Private Policy

Private policy

SEIKO Germany, Branch of Seiko Watch Europe S.A.S. (hereinafter referred to as "we") takes the protection of personal data very seriously.

We protect your privacy and your private data. We collect, process and use personal data in accordance with the content of this Privacy Policy and the applicable data protection laws.

These data protection regulations govern which personal data we collect, process and use about you.

I.         NAME AND ADDRESS OF THE PERSON RESPONSIBLE

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 regulations is

SEIKO Germany, Branch of Seiko Watch Europe S.A.S.

Siemensring 44m

47877 Willich

Telephone:02154 943 701

E-mail: [email protected]

 If you have any questions about data protection, please contact our data protection officer using the keyword "Data protection homepage". Please send your enquiry to [email protected].

II.       GENERAL INFORMATION ON DATA PROCESSING

1.  Scope of the processing of personal data

We only process our users' personal data to the extent necessary to provide a functional website and the content and services. The processing of users' personal data takes place regularly only with the consent of the user. An exception applies in cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by law.

2. 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 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis.

When processing personal data that is necessary for the fulfilment of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of 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 para. 1 lit. c GDPR serves as the legal basis.

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

If the 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 the former interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing.

 3. Data erasure and storage duration

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Data may also 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 prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.

III.       PROVISION OF THE WEBSITE AND CREATION OF LOG FILES

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer. The following data is collected:

1) Information about the browser type and version used

2) The user's operating system

3) The user's internet service provider

4) The IP address of the user

5) Date and time of access

6) Websites from which the user's system accesses our website

7) Websites that are accessed by the user's system via our website

The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.

2. Legal basis for data processing

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

3. Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.

Data is stored in log files to ensure the functionality of the website. We also use the data to optimise the website and to ensure the security of our information technology systems. The data is not analysed for marketing purposes in this context.

These purposes also constitute our legitimate interest in data processing in accordance with Art. 6 para. 1 lit. f GDPR.

4.    Duration of storage

The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or anonymised so that it is no longer possible to identify the accessing client.

5.    Possibility of objection and removal

The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, the user has no option to object.

IV.       use of Cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

We use cookies to make the website more user-friendly. These are technically necessary cookies. These cookies are necessary for the website to function and cannot be deactivated in your systems. As a rule, these cookies are only set in response to actions you take that correspond to a service request, such as setting your privacy preferences, logging in or filling out forms. You can set your browser to block these cookies or to notify you about these cookies. However, some areas of the website will then not work. These cookies do not store any personal data. These are the following cookies:

If you have given your consent to this, we also use cookies on our website that enable us to analyse the surfing behaviour of users. When accessing our website, the user is informed about the use of cookies for analysis purposes and their consent to the processing of the personal data used in this context is obtained. In this context, reference is also made to this privacy policy.

Marketing cookies are used to track and collect visitor actions on the website. These cookies store user data and behavioural information that enables advertising services to address more target groups. A more personalised user experience can also be provided depending on the information collected. These are the following cookies:

 2. Legal basis for data processing

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f GDPR.

The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 lit. a GDPR if the user has given consent to this.

 3. Purpose of data processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of the website cannot be offered without the use of cookies. For these, it is necessary for the browser to be recognised even after a page change. Analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus constantly optimise our offer.

4. Duration of storage, cancellation and removal options

Cookies are stored on the user's computer and transmitted by it to our website. As a user, you therefore 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 the functions of the website to their full extent.

The specific duration of storage of the individual cookies can be found in the tables above.

You have the right to revoke your declaration of consent under data protection law with regard to the processing of your data by the described analysis and marketing cookies at any time. To revoke your consent, simply send us an e-mail to: [email protected].

V.          CONTACT FORM AND E-MAIL CONTACT

1. Description and scope of data processing

There is a contact form on our website that 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. These data are:

• Telephone number

• Name

• E-mail address

 The following data is also stored at the time the message is sent:

• IP address of the user

• Date and time of registration

Your consent is obtained for the processing of the data as part of the sending process and reference is made to this privacy policy.

Alternatively, you can contact us via the e-mail address provided. In this case, the user's personal data transmitted with the e-mail will be stored.

The data will not be passed on to third parties in this context. The data is used exclusively for processing the conversation.

2. Legal basis for data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. a GDPR if the user has given consent.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.

3. Purpose of data processing

The processing of the personal data from the input mask serves us solely to process the contact. If contact is made by email, this also constitutes the necessary legitimate interest in processing the data.

The other personal data processed during the sending process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of storage

The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. For the personal data from the input screen of the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Right of objection, cancellation and removal

If the user contacts us via the contact form, the user can revoke their consent to the processing of personal data at any time. A simple email to us is sufficient to withdraw consent: [email protected]  

If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.

