1. Name and contact details of the person responsible for processing and the company data protection officer
Pohlmann & Company – Compliance and Governance Advisory LLP, Guiollettstrasse 48, 60325 Frankfurt am Main, Germany.
Pohlmann & Company – Rechtsanwälte LLP, Guiollettstrasse 48, 60325 Frankfurt am Main, Germany.
This privacy statement is valid for data processing by all the sites of the companies named above in the scope of the General Data Protection Regulation (Datenschutz-Grundverordnung – DSGVO).
The company data protection officer for both companies is:
Attorney at law Dr. Jochen Notholt
Tel.: +49 (0)89 41614295-2
2. Collection and storage of personal data; types of data; purpose of the processing
a) When visiting our website
When you visit our website www.pohlmann.company.com, the browser used on your end device automatically sends information to the server of our website. This information is temporarily stored in a log file. The following information is collected without any action on your part and stored until it is automatically erased:
- IP address of the inquiring computer,
- date and time of access,
- name and URL of the accessed file,
- website from which access is made (referrer URL),
- browser used and possibly the operating system of your computer as well as the name of your access provider.
We process the indicated data for the following purposes:
- to ensure a smooth connection to our website,
- to ensure a convenient use of our website,
- to evaluate system security and stability and
- for other administrative purposes.
b) When registering for our newsletter
Provided you have given your express consent thereto pursuant to Art. 6 paragraph 1 sentence 1 lit. a GDPR, we use your email address to send our newsletter to you on a regular basis. The provision of an email address is sufficient in order to receive the newsletter. Additional voluntary particulars serve merely to personalise the newsletter. You may unsubscribe from the newsletter at any time, for example via the link shown at the end of every newsletter. Alternatively, you can also send your request to unsubscribe to email@example.com at any time by e-mail.
We use the Google reCaptcha service to determine whether a person or computer makes a particular entry in our newsletter form. Google uses the following data to determine whether you are a human being or a computer: IP address of the terminal device used, the website that you visit on our site and on which the captcha is embedded, the date and duration of the visit, the identification data of the browser and operating system type used, Google account if you are logged in to Google, mouse movements on the reCaptcha areas and tasks for which you must identify images. The legal basis for the data processing described is Art. 6 Para. 1 lit. f Basic Data Protection Regulation. There is a legitimate interest on our part in this data processing to ensure the security of our website and to protect us from automated entries (attacks).
3. Disclosure of data
Your personal data are not transmitted to third parties for purposes other than for those listed below. We forward your personal data to third parties only if:
- you have given your express consent thereto pursuant to Art. 6 paragraph 1 sentence 1 lit. a GDPR,
- disclosing your personal data is necessary pursuant to Art. 6 paragraph 1 sentence 1 lit. f GDPR in order to assert, exercise or defend legal claims and there is no reason to assume that you have an interest in the non-disclosure of your data which requires protection and overrides our interests,
- in the event that disclosure is necessary pursuant to Art. 6 paragraph 1 sentence 1 lit. c GDPR for compliance with a legal obligation or
- this is legally admissible and pursuant to Art. 6 paragraph 1 sentence 1 lit. b GDPR is necessary for the performance of contracts with you.
5. Analytical and tracking tools (Google Analytics)
The tracking measures that we use and have listed below are carried out on the basis of Art. 6 paragraph 1 sentence 1 lit. f GDPR. Through the tracking measures used we wish to ensure a needs-based design and continuous optimisation of our website. On the other hand, we use tracking measures to compile statistics on the use of our website and evaluate these in order to optimise our website for you. These interests are to be considered legitimate within the meaning of the provision indicated above. The respective data processing purposes and data categories can be seen from the respective tracking tools.
