Privacy Policy
This privacy policy clarifies the nature, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and its associated websites, functions, and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”). With regard to the terminology used, such as “processing” or “controller,” we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Controller
Temel Nal / SANAS Rechtsanwälte GbR
Goethestrasse 17
80336 Munich, Germany
Email address: info@sanas-legal.de
Owner: Temel Nal
Link to Legal Notice: https://sanas-legal.de/impressum/
Types of processed data:
– Inventory data (e.g., names, addresses).
– Contact data (e.g., email, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offering (hereinafter, we also refer to the data subjects collectively as “users”).
Purpose of processing
– Provision of the online offering, its functions, and content.
– Responding to contact requests and communicating with users.
– Security measures.
– Reach measurement/marketing
Terminology used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data.
“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
The “controller” 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.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR; the legal basis for processing for the fulfillment of our services and implementation of contractual measures as well as responding to inquiries is Art. 6(1)(b) GDPR; the legal basis for processing for the fulfillment of our legal obligations is Art. 6(1)(c) GDPR; and the legal basis for processing to protect our legitimate interests is Art. 6(1)(f) GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6(1)(d) GDPR serves as the legal basis.
Security measures
In accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access, input, disclosure, ensuring availability, and its separation. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and response to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default (Art. 25 GDPR).
Cooperation with processors and third parties
If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them, or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g., if a transmission of the data to third parties, such as payment service providers, is required for contract fulfillment pursuant to Art. 6(1)(b) GDPR), if you have consented, if a legal obligation provides for this, or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.).
If we commission third parties to process data on the basis of a so-called “data processing agreement,” this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosure or transmission of data to third parties, this only happens if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means, for example, that processing is carried out on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
You have the right to request confirmation as to whether relevant data is being processed and to receive information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
In accordance with Art. 16 GDPR, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that relevant data be deleted immediately, or alternatively, in accordance with Art. 18 GDPR, to demand a restriction of the processing of the data.
You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to demand its transmission to other controllers.
Furthermore, pursuant to Art. 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority.
Right of withdrawal
You have the right to withdraw consents granted pursuant to Art. 7(3) GDPR with effect for the future.
Right to object
You may object to the future processing of data concerning you in accordance with Art. 21 GDPR at any time. The objection may be made in particular against processing for the purposes of direct marketing.
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, or “session cookies” or “transient cookies,” are cookies that are deleted after a user leaves an online offering and closes their browser. In such a cookie, for example, the contents of a shopping cart in an online shop or a login status can be stored. Cookies are referred to as “permanent” or “persistent” if they remain stored even after the browser is closed. For example, the login status can be stored if users visit the site after several days. Likewise, the interests of users can be stored in such a cookie, which are used for reach measurement or marketing purposes. “Third-party cookies” are cookies offered by providers other than the controller who operates the online offering (otherwise, if they are only the controller’s cookies, they are called “first-party cookies”).
We may use temporary and permanent cookies and clarify this within the framework of our privacy policy.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser’s system settings. Stored cookies can be deleted in the browser’s system settings. The exclusion of cookies can lead to functional restrictions of this online offering.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case, it may not be possible to use all functions of this online offering.
Deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no legal retention obligations to the contrary. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
According to legal requirements in Germany, retention occurs in particular for 10 years pursuant to §§ 147(1) AO, 257(1) Nos. 1 and 4, (4) HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years pursuant to § 257(1) Nos. 2 and 3, (4) HGB (commercial letters).
According to legal requirements in Austria, retention occurs in particular for 7 years pursuant to § 132(1) BAO (accounting documents, vouchers/invoices, accounts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate, and for 10 years for documents in connection with electronically provided services, telecommunications, broadcasting, and television services provided to non-entrepreneurs in EU member states for which the Mini One-Stop Shop (MOSS) is used.
Contractual services
We process the data of our contractual partners and interested parties as well as other clients, customers, or contractual partners (collectively referred to as “contractual partners”) in accordance with Art. 6(1)(b) GDPR in order to provide our contractual or pre-contractual services to them. The data processed in this context, the nature, scope, purpose, and necessity of its processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., email addresses and telephone numbers) as well as contractual data (e.g., services used, contract content, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
As a matter of principle, we do not process special categories of personal data unless these are components of a commissioned or contractual processing.
We process data required for the establishment and fulfillment of contractual services and point out the necessity of providing it, unless this is evident to the contractual partners. Disclosure to external persons or companies only takes place if it is required within the framework of a contract. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client as well as the legal requirements.
In the context of using our online services, we may store the IP address and the time of the respective user action. Storage is based on our legitimate interests, as well as the interests of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary to pursue our claims pursuant to Art. 6(1)(f) GDPR or there is a legal obligation to do so pursuant to Art. 6(1)(c) GDPR.
The data is deleted when it is no longer required for the fulfillment of contractual or legal duties of care as well as for dealing with any warranty and comparable obligations, whereby the necessity of retaining the data is reviewed every three years; otherwise, the legal retention obligations apply.
Contacting us
When contacting us (e.g., via contact form, email, telephone, or social media), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6(1)(b) (within the framework of contractual/pre-contractual relationships) and Art. 6(1)(f) (other inquiries) GDPR. The user’s details may be stored in a Customer Relationship Management system (“CRM system”) or comparable inquiry organization.
We delete the inquiries if they are no longer necessary. We review the necessity every two years; furthermore, the legal archiving obligations apply.
Google Universal Analytics
We use Google Analytics in the form of “Universal Analytics.” “Universal Analytics” refers to a process by Google Analytics in which user analysis is carried out on the basis of a pseudonymous user ID, thereby creating a pseudonymous profile of the user with information from the use of different devices (so-called “cross-device tracking”).
Integration of third-party services and content
Within our online offering, we use content or service offerings from third-party providers on the basis of our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Art. 6(1)(f) GDPR) in order to integrate their content and services, such as videos or fonts (hereinafter collectively referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the users, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the display of this content. We endeavor to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, as well as being linked to such information from other sources.
YouTube
We integrate videos from the “YouTube” platform of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google Fonts
We integrate fonts (“Google Fonts”) from the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google Maps
We integrate maps from the “Google Maps” service of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually as part of the settings of their mobile devices). The data may be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Created with Datenschutz-Generator.de by Dr. Thomas Schwenke, Attorney at Law
