We are pleased that you have shown interest in our content. Data protection is a particularly high priority for Nela Kacmarcik. The use of Nela Kacmarcik websites is possible without indicating personal data; however, if the user wishes to use specific services through our website, the processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for the processing, we request the consent of the data subject.
Guidelines
The processing of personal data, such as the name, email address, and telephone number of the data subject, is always in accordance with the General Data Protection Regulation of the European Union (GDPR) and in accordance with the law of the country applicable to NKM online. With this data protection statement, our business aims to inform the public about the nature, scope, and purpose for which it collects, uses, and processes personal data. Furthermore, this notice informs data subjects about their rights that they can exercise.
As the data controller, NKM online has implemented numerous technical and organizational measures to ensure the most comprehensive protection of personal data processed through this website. However, data transfers over the internet can generally have security vulnerabilities, and absolute protection cannot be guaranteed. For this reason, each data subject can transmit personal data to us through alternative means of communication, such as, for example, by phone.
1. Definitions
The data protection statement by NKM online is based on terms used by the European legislator in the General Data Protection Regulation (GDPR). The statement is designed to be understandable for the general public, as well as for clients and business partners. The terms used in the statement are explained as follows:
- Personal data:
Personal data refers to any information related to an identified or identifiable natural person (“data subject”). An identified natural person is one who can be directly or indirectly identified, especially by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. - Data subject:
A data subject is a specific or identifiable natural person whose personal data is processed by the data controller responsible for data processing. - Data processing:
Data processing includes any operation or set of operations 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 of data. - Restriction of data processing:
Restriction of data processing is the marking of stored personal data with the aim of limiting their processing in the future. - Profiling:
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, especially for analyzing or predicting aspects concerning work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movement of that natural person. - Pseudonymization:
Pseudonymization is the processing of personal data in such a way 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 subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person. - Data controller or controller responsible for data processing:
A data controller or controller responsible for data processing is a natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of processing personal data; where the purposes and means of such processing are determined by European Union law or the law of a member state, the data controller or the specific criteria for its appointment may be provided for by European Union law or the law of a member state. - Processor:
A processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the data controller. - Recipient:
A recipient is a natural or legal person, public authority, agency, or other body to which personal data is disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry in accordance with European Union law or the law of a member state are not considered recipients; the processing of such data by these public authorities must be in compliance with the applicable data protection rules and in accordance with the purpose of the processing. - Third party:
A third party is a natural or legal person, public authority, agency, or other body or person who is not the data subject, data controller, processor, and persons authorized to process personal data directly by the data controller or processor. - Consent:
Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data for a specific purpose.
2. Name and address of the data controller
The data controller, in accordance with the General Data Protection Regulation (GDPR), other data protection regulations applicable in the member countries of the European Union, and other provisions related to data protection, is:
NKM online
Palinovečka 19L
10000 Zagreb
Croatia
Phone: 0912257057
Email: info@nkmonline.hr
Website: nkmonline.hr
3. Cookies
The Nela Kacmarcik website uses cookies. Cookies are text files stored in the computer system through the internet browser.
Many websites and servers use cookies. Many cookies contain a unique identifier known as a cookie ID. The cookie ID is a string of characters through which websites and servers can assign a specific internet browser in which the cookie is stored. This allows visited websites and servers to distinguish individual internet browsers of users from other internet browsers that contain different cookies. A specific internet browser can be recognized and identified using a unique cookie ID.
By using cookies, Nela Kacmarcik has the ability to provide users of this website with services that are more user-friendly, which would not be possible without the use of cookies.
Through cookies, information and offerings on our website can be optimized, taking into account the needs of users. Cookies allow us, as mentioned earlier, to recognize users of our website. The purpose of this recognition is to make it easier for users to use our website. A user of our website who uses cookies, for example, does not have to enter access data each time they access the website because it is retrieved by the website, and the cookie is stored on the user’s computer system. Another example is the cookie for virtual shopping carts in an online store. The online store remembers the products that a customer placed in the virtual shopping cart through a cookie.
The data subject can prevent the setting of cookies at any time through our website by adjusting the settings of the internet browser used and may thus permanently deny the setting of cookies. Furthermore, already set cookies can be deleted at any time via the internet browser or other software programs. This is possible in all popular internet browsers. If the data subject deactivates the setting of cookies in the used internet browser, it may not be possible to use all the functions of our website to their full extent.
