I. Name and Address of the Responsible Party

The responsible party in the sense of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection provisions is:

  • Speechninjas Technologies Ltd
  • 128 City Road, 
  • London, EC1V 2NX
  • United Kingdom 
  • Email: info@speechnin

Website: https://speechninjas.com/

II. General Information on Data Processing

  • Scope and Purpose of Processing Personal Data

We generally process personal data of our users only to the extent necessary to provide a functioning website as well as our content and services. The processing of personal data of our users regularly occurs only with the user’s consent (e.g., through the use of a cookie banner). An exception applies in cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by legal regulations.

  • Legal Basis for Processing Personal Data

Insofar as we obtain the consent of the data subject for processing operations of personal data, Art. 6 Para. 1 lit. a GDPR serves as the legal basis.

For the processing of personal data necessary for the performance of a contract to which the data subject is a party, Art. 6 Para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations necessary to carry out pre-contractual measures.

Insofar as processing of personal data is required to fulfill a legal obligation to which our company is subject, Art. 6 Para. 1 lit. c GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 Para. 1 lit. d GDPR serves as the legal basis.

If processing is necessary to safeguard a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the first-mentioned interest, Art. 6 Para. 1 lit. f GDPR serves as the legal basis for processing.

  • Deletion of Data and Duration of Storage

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Storage may also take place if this has been provided for by the European or national legislator in EU regulations, laws, or other provisions to which the controller is subject. Blocking or deletion of the data also occurs when a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfillment of a contract.

  • Data Transfer to Third Parties, Processors, and Joint Controllers

We transfer personal data only if the transfer is lawful under applicable data protection laws. For example, this may be the case if we are legally obliged to transmit data to (investigative) authorities. However, transmission may also be considered if we transmit personal data to processors or share it with joint controllers.

If possible or even legally required, each data transfer will be recorded in writing and regulated by clearly defined rights and obligations. This means that we, for example, conclude contracts with our processors that are intended to contribute to the protection of your personal data.

If a data transfer takes place, you will be informed accordingly.

III. Provision of the Website and Creation of Log Files

  • Description and Scope of Data Processing

Each time our website is accessed, our system (and possibly the system of our hosting provider) automatically collects data and information from the computer system of the calling computer.

Typically, the following data is collected:

  • Information about the browser type and version used
  • The user’s operating system
  • The user’s internet service provider
  • The user’s IP address
  • Date and time of access
  • Websites from which the user’s system reaches our website
  • Websites accessed by the user’s system via our website

The data is also stored in the log files of our system. Storage of this data together with other personal data of the user does not take place.

  • Legal Basis for Data Processing

The legal basis for the temporary storage of data and log files is Art. 6 Para. 1 lit. f GDPR.

  • Purpose of Data Processing

The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session.

The storage in log files is done to ensure the functionality of the website. In addition, the data helps us to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes also constitute our legitimate interest in data processing according to Art. 6 Para. 1 lit. f GDPR.

  • Duration of Storage

The data is deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. In the case of collecting data for the provision of the website, this is the case when the respective session is ended.

In the case of storing data in log files, this is after a maximum of seven days. Various security reasons (e.g., to investigate crimes) justify extended storage. In the case of other storage of the data, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.

  • Objection and Removal Possibility

The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

IV. Use of Cookies

a) Description and Scope of Data Processing

Our website uses cookies. Cookies are text files that are stored in the internet browser or by the internet browser on the user’s computer system. If a user visits a website, a cookie may be stored on the user’s operating system. A cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is revisited.

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser be identifiable even after a page change (e.g., log-in information, website settings, etc.).

We also use cookies on our website that enable an analysis of the user’s surfing behavior.

In this way, data can be transmitted that says something about the frequency of page views or the use of website functions.

The data collected in this way from the users is pseudonymized by technical precautions. Therefore, it is no longer possible to assign the data to the calling user. The data is not stored together with other personal data of the users.

When accessing our website, users are informed by an information banner (cookie banner) about the use of cookies for analysis purposes and referred to this privacy policy. The use of cookies for analysis purposes (or reach measurement) requires your consent. Consent is only given with a click on the corresponding button of the info banner. Processing for analysis purposes does not take place without your consent. In this context, there may also be a reference to how the storage of cookies can be prevented in the browser settings.

b) Legal Basis for Data Processing

The legal basis for the processing of personal data using technically necessary cookies is Art. 6 Para. 1 lit. f GDPR.

