Privacy Policy
The
use
of
the
Internet
pages
of
André
Frey
is
possible
without
any
indication
of
personal
data;
however,
if
a
data
subject
wants
to
use
special
enterprise
services
via
my
website,
processing
of
personal
data
could
become
necessary.
If
the
processing
of
personal
data
is
necessary
and
there
is
no
statutory
basis
for
such
processing,
we
generally obtain consent from the data subject.
The
processing
of
personal
data,
such
as
the
name,
address,
e-mail
address,
or
telephone
number
of
a
data
subject
shall
always
be
in
line
with
the
General
Data
Protection
Regulation
(GDPR),
and
in
accordance
with
the
country-specific
data
protection
regulations
applicable
to
André
Frey.
By
means
of
this
data
protection
declaration,
André
Frey
would
like
to
inform
the
general
public
of
the
nature,
scope,
and
purpose
of
the
personal
data
I
collect,
use
and
process.
Furthermore,
data
subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
André
Frey
has
implemented
numerous
technical
and
organizational
measures
to
ensure
the
most
complete
protection
of
personal
data
processed
through
this
website.
However,
Internet-based
data
transmissions
may
in
principle
have
security
gaps,
so
absolute
protection
may
not
be
guaranteed.
For
this
reason,
every
data
subject
is
free to transfer personal data to me via alternative means, e.g. by telephone.
1. Definitions
The
data
protection
declaration
of
André
Frey
is
based
on
the
terms
used
by
the
European
legislator
for
the
adoption
of
the
General
Data
Protection
Regulation
(GDPR). Our data protection declaration should be legible and understandable for the general public. To ensure this, I would like to first explain the terminology used.
In this data protection declaration, I use, inter alia, the following terms:
a) Personal data
Personal
data
means
any
information
relating
to
an
identified
or
identifiable
natural
person
(“data
subject”).
An
identifiable
natural
person
is
one
who
can
be
identified,
directly
or
indirectly,
in
particular
by
reference
to
an
identifier
such
as
a
name,
an
identification
number,
location
data,
an
online
identifier
or
to
one
or
more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
c) Processing
Processing
is
any
operation
or
set
of
operations
which
is
performed
on
personal
data
or
on
sets
of
personal
data,
whether
or
not
by
automated
means,
such
as
collection,
recording,
organisation,
structuring,
storage,
adaptation
or
alteration,
retrieval,
consultation,
use,
disclosure
by
transmission,
dissemination
or
otherwise
making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
e) Profiling
Profiling
means
any
form
of
automated
processing
of
personal
data
consisting
of
the
use
of
personal
data
to
evaluate
certain
personal
aspects
relating
to
a
natural
person,
in
particular
to
analyse
or
predict
aspects
concerning
that
natural
person's
performance
at
work,
economic
situation,
health,
personal
preferences,
interests,
reliability, behaviour, location or movements.
f) Pseudonymisation
Pseudonymisation
is
the
processing
of
personal
data
in
such
a
manner
that
the
personal
data
can
no
longer
be
attributed
to
a
specific
data
subject
without
the
use
of
additional
information,
provided
that
such
additional
information
is
kept
separately
and
is
subject
to
technical
and
organisational
measures
to
ensure
that
the
personal
data are not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for the processing
Controller
or
controller
responsible
for
the
processing
is
the
natural
or
legal
person,
public
authority,
agency
or
other
body
which,
alone
or
jointly
with
others,
determines
the
purposes
and
means
of
the
processing
of
personal
data;
where
the
purposes
and
means
of
such
processing
are
determined
by
Union
or
Member
State
law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient
Recipient
is
a
natural
or
legal
person,
public
authority,
agency
or
another
body,
to
which
the
personal
data
are
disclosed,
whether
a
third
party
or
not.