4. Collection of general data and information
The Nela Kacmarcik website collects a range of general data and information when data subjects or an automated system access the website. These general data and information are stored in server log files. The data and information collected may include (1) the type of internet browser and its versions used, (2) the operating system used by the accessing system, (3) the website from which the accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the website, (6) the Internet Protocol (IP) address, (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using this general data and information, NKM online does not draw any conclusions about the data subject. Instead, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website and its advertisements, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack. Therefore, NKM online analyzes and statistically evaluates the anonymous data collected to increase the protection and security of our company’s data and ensure the optimal level of protection for the personal data we process. Anonymous server log file data is stored separately from any personal data provided by the data subject.
5. Subscription to our email notifications (newsletters)
The Nela Kacmarcik website provides users with the opportunity to subscribe to the company’s email notifications (newsletter). The form used for newsletter sign-up determines which personal data is transmitted and when the newsletter is ordered from the data controller.
NKM online regularly informs its clients and business partners about the company’s offers via newsletters. Our newsletter can only be received by the data subject if (1) the data subject has a valid email address, and (2) the data subject has subscribed to receive email notifications. For legal reasons, a confirmation email will be sent to the address first registered by the data subject for newsletter delivery, as part of the double opt-in process. This email confirmation is used to verify whether the owner of the email address as the data subject is authorized to receive the newsletter.
Upon newsletter sign-up, we also store the IP address of the computer system assigned by the Internet Service Provider (ISP) and used by the data subject at the time of registration, as well as the date and time of registration. Collecting this data is necessary to understand possible misuse of a data subject’s email address later on, serving as a means of legal protection for the data controller.
Personal data collected as part of the newsletter sign-up will only be used to send our email notifications (newsletter). In addition, newsletter subscribers may be informed via email if necessary for the provision of the email notification service or registration, as this may be the case when changing the newsletter offer or in the event of changes in technical circumstances. Personal data collected through the email service will not be transmitted to third parties. The data subject can unsubscribe from our notifications at any time. Consent to store personal data given for newsletter delivery can be revoked at any time. To revoke consent, there is an appropriate link in each newsletter. Subscription to the newsletter can also be canceled at any time directly on the data controller’s website or by notifying the data controller through other means.
6. Email notifications – Tracking
Email notifications from Nela Kacmarcik contain so-called tracking pixels. A tracking pixel is a miniature graphic element embedded in HTML-format email messages to enable the recording and analysis of log files. This allows for the statistical analysis of the success or failure of online promotional campaigns. Based on the embedded tracking pixel, NKM online can see if and when the data subject opened the email and which links in the email message were accessed by the data subject.
Personal data collected in tracking pixels contained in the newsletter are stored and analyzed by the data controller to optimize newsletter delivery and to tailor the content of future newsletters even more to the interests of data subjects. This personal data will not be forwarded to third parties. Data subjects have the right to revoke the separate consent given in the double opt-in process at any time. Upon revocation, the data controller will delete this personal data. NKM online will automatically consider opting out of receiving the newsletter as a revocation.
7. Contact option through the website
The Nela Kacmarcik website contains information that allows for quick electronic contact with our company, as well as direct communication with us, including the general email address. If a data subject contacts the data controller via email or through the contact form, the personal data entered by the data subject is automatically stored. Such personal data voluntarily transmitted by data subjects to the data controller is stored for processing or contacting the data subject. These personal data will not be transferred to third parties.
8. Routine erasure and blocking personal data
The data controller processes and stores the personal data of data subjects only for the period necessary to achieve the purpose of storage or as stipulated by the European legislator or other applicable laws or regulations.
If the purpose of storage cannot be achieved or if the storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or deleted in accordance with legal requirements.
9. Rights of respondents
- Right to Confirmation
Every data subject has the right, as guaranteed by European legislation, to request from the data controller confirmation of whether their personal data is being processed or not. If the data subject wishes to exercise the right to request confirmation, they can contact any employee of the data controller at any time. - Right of Access
Every data subject has the right, as guaranteed by European legislation, to obtain information free of charge from the data controller about their personal data stored at any time, as well as a copy of that data. Furthermore, European directives and regulations grant data subjects 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 request rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- 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, referred to in Article 22(1) and (4) of the General Data Protection Regulation (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. Additionally, the data subject has the right to obtain information as to whether personal data are transferred to a third country or to an international organization. If this is the case, the data subject has the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to exercise the right of access, they can contact any employee of the data controller at any time.
