This privacy policy informs you about the nature, scope, and purpose of the processing of personal data (hereinafter referred to as "data") within our online offering and the associated websites, features, 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 Article 4 of the General Data Protection Regulation (GDPR).

Controller

Groenewold IT Solutions GmbH
Große Roßbergstraße 3a
26789 Leer
Email address: info@groenewold-it.solutions
Managing Director / Owner: Björn Groenewold
Link to legal notice: Legal Notice

Types of Data Processed

Master data (e.g., names, addresses).
Contact data (e.g., email, phone numbers).
Content data (e.g., text input, 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 features, 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 person is one who can be identified, directly or indirectly, e.g. by reference to a name, an identification number, location data, or an online identifier (e.g. cookie).

Identification may also be by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that 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 encompasses virtually any handling of data.

"Pseudonymisation" 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.

Such additional information must be kept separately and be subject to technical and organisational measures so 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 analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.

"Controller" means 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.

Applicable Legal Bases

In accordance with Article 13 GDPR, we inform you of the legal bases for our data processing. Unless the legal basis is stated in the privacy policy, the following applies:

The legal basis for obtaining consent is Article 6(1)(a) and Article 7 GDPR. Processing to fulfil our services, carry out contractual measures, and respond to enquiries is based on Article 6(1)(b) GDPR. Fulfilling our legal obligations is based on Article 6(1)(c) GDPR; safeguarding our legitimate interests on Article 6(1)(f) GDPR.

Where vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR applies.

Security Measures

In accordance with Article 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 varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.

These measures include safeguarding the confidentiality, integrity, and availability of data by controlling physical access, access, input, disclosure, availability, and separation.

We have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data threats. We also take the protection of personal data into account when developing or selecting hardware, software, and procedures (data protection by design and by default, Article 25 GDPR).

Cooperation with Processors and Third Parties

We disclose, transmit, or grant access to data only on the basis of a legal permission, your consent, a legal obligation, or our legitimate interests.

Examples: transmission to payment service providers for contract performance (Article 6(1)(b) GDPR), or use of agents and web hosts.

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 Article 28 GDPR.

Transfers to Third Countries

We process data in third countries (outside the EU/EEA), or disclose it to third parties, only to fulfil (pre-)contractual obligations, on the basis of your consent, a legal obligation, or our legitimate interests.

Subject to legal or contractual permissions, we only process or have data processed in a third country if the special requirements of Articles 44 et seq. GDPR are met – e.g. via an officially recognised level of data protection or standard contractual clauses.

Rights of Data Subjects

You have the right to obtain confirmation as to whether data concerning you is being processed and to obtain information about this data, as well as further information and a copy of the data, in accordance with Article 15 GDPR.

In accordance with Article 16 GDPR, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.

In accordance with Article 17 GDPR, you have the right to request that data concerning you be deleted without undue delay, or, alternatively, to request a restriction of the processing of the data in accordance with Article 18 GDPR.

You have the right to request that the data concerning you, which you have provided to us, be received in accordance with Article 20 GDPR and to request its transmission to other controllers.

Furthermore, in accordance with Article 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority.

Right of Withdrawal

You have the right to withdraw consent granted pursuant to Article 7(3) GDPR with effect for the future.

Right to Object

You may object to the future processing of data concerning you at any time in accordance with Article 21 GDPR. The objection may be made in particular against processing for the purposes of direct marketing.

Cookies and Right to Object to Direct Marketing

"Cookies" are small files stored on users' computers. A cookie stores information about a user (or device) during or after a visit to an online offering.

Session cookies (transient): Deleted after the user leaves the offering and closes the browser. They may store e.g. shopping cart content or login status.

Permanent cookies (persistent): Remain stored after the browser is closed – e.g. for login status on return visits or for reach measurement and marketing.

First-party and third-party cookies: First-party cookies are set by the operator of the online offering; third-party cookies are set by other providers.

We may use temporary and permanent cookies and will clarify this in the context 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 may lead to functional limitations 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 EU site http://www.youronlinechoices.com/ Furthermore, the storage of cookies can be achieved by disabling them in the browser settings. Please note that in this case not all functions of this online offering may be available.

Deletion of Data

Data is deleted or restricted in accordance with Articles 17 and 18 GDPR. Unless stated otherwise here, we delete stored data as soon as it is no longer required and no statutory retention obligations apply.

If data is required for other legally permissible purposes, processing is restricted (data is blocked) – e.g. for commercial or tax retention.

Germany: Retention in particular for 10 years (Sections 147(1) AO, 257(1) Nos. 1 and 4, (4) HGB) and 6 years (Section 257(1) Nos. 2 and 3, (4) HGB – commercial letters).

