11. Data protection provisions about the application and use of Matomo
On this website, the controller has integrated the Matomo component. Matomo is an open-source software tool for web analysis. Web analysis is the collection, gathering and evaluation of data on the behaviour of visitors from Internet sites. A web analysis tool collects, inter alia, data on the website from which a data subject came to a website (so-called referrer), which pages of the website were accessed or how often and for which period of time a sub-page was viewed. A web analysis is mainly used for the optimization of a website and the cost-benefit analysis of Internet advertising.

The software is operated on the server of the controller, the data protection-sensitive log files are stored exclusively on this server.

The purpose of the Matomo component is the analysis of the visitor flows on our website. The controller uses the obtained data and information, inter alia, to evaluate the use of this website in order to compile online reports, which show the activities on our Internet pages.

Matomo sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, an analysis of the use of our website is enabled. With each call-up to one of the individual pages of this website, the Internet browser on the information technology system of the data subject is automatically through the Matomo component prompted to submit data for the purpose of online analysis to our server. During the course of this technical procedure, we obtain knowledge about personal information, such as the IP address of the data subject, which serves to understand the origin of visitors and clicks.

The cookie is used to store personal information, such as the access time, the location from which access was made, and the frequency of visits to our website. With each visit of our Internet pages, these personal data, including the IP address of the Internet access used by the data subject, are transferred to our server. These personal data will be stored by us. We do not forward this personal data to third parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the used Internet browser would also prevent Matomo from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Matomo may be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility of objecting to a collection of data relating to a use of this Internet site that are generated by Matomo as well as the processing of these data by Matomo and the chance to preclude any such. For this, the data subject must set a "Do Not Track" option in the browser.

With each setting of the opt-out cookie, however, there is the possibility that the websites of the controller are no longer fully usable for the data subject.

Further information and the applicable data protection provisions of Matomo may be retrieved under https://matomo.org/privacy/.


12. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.


13. Rights of the data subject

a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
• the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
• the existence of the right to lodge a complaint with a supervisory authority;
• where the personal data are not collected from the data subject, any available information as to their source;
• the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
• The data subject withdraws consent to which the processing is based according to point (a) of Article 6 (1) of the GDPR, or point (a) of Article 9 (2) of the GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Article 21 (1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (2) of the GDPR.
• The personal data have been unlawfully processed.
• The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data have been collected in relation to the offer of information society services referred to in Article 8 (1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Bowspirit Management GmbH, he or she may, at any time, contact any employee of the controller. An employee of Bowspirit Management GmbH shall promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to Article 17 (1) 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 other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the Bowspirit Management GmbH will arrange the necessary measures in individual cases.

e) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
• The data subject has objected to processing pursuant to Article 21 (1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Bowspirit Management GmbH, he or she may at any time contact any employee of the controller. The employee of the Bowspirit Management GmbH will arrange the restriction of the processing.

f) Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6 (1) of the GDPR or point (a) of Article 9 (2) of the GDPR, or on a contract pursuant to point (b) of Article 6 (1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20 (1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of the Bowspirit Management GmbH.

g) Right to object
Each data subject shall have the right granted by the European legislator 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 point (e) or (f) of Article 6 (1) of the GDPR. This also applies to profiling based on these provisions.

The Bowspirit Management GmbH shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If the Bowspirit Management GmbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Bowspirit Management GmbH to the processing for direct marketing purposes, the Bowspirit Management GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Bowspirit Management GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89 (1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of the Bowspirit Management GmbH. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the Bowspirit Management GmbH shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the Bowspirit Management GmbH.

i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the Bowspirit Management GmbH.


14. Registration on our website
The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address - assigned by the Internet service provider (ISP) and used by the data subject - date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.


15. Contact possibility via the website
The website of the Bowspirit Management GmbH contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address).

If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.


16. Request by e-mail, telephone or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

The processing of these data is based on Article 6 (1) lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases, the processing is based on your consent (Article 6 (1) lit. a GDPR) and/or on our legitimate interests (Article 6 (1) lit. f GDPR), since we have a legitimate interest in the effective processing of requests addressed to us.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.


17. Data protection for applications and the application procedures
The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).


18. Subscription to our newsletters
On the website of the Bowspirit Management GmbH, users are given the opportunity to subscribe to our enterprise's newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

The Bowspirit Management GmbH informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise's newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.

