Data protection

 

Our website address is: http://www.cirlo.de.

 

 

Thank you very much for your interest in our website and the information provided there. Since we take the protection of the privacy of both the users of our homepage and our customers very seriously and observe the legal provisions for the protection of personal data, such as those contained in the Federal Data Protection Act and the Telemedia Act, we will inform you below how we deal with your data:

Data collection and data processing
If our website is accessed and the files stored there are accessed, these are logged for statistical purposes and to improve our online offer. The data on the access and retrieval do not allow us to draw any conclusions about your person. We save the data in so-called server log files. The logged and stored data are: Name of the file called up, date and time of the call, amount of data transferred, notification of the success of the access or call, IP address of the requesting device.

We only collect personal data ourselves if the site user discloses it to us on a voluntary basis, for example in the form of inquiries (for example by electronic mail or by using a contact form on our homepage) or in the context of legal agreements with us.

 

Responsibility within the meaning of the General Data Protection Regulation
The person responsible within the meaning of the General Data Protection Regulation is the operator of the website you are currently accessing. Our contact details can be found in the provider identification (imprint) on the homepage you have visited.

 

Data collection and data processing
1. Creation of log files when you visit our website.  If our website is accessed and the files stored there are accessed, data is automatically logged. We save this data in so-called server log files.The logged and stored data are specifically:
• Name of the file called up
• Date and time of the call
• Amount of data transferred
• Notification of the success of the access or retrieval
• IP address of the requesting device
• Browser type
• Operating system used by the visitor.A combination of the same data with other personal data of the visitor to our homepage is not possible, which is why the information provided does not allow us to draw any conclusions about your person. 

Processing Purpose
The storage of your IP address is necessary because without this the contents of our website cannot be transferred to your computer. Your IP address must be saved for the duration of the session – i.e. the connection between the internet browser you use when you call up or access the website (so-called “client-side application”) on the one hand and the server we use to operate the homepage on the other remain. The purpose of storing your data in server log files is, on one hand, to ensure the functionality of our homepage and, on the other hand, to optimize the website you visit. This data also helps us to maintain the security of the information technology systems used here. 

Legal basis for processing the data
The relevant legal basis for the storage of the data and also the server log files, taking into account the processing purpose described for the period up to and including May 24th, 2018, is § 15 I TMG, starting from May 25th, 2018 then Art. 6 I letter f DS-GVO (processing is necessary to safeguard the legitimate interests of the person responsible or a third party). 

Retention period
We delete the automatically stored access and retrieval data at the point in time from which they are no longer necessary to achieve the purpose for which they were collected. As far as the provision of our homepage is concerned, this is the case when the respective session – the connection between the internet browser you use when you call up or access the website (so-called “client-side application”) on the one hand and the one we use for on the other hand, the operation of the server used on the homepage – has ended. The stored IP address and the server log file containing  are deleted no later than 7 days after the time of storage, so that no assignment of the other data (name of the file accessed, date and time of access, amount of data transferred, notification of the success of the access or retrieval, browser type, operating system used by the visitor) for the requesting device and its IP address. 

Opposition option
The data collected for the provision of our homepage and their storage in server log files are indispensable and absolutely necessary for the operation of the local website. Therefore, you have no option to object in this regard. Processing of personal data in the event of inquiries about our range of services or products, we collect personal data even if the site user gives us such data on a voluntary basis in the form of inquiries about our range of services or products (for example by electronic mail). The personal data of the questioner transmitted to us with the request will be saved. These data are in no way passed on to third parties and are used solely for processing the correspondence initiated by the request. 

Processing purpose
The processing of the data transmitted to us within the scope of the service or product-related request serves to process the request as well as the subsequent response. 

Legal basis for processing the data.
The relevant legal basis for the storage of the data that is transmitted to us in the context of inquiries about our range of services or products is, taking into account the processing purpose described above, for the period up to and including May 24th, 2018, § 28 I 1 No. 2 BDSG, beginning on May 25th, 2018 Art. 6 I letter f GDPR (The processing is necessary to safeguard the legitimate interests of the person responsible or a third party).If the request is already directed towards the conclusion of a contract with us, Section 28 I 1 No. 1 BDSG is also applicable for the period up to and including May 24, 2018, beginning on May 25th, 2018 Art. 6 I letter b, 2nd alternative GDPR legal basis for data processing.