- Right to Rectification
Every data subject has the right, as guaranteed by European legislation, to obtain from the data controller the rectification of inaccurate personal data concerning them without undue delay. 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, they can contact any employee of the data controller at any time. - Right to Erasure (“Right to be Forgotten”)
Every data subject has the right, as guaranteed by European legislation, to demand from the data controller the erasure of personal data concerning them without undue delay, and the data controller is obligated to erase personal data without undue delay if one of the following grounds applies, provided that the processing is not necessary:- The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2) 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 data controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR. If one of the above reasons applies, and a data subject wishes to request the erasure of personal data stored by Nela Kacmarcik, they can contact any employee of the data controller at any time. The employee of NKM online will promptly ensure that the erasure request is complied with. If the data controller has made the personal data public and is obliged to erase the personal data pursuant to Article 17(1) GDPR, the data controller, taking account of available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform other data controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. Employees of NKM online will arrange the necessary measures in individual cases.
- Right to Restriction of Processing
Every data subject has the right, as guaranteed by European legislation, to obtain from the data 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 data 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 the restriction of their use instead.
- The data 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 pending the verification whether the legitimate grounds of the data 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 the processing of personal data stored by Nela Kacmarcik, they can contact any employee of the data controller at any time. The employee of NKM online will arrange the restriction of the processing.
- Right to Data Portability
Every data subject has the right, as guaranteed by European legislation, to receive the personal data concerning them, which was provided to a data controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another data controller without hindrance from the data controller to which the personal data has been provided, where:- The processing is based on consent pursuant to point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR, or on a contract pursuant to point (b) of Article 6(1) GDPR, and
- The processing is carried out by automated means. In exercising their right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have personal data transmitted directly from one data controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. To exercise the right to data portability, the data subject may contact any employee of NKM online at any time.
- Right to Object
Every data subject has the right, as guaranteed by European legislation, for reasons arising from their particular situation, to object at any time to the processing of personal data concerning them, which is based on points (e) or (f) of Article 6(1) GDPR. This also applies to profiling based on these provisions. NKM online will no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims. If NKM online 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 them for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to NKM online processing for direct marketing purposes, NKM online will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them by NKM online 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 any employee of NKM online. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use their right to object by automated means using technical specifications. - Automated Individual Decision-Making, Including Profiling
Every data subject has the right, as guaranteed by European legislation, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them unless the decision:- Is necessary for entering into, or the performance of, a contract between the data subject and a data controller.
- Is authorized by Union or Member State law to which the data controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or
- Is based on the data subject’s explicit consent. If the decision is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or it is based on the data subject’s explicit consent, NKM online will 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 their point of view, and to contest the decision. If the data subject wishes to exercise rights concerning automated individual decision-making, they can contact any employee of NKM online at any time.
- Right to Withdraw Consent for Data Protection
Every data subject has the right, as guaranteed by European legislation, to withdraw their consent to the processing of their personal data at any time. If the data subject wishes to exercise the right to withdraw consent, they can contact any employee of NKM online at any time.
10. Data protection provisions regarding the use of Facebook
On this website, the data controller has integrated components of the company Facebook. Facebook is a social network.
A social network is an online meeting place, a virtual community that typically allows users to communicate and interact with each other in the digital space. A social network can serve as a platform for the exchange of opinions and experiences, or enable the online community to provide personal or business-related information. Facebook enables social network users to create private profiles, upload photos, and connect through friend requests.
The company operating Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside the United States or Canada, the data controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Each time an individual accesses one of the individual pages of this website managed by the data controller and on which a Facebook component (Facebook plug-in) is integrated, the internet browser on the data subject’s information system is automatically prompted to download a display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all Facebook plug-ins can be accessed at https://developers.facebook.com/docs/plugins/. During this technical process, Facebook is informed about which specific sub-page of our website the data subject has visited.
If a person is simultaneously logged into Facebook, Facebook detects each time our website is accessed by the data subject and for the entire duration of their stay on our website – which specific sub-pages of our website were visited by the data subject. This data is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated on our website, e.g., the “Like” button or if the data subject comments, Facebook associates this information with the data subject’s personal Facebook user account and stores personal data.
Facebook always receives, via the Facebook component, information about the visit to our website by the data subject, whenever the person is logged into Facebook at the same time as the visit to our website. This happens regardless of whether the data subject clicks on the Facebook component or not. If such transmission of information to Facebook is not desirable for the data subject, he or she can prevent this by logging off from their Facebook account before calling up our website.
The data protection guideline published by Facebook, available at https://facebook.com/about/privacy/, provides information about the collection, processing, and use of personal data by Facebook. Additionally, it is explained what settings Facebook offers to protect the privacy of the data subject. Furthermore, various options are available to prevent data transfer to Facebook. These applications may be used by the data subject to prevent data transfer to Facebook.
11. Data protection provisions regarding the use of Google Analytics
On this website, the data controller has integrated the Google Analytics component (with anonymization function). Google Analytics is a web analytics service. Web analytics collects and analyzes data about the behavior of website visitors. Web analysis is mainly used for optimizing the website and conducting cost-benefit analysis of internet advertising.