The legal basis for the processing of personal data using cookies for analysis purposes and reach measurement, in the case of the user’s consent, is Art. 6 Para. 1 lit. a GDPR.

c) Purpose of Data Processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.

The user data collected by technically necessary cookies are not used to create user profiles.

The use of analysis cookies is for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus continually optimize our offer.

These purposes also constitute our legitimate interest in the processing of personal data according to Art. 6 Para. 1 lit. f GDPR and for analysis purposes according to Art. 6 Para. 1 lit. a GDPR.

e) Duration of Storage, Objection and Removal Possibility

Cookies are stored on the user’s computer and transmitted from it to our site. Therefore, as a user, you have full control over the use of cookies. By changing the settings in your internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website to their full extent.

V. Contacting Us

Whenever you contact us (e.g., via contact form, email, telephone, or via social media), the user’s information is processed for handling and processing the specific contact request according to Art. 6 Para. 1 lit. b. (in the context of contractual/pre-contractual relationships), Art. 6 Para. 1 lit. f. (other requests) GDPR. In addition, we point out that the information can be stored in a computer/software system (e.g., in a “CRM system”). The reason for storing in a computer/software system is the objective of optimizing and accelerating our processes (Art. 6 Para. 1 lit. f GDPR).

We delete the data as soon as it is no longer necessary. The necessity is reviewed every two years (the necessity of storage can also be given by legal regulations).

VI. Contact Form and Email Contact

  • Description and Scope of Data Processing

Our website includes a contact form that can be used for electronic contact. If a user takes advantage of this opportunity, the data entered in the input mask will be transmitted to us and stored. This data includes:

  • Name
  • Company
  • Email
  • Subject
  • Message/Text

At the time of sending the message, the following data is also stored:

  • The user’s IP address
  • Date and time of registration

For the processing of the data, your consent is obtained during the sending process and reference is made to this privacy policy.

Alternatively, contact can be made via the provided email address. In this case, the personal data of the user transmitted with the email will be stored.

There is no disclosure of the data to third parties in this context. The data is exclusively used for processing the conversation.

  • Legal Basis for Data Processing

The legal basis for processing data, where the user’s consent has been obtained, is Art. 6 (1) lit. a GDPR.

The legal basis for processing data transmitted in the course of sending an email is Art. 6 (1) lit. f GDPR. If the email contact aims at the conclusion of a contract, then additional legal basis for the processing is Art. 6 (1) lit. b GDPR.

  • Purpose of Data Processing

The processing of personal data from the input mask serves us only for processing the contact. In the case of contact via email, this also includes the necessary legitimate interest in the processing of the data.

The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

  • Duration of Storage

The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those that were sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively resolved.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

  • Opposition and Removal Possibility

The user has the possibility to revoke their consent to the processing of personal data at any time. If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.

The revocation of consent must be made in writing to us (our contact details can be found above – Name and Address of the Controller.

All personal data stored in the course of contacting us will be deleted in this case.

VII. Web Analysis by Google Analytics / Google Tag Manager

For the purpose of the needs-based design and continuous optimization of our pages, we use Google Analytics, a web analytics service provided by Google Inc. (https://about.google/intl/en-GB/google-in-uk/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter “Google”). Google offers guarantees to comply with European data protection regulations (https://support.google.com/analytics/answer/9019185?hl=de&ref_topic=2919631).

In this context, pseudonymized usage profiles are created and cookies (see below) are used on our behalf. The information generated by a cookie about your use of this website such as

  • Browser type/version
  • Operating system used
  • Referrer URL
  • Hostname of the accessing computer
  • Time of the server request

are transferred to a Google server in the USA and stored there. The information is used to evaluate the use of the website, to compile reports on website activities, and to provide other services related to website use and internet use for the purposes of market research and needs-based design of these internet pages. This information may also be transferred to third parties if required by law or if third parties process this data on behalf of Google. In no case will your IP address be merged with other Google data. The IP addresses are anonymized, so that an assignment is not possible (IP masking).