Austria: In particular 7 years (Section 132(1) BAO), 22 years for real property, 10 years for MOSS-relevant documents.

Business-Related Processing

In addition, we process – contract data (e.g., subject matter of the contract, term, customer category) – payment data (e.g., bank details, payment history) of our customers, prospects, and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.

Agency Services

We process customer data in the scope of our contractual services – including conceptual and strategic consulting, campaign planning, software and design development or maintenance, implementation of campaigns and processes, server administration, data analysis, and training.

We process master, contact, content, contract, and payment data, as well as usage and metadata (e.g. for measuring marketing success). We do not as a rule process special categories of personal data unless part of a commissioned processing. Data subjects include our customers, prospects, their customers, users, website visitors, employees, and third parties.

Purpose: provision of contractual services, billing, and customer service. Legal bases: Article 6(1)(b) GDPR (contract), Article 6(1)(f) GDPR (analysis, statistics, security). We process only necessary data and disclose to external parties only when required for an assignment.

For data provided to us under an assignment, we follow the client's instructions and the requirements of Article 28 GDPR and do not process data for purposes other than the assignment.

We delete the data after the expiration of statutory warranty and comparable obligations. The necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after their expiration (6 years pursuant to Section 257(1) HGB, 10 years pursuant to Section 147(1) AO). In the case of data disclosed to us by the client in the context of an assignment, we delete the data in accordance with the terms of the assignment, generally after the end of the assignment.

Contractual Services

We process the data of our contractual partners, prospects, and other clients, customers, or contractual partners (uniformly referred to as "contractual partners") in accordance with Article 6(1)(b) GDPR in order to provide our contractual or pre-contractual services to them. The data processed, 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 phone numbers), as well as contract data (e.g., services used, contract content, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).

As a general rule, we do not process special categories of personal data unless they are part of a commissioned or contractual processing.

We process data that is necessary for the establishment and fulfilment of contractual services and point out the necessity of providing them, insofar as this is not evident to the contractual partners. Disclosure to external persons or companies only takes place if it is required in the context of a contract. When processing the data provided to us in the context of an assignment, we act in accordance with the instructions of the clients and the legal requirements.

When you use our online services we may store your IP address and the time of the action – based on our legitimate interests and your interest in protection against misuse. We do not pass this data on to third parties unless necessary to pursue our claims (Article 6(1)(f) GDPR) or required by law (Article 6(1)(c) GDPR).

The deletion of data takes place when the data is no longer required for the fulfilment of contractual or statutory duty of care obligations, 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 statutory retention obligations apply.

Administration, Financial Accounting, Office Organisation, Contact Management

We process data for administration, organisation of operations, financial accounting, and statutory obligations (e.g. archiving). We process the same categories of data as for our contractual services. Legal bases: Article 6(1)(c) and (f) GDPR.

Data subjects include customers, prospects, business partners, and website visitors. Purpose: administration, accounting, office organisation, and archiving – to maintain our business and provide our services. Deletion follows the same rules as for contractual services and communication.

In this context, we disclose or transmit data to the tax authorities, advisors such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information about suppliers, event organisers, and other business partners, e.g., for the purpose of subsequent contact. This predominantly company-related data is generally stored permanently.

Contact

When contacting us (e.g., via contact form, email, telephone, or via social media), the user's information is processed for the purpose of handling the contact request and its processing pursuant to Article 6(1)(b) GDPR. User information may be stored in a Customer Relationship Management System ("CRM System") or comparable request organisation. We delete the requests once they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.

Hosting and Email Delivery

Our hosting services provide infrastructure, platform, computing capacity, storage, databases, email delivery, security, and technical maintenance for this online offering.

We or our hosting provider process master, contact, content, contract, usage, and meta data of customers, prospects, and visitors. Legal basis: legitimate interest in efficient and secure provision (Article 6(1)(f) GDPR) in conjunction with Article 28 GDPR (data processing agreement).

Google Analytics

We use Google Analytics, a web analytics service of Google LLC, on the basis of our legitimate interests in analysis, optimisation, and economic operation (Article 6(1)(f) GDPR). Google uses cookies. Information generated by the cookie about use of our offering is generally transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google evaluates use of our offering, compiles reports, and provides related services. Pseudonymous user profiles may be created from the processed data.

We use Google Analytics only with IP anonymisation: the IP is truncated by Google within the EU/EEA; only in exceptional cases is the full IP sent to a US server and truncated there.

The IP address transmitted by the browser is not merged with other Google data. You can disable cookies in your browser settings or prevent collection and processing by Google by installing the browser plugin available at: http://tools.google.com/dlpage/gaoptout?hl=en.

For further information about Google's use of data, settings, and opt-out options, please refer to Google's privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

The personal data of users is deleted or anonymised after 14 months.