Privacy Policy
- Scope of application
This privacy policy informs users about the nature, scope and purpose of the collection and use of personal data by the Mülheimer Verband Freikirchlich-Evangelischer Gemeinden e. V. Legal Notice
on this website. The legal basis for data protection can be found in the EU Data Protection Regulation (EU) 2016/679 (DS-GVO), the Federal Data Protection Act (BDSG), the Digital Services Act ( DSA), the Telecommunications Telemedia Data Protection Act (TTDSG), as well as in the data protection regulations of the Mülheimer Verband Freikirchlich-Evangelischer Gemeinden e.V. (MV-DSO). https://cloud.mv-feg.de/index.php/s/ECbPiqQWEbS37RD
- An overview of data protection
General information
The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.
Data recording on this website
Who is the responsible party for the recording of data on this website (i.e., the “controller”)?
The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.
How do we record your data?
We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.
Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.
What rights do you have as far as your information is concerned?
You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.
- Hosting
We are hosting the content of our website at the following provider:
Hetzner
The provider is the Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany (hereinafter referred to as Hetzner).
For details, please view the data privacy policy of Hetzner:
https://www.hetzner.com/de/rechtliches/datenschutz.
We use Hetzner on the basis of § 7 (1) f MV-DSO (cf. Art. 6(1)(f) GDPR). We have a legitimate interest in the most reliable depiction of our website possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR) and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the MV-DSO.
- General information and mandatory information
Data protection
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.
We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.
Information about the responsible party (referred to as the “controller” in the GDPR)
The data processing controller on this website is:
Mülheimer Verband Freikirchlich-Evangelischer Gemeinden e.V.
Habenhauser Dorfstraße 27
28279 Bremen
Phone: +49 (0) 421/8399130
E-mail: geschaeftsstelle@muelheimer-verband.de
The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).
Storage duration
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.
General information on the legal basis for the data processing on this website
If you have consented to data processing, we process your personal data on the basis of § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR) or § 10 MV-DSO (cf. Art. 9 (2)(a) GDPR), if special categories of data are processed according to § 10 MV-DSO (cf. Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on § 12 Abs 3 lit. a MV-DSO (cf. Art. 49 (1)(a) GDPR). If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of § 7 (1) b MV-DSO (cf. Art. 6(1)(b) GDPR). Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of § 7 (1) c MV-DSO (cf. Art. 6(1)(c) GDPR). Furthermore, the data processing may be carried out on the basis of our legitimate interest according to § 7 (1) f MV-DSO (cf. Art. 6(1)(f) GDPR). Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.
Designation of a data protection officer
We have appointed a data protection officer.
Ralf Tumat
Wolfsklingenweg 15
71364 Winnenden
Phone: + 49 ( 0) 162 7511498
E-mail: datenschutz@muelheimer-verband.de
Information on the data transfer to third-party countries that are not secure under data protection law and the transfer to US companies that are not DPF-certified
We use, among other technologies, tools from companies located in third-party countries that are not safe under data protection law, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). If these tools are enabled, your personal data may be transferred to and processed in these countries. We would like you to note that no level of data protection comparable to that in the EU can be guaranteed in third countries that are insecure in terms of data protection law.
We would like to point out that the US, as a secure third-party country, generally has a level of data protection comparable to that of the EU. Data transfer to the US is therefore permitted if the recipient is certified under the “EU-US Data Privacy Framework” (DPF) or has appropriate additional assurances. Information on transfers to third-party countries, including the data recipients, can be found in this Privacy Policy.
Recipients of personal data
In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR), or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded.
Revocation of your consent to the processing of data
A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
Right to object to the collection of data in special cases; right to object to direct advertising § 18 MV-DSO (cf. Art. 21 GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF § 7 ( 1) (E) OR (F) der MV-DSO (CF ART. 6(1)(E) OR (F) GDPR), YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO § 18 DER MV-DSO (CF. ART. 21(1) GDPR)).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO § 18 DER MV-DSO (CF. ART. 21(2) GDPR)).
Right of appeal to the competent supervisory authority
In the event of violations of data protection law, the person concerned has a right of appeal to the competent supervisory authority. The competent supervisory authority for data protection issues is the Data Protection Mühlheimer Verband e. V.. You can reach this as follows:
datenschutzaufsicht@muelheimer-verband.de
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.
Right to demand processing restrictions
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:
In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
If you have raised an objection pursuant to § 18 MV-DSO cf. (Art. 21(1) GDPR), your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.
SSL and/or TLS encryption
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.
Rejection of unsolicited e-mails
We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.
- Recording of data on this website
Server log files
The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:
The type and version of browser used
The used operating system
Referrer URL
The hostname of the accessing computer
The time of the server inquiry
The IP address
This data is not merged with other data sources.