Retention period
We delete the data transmitted to us in the course of service or product-related inquiries or collected by us in this context at the point in time from which they are no longer necessary to achieve the purpose of their storage. Insofar as it concerns an inquiry about our range of services or products, this is the case if the inquiry has been answered from here and the circumstances show that no further correspondence with the person making the request is required. 

Opposition option 
The questioner is entitled to object to the storage of his personal data. However, his request can then no longer be answered. If you want to declare such an objection, we kindly ask you in advance to use at least the text form and to send the declaration of objection to one of the contact options given in the imprint of our website (postal address, e-mail, fax). After receipt of the objection, the personal data that was transmitted to us as part of the request and stored here will be deleted immediately.  

Processing purpose 
The processing of the data transmitted to us within the scope of the service or product-related request serves to process the request as well as the subsequent response. 

Legal basis for processing the data
The legal basis for data processing: § 4 I BDSG in conjunction with §§ 12, 13 TMG, starting from May 25th, 2018 then Art. 6 I Letter a GDPR (consent by the person concerned to the processing of the personal data concerning them for one or more specific purposes). 

Right of withdrawal
You are entitled to withdraw your consent to the processing of your personal data. If you want to withdraw your consent, we kindly ask you in advance to use at least the text form and to send the declaration of withdrawal to one of the contact options given in the legal notice on our website (postal address, email, fax). After receipt of the revocation, the personal data will be deleted immediately, unless there is another legal basis for the processing of this data. The legality of the data processing that took place on the basis of your consent prior to your revocation is not affected by the declaration of revocation. 

Retention period 
If you do not revoke your consent, we will delete the data transmitted to us in the course of service or product-related inquiries or collected in this context in any case at the point in time from which it is no longer necessary to achieve the purpose of its storage are necessary. Insofar as it concerns an inquiry about our range of services or products, this is the case if the inquiry has been answered from here and the circumstances show that no further correspondence with the person making the request is required. 

Processing of personal data for contract initiation, contract fulfillment and contract amendment 
We process the personal data that is necessary for the conclusion of a contract between you and us, for its fulfillment or for its amendment. These data are:
• Name and address of the contractual partner,
• Type and number of the booked service or goods,
• the payment method used.Depending on the subject of the (contractual) service concerned, further data may be required. If the payment method used is SEPA direct debit, the following will also be processed:
– the account details of the contractual partner. If payment by credit card has been agreed with our contractual partner, the following will also be processed:
– the credit card data of the contractual partner. If the purchase of the services and / or goods ordered from us is subject to legal restrictions (e.g. age restrictions), the data will also be processed which, due to the relevant legal restrictions, is required for the fulfillment of the contract in addition to the data already specified above (e.g. in the case of statutory age restrictions, the age of the contract partner). 

Processing purpose 
The processing of the named data serves to execute the contracts concluded with us, including the provision of services as agreed. Transfer of data to third parties: the data required for the performance of the contract will be transferred to third parties in the following cases:a. Agreed payment mode SEPA direct debit Your account details will be forwarded to the bank processing the payment.b. Agreed payment mode credit card. Your credit card details will be forwarded to the bank processing the payment or the payment service provider.c. Dispatch of goods or delivery. Your address and the data on the goods ordered will be forwarded to the shipping or transport company we have engaged for delivery purposes.d. Fulfillment of tax obligations. If we have mandated a tax advisor, the data will be passed on to him to the extent that is absolutely necessary to fulfill our tax obligations. 

Legal basis for processing the data
The relevant legal basis for the processing of the data, taking into account the processing purpose described, is Art. 6 I Letter b, 1st alternative GDPR (processing is necessary for the performance of a contract to which the data subject is a party), which also includes processing records on the occasion of pre-contractual measures. 

Retention period 
We store the data required for the fulfillment and the change of an existing contractual relationship with us until the expiry of the statutory, in particular tax retention periods. For example, the retention period for contracts and standing order documents, insofar as they do not form a basis for booking, as well as for shipping documents is currently 6 years (in the case of standing order documents, this period begins after the contract expires), see § 147 III 1 Tax Code (AO). According to Section 147 II in conjunction with Section 147 I No. 1, 4 and 4 a of the Tax Code (AO), invoices must be kept for ten years. After the statutory retention periods have expired, we delete or block the data, provided that they are no longer required for the conclusion of a contract or for the performance of a contract.If no contract has been concluded between you and us, we will delete the data collected or transmitted for pre-contractual measures if the circumstances indicate that further correspondence with you regarding the service or goods to which dialogues or offers from your or our side related, is no longer necessary. 