The company providing the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
For web analytics through Google Analytics, the data controller uses the application “_gat. _AnonymizeIp”. This application shortens and anonymizes the IP address of the data subject’s internet connection when accessing our websites from a member state of the European Union or another contracting state to the Agreement on the European Economic Area (EEA).
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, among other things, to evaluate the use of our website and to provide online reports that show the activities on our websites and provide other services related to the use of our website.
Google Analytics sets a cookie on the information system of the data subject. The definition of cookies is explained above. By setting the cookie, Google can analyze the use of our website. Each time one of the individual pages of this website, which is managed by the data controller and on which a Google Analytics component is integrated, is called up, the internet browser on the information system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online advertising and commission settlement with Google. During this technical process, Google gains knowledge of personal data, such as the IP address of the data subject, which serves Google, among other things, to understand the origin of visitors and clicks and subsequently enable commission settlement.
The cookie is used to store personal information, such as the access time, the location from which access was made, and the frequency of visits to our website by the data subject. Each time our websites are visited, such personal data, including the IP address of the internet access used by the data subject, will be transmitted to Google in the United States of America, and Google stores them in the United States of America. Google may transfer this personal data collected through the technical procedure to third parties.
As stated above, the data subject can prevent the setting of cookies at any time through our website by means of an appropriate adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the used internet browser would also prevent Google Analytics from setting a cookie on the information system of the data subject. In addition, cookies that have already been set by Google Analytics can be deleted at any time via the internet browser or other software programs.
Furthermore, the data subject has the opportunity to object to the collection of data generated by Google Analytics that is related to the use of this website and the processing of this data by Google, as well as the possibility to prevent such data collection or processing. To do this, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics through JavaScript that all data and information about visits to websites should not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information system of the data subject is later deleted, formatted, or reinstalled, the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to perform the reinstallation or reactivation of the browser add-ons.
Additional information and applicable data protection provisions of Google can be retrieved under https://www.google.com/intl/en/policies/privacy/ and http://www.google.com/analytics/terms/us.html. Google Analytics is explained in more detail under the following link https://www.google.com/analytics/.
12. Data protection provisions regarding the use of Instagram
On this website, the data controller has integrated components of the Instagram service. Instagram is a service that can be described as an audiovisual platform, enabling users to share photos and videos and distribute such data on other social networks.
The company providing the Instagram service is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Each time one of the individual pages of this website, managed by the data controller and containing the Instagram component (Instagram button), is accessed, the internet browser on the data subject’s information system is automatically prompted to download a display of the corresponding Instagram component from Instagram. During this technical process, Instagram is informed about which specific subpage of our website is visited by the data subject.
If the user is simultaneously logged into Instagram, Instagram detects each call to our website by the data subject – and for the entire duration of their stay on our website – which specific subpage of our website the data subject has visited. This data is collected through the Instagram component and is associated with the corresponding Instagram account of the data subject. If the user clicks on one of the Instagram buttons integrated on our website, Instagram matches this information with the personal Instagram user account of the data subject and stores personal data.
Instagram receives information via the Instagram component that the data subject has visited our website provided that the data subject is logged into Instagram at the time of calling up our website. This occurs regardless of whether the user clicks on the Instagram button or not. If such a transmission of information to Instagram is not desirable for the data subject, they can prevent it by logging out of their Instagram account before calling up our website.
Additional information and applicable data protection provisions of Instagram can be found at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.
13. Data protection provisions regarding the use of LinkedIn
On this website, the data controller has integrated LinkedIn components. LinkedIn is an online social network that enables users to connect with existing business contacts and establish new business relationships. With over 400 million registered users in more than 200 countries, LinkedIn is currently the largest platform for professional networking and one of the most visited websites globally.
The company providing the LinkedIn service is LinkedIn Corporation, headquartered at 2029 Stierlin Court, Mountain View, CA 94043, United States. For privacy policy matters outside the United States, LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.
Whenever a user visits one of the individual pages of this website managed by the data controller and on which the LinkedIn component (LinkedIn plug-in) is integrated, the web browser on the user’s information system is automatically prompted to download a display of the corresponding LinkedIn component from LinkedIn. Additional information about the LinkedIn plug-in can be found at https://developer.linkedin.com/plugins. During this technical process, LinkedIn receives information about which specific subpages of our website are visited by users.