The user can object to the processing of their data by sending an email to [email protected] or by post. All personal data stored in the course of making contact will be deleted in this case. The processing of personal data serves us solely to process the contact. This also constitutes the necessary legitimate interest in processing the data.

VI.          Newsletter

1. Description and scope of data processing

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

• E-mail address

The following data is also stored at the time the message is sent:

• IP adress of the user

• Date and time of registration

Your consent is obtained for the processing of the data as part of the sending process and reference is made to this privacy policy.

If you purchase goods on our website and enter your e-mail address, this may subsequently be used by us to send you a newsletter. In such a case, only direct advertising for our own similar goods will be sent via the newsletter.

2. Legal basis for data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. a GDPR if the user has given consent.

The legal basis for sending the newsletter as a result of the sale of goods is Section 7 (3) UWG.

3. Purpose of data processing

The purpose of collecting the user's e-mail address is to deliver the newsletter.

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

 4. Duration of storage

The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. The user's e-mail address is therefore stored for as long as the subscription to the newsletter is active.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Right of cancellation and removal

Subscription to the newsletter can be cancelled at any time. There is a corresponding link for this purpose in every newsletter. Alternatively, the subscription can also be cancelled by sending an email to [email protected].

VII.          Registration

1. Description and scope of data processing

On our website, we offer users the opportunity to register by providing personal data. The data is entered into an input mask and transmitted to us and stored. The data is not passed on to third parties. The following data is collected as part of the registration process:

• First name, surname

• Date of birth

• E-mail address

The following data is also stored at the time the message is sent:

• IP address of the user

• Date and time of booking

2. Legal basisfor data processing

The data entered during registration is processed for the purpose of implementing the user relationship established by the registration and, if necessary, for the initiation of further contracts (Art. 6 para. 1 lit. b GDPR).

3. Purpose of data processing

Registration of the user is required to fulfil a contract with the user or to carry out pre-contractual measures. The other personal data processed during the sending process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of storage

The data will be deleted as soon as it is no longer required to fulfil the purpose for which it was collected.

This is the case for the data collected during the registration process if the registration on our website is cancelled or amended.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Possibility of objection and removal

As a user, you have the option of cancelling your registration at any time. You can have the data stored about you amended at any time.

VIII.          order

1.Description and scope of data processing

On our website, we offer users the opportunity to order goods by providing personal data. As part of the ordering process, data is entered into an input mask and transmitted to us and stored. The following data is collected as part of the registration process:

         • First name, surname

         • Date of birth

         • E-mail address

The following data is also stored at the time the message is sent:

        • IP address of the user

        • Date and time of the booking

The data may be passed on to the following service providers:

• Shipping service provider

• payment service provider

• Credit agencies

• Dept collection service provider

If we use them as processors, the service providers will only have access to your data to the extent and for the period required for the provision of the respective service.

2. Legal basis for data processing

The data entered during registration is processed for the purpose of implementing the user relationship established by the registration and, if necessary, for the initiation of further contracts (Art. 6 para. 1 lit. b GDPR).

3. Purpose of data processing

The processing of the data serves to fulfil the purchase contract.

The other personal data processed during the sending process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of storage

The data will be deleted as soon as it is no longer required to fulfil the purpose for which it was collected.

After fulfilment of the purchase contract, your data will be deleted unless we are obliged to store the data beyond this due to commercial and/or tax regulations.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

IX.       Google Web Fonts

This site uses so-called web fonts provided by Google for the standardised display of fonts. When you access a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly. For this purpose, the browser you are using must connect to Google's servers. This informs Google that this website has been accessed via your IP address.

The use of Google Web Fonts is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the uniform presentation of the typeface on its website. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

If your browser does not support web fonts, a standard font will be used by your computer.

Weitere Informationen zu Google Web Fonts finden Sie unter

https://developers.google.com/fonts/faq and in Google's privacy policy:

https://policies.google.com/privacy?hl=de.

 X.       Facebook Pixel

This website uses visitor action pixels from Facebook to measure the conversion of visitor actions. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the data collected is also transferred to the USA and other third countries. This allows the behaviour of site visitors to be tracked after they have been redirected to the provider's website by clicking on a Facebook ad. This allows the effectiveness of Facebook ads to be evaluated for statistical and market research purposes and future advertising measures to be optimised. The data collected is anonymous to us as the operator of this website; we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook Data Usage Policy. This enables Facebook to place adverts on Facebook pages and outside of Facebook. This use of the data cannot be influenced by us as the website operator. The use of Facebook pixels is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in effective advertising measures including social media. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

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 and

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

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Facebook 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. The processing carried out by Facebook 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. The text of the agreement can be found 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 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 products. You can assert data subject rights (e.g. requests for information) regarding the data processed by Facebook directly with Facebook. If you assert your data subject rights with us, we are obliged to forward them to Facebook. You can find further information on protecting your privacy in Facebook's data protection information:

https://de-de.facebook.com/about/privacy/.