However,
public
authorities
which
may
receive
personal
data
in
the
framework
of
a
particular
inquiry
in
accordance
with
Union
or
Member
State
law
shall
not
be
regarded
as
recipients;
the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
j) Third party
Third
party
is
a
natural
or
legal
person,
public
authority,
agency
or
body
other
than
the
data
subject,
controller,
processor
and
persons
who,
under
the
direct
authority
of the controller or processor, are authorised to process personal data.
k) Consent
Consent
of
the
data
subject
is
any
freely
given,
specific,
informed
and
unambiguous
indication
of
the
data
subject's
wishes
by
which
he
or
she,
by
a
statement
or
by
a
clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and Address of the controller
Controller
for
the
purposes
of
the
General
Data
Protection
Regulation
(GDPR),
other
data
protection
laws
applicable
in
Member
states
of
the
European
Union
and
other
provisions related to data protection is:
André Frey
Zitterweg 12a
49565 Bramsche
Germany
Phone: +49 (0)173 7228967
Email:
mail@stenbaecken.com
Website:
www.stenbaecken.com
3. Cookies
The Internet pages of André Frey use cookies. Cookies are text files that are stored in a computer system via an Internet browser.
Many
Internet
sites
and
servers
use
cookies.
Many
cookies
contain
a
so-called
cookie
ID.
A
cookie
ID
is
a
unique
identifier
of
the
cookie.
It
consists
of
a
character
string
through
which
Internet
pages
and
servers
can
be
assigned
to
the
specific
Internet
browser
in
which
the
cookie
was
stored.
This
allows
visited
Internet
sites
and
servers
to
differentiate
the
individual
browser
of
the
dats
subject
from
other
Internet
browsers
that
contain
other
cookies.
A
specific
Internet
browser
can
be
recognized
and
identified using the unique cookie ID.
Through the use of cookies, André Frey can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By
means
of
a
cookie,
the
information
and
offers
on
my
website
can
be
optimized
with
the
user
in
mind.
Cookies
allow
us,
as
previously
mentioned,
to
recognize
our
website
users.
The
purpose
of
this
recognition
is
to
make
it
easier
for
users
to
utilize
our
website.
The
website
user
that
uses
cookies,
e.g.
does
not
have
to
enter
access
data
each
time
the
website
is
accessed,
because
this
is
taken
over
by
the
website,
and
the
cookie
is
thus
stored
on
the
user's
computer
system.
Another
example
is
the
cookie
of
a
shopping
cart
in
an
online
shop.
The
online
store
remembers
the
articles
that
a
customer
has
placed
in
the
virtual
shopping
cart
via
a
cookie.
The
data
subject
may,
at
any
time,
prevent
the
setting
of
cookies
through
my
website
by
means
of
a
corresponding
setting
of
the
Internet
browser
used,
and
may
thus
permanently
deny
the
setting
of
cookies.
Furthermore,
already
set
cookies
may
be
deleted
at
any
time
via
an
Internet
browser
or
other
software
programs.
This
is
possible
in
all
popular
Internet
browsers.
If
the
data
subject
deactivates
the
setting
of
cookies
in
the
Internet
browser
used,
not
all
functions
of
our
website
may
be
entirely usable.
4. Collection of general data and information
The
website
of
André
Frey
collects
a
series
of
general
data
and
information
when
a
data
subject
or
automated
system
calls
up
the
website.
This
general
data
and
information
are
stored
in
the
server
log
files.
Collected
may
be
(1)
the
browser
types
and
versions
used,
(2)
the
operating
system
used
by
the
accessing
system,
(3)
the
website
from
which
an
accessing
system
reaches
our
website
(so-called
referrers),
(4)
the
sub-websites,
(5)
the
date
and
time
of
access
to
the
Internet
site,
(6)
an
Internet
protocol
address
(IP
address),
(7)
the
Internet
service
provider
of
the
accessing
system,
and
(8)
any
other
similar
data
and
information
that
may
be
used
in
the
event of attacks on our information technology systems.
When
using
these
general
data
and
information,
André
Frey
does
not
draw
any
conclusions
about
the
data
subject.
Rather,
this
information
is
needed
to
(1)
deliver
the
content
of
our
website
correctly,
(2)
optimize
the
content
of
our
website
as
well
as
its
advertisement,
(3)
ensure
the
long-term
viability
of
our
information
technology
systems
and
website
technology,
and
(4)
provide
law
enforcement
authorities
with
the
information
necessary
for
criminal
prosecution
in
case
of
a
cyber-attack.
Therefore,
André
Frey
analyzes
anonymously
collected
data
and
information
statistically,
with
the
aim
of
increasing
the
data
protection
and
data
security
of
our
enterprise,
and
to
ensure
an
optimal
level
of
protection
for
the
personal
data
we
process.
The
anonymous
data
of
the
server
log
files
are
stored
separately
from
all
personal data provided by a data subject.
