Reinhild Schulte Guerra
Rua da República, 72
Types of processed data:
Purpose of data processing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, when they 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. cookie) or to one or more special features that express 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 goes far and includes virtually every handling of data.
“Responsible person” means the natural or legal person, public authority, body or other that decides, alone or in concert with others, 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. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing in order to perform our services, to execute contractual measures and to answer to inquiries is Art. 6 (1) lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, the legal basis will be Art. 6 para. 1 lit. d GDPR.
Collaboration with Contract Processors and Third Parties
If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR is necessary to fulfill the contract), or if you have consented, if it is a legal obligation or based on our legitimate interests (e.g. the use of agents, webhosters, etc.).
If we commission third parties to process data on the basis of a so-called “contract processing contract”, this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (ie outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or of disclosure or transmission of data to third parties, this will only be done if it is 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 have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. GDPR. That means the processing is done e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
Rights of data subjects
You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.
In Accordance with Art. 16 GDPR, you have he right to demand completion of the data concerning you or the correction of any incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.
You have the right to demand to receive the data relating to you which you have provided in accordance with Art. 20 GDPR and request their transmission to other responsible persons.
In accordance with 77 GDPR, you have the right to file a complaint with the competent supervisory authority.
You have the right to withdraw from any consent granted in accordance with. Art. 7 para. 3 GDPR with effect for the future.
Right to Object
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.
Cookies and the Right to Object against Direct Mail
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visiting a site. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart are stored in an online store, or a login status. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit the site after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for determination of reach or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, this is called “first-party cookies”).
If users do not want cookies stored on their computer, 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 offer.
Deletion of Data
According to legal requirements in Germany, some data must be stored for 6 years pursuant to § 257 paragraph 1 HGB (trading books, inventories, opening balance sheets, annual accounts, trade letters, accounting documents, etc.) and other for 10 years in accordance with § 147 Abs. 1 AO (books, records , management reports, accounting documents, trade and business letters, documents relevant to taxation, etc.).
According to legal regulations in Austria some data must be stored for 7 years according to § 132 paragraph 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.), or for 22 years if in connection with real estate and for 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is used.
In addition we process
of our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
The hosting services we use are for the purpose of providing the following services: infrastructure and platform services, computing capacity, storage and database services, security and technical maintenance services we use to operate this online service.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer based on our legitimate interests in an efficient and secure provision of this online offer according to Art. 6 para. 1 lit. f GDPR together with Art. 28 GDPR (conclusion of contract processing contract).
Collection of Access Data and Log Files
On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR we or our hosting provider collect data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider ,
Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.
We process the data of our customers, clients and interested parties (uniformly referred to as “customers”) in accordance with Art. 6 para. 1 lit. b. GDPR in order to provide them with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the respective contract. This includes in principle inventory and master data of the customer (name, address, etc.), as well as the contact data (e-mail address, telephone, etc.), the contract data (content of the commission, fees, terms, information about the companies / Insurers / services) and payment data (commissions, payment history, etc.). We may also process information about the characteristics and circumstances of persons or things belonging to them, if this is part of our contract. This can be for example information about personal circumstances, mobile or immovable property.
As part of our assignment, it may also be necessary for us to process special categories of data in accordance with Art. Art. 9 para. 1 GDPR, in particular information about the health of a person. For this we get an explicit consent of the customer if necessary, in accordance with Art. 6 (1) (a), Art. 7, Art. 9 (2) lit. a GDPR.
To the extent necessary for the fulfillment of the contract or as required by law, we disclose or transmit the data of customers in the context of coverage, conclusion and settlement of contracts to providers of brokered services / objects, insurers, reinsurers, brokerage pools, technical service providers, other service providers, such as cooperating associations as well as financial service providers, credit institutions and capital investment companies as well as social security funds, tax authorities, tax consultants, legal advisers, auditors, insurance arbitrators and the institution Federal Financial Supervisory Authority (BaFin). Furthermore, we can hire subcontractors, such as sub mediators. We obtain the consent of the customer if this is required for the disclosure / transmission of the data (which may be the case, for example, in the case of special categories of data pursuant to Art. 9 GDPR).
