This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as 'data') within our online service and associated websites, functions and content as well as external online presences, such as our social media profile (hereinafter jointly referred to as the 'online service'). With regard to the terms used, such as 'personal data' or its 'processing', we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
As of 13 June 2018
|Managing Directors:||Alexander Post, Samsoor Hemat|
|Telephone:||+49 221 9859 240|
Data Protection Officer:
Mr Fouad Tachrifet
|Telephone:||+49 221 9859 240|
The data protection declaration of venITure GmbH is based on the terms used by the European regulations and regulator in the enactment of the General Data Protection Regulation directive (GDPR). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. In order to guarantee this, we would like to explain the terms used in advance.
We use the following terms in this data protection declaration, among others:
Personal data: Personal data is any information relating to an identified or identifiable natural person (hereinafter "data subject"). A natural person shall be regarded as identifiable if, directly or indirectly, in particular by attribution to an identifier such as a name, an identification number, location data, an online identifier or one or more specific characteristics, the expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person can be identified.
Data subject: A data subject is any identified or identifiable natural person whose personal data is processed by the data controller
Processing: Processing means any operation or set of operations which is carried out with or without the aid of automated means relating to personal data, such as collection, recording, organisation, sorting, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or integration, qualification, deletion or destruction.
Limitation of processing: Limitation of processing is the marking of stored personal data with the intention of limiting future processing.
Profiling: Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to work performance, financial situation, health, personal preferences, interests, reliability, conduct, or whereabouts or movement of that natural person.
Pseudonymisation: Pseudonymisation means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.
Data controller: The data controller is a natural or legal person, public authority, agency or other body who alone, or jointly with others, decides on the purposes and means of the processing of personal data. Where the purposes and means of such processing are laid down by Union law or by the law of the Member States, the person or persons responsible may be designated in accordance with Union law or the law of the Member States, as the case may be.
Processor: A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller.
Recipient: A natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, authorities which may receive personal data in the context of a specific investigation mandate under Union law or the law of the Member States shall not be considered as recipients
Third party: Any natural or legal person, public authority, agency or body other than the data subject, the data controller, the processor and the persons authorised to process the personal data under the direct responsibility of the data controller or processor.
Consent: Consent shall mean any voluntary, informed and unambiguous expression by the data subject of his or her will in the particular case, in the form of a statement or other unequivocal confirmatory act, indicating that he or she consents to the processing of his or her personal data.
2.1 We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing we carry out make this necessary.
2.2 In the event of such a change, we will notify you at least six weeks before it takes effect. You are generally entitled to a right of revocation with regard to the consent you have given.
2.3 Please note that (if you do not exercise your right of withdrawal) the current version of the data protection declaration is the valid one.
3.1 In accordance with Art. 13 GDPR we inform you about the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing in order to fulfil our services and carry out contractual measures as well as answer inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing in order to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR.
3.2 In the event that vital interests of the data subject or another natural person necessitate the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
4.1 We collect, store, use, transmit or delete the following personal data:
4.2 In principle, no special categories of data pursuant to Article 9 paragraph 1 GDPR will be processed unless they are supplied by the customer or user etc. for processing.
5.1 We will inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded that a data subject makes personal data available to us which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide personal data would mean that the contract could not be concluded with the data subject. Before the data subject provides personal data, the data subject must contact our data protection officer. Our data protection officer informs the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of a contract, whether there is an obligation to provide the personal data and what consequences the nonavailability of the personal data would have.
6.1 We take appropriate technical and organisational measures in accordance with Art. 32 GDPR, taking into account the current state of the art, the implementation costs and the nature, extent, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk; these measures include in particular safeguarding the confidentiality, integrity and availability of data by controlling the physical access to the data as well as the access to, inputting, passing on, safeguarding the availability and separation of the data concerning them. In addition, we have established procedures to ensure that data subjects' rights are exercised, that data is deleted and that we react to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Art. 25 GDPR).
6.2 The security measures include in particular the encrypted transmission of data between your browser and our server.
7.1 Insofar as we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, pursuant to Art. 6 Para. 1 lit. b GDPR is necessary for the performance of the contract), if you have consented to this, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
7.2 If we commission third parties with the processing of data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 GDPR.
8.1 If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only occur if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the data to be processed in a third country only if the special requirements of Art. 44 ff. of GDPR are met. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the USA through the "Privacy Shield") or the observance of officially recognised special contractual obligations (so-called "standard contractual clauses").