Brevo is the email marketing software used. This means your information is transmitted to Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany (hereinafter referred to as "Brevo"). Brevo is prohibited from selling your data and from using it for purposes other than sending email. Brevo is a certified German email marketing software provider, working in accordance with the European directive 95/46 (GDPR), as well as the German Federal Data Protection Act (BDSG). More info: https://www.brevo.com/information-for-email-recipients/


19. Newsletter-Tracking
The newsletter of the Bowspirit Management GmbH contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the Bowspirit Management GmbH may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. The Bowspirit Management GmbH automatically regards a withdrawal from the receipt of the newsletter as a revocation.


20. Mynewsdesk Newsroom
We use the services of Mynewsdesk AB, Rosenlundsgatan 40, 118 53 Stockholm, Sweden (hereinafter referred to as "Mynewsdesk") for our press and public relations work.

The cookie policy published by Mynewsdesk and available at https://www.mynewsdesk.com/about/terms-and-conditions/cookies and the overview of cookies used at https://www.mynewsdesk.com/com/about/terms-and-conditions/cookies/cookie-list provide information on the collection, processing and use of personal data by Mynewsdesk.

The privacy policy published by Mynewsdesk, which is available at https://www.mynewsdesk.com/about/terms-and-conditions/privacy_policy, and the privacy policy for users, which is available at https://www.mynewsdesk.com/about/terms-and-conditions/privacy_policy_contacts, discloses the collection, processing and use of personal data by Mynewsdesk.

The press releases of Bowspirit Management GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in e-mails sent in HTML-format to enable log file recording and analysis. This allows statistical evaluation of the success or failure of PR campaigns. Based on the embedded pixel-code, Bowspirit Management GmbH can recognize whether and when an e-mail was opened by a data subject and which links in the e-mail were called by the data subject.

Such personal data collected via the tracking pixels contained in the press releases are stored and evaluated by the controller for processing in order to optimise the dispatch of press releases and news and to adapt the content of messages even better to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects are entitled at any time to revoke the relevant separate declaration of consent given via the double opt-in procedure. After a revocation these personal data will be deleted by the controller for the processing. Bowspirit Management GmbH automatically interprets a deregistration from the receipt of press releases as a revocation.


20a. WhatsApp
To establish contact, the provider enables the customer, among other things, to make contact via the messenger service WhatsApp.

The operating company of WhatsApp is WhatsApp LLC, 1601 Willow Road, Menlo Park, California 94025, United States.
If a person lives in the European Region the controller is the WhatsApp Ireland Limited, c/o Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

When the user communicates with the provider via WhatsApp, both the provider and WhatsApp receive the mobile phone number of the user and the information that the user has contacted the provider.

The abovementioned data are also forwarded by WhatsApp to servers of their mother company Meta Platforms, Inc. in the United States and are processed by WhatsApp and Meta Platforms in accordance with the WhatsApp privacy policy, which also includes processing for their own purposes, such as improving the WhatsApp service.

In the opinion of the data protection supervisory authorities, however, the United States do not currently have an adequate level of data protection. However, there are so-called standard contractual clauses:

https://faq.whatsapp.com/general/about-standard-contractual-clauses

These are private law agreements, however, and therefore have no direct impact on the access options of the authorities in the United States.

More information about the purpose and scope of the data collection and the further processing of these data by WhatsApp and Meta Platforms as well as related rights and setting options for protecting privacy are contained in privacy guidelines from WhatsApp: https://www.whatsapp.com/legal/#privacy-policy.

The legal basis for this processing and the transmission to WhatsApp is Article 6 (1) lit. b GDPR, insofar as the establishment of contact relates to an existing contractual relationship or serves to initiate such a contractual relationship. If contact is not made for the above purposes, the legal basis is Article 6 (1) lit. f GDPR. The legitimate interest of the provider is to improve the quality of service.


20b. Broadcasting via WhatsApp Channels
You may subscribe to a broadcasting service of ours via the messenger service WhatsApp.