The data will be deleted after legal warranty and comparable obligations end, whereby the necessity of the storage of the data is checked every three years; otherwise the statutory storage obligations apply.
In the case of legal archiving obligations, the data will be deleted after its expiration.
Provision of contractual services
We process inventory data (e.g., names and addresses as well as contact information of users), contract data (e.g., services used, names of contacts, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. Art. 6 para. 1 lit b. GDPR. The entries marked as obligatory in online forms are required for the conclusion of the contract.
As part of the use of our online services, we store the IP address and the time of each user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A transfer of these data to third parties does not happen, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c GDPR.
We process usage data (e.g., the visited web pages of our online offering, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile to inform the user e.g. to display product offers based on their previously used services.
The deletion of the data happens after expiration of legal warranty and comparable obligations, the necessity of the storage of the data is checked every three years; in the case of legal archiving obligations, the data will be deleted after its term. Information in the customer’s account remains until the account is deleted.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks and organization of our business, financial accounting and compliance with legal obligations, such as archiving. We process the same data that we process in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose of and interest in processing lies in administration, financial accounting, office organization, data archiving, that is, tasks that serve to maintain our business, perform our duties and provide our services. The data will be deleted in accordance with contractual services and communication, see also the information provided under these processing activities.
We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors, and other tax agencies and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, event managers and other business partners, e.g. for later contact. We generally store this mostly company-related data permanently.
We process the applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. The processing of the applicant´s data takes place in order to fulfill our (pre-) contractual obligations in the context of the application process within the meaning of Art. 6 para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR if the data processing e.g. is required for us in the context of legal proceedings (in Germany, § 26 BDSG applies additionally).
The application process requires applicants to provide us with their data. The necessary applicant data are marked in our online form, otherwise result from the job descriptions and basically include the information on the person, postal and contact addresses and the application documents, such as application letter, CV and the certificates. Also, applicants can voluntarily provide us with additional information.
Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily communicated within the framework of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b GDPR (e.g., health information such as disability or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the context of the application procedure, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (for example health data, if necessary for the profession).
If provided, applicants can submit their applications to us via an online form on our website. The data will be encrypted according to the state of the art and transmitted to us.
Furthermore, applicants can send us their applications via e-mail. However, please note that e-mails are generally not sent in encrypted form and that applicants themselves must provide encryption. We can therefore take no responsibility for the transmission of the application between the sender and the reception on our server and therefore recommend rather to use an online form or the postal delivery. Instead of applying via the online form and e-mail, applicants still have the opportunity to send us the application by post.
The data provided by the applicants may be further processed by us in the event of a successful application for employment purposes. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to at any time.
Unless the candidate withdraws legally, the data is deleted after a period of six months, so that we can answer any follow-up questions to the application and meet our obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with the tax regulations.
When contacting us (for example by contact form, e-mail, telephone or via social media) we process the information of the user to answer the contact request in accordance with. Art. 6 para. 1 lit. b) GDPR. User information can be stored in a Customer Relationship Management System (“CRM System”) or a comparable request file.
We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, the legal archiving obligations apply.
In the following we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described to obtain the customers consent, the consent of the user applies only to this tzpe of newsletter. Incidentally, our newsletter contains information about our services and us.
Double opt-in and logging: Registration for our newsletter is done in a so-called double-opt-in procedure. That means after registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.
Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.
Germany: The dispatch of the newsletter and the associated performance assessment is based on the consent of the recipient in accordance with Art. 6 para. 1 lit. a, Art. 7 GDPR in connection with § 7 Abs. 2 Nr. 3 UWG or on the basis of the legal permission according to Art. § 7 Abs. 3 UWG.
The logging of the registration process is based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. Our interest lies in the use of a user-friendly and secure newsletter system, which serves both our business interests and the expectations of the users and also allows us to prove your consent.
