Privacy

 

Privacy Policy

 

Introduction

This Privacy Policy informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our range of services and on our websites, mobile applications, functions and contents connected with them as well as external online representations, e.g. Social Media Profiles (hereinafter collectively referred to as “Services”):

  • In the second section you will find information about your rights, the relevant legal standards and general information about our data processing.
  • The third section contains information on the individual processing operations. This section is divided into further areas, such as our key services, reach measurement or marketing.
  • The fourth and final section contains a glossary with explanations and descriptions of the terms used in this Privacy Policy. This means that if you do not know the terms used (e.g. “personal data” or “cookie”), please refer to the last section. All terms used (e.g. “responsible” or “user”) are to be understood gender-neutral.

Table of Contents

Section I – Controller and Overview of Data Processing

Type of processed data:

Categories of data subjects

Purpose of Processing

Section II – Rights of data subjects, legal basis for the processing and general information

Rights of Data Subjects

Right of Withdrawal

Right to Object

Cookies and Right to Object in Direct Marketing

Solely Automated individual decision-making

Erasure of data and archiving obligations

Changes and Updates to this Privacy Policy

Relevant Legal Basis for the Processing;

Security of Data Processing

Disclosure and Transmission of Data

Transfers to Third Countries

Section III – Processing operations

Answering Inquiries and Client Service

Business and market research

Communication via Mail, E-Mail, Fax or Telephone

Hosting

Server-Logs

Google Services and Content

Google Tag Manager

Google Analytics

Section IV – Definitions

 

Section I – Controller and Overview of Data Processing

STEREOFOCUS

BEN DENIZ

ZUR MÜHLE 7, D-38442 WOLFSBURG, Deutschland

Phone: +49 177 5243267

E-Mail: mail@stereofocus.com

Complete legal information: https://www.stereofocus.com/impressum.

 

Type of processed data:

  • Client master data / inventory data (for example, names, addresses).
  • Contact data (e.g., e-mail addresses, telephone numbers).
  • Content data (e.g., entries in the contact form, content of clients, such as documents, images, etc.).
  • Usage data (e.g., visited websites, interest in content, access times).
  • Metadata (e.g., device information, IP addresses).

 

Categories of data subjects

  • Clients, interested parties, business partners, third parties.
  • Visitors and users of our online services.

In the following, we will also summarise the data subjects as “users”.

Purpose of Processing

  • Response to contact requests and communication with users.
  • Marketing, advertising and market research.
  • Security measures.

As of: May 2018

 

Section II – Rights of data subjects, legal basis for the processing and general information

Rights of Data Subjects

You have the right to obtain from the controller confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the further information and a copy of the data in accordance with Art. 15 GDPR.

You have correspondingly. In accordance with Article 16 of the GDPR, the right to obtain from the controller the rectification of inaccurate personal data concerning you, or the completion of the data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that relevant data be erased without undue delay or, alternatively, to demand a restriction of the processing of the data in accordance with Art. 18 GDPR.

You have in accordance with Art. 20 GDPR the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

In accordance with Art. 77 GDPR, you also have the right to file a complaint with a supervisory authority.

Right of Withdrawal

You have the right to withdraw consents granted pursuant to Art. 7 (3 GDPR with effect for the future.

Right to Object

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

Cookies and Right to Object in Direct Marketing

We use temporary and permanent cookies, i.e. small files that are stored on the user’s devices (for the explanation of the term and function, see last section of this Privacy Policy). In part, cookies serve security purposes or are required for the operation of our online services (e.g., for the appearance of the website) or to save the user’s decision when confirming a cookie banner. In addition, we or our technology partners use cookies to measure the reach and for marketing purposes, about which the users will be informed in the scope of the Privacy Policy.

If users do not want cookies to be stored on their computer, they are advised to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online services.

An objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/.

Solely Automated individual decision-making

In accordance with Art. 22 GDPR, you have the right not to be subject to a decision based exclusively on automated processing – including profiling – which has legal effect concerning you or similarly significantly affects you.

We inform you that we do not use exclusively automated individual decision-making.

Erasure of data and archiving obligations

The data processed by us will be erased or its processing restricted in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this Privacy Policy, the data stored by us will be erased as soon as it is no longer required for its intended purpose and there are no legal obligations to retain it. If the data are not erased because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is excluded and not processed for other purposes. This applies, for example, to data that must be retained for commercial or taxation reasons.

Changes and Updates to this Privacy Policy

We ask you to keep yourself regularly informed about the contents of our Privacy Policy. We will adapt the Privacy Policy as soon as any changes in data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

Relevant Legal Basis for the Processing;

In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not explicitly stated in the Privacy Policy, the following applies: The legal basis for obtaining consents is Art. 6 (1) lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and performance of contractual measures as well as for answering inquiries is Art. 6 (1) lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 (1) lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f GDPR. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.