Objection option
If the processing of your personal data was related to pre-contractual measures and these measures did not result in a contract between you and us, you are entitled to object to the data storage. If you want to declare such an objection, we ask you in advance to use at least the text form and to send the declaration of objection to one of the contact options given in the imprint of our website (postal address, e-mail, fax). After receipt of the objection, the personal data that was collected by us when taking pre-contractual measures or transmitted to us and stored here will be deleted immediately.With regard to the data that are required for the fulfillment of the contract or any changes to the contract, you have no option of objection due to its necessity for the stated purposes. 

Otherwise processing
If the collection and use of personal data is not possible due to actual circumstances and none of the above-mentioned constellations apply, the data processing takes place regularly only with the consent of the person concerned. Incidentally, the collection and use of personal data only takes place in order to enable us to operate our website properly and to improve it.  

Legal basis for the processing of the data
The legal basis for those data processing for which the consent of the data subject is obtained from here Art. 6 I letter a GDPR (Consent by the data subject to the processing of personal data concerning them for one or more specific purposes).

Right of withdrawal
You are entitled to withdraw your consent to the processing of your personal data. Should you wish to withdraw your consent, we kindly ask you in advance to use at least the text form and to send the declaration of withdrawal to one of the contact options given in the legal notice on our website (postal address, email, fax). After receipt of the revocation, the personal data will be deleted immediately, unless there is another legal basis for the processing of this data.The legality of the data processing that took place on the basis of your consent prior to your revocation is not affected by the declaration of revocation. 

Use of Google Analytics
Currently no use of Google Analytics ! (This is a web analysis service offered by Google Inc. (www.google.de; address: 1600 Amphitheater Parkway, Mountain View, CA 94043, United States of America) that uses so-called “cookies”. “Cookies” are text files which, at the instigation of the operator of a homepage, are transmitted to the respective page user when they are called up and are temporarily stored on their end device, which allows an analysis of the user behavior of the page visitor. A distinction is made between two types of “cookies”, namely temporary and permanent. The former are automatically removed from your device as soon as you close your Internet browser. The latter remain stored on your end device even after you close the internet browser you are using, which the website operator can recognize the next time you access their website.The information generated by a “cookie” from the web analysis service “Google Analytics” about your use of our website is transferred to a server operated by Google Inc. in the United States of America and stored there. Google Inc. will use this information to evaluate your use of our website, to compile reports on website activity for the website operator and to provide the website operator with other services relating to website and internet usage. “Google Analytics” records, for example, the date and time of your access to our homepage, the homepage you previously accessed, information about the internet browser you are using, the IP address of the requesting device.We only use the tracking tool “Google Analytics” with activated IP anonymization. The IP addresses of visitors to our homepage are shortened within member states of the European Union or in contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address of the site visitor be transferred to a Google Inc. server in the USA and the IP address will be shortened there.If required by law or if the information collected by “Google Analytics” is processed by third parties on behalf of Google Inc., Google Inc. will also transmit this data to the third party commissioned by it. The use of this information is either anonymized or pseudonymized. Google provides more information on this at http://www.google.com/intl/de/policies/privacy/#information.The IP address transferred from your browser when using the “Google Analytics” service is not merged with other Google data.By using our website, you agree that the Google. Inc. processes the data collected about you as part of your website visit in the manner described above for the aforementioned purpose.By changing the settings of your Internet browser, you can ensure that you are informed about upcoming caching of “cookies” on your device. It is also possible to configure the Internet browser in such a way that you do not accept any or all of the “cookies”. We would like to point out that the functionality of our homepage may be impaired if the “cookies” used on our homepage are rejected.You also have the option of preventing the collection of information, including the IP address of your device, by the “Google Analytics cookie” and the processing of that data by Google Inc. by following the link below and being ready to download  the ready-to-use  browser plug-in on your device: https://tools.google.com/dlpage/gaoptout?hl=de. An alternative to the option described above is that you click on the designated link to prevent “Google Analytics” from being recorded on our website in the future. If you opt for this procedure, a so-called “opt-out cookie” will be stored on your device. If you remove all “cookies” from your device, you must click the link above again to install an “opt-out cookie”.

