PRIVACY POLICY

I.  Name and address of the person responsible

The person responsible within the meaning of the Basic Data Protection Regulation and other national data protection laws of the Member States and other provisions of data protection law is the:

Sandmaster GmbH
Mr. Christoph Mayer-Klenk, management
Heinrich-Otto-Straße 22
73240 Wendlingen am Neckar
Germany
Phone +49 (0)7024 805 90 0
Fax +49 (0)7024 805 90 20
Email info@sandmaster.de

 

II.  Name and address of the Data Protection Officer

The data protection officer of the responsible person is:

stratego IT management GmbH
Mr. Udo Noller
Hofäckerstraße 32
74374 Zaberfeld
Germany
Phone +49 (0)7024 805 90 46
Email  datenschutz@sandmaster.de

 

III.  general information on data processing

1. the scope of processing of personal data

 As a matter of principle, we process personal data of our users only to the extent necessary to provide a functional website and our contents and services. The processing of personal data of our users regularly only takes place with the user’s consent. An exception is made in those cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by legal regulations.

 

2. legal basis for the processing of personal data

 Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 sentence 1 lit. a of the EU Basic Data Protection Regulation (DSGVO) serves as the legal basis.

In the processing of personal data necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 sentence 1 letter b FADP serves as the leal basis. This also applies to processing operations which are necessary to carry out pre-contractual measures.

Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 sentence 1 lit. c DSGVO serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 sentence 1 lit. d FADP serves as the legal basis.

If the processing is necessary to safeguard a legitimate interest of our company or of a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 sentence 1 letter f DSGVO serves as the legal basis for the processing.

 

3. data erasure and storage duration

The personal data of the person concerned will be deleted or blocked as soon as the purpose of the storage no longer applies. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other regulations to which the person responsible is subject. Data will also be blocked or deleted when a storage period prescribed by the above-mentioned standards expires, unless there is a need to continue storing the data for the purpose of concluding or fulfilling a contract.

 

IV.  Rights of the data subject

If personal data are processed by you, you are the data subject within the meaning of the DSGVO and you are entitled to the following rights in relation to the person responsible:

 

1. Right of information

1. you can request confirmation from the person responsible as to whether personal data concerning you is being processed by us

If such processing is carried out, you may ask the controller for information on: 1. the purposes for which the personal data are processed;

2. the categories of personal data being processed;
3. the recipients or categories of recipients to whom the personal data concerning you have been disclosed are still being disclosed;
4. the existence of a

right of appeal to a supervisory authority;

7. all available information on the origin of the data if the personal data are not collected from the data subject;
8. the existence of automated decision-making, including profiling in accordance with Article 22 (1) and (4) FADP, and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 DPA in connection with the

 

2.  right of rectification

You have the right to ask the data controller to correct and/or complete the data if the personal data processed concerning you is incorrect or incomplete. The data controller shall make the correction without delay.

 

3.  right to restrict processing

 Under the following conditions, you may request the restriction of the processing of personal data concerning you:

• if you dispute the accuracy of the personal data concerning you for a period of time that allows the person responsible to verify the accuracy of the personal data;
• the processing is unlawful and you object to the deletion of the personal data and request instead the restriction of the use of

the personal data;

• the controller no longer needs the personal data for the purposes of the processing, but you

need it in order to

exercise or defend your rights, or

• if you have lodged an objection to the processing pursuant to Art. 21 para. 1 DPA and it has not yet been established whether the legitimate reasons of the controller outweigh

your reasons.

If the processing of personal data relating to you has been restricted, such data may be processed, with the exception of storage, only with your consent or for the purpose of pursuing, exercising or defending legal claims or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or of a Member State. If the restriction on processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

 

4.  right of cancellation

1. Duty to delete

You may request the controller to delete personal data concerning you without delay and the controller is obliged to delete such data without delay if one of the following reasons applies:

1. the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed

2. you revoke your consent on which the processing was based pursuant to Art. 6 para. 1 sentence 1 lit. a or Art. 9 para. 2 lit. a FADP, and there is no other legal basis for the processing.