You can also deactivate the remarketing function "Custom Audiences" in the settings for adverts at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.

You must be logged in to Facebook to do this.

If you do not have a Facebook account, you can deactivate usage-based advertising from Facebook on the website of the European Interactive Digital Advertising Alliance:

 http://www.youronlinechoices.com/de/praferenzmanagement/.

 XI.          Google Conversion-Tracking

This website uses Google Conversion Tracking. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

With the help of Google conversion tracking, Google and we can recognise whether the user has carried out certain actions. For example, we can analyse which buttons on our website were clicked how often and which products were viewed or purchased particularly frequently. This information is used to create conversion statistics. We find out the total number of users who have clicked on our adverts and which actions they have carried out. We do not receive any

information with which we can personally identify the user. Google itself uses cookies or comparable recognition technologies for identification purposes.

The use of Google Conversion Tracking is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

You can find more information about Google Conversion Tracking in Google's privacy policy:

https://policies.google.com/privacy?hl=de.

 XII.          Google Remarketing

This website uses Google Remarketing. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Remarketing analyses your user behaviour on our website (e.g. clicks on certain products) in order to classify you into certain advertising target groups and then display suitable advertising messages to you when you visit other online offers (remarketing or retargeting). Furthermore, the advertising target groups created with Google Remarketing can be linked to Google's cross-device functions. In this way, interest-based, personalised advertising messages that have been adapted to you depending on your previous usage and surfing behaviour on one end device (e.g. mobile phone) can also be displayed on another of your end devices (e.g. tablet or PC).

If you have a Google account, you can object to personalised advertising by clicking on the following link:

https://www.google.com/settings/ads/onweb/.

The use of Google Remarketing is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in marketing its products as effectively as possible. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

Further information and the data protection provisions can be found in Google's privacy policy at:

https://policies.google.com/technologies/ads?hl=de.

Target group formation with customer matching

Among other things, we use Google Remarketing customer matching to create target groups. Here we transfer certain customer data (e.g. email addresses) from our customer lists to Google. If the customers in question are Google users and are logged into their Google account, they are shown suitable advertising messages within the Google network (e.g. on YouTube, Gmail or in the search engine).

XIII.          Google Ads

The website operator uses Google Ads. Google Ads is an online advertising programme of Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display adverts in the Google search engine or on third-party websites when the user enters certain search terms in Google (keyword targeting). Furthermore, targeted adverts 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 analysing, 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 services and products 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/.

XIV.          Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyse the behaviour of website visitors. In doing so, the website operator receives various usage data, such as page views, length of visit, operating systems used and origin of the user. This data may be summarised by Google in a profile that is assigned to the respective user or their end device. Google Analytics uses technologies that enable the recognition of the user for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is generally transmitted to a Google server in the USA and stored there. The use of this analysis tool is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time. Data transfer to the USA is based on the standard contractual clauses of the EU Commission.

Details can be found here:

https://privacy.google.com/businesses/controllerterms/mccs/.

 IP anonymization

We have activated the IP anonymisation function on this website. This means that your IP address will be truncated by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to analyse your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

 Browser Plugin

You can prevent the collection and processing of your data by Google by downloading and installing the browser plug-in available at the following link:

https://tools.google.com/dlpage/gaoptout?hl=de.

You can find more information on how Google Analytics handles user data in Google's privacy policy:

https://support.google.com/analytics/answer/6004245?hl=de.

 Order processing

We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Demographic characteristics in Google Analytics

This website uses the "demographic characteristics" function of Google Analytics in order to be able to display suitable adverts to website visitors within the Google advertising network. This allows reports to be generated that contain statements about the age, gender and interests of site visitors. This data comes from interest-based advertising from Google and from visitor data from third-party providers. This data cannot be assigned to a specific person. You can deactivate this function at any time via the ad settings in your Google account or generally prohibit the collection of your data by Google Analytics as described in the section "Objection to data collection".

 Google Analytics E-Commerce-Tracking

This website uses the "e-commerce tracking" function of Google Analytics. With the help of e-commerce tracking, the website operator can analyse the purchasing behaviour of website visitors to improve its online marketing campaigns. Information such as orders placed, average order values, shipping costs and the time from viewing to purchasing a product is recorded. This data can be summarised by Google under a transaction ID that is assigned to the respective user or their device.