In principle, the use of Google Analytics requires your consent according to Art. 6 (1) lit. a GDPR. You will be informed about this when you call up our page (cookie banner).

You can also prevent the installation of cookies by setting your browser software accordingly; however, we would like to point out that in this case, you may not be able to fully use all functions of this website.

You can also prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and from processing this data by downloading and installing a browser add-on (https:// tools.google.com/dlpage/gaoptout?hl=de).

Alternatively to the browser add-on, especially for browsers on mobile devices, you can also prevent the collection by Google Analytics by clicking on this link. An opt-out cookie will be set which prevents the future collection of your data when visiting this website. The opt-out cookie is valid only in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you must set the opt-out cookie again.

Further information on data protection in connection with Google Analytics can be found, for example, in the Google Analytics Help (https://support.google.com/analytics?source=404#topic=3544906), in the setting for the display of advertising impressions by Google https://adssettings.google.com/authenticated, and in Google’s privacy policy https://policies.google.com/technologies/ads.

The personal data will be deleted or anonymized after 14 months in any case.

Furthermore, we use Google Tag Manager:

Google Tag Manager is a solution that allows us to manage so-called website tags via an interface and thus integrate other services into our online offer (for further details, please refer to further information in this privacy policy). The Tag Manager itself (which implements the tags) therefore does not create profiles of users or store cookies. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager;

Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA;

Legal basis: Consent (Art. 6 (1) S. 1 lit. a) GDPR);

Website: https://marketingplatform.google.com;

Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms;

Standard contractual clauses (guaranteeing data protection level in third countries): https://business.safety.google/adsprocessorterms;

Further information: https://privacy.google.com/businesses/adsservices (types of processing and the processed data).

VIII. Facebook

Based on our legitimate interest in accordance with Art. 6 Para. 1 lit. f GDPR, our website uses social media plugins from Facebook to make their use more personal. For this, we use the “LIKE” or “SHARE” button. This is an offer from Facebook.

Facebook has implemented technical and organizational measures to ensure the rights of affected individuals and the protection of personal data.

When you visit a page of our website that contains such a plugin, your browser establishes a direct connection with the servers of Facebook. The content of the plugin is transmitted directly from Facebook to your browser and integrated into the website.

By integrating the plugins, Facebook receives information that your browser has accessed the corresponding page of our website, even if you do not have a Facebook account or are not currently logged in to Facebook. This information (including your IP address) is transmitted directly from your browser to a server of Facebook in the USA and stored there.

If you are logged into Facebook, Facebook can directly associate your visit to our website with your Facebook account. If you interact with the plugins, for example, by clicking the “LIKE” or “SHARE” button, the corresponding information is also transmitted directly to a server of Facebook and stored there. The information is also published on Facebook and displayed to your Facebook friends.

Facebook may use this information for advertising, market research, and tailor-made design of the Facebook pages. To this end, Facebook creates usage, interest, and relationship profiles, e.g., to evaluate your use of our website in relation to the advertisements displayed to you on Facebook, to inform other Facebook users about your activities on our website, and to provide further services related to the use of Facebook.

If you do not want Facebook to associate the data collected through our website with your Facebook account, you must log out of Facebook before visiting our website.

For information on the purpose and scope of data collection and the further processing and use of the data by Facebook, as well as your rights in this regard and settings options for protecting your privacy, please refer to Facebook’s privacy policy (https://www.facebook.com/about/privacy/).

If a user is a Facebook member and does not want Facebook to collect data about them via this online offer and link it to their membership data stored on Facebook, they must log out of Facebook before using our online offer and delete their cookies. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e., they are adopted for all devices, such as desktop computers or mobile devices.

IX. Social Media & Plugins

Based on our legitimate interest in accordance with Art. 6 Para. 1 lit. f GDPR, our website uses social media plugins from various manufacturers to make their use more personal. For this, we use, for example, the “LIKE” or “SHARE” button.

All social media platforms have implemented technical and organizational measures to ensure the rights of affected individuals and the protection of personal data.

When you visit a page of our website that contains such a plugin, your browser establishes a direct connection with the servers of the platform. The content of the plugin is transmitted directly from the respective provider to your browser and integrated into the website.