The operating company of WhatsApp is WhatsApp LLC, 1601 Willow Road, Menlo Park, California 94025, United States.
If a person lives in the European Region the controller is the WhatsApp Ireland Limited, c/o Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

Some of the user data is processed on WhatsApp servers or servers of their mother company Meta Platforms, Inc. in the United States. You can find WhatsApp's privacy policy at https://www.whatsapp.com/legal/#privacy-policy. Further privacy information on WhatsApp Channels can be found at https://www.whatsapp.com/legal/channels-privacy-policy respectively https://www.whatsapp.com/legal/channels-privacy-policy-eea.

To receive our broadcast via WhatsApp Channels, you need a WhatsApp user account. Details of what information WhatsApp collects when you register can be found in WhatsApp's aforementioned privacy policy.

If you subscribe to our channel on WhatsApp, the mobile phone number you entered during the registration process will be processed by WhatsApp. In addition, your IP address and the date and time of your registration will be stored.

The legal basis for the broadcast is Article 6 (1) lit. a GDPR.

You can revoke your consent to the broadcast at any time with effect for the future in accordance with Article 7 (3) GDPR. To do so, you only need to cancel the corresponding subscription to our channel in the WhatsApp app.

31. Data protection provisions about the use of the Spreadshirt-Shop
Our website links to our shop at the printing-on-demand provider Spreadshirt.

The company operating the services of Spreadshirt is sprd.net AG, Gießerstraße 27, 04229 Leipzig, Germany (hereinafter referred to as "Spreadshirt").

According to Article 4 GDPR, "processor" is anyone who processes personal data on behalf of the person responsible. "Controller" is on the other hand who decides on the purposes and means of data processing.
Within the Spreadshirt-Shop, Spreadshirt always decides on the purposes and means of processing, i.e. the shop functionalities.

We are only intermediaries for any orders placed there. The processing by Spreadshirt does not take place "on our behalf" either, but on the basis of their own legal relationship with the (potential) customers in the shop.

A transmission of the customer's IP address from us to Spreadshirt does not take place.
Rather, the IP address is collected by Spreadshirt itself when loading the shop, if necessary again and independently of the user's visit to our websites.

Spreadshirt's current data privacy policy is available at https://service.spreadshirt.com/hc/en-gb/articles/115000978409/?shop_name=bowspirit-kids-group&shop_id=100393512.


32. Data protection provisions about the use of the Art Heroes-Shop
Our website links to our shop at the printing-on-demand provider Art Heroes.

The company operating the services of Art Heroes is We Make It Work BV, Hendrik Figeeweg 3G-6, 2031 BJ Haarlem, Netherlands (hereinafter referred to as "Art Heroes").

According to Article 4 GDPR, "processor" is anyone who processes personal data on behalf of the person responsible. "Controller" is on the other hand who decides on the purposes and means of data processing.
Within the Art Heroes-Shop, Art Heroes always decides on the purposes and means of processing, i.e. the shop functionalities.

We are only intermediaries for any orders placed there. The processing by Art Heroes does not take place "on our behalf" either, but on the basis of their own legal relationship with the (potential) customers in the shop.

A transmission of the customer's IP address from us to Art Heroes does not take place.
Rather, the IP address is collected by Art Heroes itself when loading the shop, if necessary again and independently of the user's visit to our websites.

Art Heroes' current data privacy policy is available at https://www.artheroes.com/en/privacystatement-we-make-it-work-b-v-artheroes-1344420.


33. Legal basis for the processing
Article 6 (1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6 (1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Article 6 (1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Article 6 (1) lit. d GDPR. Finally, processing operations could be based on Article 6 (1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).


34. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6 (1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.


35. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.


36. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.


37. Note on data transfer to the United States and other third countries
Among other things, we use tools from companies based in the United States or other third countries that are not secure under data protection law. If these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that no level of data protection comparable to that in the European Union (EU) can be guaranteed in these countries.
For example, US companies are obliged to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. intelligence services) process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no influence on these processing activities.


38. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.


39. Supervisory authorities
You can complain to a supervisory authority at any time, e.g. to the competent supervisory authority of the (federal) state in which you live or to the authority responsible for us.

You can find a list of the supervisory authorities (for the non-public sector) and their addresses in Germany at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html


40. Change of our privacy policy
We reserve the right to adapt this privacy policy so that it always complies with the current legal requirements or in order to implement changes to our services in the privacy policy, e.g. when introducing new services. Your new visit will then be subject to the new privacy policy.