can no longer be allocated to the accessing user. The data will not be stored together with other personal data relating to the users.

When they visit our website, users see an information banner informing them about the use of cookies for analytical purposes, and referring them to this data privacy statement. Within this context, information is also provided on how the storage of cookies can be prevented in the browser settings.

Legal basis for data processing

The legal basis for the processing of personal data using cookies is Art. 6 (1f) GDPR.

Purpose of data processing

The purpose of using technically necessary cookies is to make it easier for users to use websites. Some functions of our website cannot be offered without the use of cookies. These functions require the browser to be recognized again, even after a page change. We need cookies for the following applications: Language settings

The user data collected by technically necessary cookies is not used to create user profiles.

The analysis cookies are used to improve the quality of our website and its content. The analysis cookies show us how the website is being used, allowing us to optimise our offering on an ongoing basis.

Our legitimate interest in the processing of personal data in accordance with Art. 6 (1f) GDPR also lies in these purposes.

Duration of storage, options for objections and elimination

Cookies are stored on the user's computer and transmitted to our site from this computer. This means that you, as the user, have full control over the use of cookies. You can deactivate or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been saved 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 of the functions of the website in full.

VI. Newsletter

Description and scope of data processing

You can subscribe to a free newsletter on our website. When registering for the newsletter, the data from the input mask is transmitted to us.

In addition, the following data is collected upon registration: Language, date and time of registration

In the course of the registration process, your consent is obtained for the processing of the data and reference is made to this data privacy statement.

If you purchase goods or services on our website and provide us with your e-mail address, we may use this e-mail address to send you a newsletter in the future. In such cases, the newsletter will only be used to send you direct advertising for similar goods or services that we offer.

No data is passed on to third parties in connection with data processing for the dispatch of newsletters. The data will only be used to send out the newsletter.

Legal basis for data processing

The legal basis for the processing of data following registration for the newsletter by the user with the user’s consent is Art. 6 (1a) GDPR.

The legal basis for sending the newsletter as a result of the sale of goods or services is section 7 (3) of the German Unfair Competition Act (UWG).

Purpose of data processing

The user's e-mail address is collected so that the newsletter can be sent out.

The collection of other personal data as part of the registration process serves to prevent the misuse of the services or the e-mail address used.

Duration of storage

The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. This means that the user's e-mail address will be stored for as long as the subscription to the newsletter is active.

The other personal data collected during the registration process will generally be erased after a period of seven days.

Options for objections and elimination

The subscription to the newsletter can be cancelled by the user at any time. A corresponding link can be found on the website for this purpose.

VII. Contact form and e-mail contact

Description and scope of data processing

There is a contact form on our website which can be used to contact us electronically. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored.

This data includes: Name, e-mail address and subject, Telephone number and message are optional

No further data will be stored when the message is sent. In the course of the input mask dispatch process, your consent is obtained for the processing of the data and reference is made to this data privacy statement. Alternatively, you can contact us using the e-mail address provided. In this case, the user's personal data transmitted in the e-mail will be stored. The data will not be passed on to third parties within this context. The data will only be used to process the conversation.

Legal basis for data processing

The legal basis for the processing of data with the user’s consent is Art. 6 (1a) GDPR. The legal basis for the processing of data transmitted when an e-mail is sent is Art. 6 (1f) GDPR. If the e-mail contact is aimed at the conclusion of an agreement, the additional legal basis for the processing is Art. 6 (1b) GDPR.

Purpose of data processing

We only process the personal data from the input mask to process the enquiry. In the event of contact by e-mail, this also constitutes the necessary legitimate interest in the processing of the data. The other personal data processed during the dispatch process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

Duration of storage

The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. For the personal data from the contact form input mask and the data that was sent by e-mail, this is the case when the conversation with the user is finished. The conversation is also considered to have ended when it can be inferred from the circumstances that the matter in question has been definitively clarified. The other personal data collected during the dispatch process will be erased after a period of seven days at the most.

Options for objections and elimination

The user can revoke his/her consent to the processing of personal data at any time. If the user contacts us by e-mail, he/she can object to the storage of his/her personal data at any time. In such cases, the conversation cannot be continued.

All personal data stored in the course of the user’s contact with us will be erased in this case.