5. Routine erasure and blocking of personal data
The
data
controller
shall
process
and
store
the
personal
data
of
the
data
subject
only
for
the
period
necessary
to
achieve
the
purpose
of
storage,
or
as
far
as
this
is
granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If
the
storage
purpose
is
not
applicable,
or
if
a
storage
period
prescribed
by
the
European
legislator
or
another
competent
legislator
expires,
the
personal
data
are
routinely blocked or erased in accordance with legal requirements.
6. Rights of the data subject
a) Right of confirmation
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
obtain
from
the
controller
the
confirmation
as
to
whether
or
not
personal
data
concerning
him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact mail@stenbaecken.com.
b) Right of access
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
obtain
from
the
controller
free
information
about
his
or
her
personal
data
stored
at
any
time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
•
the purposes of the processing;
•
the categories of personal data concerned;
•
the
recipients
or
categories
of
recipients
to
whom
the
personal
data
have
been
or
will
be
disclosed,
in
particular
recipients
in
third
countries
or
international
organisations;
•
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
•
the
existence
of
the
right
to
request
from
the
controller
rectification
or
erasure
of
personal
data,
or
restriction
of
processing
of
personal
data
concerning
the
data
subject, or to object to such processing;
•
the existence of the right to lodge a complaint with a supervisory authority;
•
where the personal data are not collected from the data subject, any available information as to their source;
•
the
existence
of
automated
decision-making,
including
profiling,
referred
to
in
Article
22(1)
and
(4)
of
the
GDPR
and,
at
least
in
those
cases,
meaningful
information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore,
the
data
subject
shall
have
a
right
to
obtain
information
as
to
whether
personal
data
are
transferred
to
a
third
country
or
to
an
international
organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact mail@stenbaecken.com.
c) Right to rectification
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
obtain
from
the
controller
without
undue
delay
the
rectification
of
inaccurate
personal
data
concerning
him
or
her.
Taking
into
account
the
purposes
of
the
processing,
the
data
subject
shall
have
the
right
to
have
incomplete
personal
data
completed,
including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact mail@stenbaecken.com.
d) Right to erasure (Right to be forgotten)
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
obtain
from
the
controller
the
erasure
of
personal
data
concerning
him
or
her
without
undue
delay,
and
the
controller
shall
have
the
obligation
to
erase
personal
data
without
undue
delay
where
one
of
the
following
grounds
applies,
as
long
as
the
processing is not necessary:
•
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
•
The
data
subject
withdraws
consent
to
which
the
processing
is
based
according
to
point
(a)
of
Article
6(1)
of
the
GDPR,
or
point
(a)
of
Article
9(2)
of
the
GDPR,
and
where there is no other legal ground for the processing.
•
The
data
subject
objects
to
the
processing
pursuant
to
Article
21(1)
of
the
GDPR
and
there
are
no
overriding
legitimate
grounds
for
the
processing,
or
the
data
subject objects to the processing pursuant to Article 21(2) of the GDPR.
•
The personal data have been unlawfully processed.
•
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
•
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If
one
of
the
aforementioned
reasons
applies,
and
a
data
subject
wishes
to
request
the
erasure
of
personal
data
stored
by
André
Frey,
he
or
she
may,
at
any
time,
contact mail@stenbaecken.com. André Frey shall promptly ensure that the erasure request is complied with immediately.
Where
the
controller
has
made
personal
data
public
and
is
obliged
pursuant
to
Article
17(1)
to
erase
the
personal
data,
the
controller,
taking
account
of
available
technology
and
the
cost
of
implementation,
shall
take
reasonable
steps,
including
technical
measures,
to
inform
other
controllers
processing
the
personal
data
that
the
data
subject
has
requested
erasure
by
such
controllers
of
any
links
to,
or
copy
or
replication
of,
those
personal
data,
as
far
as
processing
is
not
required.
André
Frey
will arrange the necessary measures in individual cases.
e) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
•
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
•
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
•
The
controller
no
longer
needs
the
personal
data
for
the
purposes
of
the
processing,
but
they
are
required
by
the
data
subject
for
the
establishment,
exercise
or
defence of legal claims.
•
The
data
subject
has
objected
to
processing
pursuant
to
Article
21(1)
of
the
GDPR
pending
the
verification
whether
the
legitimate
grounds
of
the
controller
override those of the data subject.