9.1 The website of venITure GmbH collects certain general data and information each time the website is accessed by a data subject or an automated system. This general data and information are stored in the log files of the server. This includes browser types and versions used, the operating system used by the accessing system, the website from which an accessing system accesses our website (the so-called referrer), the child websites which are accessed via an accessing system, the date and time of access to the website, an Internet protocol address (IP address), the Internet service provider of the accessing system and other similar data and information which serve to avert dangers in the event of attacks on our information technology systems.
9.2 When using this general data and information, we do not draw any conclusions about the data subject. This information is required to correctly deliver the content of our website, to optimize the content and advertising of our website, to ensure the long-term functionality of our information technology systems and the technology of our website, and to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyber-attack. This anonymously collected data and information is therefore evaluated by us both statistically and with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimum level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by the data subject.
10.1 We process basic data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 Para. 1 lit b. GDPR. The entries marked as mandatory in online forms are required for the conclusion of the contract.
10.2 Users can optionally create a user account on servicedesk.venITure.net for finding out the current status of requests, or for viewing previous requests. Within the framework of registration, the required mandatory information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their user account-associated data will be deleted, subject to its retention for commercial or tax reasons pursuant to Art. 6 para. 1 lit. c GDPR. It is the responsibility of the user to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.
10.3 Within the scope of registration and renewed registrations as well as use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so pursuant to Art. 6 Para. 1 lit. c GDPR.
10.4 We process usage data (e.g., the websites visited on our website, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile in order to display, for example, product information based on the services the user has previously used.
10.5 The deletion takes place after expiration of legal warranty and comparable obligations, the necessity of data retention is reviewed every three years; in the case of legal archiving obligations, the deletion takes place after their expiration (end of commercial (6 years) and tax (10 years) retention obligation); information in the customer account remain until its deletion.
12.1 Due to legal regulations, the website of venITure GmbH contains information that enables quick electronic contact to our company as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a data subject contacts the data controller by email or via a contact form, the personal data transmitted by the data subject shall be automatically stored. Such personal data transmitted voluntarily by a data subject to the data controller are stored for the purposes of processing or contacting the data subject.
12.2 The data of the user can be stored in our Customer Relationship Management System or comparable inquiry organization.
12.3 We will delete the requests if they are no longer necessary. We check the necessity every two years; inquiries from customers who have a customer account are stored permanently and refer to the customer account details (9.2) for deletion. In the case of statutory archiving obligations, deletion takes place after their expiration (end of commercial (6 years) and tax (10 years) retention obligation).
13.1 If users leave comments or other contributions, their IP addresses will be deleted on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act. GDPR stored for 7 days.
13.2 This is done for our security, if someone leaves illegal contents (insults, forbidden political propaganda, etc.) in comments and contributions. In this case, we ourselves can be prosecuted for the comment or contribution and are therefore interested in the author's identity.
14.1 On the website of venITure GmbH, users are given the opportunity to subscribe to the newsletter of our company. The personal data transferred to the person responsible for processing when ordering the newsletter is determined by the input field used for this purpose.
14.2 venITure GmbH informs its customers and business partners in regular intervals about offers of the company by means of a newsletter. The newsletter of our company can only be received by the data subject if
14.3 For legal reasons, a confirmation email in the double opt-in procedure will be sent to the email address entered for the first time by a data subject for the purpose of sending the newsletter. This confirmation email is used to check whether the owner of the email address as the data subject has authorised receipt of the newsletter.
14.4 When registering for the newsletter, we also store the IP address assigned by the Internet Service Provider (ISP) to the computer system used by the data subject at the time of registration as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of the email address of a data subject at a later date and therefore serves to legally safeguard the data controller.
14.5 The personal data collected as part of a newsletter registration will only be used to send our newsletter. Furthermore, subscribers to the newsletter could be informed by email if this is necessary for the operation of the newsletter service or registration in this respect, as might be the case in the event of changes to the newsletter offer or changes to the technical conditions. The personal data collected as part of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be cancelled by the data subject at any time. The consent to the storage of personal data, which the data subject has given us for the newsletter subscription, can be revoked at any time. For the purpose of revoking your consent, a corresponding link can be found in every newsletter. It is also possible at any time to unsubscribe from the newsletter dispatch directly on the website of the data controller or to inform the data controller of this in any other way.
