We are very pleased about your interest in our company. Use of the internet pages of Silke Steinhauser is generally possible without providing any personal data. However, if a data subject wishes to make use of special services of our company via our website, processing of personal data may become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, email address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to Silke Steinhauser. By means of this privacy policy, our company wishes to inform the public about the type, scope and purpose of the personal data collected, used and processed by us. Furthermore, data subjects are informed of their rights by means of this privacy policy. Silke Steinhauser, as the controller responsible for processing, has implemented numerous technical and organizational measures to ensure the most complete protection possible of personal data processed via this website. Nevertheless, internet-based data transmissions may generally have security gaps, so absolute protection cannot be guaranteed. For this reason, it is open to any data subject to transmit personal data to us by alternative means, for example by telephone.
1. Definitions
The privacy policy is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance. In this privacy policy, we use, among others, the following terms:
a) Personal data
Personal data is any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
c) Processing
Processing is any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting its future processing.
e) Profiling
Profiling is any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
f) Pseudonymization
Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures ensuring that the personal data is not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for processing
The controller or controller responsible for processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or the specific criteria for its designation may be provided for by Union law or by the law of the Member States.
h) Processor
A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient
A recipient is a natural or legal person, public authority, agency or another body to whom the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union law or the law of the Member States shall not be regarded as recipients.
j) Third party
A third party is a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
k) Consent
Consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes in the form of a statement or other clear affirmative action by which the data subject signifies agreement to the processing of personal data relating to him or her.
2. Name and address of the controller responsible for processing
The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:
Silke Steinhauser
Kornhofen 4
87730 Bad Grönenbach
Tel.: +49 173 6606994
silke@silkesteinhauser.de
3. Routine erasure and blocking of personal data
The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage, or insofar as this is provided for by the European legislator or another legislator in laws or regulations to which the controller is subject. If the purpose of storage no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or erased in accordance with the statutory provisions.
4. Rights of the data subject
a) Right to confirmation
Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may contact an employee of the controller at any time.
b) Right of access
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain at any time free information from the controller about the personal data stored about him or her and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to rectification or erasure of personal data concerning him or her or to restriction of processing by the controller or of the right to object to such processing;
the existence of the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject: any available information as to their source;
the existence of automated decision-making, including profiling, pursuant to 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.
Furthermore, the data subject has the right to be informed whether personal data are transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards relating to the transfer.
If a data subject wishes to exercise this right of access, he or she may contact an employee of the controller at any time.
c) Right to rectification
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning him or her. Furthermore, taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may contact an employee of the controller at any time.
d) Right to erasure (right to be forgotten)
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, where one of the following grounds applies and insofar as the processing is not necessary:
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent on which the processing is based pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services pursuant to Article 8(1) GDPR.
If one of the above grounds applies and a data subject wishes to request the erasure of personal data stored by Silke Steinhauser, he or she may contact an employee of the controller at any time. Silke Steinhauser will ensure that the erasure request is complied with without undue delay.
If the personal data have been made public by Silke Steinhauser and our company is obliged as controller pursuant to Article 17(1) GDPR to erase the personal data, Silke Steinhauser shall take reasonable steps, including technical measures, taking account of available technology and the cost of implementation, to inform other controllers processing the published personal data that the data subject has requested the erasure by such controllers of any links to, or copies or replications of, those personal data, insofar as processing is not required. Silke Steinhauser will arrange the necessary measures in individual cases.
e) Right to restriction of processing
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
The data subject has objected to processing pursuant to Article 21(1) GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.
If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Silke Steinhauser, he or she may contact Silke Steinhauser at any time. Silke Steinhauser will arrange the restriction of the processing.
f) Right to data portability
Every data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning him or her, which was provided by the data subject to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may contact Silke Steinhauser at any time.
g) Right to object
Every data subject affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time to the processing of personal data concerning him or her which is based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.
Silke Steinhauser shall no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defense of legal claims.
If Silke Steinhauser processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning him or her for such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to processing for direct marketing purposes, Silke Steinhauser will no longer process the personal data for these purposes.
In addition, the data subject has the right to object, on grounds relating to his or her particular situation, to processing of personal data concerning him or her by Silke Steinhauser for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the data subject may contact Silke Steinhauser. Furthermore, the data subject is free to exercise his or her right to object in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Every data subject affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning him or her or similarly significantly affects him or her, provided that the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller or (2) it is based on the data subject’s explicit consent, Silke Steinhauser shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
If the data subject wishes to exercise rights concerning automated decisions, he or she may contact an employee of the controller at any time.
i) Right to withdraw data protection consent
Every data subject affected by the processing of personal data has the right granted by the European legislator to withdraw his or her consent to the processing of personal data at any time.
If the data subject wishes to exercise the right to withdraw consent, he or she may contact an employee of the controller at any time.
5. Legal basis for processing
Article 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, such as processing operations necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Article 6(1)(b) GDPR. The same applies to such processing operations which are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation by which processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Article 6(1)(c) GDPR. In rare cases, processing of personal data may become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and his or her name, age, health insurance data or other vital information had to be passed on to a doctor, a hospital or other third parties. In such cases, the processing would be based on Article 6(1)(d) GDPR. Finally, processing operations may be based on Article 6(1)(f) GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not override those interests. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, the legislator took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 GDPR).
6. Legitimate interests pursued by the controller or a third party
Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and our shareholders.
7. Duration for which the personal data are stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiration of this period, the corresponding data are routinely erased, provided that they are no longer required for the performance or initiation of a contract.
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