3. you lodge an objection to the processing pursuant to Art. 21(1) DPA and there are no legitimate grounds for processing that take precedence, or you lodge an objection to the processing pursuant to Art. 21(2)

4. the personal data concerning you have been processed unlawfully

5. deletion of the personal data concerning you is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject

6. the personal data concerning you have been collected in relation to information society services offered, in accordance with Art. 8 para. 1 DSGVO

 

1. Information to third parties

If the data controller has made public the personal data concerning you and is obliged to delete them pursuant to Art. 17 para. 1 DPA, he shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform data controllers who process the personal data that you, as a data subject, have requested them to delete all links to these personal data or copies or replications of these personal data.

(c) Exceptions

The right of cancellation does not exist insofar as the processing is necessary

1. for the exercise of the right to freedom of expression and information;
2. to comply with a legal obligation requiring

processing under Union or national law to which the controller is subject,

or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;

3. for reasons of public interest relating to public health pursuant to Art. 9 para. 2 lit. h and i as well as Art. 9 para. 3 DSGVO;
4. for archiving, scientific or historical research purposes in the public interest or for statistical purposes in accordance with Art. 89 para. 1DSGVO, insofar as the right referred to in section a) is likely to render impossible or seriously prejudice the attainment of the objectives of such processing, or. to assert, exercise or defend legal claims.

 

5.  right to information

If you have asserted the right to rectify, erase or limit the processing vis-à-vis the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification, erasure or limitation of processing, unless this proves impossible or involves a disproportionate effort. You have the right vis-à-vis the controller to be informed of these recipients.

 

6.  right to data transferability

You have the right to receive the personal data concerning you that you have provided to the data controller in a structured, common and machine-readable format. You also have the right to have this data communicated to another person in charge without interference from the person in charge to whom the personal data has been communicated, provided that

1. the processing is based on a consent pursuant to Art. 6 para. 1 sentence 1 letter a DSGVO or Art. 9 para. 2 letter a DSGVO or on a contract pursuant to Art. 6 para. 1 sentence 1 letter b DSGVO and. the processing is carried out by means of automated procedures. In exercising this right, you also have the right to request that personal data relating to you be transferred directly from one responsible party to another, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this. The right to data transferability shall not apply to processing of personal data which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

 

7. right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is carried out pursuant to Article 6 paragraph 1 sentence 1 letter e or f FADP; this also applies to profiling based on these provisions.

The controller shall no longer process the personal data concerning you, unless he can demonstrate compelling reasons for processing which are justified on grounds of protection of your interests, rights and freedoms, or if the processing serves to assert, exercise or defend legal claims. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including

profiling, insofar as it is related to such direct marketing. If you object to processing for the purposes of direct marketing, the personal data concerning you will no longer be processed for those purposes. You have the possibility to exercise your right of objection in relation to the use of information society services, without prejudice to Directive 2002/58/EC, by means of automated procedures using technical specifications.

8th right to revoke the data protection declaration of consent You have the right to revoke your data protection declaration of consent at any time. Revocation of consent does not affect the legality of the processing that has taken place on the basis of the consent until revocation.

You have the right not to be subject to a decision based solely on automated processing, including profiling, that has legal effect on you or significantly affects you in a similar manner. This shall not apply if the decision

1. is necessary for the conclusion or fulfilment of a contract between you and the person responsible

2. is authorised by Union law or by the law of the Member States to which the person responsible is subject and that law

contains appropriate

measures to safeguard your rights and freedoms and your legitimate interests; or

3. with your express consent. However, these decisions may not be based on special categories of personal data

pursuant to Art. 9 para. 1 DSGVO, unless Art. 9 para. 2 lit. a or g DSGVO applies and appropriate measures have been taken to protect rights and freedoms and your legitimate interests.