If you are logged into the social media platform, the provider can directly associate your visit to our website with your user account. If you interact with the plugins, for example, by clicking the “LIKE” or “SHARE” button, the corresponding information is also transmitted directly to a server of the provider and stored there. The information is also published on the respective platform and displayed to your social media contacts.

By integrating the plugins, the platform operator receives information that your browser has accessed the corresponding page of our website, even if you do not have a user account with the provider or are not currently logged in. This information (including your IP address) is transmitted directly from your browser to a server of the provider (e.g., in the USA) and stored there.

The platform operator may use this information for advertising, market research, and tailor-made design of the platform. To this end, usage, interest, and relationship profiles are created, e.g., to evaluate your use of our website in relation to the advertisements displayed to you on the platform, to inform other platform users about your activities on our website, and to provide further services related to the use of the platform.

If you do not want the platform operator to associate the data collected through our website with your user account, you must log out of the platform before visiting our website.

For information on the purpose and scope of data collection and the further processing and use of the data by the provider, as well as your rights in this regard and settings options for protecting your privacy, please refer to the privacy policies of the respective providers:

Facebook: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy;

Opt-Out: Ad settings: https://www.facebook.com/settings?tab=ads; Additional privacy information: Agreement on joint processing of personal data on Facebook pages: https://www.facebook.com/legal/terms/page_controller_addendum, Privacy notes for Facebook pages: https://www.facebook.com/legal/terms/information_about_page_insights_data.

If a user is a Facebook member and does not want Facebook to collect data about them via this online offer and link it to their membership data stored on Facebook, they must log out of Facebook before using our online offer and delete their cookies.

Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e., they are adopted for all devices, such as desktop computers or mobile devices.

LinkedIn: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy;

Xing: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.

SalesViewer® – Technology: On this website, data for marketing, market research, and optimization purposes is collected and stored using the SalesViewer® technology of SalesViewer® GmbH based on the legitimate interests of the website operator (Art. 6 Para.1 lit.f GDPR).

For this purpose, a JavaScript-based code is used to collect company-related data and its respective use. The data collected using this technology are encrypted using a non-reversible one-way function (so-called hashing). The data are immediately pseudonymized and not used to personally identify the visitor of this website.

The data stored as part of Salesviewer will be deleted as soon as they are no longer needed for their intended purpose and there are no legal retention obligations to prevent their deletion.

You can object to the data collection and storage at any time with effect for the future by clicking this link here to prevent future collection by SalesViewer® within this website. An opt-out cookie for this website will be placed on your device. If you delete your cookies in this browser, you must click this link again.

X. Online Conference Tools, Video Meeting Tools

To ensure smooth communication exchange, we use various online conference tools or video conference tools. This means that your personal data will be processed by other responsible parties when using the service, and thus the processing of your personal data is not within our control.

The use of video conference or online conference tools is voluntary and based on your consent in accordance with Art. 6 Para. 1 lit. a GDPR.

Further data protection information can be found on the websites of the individual providers listed below.

Microsoft Corporation, One Microsoft Way – Redmond, WA 98052-6399 USA; Information on data protection: Microsoft Teams Security and Microsoft Teams Security Compliance Overview

Zoom: Zoom Video Communications, Inc., 55 Almaden Blvd Suite 600 – San Jose, CA 95113 – USA; Data protection information: Zoom Privacy

Google Meet: Google Ireland Limited, Gordon House, Barrow Street Dublin 4, Ireland, Data protection information: Google Privacy Policies

XI. Marketing Automation with Mautic

We use Mautic on this website, an open-source tool for marketing automation. It is an analysis and tracking software for assigning and storing usage data (including used browser, last visited page, duration of stay). The software uses this information to individualize our marketing measures and better align them with the interests of each individual user. The software also helps us to better evaluate the success of individual marketing measures. For this purpose, we have concluded an AV contract with our host for the marketing tool Mautic.

Mautic is hosted on the same server as our website in Germany. Data is not shared with third parties. We collect and process data with Mautic only to the extent necessary to achieve business objectives with you.