This data is recorded on the basis of § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR). The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.
Contact form
If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.
The processing of these data is based on § 7 (1) b MV-DSO (cf. Art. 6(1)(b) GDPR), if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR) or on your agreement § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.
The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.
Request by e-mail, telephone, or fax
If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.
These data are processed on the basis of § 7 (1) b MV-DSO (cf. Art. 6(1)(b) GDPR) if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR) or on the basis of your consent § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time.
The data sent by you to us via contact requests remain with us until you request us to delete, revoke your
consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request).
Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
- Newsletter
Newsletter data
If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the handling of the newsletter, we use newsletter service providers, which are described below.
Mailjet
This website uses Mailjet for sending newsletters. The provider is Mailgun Technologies Inc., 112 E Pecan Sr.
#1135, San Antonio, Texas 78205, USA.
Mailjet is a service with which, among other things, the dispatch of newsletters can be organized and analyzed. The data entered by you for the purpose of receiving the newsletter will be stored on the servers of Mailjet.
Data analysis by Mailjet
With the aid of Mailjet we are able to analyze our newsletter campaigns. For example, we can see if a newsletter message has been opened and which links have been clicked. In this way, we can determine which links have been clicked particularly often.
We can also see whether certain previously defined actions were performed after opening/clicking (conversion rate). For example, we can tell if you have made a purchase after clicking on the newsletter.
Mailjet also allows us to classify newsletter recipients into different categories (“clusters”). For example, the newsletter recipients can be subdivided according to age, gender, or place of residence. In this way, the newsletters can be better adapted to the respective target groups. If you do not want Mailjet to analyze you, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message. Furthermore, you can unsubscribe from the newsletter directly on the website.
For detailed information on the functions of Mailjet, please refer to the following link:
https://www.mailjet.de/funktion/.
Mailjet’s privacy policy can be found at:
https://www.mailjet.de/sicherheit-datenschutz/.
Legal Basis
Data processing is based on your agreement § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR). You can revoke this agreement at any time. The legality of the data processing operations that have already taken place remains unaffected by the revocation.
Data transfer to the US is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://www.mailjet.de/av-vertrag/.
Storage period
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the MV-DSO.
- Plug-ins and Tools
YouTube with expanded data protection integration
This website integrates videos from the YouTube website. The operator of the website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
When you visit one of these websites on which YouTube is integrated, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.
We use YouTube in extended data protection mode. According to YouTube, videos that are played in extended data protection mode are not used to personalize browsing on YouTube. Ads that are played in extended data protection mode are also not personalized. No cookies are set in extended data protection mode. Instead, so-called local storage elements are stored in the user’s browser, which contain personal data similar to cookies and can be used for recognition. Details on the extended data protection mode can be found here:
https://support.google.com/youtube/answer/171780.
After activating a YouTube video, further data processing operations may be triggered over which we have no influence.
The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR), this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR) and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under:
https://policies.google.com/privacy?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/s/participant-search/participant-
detail?contact=true&id=a2zt000000001L5AAI&status=Active
Google Fonts (local embedding)
This website uses so-called Google Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google’s servers will not be established in conjunction with this application.
For more information on Google Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.
Adobe Fonts
In order to ensure the uniform depiction of certain fonts, this website uses fonts called Adobe Fonts provided by Adobe Systems Incorporated, 345 Park Avenue, San Jose, CA 95110-2704, USA (Adobe).
When you access pages of this website, your browser will automatically load the required fonts directly from the Adobe site to be able to display them correctly on your device. As a result, your browser will establish a connection with Adobe’s servers in the United States. Hence, Adobe learns that your IP address was used to access this website. According to the information provided by Adobe, no cookies will be stored in conjunction with the provision of the fonts.
Data are stored and analyzed on the basis of § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR). The website operator has a legitimate interest in a uniform presentation of the font on the operator’s website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR)and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://www.adobe.com/de/privacy/eudatatransfers.html.
For more information about Adobe Fonts, please read the policies under:
https://www.adobe.com/privacy/policies/adobe-fonts.html.
Adobe’s Data Privacy Declaration may be reviewed under:
https://www.adobe.com/privacy/policy.html.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/s/participant-search/participant-
detail?contact=true&id=a2zt0000000TNo9AAG&status=Active
OpenStreetMap
We are using the mapping service provided by OpenStreetMap (OSM).
We embed the map data from OpenStreetMap on the server of the OpenStreetMap Foundation, St John’s Innovation Centre, Cowley Road, Cambridge, CB4 0WS, United Kingdom. The United Kingdom is considered a secure third country under data protection law. This means that the United Kingdom has a level of data protection that is equivalent to the level of data protection in the European Union. When using the OpenStreetMap maps, a connection is established to the servers of the OpenStreetMap-Foundation. In the process and among other things, your IP address and other information about your behavior on this website may be forwarded to the OSMF. OpenStreetMap may store cookies in your browser or use similar recognition technologies for this purpose.