With regard to the cases referred to in (1) and (3), the responsible person shall take appropriate measures to safeguard the rights and freedoms and your legitimate interests, which shall include at least the right to obtain the intervention of any person from the responsible person, to express his or her point of view and to challenge the decision.

 

10. right of appeal to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State in which you are resident, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you is in breach of the DPA.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and the results of the complaint, including the possibility of a judicial remedy under Art. 78 DSGVO.

 

V.  Provision of the website and creation of log files

 

1. description and scope of data processing

 

Whenever our website is called up, our system automatically collects data and information from the computer system of the calling computer.

The following data is collected:

• Information about the browser type and version used
• The user’s operating system
• The Internet service provider of the user
• Date and time of access
• Websites from which the user’s system accesses our website

The data is also stored in the log files of our system. Not affected by this are the IP addresses of the user or other data that allow the data to be assigned to a user. This data is not stored together with other personal data of the user.

2 Legal basis for data processingThe legal basis

for the temporary storage of data is Art. 6 para. 1 sentence 1 letter f DSGVO.

3. purpose of data processingThe

temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session. These purposes also include our legitimate interest in data processing in accordance with Art. 6 Para. 1 S. 1 lit. f DSGVO.

4. duration of storageThe

data will be deleted as soon as they are no longer required for the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session is ended.

5. possibility of objection and removalThe

collection of the data for the provision of the website and the storage of the data in log files is mandatory for the operation of the website. There is therefore no possibility of objection on the part of the user.

 

VI.  use of cookies

1. description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. If a user calls up a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. We use cookies to make our website more user-friendly. Some elements of our website require the calling browser to be able to be identified even after a page change.

The following data is stored and transmitted in the cookies:

• Language

settingsIn addition, we

use cookies on our website which enable an analysis of the surfing behaviour of the users. In this way the following data can be transmitted:

• Entered search terms
• Frequency of page viewsThe

user data collected in this way is pseudonymised by technical precautions. It is therefore no longer possible to assign the data to the calling user. The data is not stored together with other personal data of the users.

When accessing our website, users are informed by an info banner about the use of cookies for analysis purposes and are referred to this data protection declaration. In this context, a reference is also made to how the storage of cookies can be prevented in the browser settings.

When calling up our website, the user is informed about the use of cookies for analysis purposes and his consent to the processing of the personal data used in this context is obtained. In this context, reference is also made to this data protection declaration.

 

2.  legal basis for the data processing

 The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 sentence 1 lit. f DSGVO.

The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 sentence 1 lit. a DSGVO if the user has given his consent to this.

 

3.  purpose of the data processing

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these it is necessary that the browser is recognized even after a change of page.

We require cookies for the following applications:

• Transfer of language settings
• Memorizing search terms

The user data collected through technically necessary cookies is not used to create user profiles.

The analysis cookies are used for the purpose of improving the quality of our website and its contents. The analysis cookies tell us how the website is used and enable us to constantly optimise our offer.

Improving the content and quality of our website

These purposes also include our legitimate interest in the processing of personal data in accordance with Art. 6 para. 1 sentence 1 lit. f DSGVO.

 

4.  duration of storage, objection and removal possibility

Cookies are stored on the user’s computer and transmitted by the user to our site. Therefore you as a user have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Already stored cookies can be deleted at any time. This can also be done automatically. If cookies for our website are deactivated, it may not be possible to use all the functions of the website to their full extent.

 

VII.  contact form and email contact

1. description and scope of data processing

On our website there is a contact form which can be used for electronic contact. If a user takes advantage of this possibility, the data entered in the input mask is transmitted to us and stored.

At the time the message is sent, the following data is also stored:

• email address
• Name
• First name
• Address
• Telephone/mobile phone number
• Date and time of registration

For the processing of the data, your consent will be obtained during the sending process and reference will be made to this privacy policy.

