Responsible for the content
Salvador Paydar Escobar
80807 Munich, Bavaria
Sales tax identification number according to §27a sales tax law: 146/126/50161
Umsatzsteuer-Identifikationsnummer gemäß §27a Umsatzsteuergesetz: 146/126/50161
Types of processed data
– Master Data (e.g. personal master data, names or addresses)
– Contact Data (e.g. e-mail, telephone numbers)
– Content Data (e.g. text input)
– Usage Data (e.g. interest in content)
– Communication Data (e.g. device data Information)
Purpose of processing
– Provision of the online service, its functions and contents
– Answering of contact requests and communication with users
– Security measures
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, if it can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. Cookies) or to one or more special features, which are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
“Processing” means any process performed with or without the aid of automated procedures, or any such process associated with personal data. The term covers a wide range and covers practically every handling of data.
“Responsible person” means the natural or legal person, public authority, body or body which, alone or in concert with others, decides on the purposes and means of processing personal data.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, if the legal basis in the data protection declaration is not mentioned, the following applies: The legal basis for obtaining consent is Article 6 para. 1 lit. a and Art. 7 GDPR; The legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 para. 1 lit. b GDPR; The legal basis for processing in order to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR; In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR conduces as legal basis; The legal basis for the processing required to carry out a task in the public interest or in the exercise of official authority which has been delegated to the controller is Article 6 para. 1 lit. e GDPR; The legal basis for processing in order to safeguard our legitimate interests is Article 6 para. 1 lit. f GDPR; The processing of data for purposes other than those for which they were collected is governed by the provisions of Article 6 para. 4 GDPR; The processing of special categories of data (pursuant to Art. 9 para. 1 GDPR) is governed by the provisions of Art. 9 para. 2 GDPR.
We will take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing and the different likelihood and severity of the risk to the rights and freedoms of individuals to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and disconnection. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings.
Collaboration with contract processors, joint controllers and third parties
If in the context of our processing, we disclose data to other persons and companies, transmit to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if the data has been transmitted to third parties, such as payment service providers, to fulfill the contract), users have consented to a legal obligation to do so or on the basis of our legitimate interests.
Rights of data subjects
You have the right to ask for confirmation as to whether such data is being processed and for information about this data, as well as for further information and copy of the data in accordance with legal requirements.
You have the right, in accordance with the legal requirements, to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with the legal requirements, you have the right to demand that the relevant data be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with the statutory provisions.
Right of withdrawal
You have the right to revoke granted consent with effect for the future.
Right of objection
You may object to the future processing of your data in accordance with legal requirements at any time
“Cookies” are small files that are stored on the users’ computers. Different information can be stored within the cookies. A cookie serves primarily to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online service. Temporary cookies, or “session cookies”, are cookies that are deleted after a user leaves an online service and closes their browser. “Persistent” or “persistent” refers to cookies that remain stored even after the browser has been closed. In such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person responsible for providing the online service.
If users do not want cookies stored on their computer or device, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online service.
Deletion of data
Unless the data is deleted because it is required for other and legally permitted purposes, its processing will be restricted. I.e. that the data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.
We process our clients’ data as part of our contractual services that include conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, campaign / process / handling implementation, server administration, data analysis / consulting services, and training services.
Here we process stock data (e.g. customer master data, such as names or addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos), contract data (e.g. subject matter, term), payment data (e.g. Bank details, payment history), usage and metadata (e.g. as part of the evaluation and success measurement of marketing measures). In principle, we do not process special categories of personal data, unless these are components of a commissioned processing. Those data subjects include our customers, prospects and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contract services, billing and our customer service. The legal basis for processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data necessary for the establishment and performance of the contractual services and indicate the necessity of their information. Disclosure to external parties will only be made if required by an order. In the processing of the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as the legal requirements of a order processing acc. Art. 28 GDPR and process the data for no other purpose than the order.
We delete the data after expiration of legal warranty and comparable obligations. The necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiry (6 years, pursuant to § 257 para. 1 German Commercial Code (Handelsgesetzbuch)., 10 years, in accordance with § 147 para. 1 AO). In the case of data disclosed to us in the context of an order by the client, we delete the data according to the specifications of the order, in principle after the end of the order.
Our online service uses the “Akismet” service offered by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. The use is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR. With the help of this service, comments of real people are distinguished from spam comments. All comment information is sent to a server in the US, where it is analyzed and stored for four days for comparison. If a comment has been classified as spam, the data will be stored beyond that time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, details of the browser used, the computer system and the time of the entry.
When contacting us (e.g. by contact form, email, telephone or via social media), the information of the user to process the contact request and their processing acc. Art. 6 para. 1 lit. b (in the context of contractual / pre-contractual relationships), Art. 6 para. 1 lit. f (other inquiries) GDPR will be processed. User information can be stored in a Customer Relationship Management System (“CRM System”) or comparable request organization.
Hosting and Emailing
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mail delivery, security and technical maintenance services we use to operate this online service.
We process our hosting provider, inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in an efficient and secure provision of this online service acc. Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR.
We maintain online presence within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services.
We point out that data of the users outside the area of the European Union can be processed. This may result in risks to users because, e.g. the enforcement of user rights could be made more difficult. With respect to US providers certified under the Privacy Shield, we point out that they are committed to respecting EU privacy standards.
Furthermore, the data of the users are usually processed for market research and advertising purposes. Thus, e.g. user profiles are created from the user behavior and the resulting interests of the users. The usage profiles may in turn be used to e.g. Place advertisements inside and outside the platforms that are allegedly in line with users’ interests. For these purposes, cookies are usually stored on the computers of the users, in which the user behavior and the interests of the users are stored. Furthermore, in the usage profiles, data can also be stored independently of the devices used by the users (in particular if the users are members of the respective platforms and logged in to them).
The processing of personal data of users is based on our legitimate interests in an effective information of users and communication with users in accordance with. Art. 6 para. 1 lit. f GDPR. If the users are asked by the respective providers of the platforms for a consent to the above-described data processing, the legal basis of the processing is Art. 6 para. 1 lit. a, Art. 7 GDPR.
For a detailed description of the respective processing and the possibilities of contradiction (opt-out), we refer to the following linked information of the provider.
Also in the case of requests for information and the assertion of user rights, we point out that these can be claimed most effectively from the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information.
This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information, such as visitor traffic, on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, time of visit, and other information regarding the use of our online service.
Usage of Facebook social plugins
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online service within the meaning of Art. 6 para. 1 lit f GDPR) we use social plugins (“plugins”) of the social network facebook.com, which are operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). Content such as pictures, videos or text and buttons belong, with which users can share contents of this online service within Facebook. The list and the look of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement, providing a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user invokes a feature of this online service that includes such a plugin, their device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the device of the user and incorporated by him into the online service. In the process, user profiles of the processed data can be created. Therefore, we have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore informs users according to our knowledge.
By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online service. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example, pressing the Like button or leaving a comment, the information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save their IP address. According to Facebook, only an anonymous IP address is stored in Germany.
If a user is a Facebook member and does not want Facebook to collect data about him via this online service and link it to his member data stored on Facebook, he must log out of Facebook and delete his cookies before using our online service. Other settings and inconsistencies regarding the use of data for promotional purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US side http://www.aboutads.info/choices/ or the EU side http://www.youronlinechoices.com/. The settings are platform independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.