We use OpenStreetMap with the objective of ensuring the attractive presentation of our online offers and to make it easy for visitors to find the locations we specify on our website. This establishes legitimate grounds as defined in § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out exclusively on the basis of § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR) and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of reCAPTCHA is to determine whether data entered on this website (e.g., information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyzes the behavior of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data (e.g., IP address, time the website visitor spent on the site or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google.
reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is underway.
Data are stored and analyzed on the basis of § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR). The website operator has a legitimate interest in the protection of the operator’s websites against abusive automated spying and against SPAM. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR) and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time.
For more information about Google reCAPTCHA please refer to the Google Data Privacy Declaration and
Terms Of Use under the following links:
https://policies.google.com/privacy?hl=en and
https://policies.google.com/terms?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an
agreement between the European Union and the US, which is intended to ensure compliance with European
data protection standards for data processing in the US. Every company certified under the DPF is obliged to
comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/s/participant-search/participant-
detail?contact=true&id=a2zt000000001L5AAI&status=Active
- eCommerce and payment service providers
Payment services
We integrate payment services of third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, bank account details, credit card number) are processed by the payment service provider for the purpose of payment processing. For these transactions, the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment transaction § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR). Insofar as your consent is requested for certain actions, § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR) is the legal basis for data processing; consent may be revoked at any time for the future.
We use the following payment services / payment service providers within the scope of this website:
PayPal
The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full.
Details can be found in PayPal’s privacy policy:
https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
instant transfer Sofort
The provider of this payment service is Sofort GmbH, Theresienhöhe 12, 80339 Munich, Germany (hereinafter “Sofort GmbH”). With the help of the “Sofortüberweisung” procedure, we receive a payment confirmation from Sofort GmbH in real time and can immediately begin to fulfill our obligations. If you have chosen the payment method “Sofortüberweisung”, please send the PIN and a valid TAN to Sofort GmbH, with which it can log into your online banking account. Sofort GmbH automatically checks your account balance after logging in and carries out the transfer to us with the help of the TAN you have transmitted. Afterwards, it immediately sends us a transaction confirmation. After you log in, your turnover, the credit limit of the overdraft facility and the existence of other accounts and their balances are also checked automatically. In addition to the PIN and the TAN, the payment data entered by you as well as personal data will be transmitted to Sofort GmbH. The data about your person are first and last name, address, telephone number(s), email address, IP address and possibly other data required for payment processing. The transmission of this data is necessary to determine your identity beyond doubt and to prevent fraud attempts. For details on payment with immediate bank transfer, please refer to the following link: https://www.klarna.com/sofort/.
giropay
The provider of this payment service is the paydirekt GmbH, Stephanstraße 14 – 16, 60313 Frankfurt am Main (hereinafter referred to as “giropay”).
For details, please consult giropay’s Data Privacy Policy at:
https://www.paydirekt.de/agb/index.html.
Mastercard
The provider of this payment service is the Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium (hereinafter “Mastercard”).
Mastercard may transfer data to its parent company in the US. The data transfer to the US is based on
Mastercard’s Binding Corporate Rules. Details can be found here:
https://www.mastercard.de/de-de/datenschutz.html and https://www.mastercard.us/content/dam/mccom/global/documents/mastercard-bcrs.pdf.
VISA
The provider of this payment service is the Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, United Kingdom (hereinafter “VISA”).
Great Britain is considered a secure non-EU country as far as data protection legislation is concerned. This means that the data protection level in Great Britain is equivalent to the data protection level of the European Union.
VISA may transfer data to its parent company in the US. The data transfer to the US is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.visa.de/nutzungsbedingungen/visa-globale-datenschutzmitteilung/mitteilung-zu-zustandigkeitsfragen-fur-den-ewr.html.
For more information, please refer to VISA’s privacy policy:
https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.
- Online-based Audio and Video Conferences (Conference tools)
Data processing
We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).
Furthermore, the provider of the tool processes all the technical data required for the processing of the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.
Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.
Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.
Purpose and legal bases
The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers § 7 (1) b MV-DSO (cf. Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date.
Duration of storage
Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected.
We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools.
Conference tools used
We employ the following conference tools:
Zoom
We use Zoom. The provider of this service is Zoom Communications Inc, San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. For details on data processing, please refer to Zoom’s privacy policy: https://explore.zoom.us/en/privacy/.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://explore.zoom.us/en/privacy/.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the MV-DSO.
- Custom Services
Handling applicant data
We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.
