We are very
delighted that you have shown interest in our enterprise. Data protection is of
a particularly high priority for the management of the Schreibservice Alexandra
Pack. The use of the Internet pages of the Schreibservice Alexandra Pack is
possible without any indication of personal data; however, if a data subject
wants to use special enterprise services via our website, processing of
personal data could become necessary. If the processing of personal data is
necessary and there is no statutory basis for such processing, we generally
obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or
telephone number of a data subject shall always be in line with the General
Data Protection Regulation (GDPR), and in accordance with the country-specific
data protection regulations applicable to the Schreibservice Alexandra Pack. By
means of this data protection declaration, our enterprise would like to inform
the general public of the nature, scope, and purpose of the personal data we
collect, use and process. Furthermore, data subjects are informed, by means of
this data protection declaration, of the rights to which they are entitled.
As the controller, the Schreibservice Alexandra Pack has implemented numerous
technical and organizational measures to ensure the most complete protection of
personal data processed through this website. However, Internet-based data
transmissions may in principle have security gaps, so absolute protection may
not be guaranteed. For this reason, every data subject is free to transfer
personal data to us via alternative means, e.g. by telephone.
1. Definitions
The data protection declaration of the Schreibservice Alexandra Pack is based
on the terms used by the European legislator for the adoption of the General
Data Protection Regulation (GDPR). Our data protection declaration should be
legible and understandable for the general public, as well as our customers and
business partners. To ensure this, we would like to first explain the
terminology used.
In this data protection declaration, we use, inter alia, the following terms:
a) Personal data
Personal data means any information relating to an identified or identifiable
natural person (“data subject”). An identifiable natural person is one who can
be identified, directly or indirectly, in particular by reference to an identifier
such as a name, an identification number, location data, an online identifier
or to one or more factors specific to the physical, physiological, genetic,
mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person, whose personal
data is processed by the controller responsible for the processing.
c) Processing
Processing is any operation or set of operations which is performed on personal
data or on sets of personal data, whether or not by automated means, such as
collection, recording, organisation, structuring, storage, adaptation or
alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination,
restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim
of limiting their processing in the future.
e) Profiling
Profiling means any form of automated processing of personal data consisting of
the use of personal data to evaluate certain personal aspects relating to a
natural person, in particular to analyse or predict aspects concerning that
natural person's performance at work, economic situation, health, personal
preferences, interests, reliability, behaviour, location or movements.
f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the
personal data can no longer be attributed to a specific data subject without
the use of additional information, provided that such additional information is
kept separately and is subject to technical and organisational measures to
ensure that the personal data are not attributed to an identified or
identifiable natural person.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal
person, public authority, agency or other body which, alone or jointly with
others, determines the purposes and means of the processing of personal data;
where the purposes and means of such processing are determined by Union or
Member State law, the controller or the specific criteria for its nomination
may be provided for by Union or Member State law.
h) Processor
Processor is a natural or legal person, public authority, agency or other body
which processes personal data on behalf of the controller.
i) Recipient
Recipient is a natural or legal person, public authority, agency or another
body, to which the personal data are disclosed, whether a third party or not.
However, public authorities which may receive personal data in the framework of
a particular inquiry in accordance with Union or Member State law shall not be
regarded as recipients; the processing of those data by those public
authorities shall be in compliance with the applicable data protection rules
according to the purposes of the processing.
j) Third party
Third party is a natural or legal person, public authority, agency or body
other than the data subject, controller, processor and persons who, under the
direct authority of the controller or processor, are authorised to process
personal data.
k) Consent
Consent of the data subject is any freely given, specific, informed and
unambiguous indication of the data subject's wishes by which he or she, by a
statement or by a clear affirmative action, signifies agreement to the
processing of personal data relating to him or her.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR),
other data protection laws applicable in Member states of the European Union
and other provisions related to data protection is:
Schreibservice Alexandra Pack
Alter Steinweg 26
48143 Münster
Deutschland
Phone: 0251 - 4829367
Email: info@schreibservice-pack.eu
Website: www.schreibservice-pack.eu
3. Collection of general data and information
The website of the Schreibservice Alexandra Pack collects a series of general
data and information when a data subject or automated system calls up the
website. This general data and information are stored in the server log files.
Collected may be (1) the browser types and versions used, (2) the operating
system used by the accessing system, (3) the website from which an accessing
system reaches our website (so-called referrers), (4) the sub-websites, (5) the
date and time of access to the Internet site, (6) an Internet protocol address
(IP address), (7) the Internet service provider of the accessing system, and
(8) any other similar data and information that may be used in the event of
attacks on our information technology systems.
When using these general data and information, the Schreibservice Alexandra
Pack does not draw any conclusions about the data subject. Rather, this
information is needed to (1) deliver the content of our website correctly, (2)
optimize the content of our website as well as its advertisement, (3) ensure
the long-term viability of our information technology systems and website
technology, and (4) provide law enforcement authorities with the information
necessary for criminal prosecution in case of a cyber-attack. Therefore, the
Schreibservice Alexandra Pack analyzes anonymously collected data and
information statistically, with the aim of increasing the data protection and
data security of our enterprise, and to ensure an optimal level of protection
for the personal data we process. The anonymous data of the server log files
are stored separately from all personal data provided by a data subject.
4. Contact possibility via the website
The website of the Schreibservice Alexandra Pack 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.
5. 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.
6. 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 Schreibservice Alexandra
Pack, he or she may, at any time, contact any employee of the controller. An
employee of Schreibservice Alexandra Pack 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 employee of the Schreibservice Alexandra Pack
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
Schreibservice Alexandra Pack, he or she may at any time contact any employee
of the controller. The employee of the Schreibservice Alexandra Pack 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 Schreibservice Alexandra Pack.
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 Schreibservice Alexandra Pack 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 Schreibservice Alexandra Pack 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 Schreibservice Alexandra Pack to the
processing for direct marketing purposes, the Schreibservice Alexandra Pack
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 Schreibservice Alexandra Pack 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 Schreibservice Alexandra Pack. 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 Schreibservice Alexandra Pack 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 Schreibservice Alexandra Pack.
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 Schreibservice Alexandra
Pack.
7. 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).
8. Legal basis for the processing
Art. 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 Art. 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 Art. 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).
9. 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 favor of the well-being of
all our employees and the shareholders.
10. 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.
11. 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.
12. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
This Privacy Policy has been generated by the Privacy Policy Generator of the DGD -
Your External DPO
that was developed in cooperation with German Lawyers from WILDE BEUGER SOLMECKE,
Cologne.