The principles for commercial communications outside of business relations, in particular by post, telephone, fax and e-mail, are contained in § 7 of the German Unfair Competition Act (UWG).

Security of Data Processing

We shall take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons; the measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transfer, integrity and pseudonymity. Furthermore, we have established procedures that guarantee the assertion of data subjects’ rights, the erasure of data and the response to data hazards. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design of technology and by data protection-friendly presetting (Art. 25 GDPR).

The security measures include in particular the encrypted transmission of data between your browser and our server.

Disclosure and Transmission of Data

If we disclose data to other persons and companies (processors or third parties) within the scope of our processing, transfer the data to them or otherwise grant them access to the data, this will only be carried out on the basis of a legal permission (e.g. if a transfer of the data to third parties, such as to payment service providers, is required for contract fulfilment pursuant to Art. 6 (1), lit. b GDPR), if you have consented, if a legal obligation requires this or on the basis of our legitimate interests (e.g. when using agents, web hosting services, etc.).

If we commission third parties with the processing of data on the basis of a so-called ” Data Processing Agreement”, this is done on the basis of Art. 28 GDPR.

If we disclose, transfer or otherwise grant access to data to other companies in our Group of Companies (Undertakings), this is done in particular for administrative purposes as a legitimate interest and in addition on the basis of a Data Processing Agreement.

Transfers to Third Countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transmission of data to third parties, this only takes place if it is necessary to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or let the data being processed in a third country only if the special requirements of Art. 44 ff. GDPR are met. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognized adequate data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “Standard Contractual Clauses”).

 

Section III – Processing operations

The following section provides an overview of our processing activities, which we have subdivided into other areas of operation. Please note that the areas of operation are for guidance only and that processing activities may overlap (e.g. the same data may be processed in several operations).

For reasons of clarity and comprehensibility, you will find the frequently repeated terms in Section IV of this data protection declaration.

Answering Inquiries and Client Service

We process the information in the inquiries, which we receive via our contact form and other means, e.g. via e-mail, in order to answer the inquiries. For these purposes, the inquiries may be stored in our Client Relationship Management (CRM) system or in similar procedures that serve us to manage inquiries. For client relationship management purposes (CRM) we use so-called CRM software. With the help of the software we can answer the inquiries more effectively and faster.

  • Data processed: Inventory data, contact data, contract data, payment data, usage data, metadata.
  • Data subjects: clients, prospective clients, business partners, website visitors.
  • Purpose of processing: Answering inquiries.
  • Type, scope and mode of operation of the processing: registration process, termination option.
  • Legal basis: Art. 6 (1) b./f. GDPR.
  • Necessity / interest in processing: Necessary to answer queries, optimization, user-friendliness, business interests.
  • Retention of data: We delete the requests if they are no longer required. We review the requirement every two years; requests from clients who have a client account are stored permanently and are linked to the client account details for deletion. In the case of statutory archiving obligations, the erasure takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation).

Business and market research

In order to operate our business economically and to identify market trends, client and user requirements, we analyze the data available to us on business transactions, contracts, inquiries, etc., in order to ensure that we are able to offer our clients the best possible service. For this purpose, we combine the personal data of clients from registrations and orders with the behavior-related data of clients.

In the context of the economic evaluation we bring together the data of the users independently of the used devices (e.g. if users use our on-line offer on a mobile or on a stationary device).

  • Data processed: Client master data/ inventory data, contact data, content data, mandate data/ contract data, payment data, payment data, usage data/ metadata.
  • Legal basis: Art. 6 (1) f. GDPR.
  • Data subjects: clients, prospective clients, business partners, visitors and users of the online offer.
  • Purpose of processing: business analysis, marketing, advertising, market research.
  • Type, scope and mode of operation of the processing: profiling, online behavioral advertising, first party cookies.
  • Necessity / interest in processing: Increased user-friendliness, optimization of the service, business efficiency.
  • Retention of data: If a client account was opened, with its termination, otherwise after two years from conclusion of contract. For the rest, macroeconomic analyses and general trend determinations are carried out anonymously wherever possible.
  • Retention of data: If this data is personal, the storage corresponds to the information on patent attorney and legal services. For the rest, economic analyses and general trend determinations are prepared anonymously wherever possible.

Communication via Mail, E-Mail, Fax or Telephone

Sending information material, contacting us by telephone.