The functioning of Mautic is expressed through:

a) Email marketing and campaigns: In so-called email marketing, personalized emails are sent to you. These are partly based on user behavior on the website, reading our emails, and interacting with the links contained therein. Furthermore, we send emails as part of campaigns. Assignment to the campaigns is done through segmentations and taggings.

b) Personalized web links: To recognize whether a user clicks a link from an email, Mautic adds a unique identifier to these links that was previously assigned to an individual user profile.

c) IP address: The currently used IP address of website visitors is transmitted to us with each visit to our website. Mautic uses this to recognize users of the website.

d) Reports: evaluate performance data about the collected data and display it in aggregated form.

The data collected includes:

  • Activity on our website
  • Number of page views and duration of website visitor’s stay
  • The click path of the respective visitor
  • Downloads of files provided via the website
  • Visits to landing pages
  • Openings of emails from newsletters and campaigns

When registering on the website, the provider collects through the use of Mautic:

  • Contact details (such as name, postal or email address, telephone number)
  • Business contact details (such as your job title, name of a business, business email address, telephone or fax number).
  • The IP address of the end device from which the website is used (a sequence of numbers that identifies your current computer connection on the Internet).
  • The data released are clearly recognizable to the user by filling out a form. It is marked which data are necessary to send the form.

Mautic is only used once you have expressly given your consent to the use of so-called “first-party cookies” during the initial use of our website. You can revoke this consent at any time to the contact person mentioned above. In this case, all tracking data collected via Mautic will be deleted immediately.

XII. Appointment Booking through External Tool

Cal.com: depending on how you access our services and subject to your opt-out preferences, we may use “cookies” (a small text file sent by your computer each time you visit our website and only applies to your Cal.com account or your browser) or similar technologies to record log data. When we use cookies, we use either “session” cookies (which stay until you close your browser) or “permanent” cookies (which stay until you or your browser delete them). Cal.com, Inc.; Website: Cal.com; Privacy Policy: Cal.com Privacy

XIII. Rights of the Data Subject

If personal data concerning you are processed, you are the data subject within the meaning of the GDPR, and you have the following rights against the controller:

  • Right to Information

You can request confirmation from the controller as to whether personal data concerning you are being processed.

If such processing is taking place, you can request information from the controller about the following:

  • The purposes for which the personal data are processed;
  • The categories of personal data being processed;
  • The recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
  • The planned duration of storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
  • The existence of a right to rectification or deletion of personal data concerning you, a right to restriction of processing by the controller, or a right to object to such processing;
  • The existence of a right of complaint to a supervisory authority;
  • All available information on the source of the data if the personal data are not collected from the data subject;
  • The existence of automated decision-making, including profiling, according to Art. 22 Para. 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved, as well as the scope and intended effects of such processing for the data subject.

You have the right to request information about whether the personal data concerning you are transferred to a third country or to an international organization. In this context, you can request to be informed about the appropriate guarantees according to Art. 46 GDPR in connection with the transfer.

  • Right to Rectification

You have the right to rectification and/or completion by the controller if the processed personal data concerning you are incorrect or incomplete. The controller must make the correction without delay.

  • Right to Restriction of Processing

You can request the restriction of the processing of personal data concerning you under the following conditions:

  • If you dispute the accuracy of the personal data concerning you for a period that enables the controller to verify the accuracy of the personal data;
  • If the processing is unlawful and you refuse the deletion of the personal data and instead request the restriction of the use of the personal data;
  • If the controller no longer needs the personal data for the purposes of processing, but you need them to assert, exercise, or defend legal claims, or
  • If you have objected to processing pursuant to Art. 21 Para. 1 GDPR and it has not yet been determined whether the legitimate grounds of the controller override your reasons.

Where processing of personal data concerning you has been restricted, such data may – with the exception of storage – only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

If the restriction of processing has been restricted according to the above conditions, you will be informed by the controller before the restriction is lifted.

XIII. Rights of the Data Subject

If your personal data is processed, you are a data subject under the GDPR, and you have the following rights against the controller:

  • Right of Access

You can request confirmation from the controller as to whether personal data concerning you is being processed by us.