Right to information
You are permitted to request information from us as to whether personal data relating to you is being processed by us. If this is the case, you can request free information from us about- the processing purposes,
– the categories of those data whose processing takes place,
– the recipients and / or the categories of recipients to whom we have disclosed or will disclose the data,
– the data storage period provided here, or, if it is impossible to provide specific information in this regard, our criteria for determining the data storage period,
– the right to have personal data corrected,
– the right to have personal data deleted,
– the existence of a right to restrict the processing of personal data by the person responsible within the meaning of the GDPR,
– the existence of a right to object to the processing of personal data,- the right to lodge a complaint with a supervisory authority,
– all available information on the origin of the data, insofar as the data was not collected from you as the person concerned,
– the existence of automated decision-making including profiling according to Art 22 I, IV DS-GVO and, insofar as such is to be affirmed, meaningful information about the logic involved, the scope and the intended effects of such data processing for you as the person concerned the GDPR,
– whether a transfer of personal data concerning you to a third country or to an international organization takes place by us or on our behalf, whereby in the case of such a transfer you can also request that we provide you with suitable guarantees within the meaning of Art.Inform 46 GDPR.
• If you want to assert such a request for information, please send your request in writing to one of the contact options given in the legal notice on our website.
• According to Art. 12 I 2 GDPR, this information can also be given orally to the data subject if their identity has been proven in another form. 

Right to data correction and data completion
You can ask us to correct any data stored about you on this side at any time if it is incorrect, see Art. 16 sentence 1 GDPR.The same applies to the completion of incomplete personal data, see Art. 16 sentence 2 GDPR.Should you wish a correction or a completion of personal data concerning you, we ask you to send a request in writing to one of the contact options given in the imprint of our homepage. 

Right to delete personal data
As a data subject within the meaning of the DS-GVO, you can request the immediate deletion of your personal data if one of the following conditions, Art. 17 I DS-GVO, is present:
– the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
– the data subject revokes their consent on which the processing was based in accordance with Art. 6 I Letter a GDPR or Art. 9 II Letter a GDPR, and there is no other legal basis for the processing;
– the person concerned objects to the processing in accordance with Art. 21 I DS-GVO and there are no overriding legitimate reasons for the processing, or the person concerned objects to the processing in accordance with Art. 21 II;
– the personal data has been processed unlawfully;
– the deletion of the personal data is necessary to fulfill a legal obligation under European Union law or the law of the member states to which the person responsible is subject;
– the personal data was collected in relation to information society services offered in accordance with Art. 8 I GDPR.If we have made the personal data concerning you public and are obliged to delete it in accordance with Art. 17 I GDPR, we will take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, in order to ensure that those responsible for the data processing process the personal data, to inform that you, as the data subject within the meaning of the GDPR, have requested the deletion of all links to your personal data or of copies or replications of your personal data from these responsible parties.


• Exceptions to the right to data erasure:According to Art. 17 III DS-GVO, the rights of the data subjects from Art. 17 I and II DS-GVO do not exist insofar as the data processing is carried out
–        to exercise the right to freedom of expression and information,  or
–         to fulfill a legal obligation that requires processing under the law of the European Union or of the member states to which the person responsible is subject,       or
–        to perform a task that is in the public interest or is carried out in the exercise of public authority that has been assigned to the person responsible    or
–        for reasons of public interest in the area of ​​public health in accordance with Art. 9 II letters h and i GDPR and Art. 9 III GDPR or
–        for archival purposes in the public interest, scientific or
–        historical research purposes or for statistical purposes in accordance with Art. 89 I DS-GVO, insofar as the right mentioned in paragraph 1 is likely to make the realization of the objectives of this processing impossible or seriously impair it            or
–        to assert, exercise or defend legal claims is required. 

Right to restrict the processing of personal data
As a data subject within the meaning of the GDPR, you can request that we restrict the personal data relating to you if one of the following conditions, Art. 18 I GDPR, is present:
–        the correctness of the personal data is contested by the data subject for a period of time that enables the person responsible to check the correctness of the personal data;
–        the processing is unlawful and the person concerned refuses to delete the personal data and instead requests that the use of the personal data be restricted;
–        the person responsible no longer needs the personal data for the purposes of processing, but they are required by the data subject to assert, exercise or defend legal claims;
–        the person concerned has lodged an objection to the processing in accordance with Art. 21 I DS-GVO and it has not yet been determined whether the legitimate reasons of the person responsible outweigh those of the person concerned;
–        if the processing of your personal data has been restricted, the same
– apart from their storage may only be used with your declared 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 an important public interest of the Union or a member state are processed, see Art. 18 II GDPR;
–        according to Art. 18 III DS-GVO, we are obliged to inform you, if you are a data subject within the meaning of the DS-GVO, of a restriction of data processing carried out under the conditions of Art. 18 I DS-GVO; this at a time before the restriction was lifted. 

