General Data Protection Regulation GDPR

I. Name and address of the controller 

The controller within the meaning of the General data protection regulation and other national data protection laws of the member states as well as other data protection regulations is:

Karl Josef Stein
Reichsstraße 30
14052 Berlin

Mobile: +49 (0) 1520 105 1165
Mail: kj-stein@stein-icm.com
Web: www.stein-icm.com

II. Name and address of the representative

The representative of the controller is:

Karl Josef Stein
Reichsstraße 30
14052 Berlin

Mobile: +49 (0) 1520 105 1165
e-mail: kj-stein@stein-icm.com
Website: www.stein-icm.com

III. General information about data processing

1. Scope of processing of personal data

In principle, we collect and use personal data of our users only to the extent necessary for the provision of a functional website and our content and services. The collection and use of personal data of our users takes place regularly only with the consent of the user. An exception applies to cases in which prior consent can not be obtained for reasons of fact and the processing of the data is permitted by law.

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the person concerned for processing of personal data, art. 6 para.1 lit. a of the General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.

The processing of personal data necessary for the performance of a contract to which the person concerned is a party shall be governed by art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual actions.

Insofar as the processing of personal data is required to fulfil a legal obligation to which our company is subject, art. 6 para. 1 lit. c DSGVO serves as the legal basis.

In the event that vital interests of the person concerned or any other natural person require the processing of personal data, art. 6 para. 1 lit. d GDPR serves as the legal basis.

If the processing is necessary to safeguard the legitimate interests of our company or a third party, and the interests, fundamental rights and fundamental freedoms of the person concerned do not outweigh the former interest, art. 6 para. 1 lit. f GDPR serves as the legal basis for processing.

3. Data deletion and storage duration

The personal data of the person concerned will be deleted or blocked as soon as the purpose of the storage ceases to apply. In addition, such storage may take place if provided for by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Blocking or erasure of the data also takes place when a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data for conclusion of a contract or fulfillment of the contract.

IV. Provision of the website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the calling computer.

The following data is processed here:

  1. Information about the browser type and version used
  2. The operating system of the user
  3. The Internet service provider of the user
  4. The IP address of the user
  5. Date and time of access
  6. Websites from which the system of the user comes to our website
  7. Websites that are accessed by the user’s system through our website

2. Legal basis for data processing  

As the legal basis for the temporary storage of data and log files serves art. 6 para. 1 lit. f GDPR.

3. Purpose of the data processing

The temporary storage of the IP address by the system is necessary to allow delivery of the website to the computer of the user. In order to do this, the user’s IP address must be stored for the duration of the session.

Storage in log files is done to ensure the functionality of the website. In addition, the data is used 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.

Our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f GDPR also lies in these purposes.

4. Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. In the case of collecting the data for providing the website, this is the case when the respective session is completed.

In the case of storing the data in log files, this is the case after no more than seven days. An additional storage is possible. In this case, the IP addresses of the users are erased or alienated, so that an assignment of the calling client is no longer possible.

5. Possibility of objection and erasure

The collection of data for the provision of the website and the storage of the data in log files is essential for the operation of the website. There is consequently no right of contradiction on the part of the user.

V. Use of cookies

1. 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. When a user visits a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic character string that enables a unique identification of the browser when the website is called up again.

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.

The following data is stored and transmitted in the cookies:

  1. Language-settings
  2. Browser
  3. Log-in-information

In addition, we use cookies on our website that allow an analysis of users’ browsing behavior.

In this way, the following data can be transmitted:

  1. Entered search terms
  2. Frequency of page views
  3. Use of website features

The data of the users collected in this way are pseudonymized by technical precautions. Therefore, an assignment of the data to the calling user is no longer possible. The data will not be stored together with other personal data of the users.

When accessing our website, users are informed by an information banner about the use of cookies for analysis purposes and referred to this privacy policy. In this context, there is also an indication of how the storage of cookies in the browser settings can be prevented.

When accessing our website, the user is informed about the use of cookies for analysis purposes.