Scope and purpose of the collection of data
If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment or an employment relationship. The legal grounds for the aforementioned are § 26 BDSG according to German Law (Negotiation of an Employment Relationship), § 7 (1) b MV-DSO (cf. Art. 6(1)(b) GDPR) (General Contract Negotiations) and – provided you have given us your consent – § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR). You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.
If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 BDSG and § 7 (1) b MV-DSO (cf. Art. 6(1)(b) GDPR) for the purpose of implementing the employment relationship in our data processing system.
Data Archiving Period
If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.
Longer storage may also take place if you have given your agreement § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR) or if statutory data retention requirements preclude the deletion.
- Our social media appearances
This privacy policy applies to the following social media presence
https://www.facebook.com/LifeTrustSambia/
https://www.instagram.com/lifetrustsambia/
https://www.youtube.com/channel/UCtbKbEUcs_evs_Y1MYa1Lrg
Data processing through social networks
We maintain publicly available profiles in social networks. The individual social networks we use can be found below.
Social networks such as Facebook, X etc. can generally analyze your user behavior comprehensively if you visit their website or a website with integrated social media content (e.g., like buttons or banner ads). When you visit our social media pages, numerous data protection-relevant processing operations are triggered. In detail:
If you are logged in to your social media account and visit our social media page, the operator of the social media portal can assign this visit to your user account. Under certain circumstances, your personal data may also be recorded if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address.
Using the data collected in this way, the operators of the social media portals can create user profiles in which their preferences and interests are stored. This way you can see interest-based advertising inside and outside of your social media presence. If you have an account with the social network, interest-based advertising can be displayed on any device you are logged in to or have logged in to.
Please also note that we cannot retrace all processing operations on the social media portals. Depending on the provider, additional processing operations may therefore be carried out by the operators of the social media portals. Details can be found in the terms of use and privacy policy of the respective social media portals.
Legal basis
Our social media appearances should ensure the widest possible presence on the Internet. This is a legitimate interest within the meaning of § 7 (1) f MV-DSO (cf. Art. 6 (1)(f) GDPR). The analysis processes initiated by the social networks may be based on divergent legal bases to be specified by the operators of the social networks (e.g., consent within the meaning of § 7 (1) a MV-DSO (cf. Art. 6(1)(a) GDPR) .
Responsibility and assertion of rights
If you visit one of our social media sites (e.g., Facebook), we, together with the operator of the social media platform, are responsible for the data processing operations triggered during this visit. You can in principle protect your rights (information, correction, deletion, limitation of processing, data portability and complaint) vis-à-vis us as well as vis-à-vis the operator of the respective social media portal (e.g., Facebook).
Please note that despite the shared responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are determined by the company policy of the respective provider.
Storage time
The data collected directly from us via the social media presence will be deleted from our systems as soon as you ask us to delete it, you revoke your consent to the storage or the purpose for the data storage lapses. Stored cookies remain on your device until you delete them. Mandatory statutory provisions – in particular, retention periods – remain unaffected.
We have no control over the storage duration of your data that are stored by the social network operators for their own purposes. For details, please contact the social network operators directly (e.g., in their privacy policy, see below).
Your rights
You have the right to receive information about the origin, recipient and purpose of your stored personal data at any time and free of charge. You also have the right to object, the right to data portability and the right to file a complaint with the responsible regulatory agency. Furthermore, you can request the correction, blocking, deletion and, under certain circumstances, the restriction of the processing of your personal data.
Individual social networks
We have a profile on Facebook. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (hereinafter Meta). According to Meta’s statement the collected data will also be transferred to the USA and to other third-party countries.
We have signed an agreement with Meta on shared responsibility for the processing of data (Controller Addendum). This agreement determines which data processing operations we or Meta are responsible for when you visit our Facebook Fanpage. This agreement can be viewed at the following link: https://www.facebook.com/legal/terms/page_controller_addendum.
You can customize your advertising settings independently in your user account. Click on the following link and log in:
https://www.facebook.com/settings?tab=ads.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum and
https://de-de.facebook.com/help/566994660333381.
Details can be found in the Facebook privacy policy:
https://www.facebook.com/about/privacy/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link:
https://www.dataprivacyframework.gov/participant/4452
We have a profile on Instagram. The provider of this service is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European
Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum and
https://de-de.facebook.com/help/566994660333381.
For details on how they handle your personal information, see the Instagram Privacy Policy:
https://privacycenter.instagram.com/policy/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link:
https://www.dataprivacyframework.gov/participant/4452
YouTube
We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Details on how they handle your personal data can be found in the YouTube privacy policy: https://policies.google.com/privacy?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link:
https://www.dataprivacyframework.gov/participant/5780
Source: eRecht 24 Status: October 2024