15.1 The newsletters of venITure GmbH contain so-called tracking pixels. A tracking pixel is a thumbnail image embedded in emails sent in HTML format to enable log file recording and analysis. This facilitates a statistical evaluation of the success or failure of online marketing campaigns. Using the embedded pixel code, the company can recognize whether and when an email was opened by a data subject and which links in the email were clicked by the data subject.
15.2 Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the data controller in order to optimise the newsletter subscription and to adapt the content of future newsletters even better to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects are entitled at any time to revoke the relevant separate declaration of consent submitted via the double opt-in procedure. After revocation, this personal data will be deleted by the data controller. Unsubscribing from the newsletter indicates to the company automatically as revocation.
16.1 This website uses Google (Universal) Analytics, a web analysis service provided by Google Inc. (www.google.de). Google (Universal) Analytics uses methods that allow an analysis of your use of the website, such as "cookies", text files that are stored on your computer. The information generated about your use of this website is usually transferred to a Google server in the USA and stored there. By activating IP anonymisation on this website, the IP address is shortened before transmission within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The anonymous IP address transmitted by your browser within the framework of Google Analytics is not merged with other Google data.
16.2 You can prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and Google from processing this data by downloading and installing the browser plug-in available under the following link: http://wbs.is/rom89.
16.3 As an alternative to the browser plug-in, you can click this link to prevent Google Analytics from collecting data from this website in the future. An optout cookie is stored on your end device. If you delete your cookies, you must click the link again.
17.1 This website uses Google (Universal) Analytics, a web analysis service provided by Google Inc. (www.google.de). Google (Universal) Analytics uses methods that allow an analysis of your use of the website, such as "cookies", text files that are stored on your computer. The information generated about your use of this website is usually transferred to a Google server in the USA and stored there. By activating IP anonymisation on this website, the IP address is shortened before transmission within the member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The anonymous IP address transmitted by your browser within the framework of Google Analytics is not merged with other Google data.
17.2 You can prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and Google from processing this data by downloading and installing the browser plug-in available under the following link: http://wbs.is/rom89.
17.3 As an alternative to the browser plug-in, you can click this link to prevent Google Analytics from collecting data from this website in the future. An optout cookie is stored on your end device. If you delete your cookies, you must click the link again.
18.1 On the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f., we maintain the following facilities GDPR online presences within social networks and platforms in order to communicate with customers, interested parties and users active there and to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
18.2 Unless otherwise stated in our data protection declaration, we process the data of users who communicate with us within social networks and platforms, e.g. post articles on our social media pages or send us messages.
19.1 Within the scope of our online service, we act on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 Para. 1 lit. f. of the German Civil Code). GDPR) content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content"). This always presupposes that the third-party providers of this content perceive the IP address of the user, since they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents. We strive to use only content whose respective providers use the IP address only for the distribution of the content. Third parties may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.
19.2 The following section provides an overview of third-party providers and their contents, along with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, possible objections (so-called opt-out):
20.1 You have the possibility at any time to view, modify or delete the personal data provided to us by sending us an email to the email address dataprotection@venITure.net. If you are a registered user of our site, you may also opt out of receiving further information from us in the future.
20.2 You also have the right to revoke your consent at any time with effect for the future.
20.3 The deletion of the stored personal data takes place if you revoke your consent to storage.
20.4 The data controller shall process and store the personal data of the data subject only for the period of time necessary to achieve the storage purpose or where provided for by the European directive and regulation maker or another legislator in laws or regulations to which the data controller is subject.
20.5 If the storage purpose no longer applies or if a storage period prescribed by the European directive and regulation giver or another competent legislator expires, the personal data shall be blocked or deleted routinely and in accordance with the statutory provisions.
21.1 Every data subject shall have the right, granted by the European regulations and regulator, to obtain from the data controller confirmation as to whether personal data relating to them is being processed. If a data subject wishes to exercise this right of confirmation, he or she can contact our data protection officer or another employee of the data controller at any time.
21.2 Any person affected by the processing of personal data has the right, granted by the European directive and regulation maker, to obtain at any time, free of charge, from the data controller, information on the personal data relating to them which has been stored and a copy of that information. In addition, the European legislator has provided the data subject with the following information:
21.3 The data subject also has the right to know whether personal data has been transferred to a third country or to an international organisation. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in connection with the transfer.