VIII. Rights of the data subject

If personal data relating to you is processed, you are the data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

Right of access to personal data

You can ask the controller to confirm whether personal data concerning you is processed by us.

If we do process this sort of data, you can request the following information from the controller:

  • (1) the purposes for which the personal data is being processed;
  • (2) the categories of personal data concerned;
  • (3) the recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;
  • (4) the planned duration of the storage of the personal data concerning you or, if specific information on this cannot be provided, criteria for determining the storage period;
  • (5) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
  • (6) the right to lodge a complaint with a supervisory authority;
  • (7) where the personal data is not collected from the data subject, any available information as to its source;
  • (8) the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transmitted to a third country or to an international organisation. Within this context, you can request the appropriate safeguards in accordance with Art. 46 GDPR in connection with the transmission.

Right to rectification

You have a right to rectification and/or completion vis-à-vis the controller if the personal data concerning you that is processed is incorrect or incomplete. The controller shall make the correction without delay.

Right to restriction of processing

Subject to the following conditions, you may request that the processing of personal data concerning you be restricted:

  • (1) if you contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data;
  • (2) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead;
  • (3) the controller no longer needs the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims; or
  • (4) you have objected to processing pursuant to Article 21 (1) GDPR pending the verification whether the legitimate grounds of the controller override yours.

Where the processing of the personal data concerning you has been restricted, such data shall, with the exception of storage, only be processed with your 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.

If the processing has been restricted according to the above conditions, you will be informed by the controller before the restriction is lifted.

Right to erasure

Erasure obligation

You can ask the controller to erase the personal data concerning you without undue delay and the controller shall have the obligation to erase this data without undue delay where one of the following grounds applies:

  • (1) the personal data concerning you is longer necessary in relation to the purposes for which it was collected or otherwise processed.
  • (2) you withdraw your consent on which the processing is based according to Article 6 (1a) or Article 9 (2a) GDPR, and where there is no other legal ground for the processing.
  • (3) You object to the processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21 (2) GDPR.
  • (4) The personal data concerning you has been unlawfully processed.
  • (5) The personal data concerning you has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • (6) The personal data concerning you has been collected in relation to the offer of information society services referred to in Article 8 (1) GDPR.

Information provided to third parties

Where the controller has made the personal data concerning you public and is obliged pursuant to Article 17 (1) GDPR 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 you, as the data subject, have requested the erasure by such controllers of any links to, or copy or replication of, this personal data.

Exceptions

There is no right to erasure if the processing is necessary

  • (1) for exercising the right of freedom of expression and information;
  • (2) 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;
  • (3) for reasons of public interest in the area of public health in accordance with Article 9 (2h) and (2i), as well as Article 9 (3) GDPR;
  • (4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) GDPR in so far as the right referred to in a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  • (5) for the establishment, exercise or defence of legal claims.

Right to information

If you have exercised your right to have the controller rectify, erase or restrict the processing, the latter is obliged to inform all recipients to whom the personal data concerning you has been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You shall have the right, vis-à-vis the controller, to be informed of such 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, standard and machine-readable format. In addition, you have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where:

  • (1) processing is based on consent pursuant to Article 6 (1a) GDPR or Article 9 (2a) GDPR or an agreement pursuant to Article 6 (1b) GDPR and
  • (2) the processing is carried out by automated means.

In exercising this right, you also have the right to request that the personal data concerning you be transmitted directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data portability shall not apply to the processing of personal data that is 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 to object

You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6 (1e) or (1f) GDPR, including profiling based on those provisions.

The controller shall no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Where personal data concerning you is processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where you object to processing for direct marketing purposes, the personal data concerning you shall no longer be processed for such purposes.

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

Right to revoke the data protection declaration of consent

You have the right to revoke your data protection declaration of consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Automated individual decision-making, including profiling

You shall 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 shall not apply if the decision:

  • (1) is necessary for entering into, or performance of, a contract between you and a data controller;
  • (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
  • (3) is based on your explicit consent.

These decisions shall not, however, be based on special categories of personal data referred to in Article 9 (1) GDPR, unless Article 9 (2a) or (2g) GDPR applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

In the cases referred to in (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express its 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 shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 GDPR.

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