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 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 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, provided that such additional information is kept separately and is subject to technical and organisational 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 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, the legal basis for processing to fulfil our services and carry out contractual measures as well as for responding to enquiries is Article 6(1)(b) GDPR, the legal basis for processing to fulfil our legal obligations is Article 6(1)(c) GDPR, and the legal basis for processing to safeguard our legitimate interests is Article 6(1)(f) GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.

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, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access, input, disclosure, ensuring availability, and their separation. Furthermore, 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 during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default (Article 25 GDPR).

Cooperation with Processors and Third Parties

If, in the course of our processing, we disclose data to other persons or 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 a legal permission (e.g., if a transmission of the data to third parties, such as payment service providers, is necessary for the fulfilment of a contract pursuant to Article 6(1)(b) GDPR), you have consented, 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 Article 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 the use of third-party services or the disclosure or transmission of data to third parties, this only takes place if it is for the fulfilment of our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation, or on the basis of 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. This means, for example, that the processing is carried out on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU (e.g., for the USA through the "Privacy Shield") or compliance with officially recognised special contractual obligations (so-called "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 that are stored on users' computers. Various information can be stored within 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. Such a cookie may, for example, store the content of a shopping cart in an online shop or a login status. "Permanent" or "persistent" cookies are those that remain stored even after the browser is closed. For example, the login status can be saved if users visit the site after several days. Likewise, user interests can be stored in such a cookie for reach measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the controller operating the online offering (otherwise, if they are only the controller's cookies, they are referred to as "first-party cookies").

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

The data processed by us will be deleted or restricted in its processing in accordance with Articles 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 the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other legally permissible purposes, its processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

According to legal requirements in Germany, retention is in particular for 10 years pursuant to Sections 147(1) AO, 257(1) Nos. 1 and 4, (4) HGB (books, records, management reports, accounting documents, commercial books, documents relevant for taxation, etc.) and 6 years pursuant to Section 257(1) Nos. 2 and 3, (4) HGB (commercial letters).

According to legal requirements in Austria, retention is in particular for 7 years pursuant to Section 132(1) BAO (accounting documents, receipts/invoices, accounts, vouchers, business papers, statements of income and expenditure, etc.), for 22 years in connection with real property, 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.

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 the data of our customers within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services, and training services.

In this context, we process master data (e.g., customer master data such as names or addresses), contact data (e.g., email, phone numbers), content data (e.g., text input, photographs, videos), contract data (e.g., subject matter of the contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). As a general rule, we do not process special categories of personal data unless they are part of a commissioned processing. The data subjects include our customers, prospects, and their customers, users, website visitors or employees, as well as third parties. The purpose of the processing is to provide contractual services, billing, and our customer service. The legal bases of the processing derive from Article 6(1)(b) GDPR (contractual services), Article 6(1)(f) GDPR (analysis, statistics, optimisation, security measures). We process data that is necessary for the establishment and fulfilment of contractual services and point out the necessity of providing them. Disclosure to external parties only occurs if it is required in the context of an assignment. 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 of commissioned processing pursuant to Article 28 GDPR and do not process the data for any purposes other than those of 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.

In the context of using our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of users in protection against misuse and other unauthorised use. As a general rule, this data is not passed on to third parties unless it is necessary for the pursuit of our claims pursuant to Article 6(1)(f) GDPR or there is a legal obligation pursuant to 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 in the context of administrative tasks, as well as the organisation of our operations, financial accounting, and compliance with statutory obligations, such as archiving. In this process, we process the same data that we process in the course of providing our contractual services. The processing bases are Article 6(1)(c) GDPR, Article 6(1)(f) GDPR. Customers, prospects, business partners, and website visitors are affected by the processing. The purpose and our interest in the processing lies in administration, financial accounting, office organisation, archiving of data, i.e., tasks that serve the maintenance of our business activities, the performance of our tasks, and the provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information provided for these processing activities.

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

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space, and database services, email delivery, security services, and technical maintenance services that we use for the purpose of operating this online offering. In this context, we, or our hosting provider, process master data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects, and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering pursuant to Article 6(1)(f) GDPR in conjunction with Article 28 GDPR (conclusion of a data processing agreement).

Google Analytics

On the basis of our legitimate interests (i.e., interest in the analysis, optimisation, and economic operation of our online offering within the meaning of Article 6(1)(f) GDPR), we use Google Analytics, a web analytics service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offering by users 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 will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering, and to provide us with further services associated with the use of this online offering and internet usage. In doing so, pseudonymous user profiles can be created from the processed data.

We only use Google Analytics with IP anonymisation enabled. This means that the IP address of users is truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated there.

The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software settings accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offering to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: 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.

Privacy Policy – Your Data at Groenewold IT Solutions