2. Legal basis for data processing  

Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing of personal data using cookies.

3. Purpose of the data processing

The purpose of using technically necessary cookies is to facilitate the use of websites for users. Some features of our website can not 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 through technically necessary cookies will not be used to create user profiles.

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

In these purposes also lies our legitimate interest in the processing of personal data in accordance with art. 6 para. 1 lit. f GDPR.

4. Duration of storage, objection and erasure possibilities

Cookies are stored on the computer of the user and are transmitted from there 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. Already saved cookies can be erased 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 in full.

VI. Contact form and e-mail contact

1. Description and scope of data processing

There is a contact form on our website which can be used for electronic contact. If a user accepts this possibility, the data entered in the input mask will be transmitted to us and stored.

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

  1. The IP address of the user
  2. Date and time of registration

For the processing of the data in the context of the sending process your consent is obtained and referred to this data protection regulation.

Alternatively, contact is possible via the provided e-mail address. In this case, the user’s personal data transmitted by e-mail will be stored.

In this context, the data will not be passed on to third parties. The data is used exclusively for processing the conversation.

2. Legal basis for data processing  

In the event of the user’s consent, the legal basis for processing the data is art. 6 para. 1 lit. a GDPR.

As the legal basis for the processing of the data transmitted in the course of sending an e-mail serves art. 6 para. 1 lit. f GDPR. If the e-mail contact aims to conclude a contract, then as additional legal basis for the processing serves art. 6 para. 1 lit. b GDPR.

3. Purpose of the data processing

The processing of the personal data from the input mask serves us only to process the making of the contact. In the case of making contact via e-mail, hereof also lies the required legitimate interest in the processing of the data.

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

4. Duration of storage

The data will be deleted as soon as it is no longer necessary for the purpose of its collection. For the personal data from the input form of the contact form and those sent by e-mail, 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 relevant facts have been finally clarified.

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

5. Objection and erasure possibilities

The user has the possibility at any time to revoke his consent to the processing of the personal data. If the user contacts us by e-mail, he may object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.

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

VII. Integration of services and content of third parties

Within our online offer based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. f GDPR), we make use of third-party content or service offerings in order to provide and integrate their content and services, such as videos or fonts (collectively referred to as “content”). This always presupposes that the third-party providers of this content perceive the IP address of the users, because without the IP address they could not send the content to their browser. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons “) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as be linked to such information from other sources.

The following presentation provides an overview of third-party providers as well as their contents, along with links to their data privacy statements, which contain further information on the processing of data:

  • Maps of the service Google Maps of the third-party provider Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Data Privacy Policy: https://www.google.com/policies/privacy/ , Opt-Out: https://www.google.com/settings/ads/ .
  • This site uses so-called web fonts provided by Google to uniformly display fonts. When you call up a page, your browser loads the required Web fonts into your browser cache to display texts and fonts correctly. To do this, the browser you use must connect to Google’s servers. This gives Google knowledge that our website has been accessed via your IP address. The use of Google Web Fonts is in the interest of a consistent and attractive presentation of our online offers. This represents a legitimate interest within the meaning of art. 6 para. 1 lit. f GDPR. If your browser does not support web fonts, a default font will be used by your computer. For more information about Google Web Fonts, visit https://developers.google.com/fonts/faq and in Google’s Data Privacy Policy: https://www.google.com/policies/privacy/.

VIII. Rights of the data subject

If your personal data is processed, you are affected within the meaning of the GDPR and you have the following rights vis-à-vis the controller:

1. Right to information

You may ask the controller to confirm if personal data concerning you is processed by us.

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

(1) the purposes for which the personal data are processed;

(2) the categories of personal data being processed;

(3) the recipients or categories of recipients to whom the personal data relating to you have been disclosed or are still being disclosed;

(4) the planned duration of the storage of your personal data or, if specific information is not available, criteria for determining the duration of storage;

(5) the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;

(6) the existence of a right of appeal to a supervisory authority;

(7) all available information on the source of the data if the personal data is not obtained from the data subject;

(8) 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 impact of such processing on the person concerned.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transmission.