If a person is simultaneously logged into LinkedIn, LinkedIn detects each call to our website by the user for the duration of their stay on our website – which specific subpage of our website the user has visited. This information is collected through the LinkedIn component and linked to the user’s corresponding LinkedIn account. If a user clicks on one of the LinkedIn buttons integrated on our website, LinkedIn assigns this information to the user’s personal LinkedIn user account and stores personal data.
LinkedIn receives information via the LinkedIn component that the user has visited our website, provided that the user is logged into LinkedIn at the time of the call to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If the user wishes to prevent the transfer of this data to LinkedIn, it is recommended to log out of the LinkedIn account before visiting our website.
LinkedIn provides the option to unsubscribe from receiving email, SMS messages, and targeted ads at https://www.linkedin.com/psettings/guest-controls. Users can also manage advertising settings. LinkedIn also uses cookies and collaborates with other entities such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. It is possible to reject the placement of such cookies at https://www.linkedin.com/legal/cookie-policy. The privacy policy for LinkedIn is available at https://www.linkedin.com/legal/privacy-policy, while the cookie policy can be found at https://www.linkedin.com/legal/cookie-policy.
14. Data protection provisions regarding the use of Youtube
On this website, the data controller has integrated YouTube components. YouTube is an online video portal that allows video publishers to upload video clips for free and other users to view, rate, and comment on them. YouTube enables the publication of all kinds of videos, providing access to full-length films, TV shows, music videos, trailers, and user-generated content through its online portal.
The company providing the YouTube service is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
Whenever a user visits one of the individual pages of this website managed by the data controller and on which the YouTube component (YouTube video) is integrated, the web browser in the user’s information technology system is automatically prompted to download a display of the YouTube component via the respective YouTube component. Further information about YouTube can be obtained at https://www.youtube.com/yt/about/en/. During this technical process, YouTube and Google acquire knowledge of which specific subpages of our website were visited by the individual.
If the user is logged into YouTube, YouTube recognizes, with each call to a subpage containing a video, which specific subpage of our website the user visited. These data are collected by YouTube and Google and assigned to the respective YouTube account of the user.
YouTube and Google will receive information through the YouTube component that the user has visited our website if the user is logged in to YouTube at the time of calling up our website; this occurs regardless of whether the person clicks on a YouTube video or not. If such data transmission to YouTube and Google is not desirable for the user, the transmission can be prevented if the user logs out of their own YouTube account before calling up our website.
The data protection provisions of YouTube, available at https://www.google.com/intl/en/policies/privacy/, provide information on the collection, processing, and use of personal data by YouTube and Google.
15. Data protection provisions for the use of PayPal as a payment processor
On this website, the data controller has integrated PayPal components. PayPal is a provider of online payment services. Payments are processed through so-called PayPal accounts, which represent virtual private or business accounts. PayPal is also capable of processing virtual payments through credit cards when the user does not have a PayPal account. PayPal accounts are managed via email addresses, making them unique from traditional account numbers. PayPal allows for initiating online payments to third parties or receiving payments. PayPal also accepts trustee functions and offers buyer protection services.
The company providing the PayPal service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg.
If a user chooses “PayPal” as the payment option in the online shop during the ordering process, the data controller automatically transmits the data of the user to PayPal. By selecting this payment option, the user agrees to the transfer of personal data required for payment processing.
The personal data transmitted to PayPal is typically first name, last name, address, email address, IP address, phone number, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also requires such personal data, which is related to the respective order.
The transmission of data is aimed at payment processing and fraud prevention. The data controller will transfer personal data to PayPal, particularly if there is a legitimate interest for the transmission. The personal data exchanged between PayPal and the data controller is transmitted to credit reporting agencies for identity and credit checks. This transfer is intended for identity and creditworthiness verification.
PayPal may, if necessary, transmit personal data to affiliated companies and service providers or subcontractors to the extent necessary for fulfilling contractual obligations or processing data on behalf of the order.
The data subject has the possibility to revoke consent for handling personal data at any time from PayPal. A revocation does not have any effect on personal data which must be processed, used, or transmitted in accordance with (contractual) payment processing.
The applicable data protection provisions of PayPal can be found at https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
16. Legal basis for processing
Article 6(1) of the 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 party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
17. Legitimate interests pursued by the controller or a third party
If the processing of personal data is based on Article 6(1) lit. f GDPR, our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
18. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
19. Provision of personal data as statutory or contractual requirement; requirement necessary to enter into a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with them. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.
20. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
Developed by the specialists for LegalTech at Willing & Able that also developed the system for gdpr training for employees. The legal texts contained in our privacy policy generator have been provided and published by Prof. Dr. h.c. Heiko Jonny Maniero from the German Association for Data Protection and Christian Solmecke from WBS law.