For the purpose of the needs-based design and continuous optimisation of our webpages, we use Google Analytics, a web analysis service of Google Inc. (https://www.google.de/intl/en/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter: “Google”). Pseudonymised user profiles are created and cookies used in this connection (see under No. 4). The information generated by the cookie pertaining to your use of this website such as
- browser type/version,
- operating system used,
- referrer URL (the pages visited beforehand),
- host name of the accessing computer (IP address),
- time of the server request,
are transferred to a Google server in the USA and stored there. The information is used to evaluate the use of our website in order to compile reports on website activities and to provide further services associated with website use and use of the Internet for the purposes of market research and the needs-based design of these webpages. This information is also transmitted to third parties where required by law or if third parties process these data as commissioned data processors. In no instance will your IP address be combined with other data of Google. The IP addresses are anonymised so that allocation to any particular person is not possible (IP masking). You can prevent the installation of cookies by entering an appropriate setting in your browser software. However, we point out that in this case, it might not be possible to fully use all the functions of this website. In addition, you can prevent the collection of the data generated by the cookie related to your use of the website (incl.your IP address) and the processing of these data by Google by downloading and installing a browser add-on (https:// tools.google.com/dlpage/gaoptout?hl=en). Alternatively to the browser add-on, particularly in the case of browsers on mobile end devices, you can prevent the collection of data by Google Analytics by clicking on this link. An opt-out cookie is placed that prevents the collection of your data when you visit this website in the future. The opt-out cookie is valid only in this browser and only for our website and is stored on your device. If you delete the cookies in this browser, you will be required to install the opt-out cookie again. Further information on data protection in connection with Google Analytics is provided in the Google Analytics Help for instance (https://support.google.com/analytics/answer/6004245?hl=en).
6. Rights of the data subject
You have the right:
- under Art. 15 GDPR to demand information on the personal data on you that we process. In particular, you may demand information on the purposes of processing, the category of personal data concerned, the categories of recipients to whom the personal data have been or will be disclosed, the envisaged period of storage, the existence of a right to rectification, deletion, restriction of processing or objection, the existence of a right to lodge a complaint, the source of the data if these were not collected by us and on the existence of automated decision-making including profiling and any meaningful information about the logic involved;
- under Art. 16 GDPR to demand the immediate rectification of inaccurate personal data or the completion of incomplete personal data that we have stored on you;
- under Art. 17 GDPR to demand the deletion of the personal that we have stored on you, unless processing is necessary to exercise the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims;
- under Art. 18 GDPR to demand the restriction of the processing of your personal data if you contest the accuracy of the data, the processing is illegitimate but you refuse to have these deleted and we no longer require the data but you require these for the assertion, exercise or defence of legal claims or you have filed an objection against processing in accordance with Art. 21 GDPR;
- under Art. 20 GDPR to receive your personal data that you provided to us in a structured, common and machine-readable format or to demand transmission to another data controller;
- under Art. 7 paragraph 3 GDPR to revoke your consent once granted to us at any time. This will result in our no longer being permitted to continue processing the data in the future which was based on this consent and
- under Art. 77 GDPR to lodge a complaint with a supervisory authority. As a rule, you may contact the supervisory authority at your customary place of abode or workplace or at the registered office of our firm.
7. Right of objection
Provided your personal data are processed on the basis of legitimate interests in accordance with Art. 6 paragraph 1 sentence 1 lit. f GDPR, you have the right under Art. 21 GDPR to object to the processing of your personal data if there are grounds relating to your particular situation or the objection is based on direct advertising. In the latter case, you have a general right to object which we will respect without your stating any particular situation. If you wish to exercise your right of revocation or objection, it is sufficient if you send an email to firstname.lastname@example.org.
8. Data security
During your visit to our website, we use the common SSL method (Secure Socket Layer) in conjunction with the respectively highest encryption level supported by your browser. As a rule, this involves 256 bit encryption. If your browser does not support 256 bit encryption, we will use 128 bit v3 technology instead. You can see whether an individual page of our website is transmitted in encrypted form by the closed key or padlock symbol shown in the lower status bar of your browser. Otherwise, we use suitable technical and organisational security measures to protect your data against accidental or intentional manipulations, partial or complete loss, destruction or unauthorised access by third parties. Our security measures are continuously improved in accordance with technical developments.
9. Validity and changes to this Privacy Statementg
This Privacy Statement is currently valid and was last revised in May 2018. Through the further development of our website and offers on this or based on amended legal or official requirements, it may become necessary to amend this Privacy Statement. You can access and print out the applicable Privacy Statement on our website at any time under https://www.pohlmann-company.com/en/privacy.