2. Right to rectification  

You have a right of rectification and/or completion vis-à-vis the data controller if the personal data processed concerning you are incorrect or incomplete. The controller shall make the correction without delay.

3. Right to restriction of processing

You may request the restriction of the processing of your personal data under the following conditions:

(1) if you dispute the accuracy of personal data concerning you for a period of time that enables the controller to verify the accuracy of the personal data;

(2) the processing is unlawful and you refuse the deletion of the personal data and instead demand the restriction of the use of the personal data;

(3) the controller no longer needs the personal data for the purposes of processing, but you need it to assert, exercise or defend legal claims; or

(4) if you have objected to the processing in accordance with art. 21 para. 1 GDPR and it has not yet determined whether the legitimate reasons of the controller outweigh your reasons.

If the processing of personal data concerning you has been restricted, such data may only be processed – apart from being stored – with your consent or for the purpose of asserting, exercising or defending rights or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or a Member State.

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

4. Right to erasure

a) Obligation to erase

You may request from the controller to erase the personal data relating to you immediately and the data controller is obliged to erase such data without undue delay where one of the following grounds applies:

(1) The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

(2) You withdraw consent on which the processing is based according to art. 6 para. 1 lit. a or art.  9 para. 2 lit. a GDPR and there is no other legal basis for processing.

(3) You object to the processing pursuant to art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or You object to the processing pursuant to art. 21 para. 2 GDPR.

(4) Your personal data have been unlawfully processed.

(5) The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

(6) The personal data concerning you have been collected in relation to the offer of information society services referred to in art. 8 para. 1 GDPR.

b) information to third parties

Where the controller has made the personal data public and is obliged pursuant to art. 17 para 1 GDPR to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

c) Exceptions

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

(1) for exercising the right to freedom of expression and information;

(2) 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;

(3) for reasons of public interest in the area of public health in accordance with art. 9 para. 2 lit. h and i as well as art. 9 para. 3 GDPR;

(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with art. 89 para. 1 GDPR in so far as the right referred to in paragraph a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

(5) for the establishment, exercise or defence of legal claims.

5. Right to information

If you have the right of rectification, erasure or restriction of processing to the controller, then he is obliged to notify all recipients to whom your personal data have been disclosed of this correction or deletion of the data or restriction of processing, unless this proves impossible or involves disproportionate effort.

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

6. Right to Data Portability

You shall have the right to receive the personal data concerning you which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

(1) the processing is based on consent pursuant to art. 6 para. 1 lit. a GDPR or Art.   9 para.   2 lit.   a GDPR or on a contract pursuant to art. 6 para. 1 lit. b GDPR and

(2) the processing is carried out by automated means.

In exercising this right, you also have the right to obtain that personal data relating to you are transmitted directly from one controller to another, insofar as this is technically feasible. Freedoms and rights of other persons may not be affected.

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

7. Right to object

You shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on art. 6 para. 1 lit. e or f GDPR, including profiling based on those provisions.

The controller shall no longer process the personal data unless he can demonstrate compelling legitimate grounds for the processing which override interests, rights and freedoms of you or the processing serves for the establishment, exercise or defence of legal claims.

Where personal data are processed for direct marketing purposes, you shall have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, your personal data shall no longer be processed for such purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

8. Right to revoke the data protection declaration of consent 

You have the right to revoke your consent to the data protection declaration at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until the revocation.

9. Automated decision on a case-by-case basis, including profiling

You shall 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:

(1) is necessary for entering into, or performance of, a contract between you and a data controller,

(2) is authorised 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

(3) is based on your explicit consent.

However, these decisions may not apply to specific categories of personal data under art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g apply and reasonable measures have been taken to safeguard the rights and freedoms and your legitimate interests.

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

10. Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you violates the provisions of the GDPR.

The supervisory authority to which the complaint has been submitted shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy according to art. 78 GDPR.