Alternatively, it is possible to contact us via the provided email address. In this case the personal data of the user transmitted with the email will be stored. In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation.

 

2.  legal basis for the data processing

The legal basis for the processing of the data is Art. 6 para. 1 sentence 1 lit. a DSGVO if the user has given his consent.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 sentence 1 letter f DSGVO. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for processing is Art. 6 para. 1 sentence 1 lit. b DSGVO.

 

3.  purpose of the data processing

The processing of the personal data from the input mask serves us only for the processing of the establishment of contact. In the case of contacting us by email, this is also the necessary legitimate interest in the processing of the data.

The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

 

4.  duration of storage 

The data will be deleted as soon as they are no longer necessary for the purpose for which they were collected. For the personal data from the input mask of the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is finished when it can be concluded from the circumstances that the matter in question has been finally clarified. The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

 

5.  possibility of opposition and removal 

The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time. In such a case the conversation cannot be continued. All personal data stored in the course of the contact will be deleted in this case.

 

VIII Plugins used

Use of Google AdWords

1. scope of processing of personal data

We use Google AdWords of Google Inc, 1600 Amphiteatre Parkway, Mountain View, CA 94043, United States on our website. This is an online advertising program where conversion tracking is used. When you come to our website through a Google ad, Google AdWords places a cookie on your computer. Each Google AdWords client is assigned a different cookie.

2. legal basis for the processing of personal data

The legal basis for the processing is Article 6 paragraph 1 sentence 1 lit. f DSGVO.

3. purpose of data processing

We only get knowledge about the total number of users who have reacted to our advertisement. No information is passed on with which we could identify you. The use is not for tracking purposes.

4. duration of storage

The cookie loses its validity after 30 days.

5. possibility of objection and removal

You can stop Google conversion tracking by deactivating the tracking procedure in your browser. You can find more information at https://www.google.com/intl/de/policies/privacy/ .

 

Use of Google Analytics Remarketing (also Google Dynamic Remarketing)

1. scope of processing of personal data

We use the remarketing function Google Inc, 1600 Amphiteatre Parkway, Mountain View, CA 94043, United States on our website. Together with Google, we offer you suitable and interest-related advertisements. Google Analytics Remarketing uses cookies. These are stored

on your computer. According to the information provided by Google, no personal data is collected. There is also no connection to the other Google services according to our own information.

2.  legal basis for the processing of personal data

The legal basis for the processing is Article 6 paragraph 1 sentence 1 lit. f DSGVO.

3.  purpose of data processing

The purpose of processing personal data is to address a target group. The cookies stored on your computer recognise you when you visit a website and can therefore display advertising that is in line with your interests.

4.  the duration of the storage of advertising data

in server logs is made anonymous by Google deleting parts of the IP address and cookie information after 9 or 18 months according to its own information.

5.  possibility of objection and removal

You can prevent the use of the remarketing function by setting the following link: https://http://www.google.de/settings/ads . You can find more detailed information on https://www.google.com/intl/de/policies/privacy/ .

 

Use of Google Maps Plugin 

1. scope of processing of personal data

We use the online map service Google Maps of Google Inc, 1600 Amphiteatre Parkway, Mountain View, CA 94043, United States on our website. By using Google Maps on our website, information about the use of our website, your IP address and addresses entered in the route planning function are transmitted to a Google server in the USA and stored there. By using our website, you agree to the processing of your data collected by Google Maps.

2.  legal basis for the processing of personal data

The legal basis for the processing is Article 6 paragraph 1 sentence 1 letter f of the DPA.

3. purpose of data processing

We have neither knowledge of the purpose of data collection, nor of the use of the data by Google.

4.  duration of storage

No information is available to us about the duration of storage.

5.  possibility of objection and removal

For further information, please visit https://www.google.com/intl/de/policies/privacy/ .

 

This privacy policy was created with the assistance of DataGuard.