 Storage duration

Data stored by Google at user and event level that is linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) is anonymized or deleted after 50 months. Details can be found under the following link:

https://support.google.com/analytics/answer/7667196?hl=de

XV.          Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store any cookies and does not carry out any independent analyses. It is only used to manage and display the tools integrated via it. However, Google Tag Manager records your IP address, which may also be transmitted to Google's parent company in the United States.

can be transmitted. The Google Tag Manager is used on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the fast and uncomplicated integration and management of various tools on its website. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

XVI.       Youtube

This website embeds videos from YouTube. The operator of the pages is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in extended data protection mode. According to YouTube, this mode means that YouTube does not store any information about visitors to this website before they watch the video. However, the transfer of data to YouTube partners is not necessarily excluded by the extended data protection mode. For example, YouTube establishes a connection to the Google DoubleClick network regardless of whether you watch a video.

As soon as you start a YouTube video on this website, a connection to the YouTube servers is established. The YouTube server is informed which of our pages you have visited.

If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

Furthermore, YouTube can store various cookies on your end device after starting a video or use comparable recognition technologies (e.g. device fingerprinting). In this way, YouTube can obtain information about visitors to this website. This information is used, among other things, to record video statistics, improve user-friendliness and prevent attempts at fraud.

If necessary, further data processing operations may be triggered after the start of a YouTube video, over which we have no influence.

The use of YouTube is in the interest of an appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

XVII.          Links to other Websites

Our homepage may contain links to third-party websites. If you follow a link to one of these websites, please note that we cannot accept any responsibility or guarantee for third-party content or data protection conditions. Please check the applicable data protection conditions before you transmit personal data to these websites.

XVIII.      Data security

All information that you transmit to us is stored on servers within the European Union. Unfortunately, the transmission of information via the Internet is not completely secure, which is why we cannot guarantee the security of data transmitted to and via our website via the Internet. However, we take the best possible technical and organizational measures to protect our website and other systems against loss, destruction, access, modification or dissemination of your data by unauthorized persons.

We take precautions to ensure the security of your personal data. Your data is conscientiously protected against loss, destruction, falsification, manipulation and unauthorized access or unauthorized disclosure.

XX.       Rights of the data subject

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

1. Right of information

You can request confirmation from the controller as to whether personal data concerning you is being processed by us. If such processing is taking place, you can request the following information from the controller: 

(1)       the purposes for which the personal data are processed;

(2)       the categories of personal data that are processed;

(3)       the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;

(4)       the planned duration of storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;

(5)      the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;

(6)       the existence of a right of appeal to a supervisory authority;

(7)       all available information on the origin of the data if the personal data is not collected from the data subject;

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.

2. Right of rectification

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

3. Right to restriction of processing

Under the following conditions, you may request the restriction of the processing of your personal data: 

(1)      if you contest the accuracy of the personal data concerning you 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 their use instead;

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

(4)      if you have objected to the processing pursuant to Art. 21 (1) GDPR and it is not yet certain whether the legitimate grounds of the controller override your grounds.

If the processing of personal data concerning you has been restricted, this data - apart from its storage - may 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 restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

4. Right of cancellation

  a) Duty of cancellation

You can demand that we delete the personal data concerning you immediately and we are obliged to delete this data immediately if one of the following reasons applies: 

(1)       The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.

(2)       You revoke your consent on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR and there is no other legal basis for the processing.

(3)       You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.

(4)       The personal data concerning you has been processed unlawfully.

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

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

            b) Information to third parties

If we have made the personal data concerning you public and we are obliged to delete it in accordance with Art. 17 para. 1 GDPR, we shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform data controllers who process the personal data that you, as the data subject, have requested them to delete all links to this personal data or copies or replications of this personal data.

           c) Exceptions

The right to erasure does not exist if the processing is necessary 

(1)        to exercise the right to 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 Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;

(4)       for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or

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

5. Right to information

If you have asserted the right to rectification, erasure or restriction of processing, we are obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right vis-à-vis the controller to be informed about these recipients.

6. Right to data portability

You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format. You also 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)       the processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and

(2)        the processing is carried out using automated procedures.

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

The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right to objection

You 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 point (e) or (f) of Article 6(1) GDPR.

We will no longer process the personal data concerning you unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these 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.

8. Right to revoke the declaration of consent under data protection law

You have the right to revoke your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. To revoke your consent or to object, simply send us an email to: [email protected]

9. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you 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 Art. 78 GDPR.

XIX.       changes to the data protection regulations

We reserve the right to amend this privacy policy at any time with effect for the future so that it always complies with current legal requirements or to implement changes to our services in the privacy policy, e.g. when introducing new services. Therefore, please check the data protection declaration again on your next visitn