If such processing is taking place, you can request information from the controller about the following:

  • The purposes for which the personal data are processed.
  • The categories of personal data that are processed.
  • The recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed.
  • The planned duration of storage of the personal data concerning you or, if specific information on this is not available, criteria for determining the storage duration.
  • The existence of a right to rectification or deletion of personal data concerning you, a right to restriction of processing by the controller, or a right to object to such processing.
  • The existence of a right to lodge a complaint with a supervisory authority.
  • All available information about the origin of the data if the personal data are not collected from the data subject.
  • The existence of automated decision-making, including profiling, according to Art. 22, paragraphs 1 and 4 of the GDPR, and – at least in these cases – meaningful information about the logic involved, as well as the scope and intended effects of such processing for the data subject.

You have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you can request to be informed about the appropriate safeguards according to Art. 46 of the GDPR in connection with the transfer.

  • Right to Rectification

You have the right to rectification and/or completion by the controller if the processed personal data concerning you are inaccurate or incomplete. The controller must make the rectification without delay.

  • Right to Restriction of Processing

Under the following conditions, you can request the restriction of the processing of personal data concerning you:

  • If you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data.
  • If the processing is unlawful and you oppose the deletion of the personal data and instead request the restriction of the use of the personal data.
  • If the controller no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise, or defense of legal claims.
  • If you have objected to processing pursuant to Art. 21, paragraph 1 of the GDPR, and it is not yet determined whether the legitimate grounds of the controller override your reasons.

Where processing of personal data concerning you has been restricted, such data – apart from their storage – may only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

If the restriction of processing has been restricted according to the above conditions, you will be informed by the controller before the restriction is lifted.

  • Right to Erasure

a) Obligation to Erase

You can demand that the personal data concerning you be deleted immediately by the controller, and the controller is obliged to delete this data without delay if one of the following reasons applies:

  • The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
  • You withdraw your consent on which the processing was based according to Art. 6, paragraph 1, lit. a, or Art. 9, paragraph 2, lit. a of the GDPR, and there is no other legal ground for the processing.
  • You object to the processing pursuant to Art. 21, paragraph 1 of the GDPR, and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21, paragraph 2 of the GDPR.
  • The personal data concerning you have been unlawfully processed.
  • The deletion of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
  • The personal data concerning you have been collected concerning offered services of the information society according to Art. 8, paragraph 1 of the GDPR.

b) Information to Third Parties

If the controller has made the personal data concerning you public and is obliged to delete them according to Art. 17, paragraph 1 of the GDPR, the controller, taking into account available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers who are processing the personal data that you, as the data subject, have requested the deletion of all links to or copies or replications of those personal data.

c) Exceptions

The right to erasure does not exist insofar as the processing is necessary:

  • For exercising the right of freedom of expression and information.
  • For compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
  • For reasons of public interest in the area of public health in accordance with Art. 9, paragraph 2, lit. h and i, as well as Art. 9, paragraph 3 of the GDPR.
  • For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Art. 89, paragraph 1 of the GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
  • For the establishment, exercise, or defense of legal claims.
  • Right to Information

If you have asserted the right to rectification, erasure, or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.

You have the right to be informed about these recipients by the controller.

  • Right to Data Portability

You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used, and machine-readable format. Furthermore, you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data have been provided, provided that:

  • The processing is based on consent according to Art. 6, paragraph 1, lit. a of the GDPR or Art. 9, paragraph 2, lit. a of the GDPR, or on a contract according to Art. 6, paragraph 1, lit. b of the GDPR, and
  • The processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The freedoms and rights of others must not be affected by this.

The right to data portability does not apply to processing personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

  • Right to Object

You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is based on Art. 6, paragraph 1, lit. e or f of the GDPR; this also applies to profiling based on these provisions.

The controller shall no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for such marketing; this also applies to profiling, to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You have the option, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise your right to object by automated means using technical specifications.

  • Right to Withdraw Consent to Data Protection

You have the right to withdraw your consent to data protection at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

  • Automated Individual Decision-Making, Including Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This shall not apply if the decision:

  • is necessary for entering into, or performance of, a contract between you and the data controller,
  • is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or
  • is based on your explicit consent.

However, decisions shall not be based on special categories of personal data referred to in Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

In the cases referred to in points (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

  • Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant of the progress and the outcome of the complaint, including the possibility of a judicial remedy pursuant to Article 78 of the GDPR.