Right to information in the event of an obligation to notify in connection with the correction or deletion of personal data or the restriction of processing 
If you have exercised your right to correct or delete personal data concerning you or to restrict the processing of this data, we are obliged to correct or delete the same to all recipients to whom the relevant data has been disclosed and to communicate data or the data processing restrictions that have taken place, see Art. 19 sentence 1 GDPR.You are to be informed of the recipients of the personal data concerning you at your request, see Art. 19 sentence 2 GDPR.Exceptions to the notification requirement:The notification obligation from § 19 sentence 1 GDPR does not exist if the notification proves to be impossible or is associated with a disproportionate effort. 

Right to data portability 
According to Art. 20 I DS-GVO, you have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format. Furthermore, you have the right to transfer this data to another person responsible without hindrance from us than the person responsible to whom the personal data was provided, provided that the processing is based on consent in accordance with Article 6 I letter a GDPR or Article 9 II letter a or on a contract in accordance with Article 6 I letter b and the processing is carried out using automated procedures. According to Art. 20 III 1 GDPR, the right to data portability does not apply to data processing that is necessary for the performance of a task that is in the public interest or in the exercise of official authority that has been transferred to the person responsible. When exercising the right to data portability, you as the person concerned have the right to have the personal data transmitted directly from one person responsible to another, as far as this is technically feasible, whereby the rights and freedoms of other persons must not be impaired. 

Right to object to data processing 
As a data subject within the meaning of the GDPR, you are entitled under Art. 21 I GDPR, for reasons that arise from your particular situation, at any time to object to the processing of personal data relating to you, which is based on Art. 6 I letters e or f takes place to file an objection; this also applies to profiling based on these provisions. In the event of a permissible objection, we will no longer process your personal data unless we can prove compelling legitimate reasons for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims. If personal data is processed in order to operate direct mail, you as the data subject have the right according to Art. 21 II GDPR to object at any time to the processing of personal data concerning you for the purpose of such advertising, which also applies to profiling, as far as it is related to such direct mail. 

Your right to automated decisions in individual cases, including profiling
As a data subject within the meaning of the GDPR, you have the right, according to Art. 22 I GDPR, not to be subject to a decision based solely on automated processing – including profiling – which has legal effects on you or you in a similar way significantly impaired. 

Exceptions to this right from Art. 22 I GDPR
According to Art. 22 II GDPR, this right does not apply if the automated decision
– is necessary for the conclusion or performance of a contract between the data subject and the person responsible (i.e. between you on the one hand and us on the other hand),
– is permissible on the basis of legal provisions of the European Union or of the member states to which the person responsible is subject and these legal provisions contain appropriate measures to safeguard the rights and freedoms and the legitimate interests of the data subject or
– takes place with the express consent of the data subject.However, the decisions described above that are excluded in accordance with Art. 22 II GDPR may not be based on special categories of personal data under Art. 9 I GDPR, unless Art. 9 II letter a or g applies and appropriate measures to protect rights and freedoms as well as the legitimate interests of the data subject have been met. In the (exceptional) cases mentioned in Art. 22 II GDPR, we take appropriate measures to safeguard your rights and your freedoms as well as your legitimate interests, including at least the right
–        to obtain the intervention of a person on the part of the person responsible,-        to present your own point of view and
–        heard on contesting the decision. 

Right to complain to a supervisory authority 
According to Art. 78 I GDPR, if you are a data subject within the meaning of the GDPR, without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your place of residence, Your place of work or the place of the alleged violation if you are of the opinion that the processing of your personal data violates the GDPR.According to Art. II GDPR, the supervisory authority to which the complaint has been submitted informs the complainant about the status and the results of the complaint, including the possibility of a judicial remedy under Article 78. We reserve the right to make changes to the data protection declaration: In order to be able to do justice to the respectively applicable legal provisions in your interest and ours, we expressly reserve the right to change or update this data protection declaration. For this reason, we recommend that you take a non-binding look at the data protection declaration on our website and read it carefully at regular intervals. Other notesWe strive to protect personal data from access by third parties as far as technically and organizationally possible. We cannot guarantee complete data security when communicating by means of electronic mail (e-mails), which is why we advise you to send us confidential information by post.