21.4 If a data subject wishes to exercise this right to information, he or she can contact our data protection officer at any time.
21.5 Any person affected by the processing of personal data has the right, granted by the European directive and regulation maker, to request the rectification without delay of inaccurate personal data concerning him or her. Furthermore, the data subject shall have the right, having regard to the purposes of the processing, to request the completion of incomplete personal data, including by means of a supplementary statement.
21.6 If a data subject wishes to exercise this right of correction, he or she can contact our data protection officer at any time.
21.7 Any person affected by the processing of personal data shall have the right, granted by the European directive and regulation, to require the data controller to delete without delay personal data concerning them which are subject to one of the following conditions and to the extent that the processing is not necessary:
21.8 If one of the above-mentioned reasons applies and a data subject wishes to have personal data stored at venITure GmbH deleted, he or she can contact our data protection officer or another employee of the data controller at any time. The data protection officer of venITure GmbH or another employee will ensure that the request for deletion is complied with immediately.
21.9 If the personal data has been made public by venITure GmbH and if our company as the responsible party is obliged to delete the personal data in accordance with Art. 17 para. 1 GDPR, venITure GmbH takes appropriate measures, also of a technical nature, taking into account the available technology and the implementation costs, to inform other persons responsible for data processing who process the published personal data that the data subject has requested the deletion of all links to this personal data or copies or replications of this personal data from these other persons responsible for data processing, insofar as the processing is not necessary. The data protection officer of venITure GmbH or another employee will take the necessary steps in individual cases.
21.10 Any person data subject to the processing of personal data has the right, granted by the European directive and regulation, to request the data controller to limit the processing if one of the following conditions is met:
21.11 If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored at venITure GmbH, he can contact our data protection officer or another employee of the data controller at any time. The data protection officer of venITure GmbH or another employee will initiate the restriction of the processing.
21.12 Any data subject involved in the processing of personal data has the right, granted by the European directive and regulation, to obtain personal data concerning him or her which have been provided by the data subject to a controller in a structured, common and machine-readable format. It also has the right to communicate such data to another controller without being hindered by the data controller to whom the personal data have been provided, provided that the processing is based on the consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR or on a contract pursuant to Art. 6 (1) (c) GDPR. GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.
21.13 Furthermore, when exercising their right to data transferability pursuant to Art. 20 para. 1 GDPR, the data subject shall have the right to arrange that the personal data be transferred directly from one responsible person to another responsible person, insofar as this is technically feasible and insofar as this does not impair the rights and freedoms of other persons.
21.14 In order to assert the right to data transferability, the data subject can contact the data protection officer appointed by venITure GmbH at any time.
21.15 Any person affected by the processing of personal data has the right granted by the European directive and regulation to object at any time, on grounds relating to his/her particular situation, to lodge an appeal against the processing of personal data concerning him/her carried out pursuant to Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.
21.16 venITure GmbH will no longer process personal data in the event of an objection, unless we can prove compelling reasons worthy of protection for the processing that outweigh the interests, rights and freedoms of the data subject or serve the processing, assertion, exercise or defence of legal claims.
21.17 If venITure GmbH processes personal data in order to conduct direct advertising, the data subject has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling in so far as it is related to such direct marketing. If the data subject objects to venITure GmbH processing his/her personal data for direct marketing purposes, venITure GmbH will no longer process the personal data for these purposes.
21.18 In addition, the data subject has the right to object to the processing of personal data relating to him by venITure GmbH for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR for reasons arising from his particular situation, unless such processing is necessary for the performance of a task in the public interest.
21.19 In order to exercise the right to object, the data subject can contact the data protection officer of venITure GmbH directly. The data subject is also free to exercise their right of objection in relation to the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.
21.20 Any person data subject to the processing of personal data has the right, granted by the European directive and regulation, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects upon them or significantly affects them in a similar manner, provided that the decision is
21.21 If the data subject wishes to exercise rights relating to automated decisions, they may at any time contact our data protection officer or another employee of the data controller for this purpose.
21.22 Any person affected by the processing of personal data has the right, granted by the European directive and regulation maker, to revoke consent to the processing of personal data at any time.
21.23 If the data subject wishes to exercise their right to revoke their consent, they can contact our data protection officer or another employee of the data controller at any time.