  • Data processed: Inventory data, address and contact data, contract data.
  • Special categories of personal data: no.
  • Legal basis: Art. 6 (1) a, Art. 7 GDPR, Art. 6 (1) f GDPR in connection with legal requirements for advertising communications.
  • Data subjects: clients, prospective clients, communication partners.
  • Purpose of processing: Commercial communication.
  • Type, scope and mode of operation of the processing: Contact is only established with the consent of the contact partners or within the scope of legal permissions.
  • Necessity / interest in processing: Information and business interests.
  • External disclosure and purpose: No.
  • Processing in third countries: No.
  • Retention of data: In the event of revoked consent, we may store the data required to prove our consent for up to three years on the basis of our legitimate interests before we can delete the data in order to be able to prove a previously given consent. The processing of these data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that at the same time the former existence of a consent is confirmed.

Hosting

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage and database services, security services, technical maintenance services.

  • Data processed: Inventory data, contact data, content data, contract data, usage data, meta/communication data.
  • Special categories of personal data: no.
  • Legal basis: Art. 6 para. 1 lit. f GDPR.
  • Data subjects: clients, prospective clients, visitors of the online service.
  • Special security measures: Data Processing Agreement.
  • Processing in third countries: none.
  • External disclosure and purpose: KNALLHART Marketing GmbH Franzstr. 51, 52064 Aachen (Webhosting).
  • Necessity / interest in processing: Security, business interests.

Server-Logs

The server on which this online service is hosted collects so-called log files each time the online service is accessed, in which user data is stored. The data is used for statistical analysis to maintain and optimize server operation and for security purposes, e.g. to detect potential unauthorized access attempts. The server logs are stored pseudonymously, i.e. the IP address is shortened by the last two digits (so-called IP masking).

  • Data processed: Usage data and metadata (name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, IP address).
  • Special categories of personal data: none.
  • Legal basis: Art. 6 (1) f., 28 GDPR.
  • Data subjects: clients, prospective clients, visitors of the online service.
  • Purpose of processing: Optimization of server operation and security monitoring.
  • Necessity / interest in processing: Security, business interests.
  • Processing in third countries: no.
  • Deletion of data: The pseudonymous data will be deleted after two months at the latest.

Google Services and Content

We use the following services and contents of the provider Google: Google Maps – Maps.

Google Tag Manager

Google Tag Manager is a tool that allows us to manage so-called website tags via an interface (and thus integrate Google Analytics and other Google marketing services into our online serviced,). The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, reference is made to the following information on the Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.

Google Analytics

We use Google Analytics for purposes of range measurement and target group building.

Google AdWords

We use Google AdWords to place ads on Google’s and Google partner’s websites and measure their performance.

  • Data processed: Usage data, metadata.
  • Type, scope and mode of operation of the processing: permanent cookies, third party cookies, tracking, conversion measurement, online behavioural advertising, profiling, cross-device-tracking.
  • Special security measures: Pseudonymisation, IP masking, conclusion of Data Processing Agreement, opt-out.
  • Opt-Out: https://adssettings.google.com/.
  • External disclosure: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
  • Privacy Policy: https://policies.google.com/privacy.
  • Processing in third countries: USA.
  • – Guarantee when processing in third countries: Privacy Shield https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
  • Retention of data: The data may be processed by Google for up to two years before it is anonymised or deleted.

Google Advertising Network

Google’s Double-Click technology enables us to target visitors to our website with targeted advertising as part of marketing campaigns for our products on our advertising partners’ websites.

  • Data processed: Usage data, metadata.
  • Type, scope, functioning of processing: permanent cookies, third party cookies, tracking, conversion measurement, interest-based marketing, remarketing, cross-device tracking, profiling.
  • Special protective measures: Pseudonymisation, IP masking, conclusion of Data Processing Agreement, opt-out.
  • Opt-Out: https://adssettings.google.com/.
  • External disclosure: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
  • Privacy Policy: https://www.google.com/policies/privacy.
  • processing in third countries: USA.
  • Guarantee for processing in third countries: Privacy Shield privacyshield.gov/participant?id=a2zt00000000001L5AAI&status=Active.
  • Deletion of data: The data will be deleted by Google and will be deleted if the customer’s data is deleted as part of the termination.

 

Section IV – Definitions

This section provides an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended primarily for understanding. The terms are sorted alphabetically.