Termination / Revocation – You may terminate the receipt of our newsletter at any time, ie. revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may save the submitted email addresses for up to three years based on our legitimate interests before we delete them to prove prior consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
Newsletter – Shipping Service Provider
The shipping service provider may use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimize or improve their own services, e.g. for the technical optimization of shipping and the presentation of newsletters or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to address them themselves or to pass the data on to third parties.
Newsletter – Success Assessment
The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the server when opening the newsletter from our server, or if we use a shipping service provider, from their server. This beacon will initially collect technical information, such as information about the browser and your system, as well as your IP address and time of retrieval.
This information is used to improve the technical performance of services based on their specifications or audience and their reading habits, based on their locations (which can be determined using the IP address) or access times. Statistical surveys also include determining if the newsletters will be opened, when they will be opened and which links will be clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our goal nor, if used, that of the shipping service provider to observe individual users. The evaluations serve instead to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
Google Universal Analytics
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
We use Google Analytics in the design as “Universal Analytics”. “Universal Analytics” means a process of Google Analytics, in which the user analysis is based on a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from the use of different devices (so-called “cross-device tracking”).
We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to its use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: http: // tools .google.com / dlpage / gaoptout? hl = de.
As an alternative to the browser add-on or in browsers on mobile devices, please click this link to prevent the future detection by Google Analytics within this website: Analytics-Opt-Out. An opt-out cookie is stored on your device. If you delete your cookies, you must click this link again.
The personal data of users will be deleted or anonymised after 14 months.
Google Marketing and Remarketing Services
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR) we use the marketing and remarketing services (“Google Marketing Services “), LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, (” Google “).
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google Marketing Services allows us to better target advertisements for and on our website so that we only present ads to users that potentially match their interests. If a user e.g. is shown ads for products he’s been interested in on other websites is called remarketing.
For these purposes, when Google and other websites using Google Marketing Services are accessed, a code will be executed by Google and so-called (re) marketing tags (invisible graphics or code, also called “web beacons “) will be incorporated into the website. With their help, the user is provided with an individual cookie, i.e. a small file is saved (instead of cookies, comparable technologies can also be used). The cookies can be set by different domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. In this file is noted which web pages the user visited, which content interested him/her and which offers he/she has clicked, as well as technical information about the browser and operating system, referring web pages, visit time and other information on the use of the online offer. The IP address of the users is also recorded, in the case of Google Analytics, the IP address is shortened in member states of the European Union or other parties to the Agreement on the European Economic Area and only in exceptional cases is transmitted to a Google server in the US and shortened there. The IP address will not be merged with data of the user within other offers from Google. The above information may also be linked by Google with such information from other sources. If the user then visits other websites, ads tailored to him/her can be displayed according to his/her interests.
The data of the users are pseudonym processed in the context of the Google marketing services. That means Google stores and processes e.g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. That means from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner might be. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users through Google Marketing Services is transmitted to Google and stored on Google’s servers in the United States.
One of the Google marketing services we use is the online advertising program “Google AdWords”. In the case of Google AdWords, each advertiser receives a different “conversion cookie”. Therefore, cookies can not be tracked through AdWords advertisers’ websites. The information collected through the cookie is used to generate conversion statistics for AdWords advertiser who have opted for conversion tracking. Advertisers will see the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, they do not receive information that personally identifies users.
In addition, we may use the “Google Tag Manager” to integrate and manage the Google Analytics and Marketing Services on our website.
If you wish to opt-out of interest-based advertising through Google Marketing Services, you can take advantage of Google’s settings and opt-out options: http://www.google.com/ads/preferences.
Click here to opt out of Google Tag Manager tracking.
Integration of Services and Contents of Third Parties
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer according to Art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to integrate their content and services, such as videos or fonts (collectively referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the users, 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. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also 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 among other technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer. This information can also be connected to similar information from other sources.