  • Aggregated Data – Aggregated data is pooled data that cannot be traced back to a person and is therefore not personal. For example, visit times on a website can be saved as median values.
  • Anonymous data – Anonymity occurs when a person cannot at least be identified by the controller using the reasonable means at his disposal on the basis of data. In particular, aggregated data may be anonymous.
  • Click tracking – “Click tracking” allows to track the movements of users within an entire website. Since the results of these tests are more accurate if the user interaction can be monitored over a certain period of time (e.g. if a user likes to return), cookies are usually stored on the user’s computers for these test purposes.
  • Consent – „consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
  • Controller – “controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Conversion – “Conversion”, or “Conversion measurement” refers to a procedure with which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the user’s devices within the websites on which the marketing activities take place and then retrieved again on the target website (e.g. this enables us to trace whether the ads we placed on other websites were effective).
  • Cookies – Cookies are small files that are stored on the user’s computer. Different data can be stored in the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to a website. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves a website and closes his browser. In such a cookie, for example, the content of a shopping basket in an online shop or a login status within a community can be stored. Cookies are referred to as “permanent” or “persistent” if they are stored even after the browser is closed. For example, the login status can be saved permanently. Likewise, the interests of users used for web analytics or marketing purposes (see e.g. “Remarketing”) may be stored in such a cookie. As a “third party cookie”, cookies are offered by providers other than the operator of the website (otherwise, if they are only the operators cookies, they are referred to as “first party cookies”).
  • Data subject – See “Personal data”.
  • Embedding – Embedding involves integrating external content or software functions (see “Plug-ins”) into one’ s own website in such a way that they are displayed or executed on this website. No copy of the content is created because it is called from the original server (e.g. videos, images, posts on social networks, widgets with ratings). With embedding, it is technically necessary for the provider of the content to obtain the IP address of the user in order to display the embedded content in the user’s browser. Furthermore, the content provider may, for example, store cookies on the user’s devices.
  • Error tracking – During error tracking, e.g. incorrectly executed program code is detected in order to eliminate it and thus guarantee the functionality and security of websites.
  • First-Party Cookies – See „Cookies”.
  • IP address – The IP address (“IP” stands for Internet Protocol) is a sequence of numbers that can be used to identify devices connected to the Internet. When a user visits a website on a server, he informs the server of his IP address. The server then knows that it must send the data packets containing the content of the website to this address.
  • IP Masking – IP masking is a method in which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing.
  • Opt-in – The term “opt-in” means, depending on the context, the same as registration or consent.. If a registration (e.g. by entering an e-mail address in an online form field) is confirmed by sending an e-mail with a confirmation link to the owner of the e-mail address, this is referred to as a Double-Opt-In (DOI).
  • Opt-Out – The term Opt-Out means unsubscription and may be an objection (e.g. against tracking) or a cancellation (e.g. for newsletter subscriptions).
  • Opt-Out-Cookie – An “Opt-Out-Cookie” is a small file (see “Cookies”) which is stored in your browser and in which it is noted that, for example, a tracking service should not process your data. The “opt-out cookie” only applies to the browser in which it was saved, i.e. in which you clicked the opt-out link. If cookies are deleted in this browser, you must click the opt-out link again. Furthermore, an opt-out link can only be limited to the domain on which the opt-out link was clicked.
  • Permanent Cookies – See „Cookies”.
  • Personal Data – “Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing – “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  • Processor – “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
  • Profiling – “Profiling” means any automated processing of personal data consisting in the use of such personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information regarding age, gender, location and movement data, interaction with websites and their contents, shopping behaviour, social interactions with other people) (e.g. interests in certain contents or products, click behaviour on a website or the location). Cookies and web beacons are often used for profiling purposes.
  • Privacy Shield – The EU-US Privacy Shield is an informal agreement in the field of data protection law negotiated between the European Union and the United States of America. It consists of a number of assurances from the US government and a decision by the EU Commission. Companies certified under the Privacy Shield offer a guarantee to comply with European data protection law (https://www.privacyshield.gov).
  • Pseudonymisation/ Pseudonyms – “Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person; E.g. if an exact interest profile of the computer user is stored in a cookie (a “marketing avatar”), but not the name of the user, then data is processed pseudonymously. If his name is stored, e.g. as part of his e-mail address or his IP address is stored, then the processing is no longer pseudonymous.
  • Third countries – Third countries are countries in which the GDPR is not directly applicable law, i.e. in general states that do not belong to the European Union (EU) or the European Economic Area (EEA).
  • Web Analytics – Web Analytics is used to evaluate the visitor flows of a website and can include their behaviour, interests or demographic information, e.g. age or gender. With the help of range analysis, website owners, for example, can see what types of people visit their website at what time and what content they are interested in. This enables them, for example, to better optimize the content of the website to the needs of their visitors. Cookies and web beacons are often used for Web Analytics purposes.
  • Special categories of personal data – Data identifying racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic data, biometric data uniquely identifying a natural person, health data or data relating to a natural person’s sex life or sexual orientation.
  • Third Party – “Third party’ means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
  • Third-Party Cookies – See „Cookies”.
  • Tracking – Tracking is defined as when the behaviour of users can be traced across several online offers, e.g. for remarketing purposes. The behavioral and interest information collected with regard to the online services used is stored as user profiles in cookies or on the servers of marketing service providers (e.g. Google or Facebook).