If
one
of
the
aforementioned
conditions
is
met,
and
a
data
subject
wishes
to
request
the
restriction
of
the
processing
of
personal
data
stored
by
André
Frey,
he
or
she
may at any time contact mail@stenbaecken.com. André Frey will arrange the restriction of the processing.
f) Right to data portability
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator,
to
receive
the
personal
data
concerning
him
or
her,
which
was
provided
to
a
controller,
in
a
structured,
commonly
used
and
machine-readable
format.
He
or
she
shall
have
the
right
to
transmit
those
data
to
another
controller
without
hindrance
from
the
controller
to
which
the
personal
data
have
been
provided,
as
long
as
the
processing
is
based
on
consent
pursuant
to
point
(a)
of
Article
6(1)
of
the
GDPR
or
point
(a)
of
Article
9(2)
of
the
GDPR,
or
on
a
contract
pursuant
to
point
(b)
of
Article
6(1)
of
the
GDPR,
and
the
processing
is
carried
out
by
automated
means,
as
long
as
the
processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore,
in
exercising
his
or
her
right
to
data
portability
pursuant
to
Article
20(1)
of
the
GDPR,
the
data
subject
shall
have
the
right
to
have
personal
data
transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time mail@stenbaecken.com.
g) Right to object
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
object,
on
grounds
relating
to
his
or
her
particular
situation,
at
any
time,
to
processing
of
personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
André
Frey
shall
no
longer
process
the
personal
data
in
the
event
of
the
objection,
unless
we
can
demonstrate
compelling
legitimate
grounds
for
the
processing
which
override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If
André
Frey
processes
personal
data
for
direct
marketing
purposes,
the
data
subject
shall
have
the
right
to
object
at
any
time
to
processing
of
personal
data
concerning
him
or
her
for
such
marketing.
This
applies
to
profiling
to
the
extent
that
it
is
related
to
such
direct
marketing.
If
the
data
subject
objects
to
André
Frey
to
the processing for direct marketing purposes, André Frey will no longer process the personal data for these purposes.
In
addition,
the
data
subject
has
the
right,
on
grounds
relating
to
his
or
her
particular
situation,
to
object
to
processing
of
personal
data
concerning
him
or
her
by
the
André
Frey
for
scientific
or
historical
research
purposes,
or
for
statistical
purposes
pursuant
to
Article
89(1)
of
the
GDPR,
unless
the
processing
is
necessary
for
the
performance of a task carried out for reasons of public interest.
In
order
to
exercise
the
right
to
object,
the
data
subject
may
contact
mail@stenbaecken.com.
In
addition,
the
data
subject
is
free
in
the
context
of
the
use
of
information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
not
to
be
subject
to
a
decision
based
solely
on
automated
processing,
including
profiling,
which
produces
legal
effects
concerning
him
or
her,
or
similarly
significantly
affects
him
or
her,
as
long
as
the
decision
(1)
is
not
is
necessary
for
entering
into,
or
the
performance
of,
a
contract
between
the
data
subject
and
a
data
controller,
or
(2)
is
not
authorised
by
Union
or
Member
State
law
to
which
the
controller
is
subject
and
which
also
lays
down
suitable
measures
to
safeguard
the
data
subject's
rights
and
freedoms
and
legitimate
interests,
or
(3)
is
not
based
on
the
data
subject's
explicit consent.
If
the
decision
(1)
is
necessary
for
entering
into,
or
the
performance
of,
a
contract
between
the
data
subject
and
a
data
controller,
or
(2)
it
is
based
on
the
data
subject's
explicit
consent,
André
Frey
shall
implement
suitable
measures
to
safeguard
the
data
subject's
rights
and
freedoms
and
legitimate
interests,
at
least
the
right
to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact mail@stenbaecken.com.
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact
mail@stenbaecken.com
.
7. Data protection provisions about the application and use of Instagram
On
this
website,
the
controller
has
integrated
components
of
the
service
Instagram.
Instagram
is
a
service
that
may
be
qualified
as
an
audiovisual
platform,
which
allows users to share photos and videos, as well as disseminate such data in other social networks.
The operating company of the services offered by Instagram is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.
With
each
call-up
to
one
of
the
individual
pages
of
this
Internet
site,
which
is
operated
by
the
controller
and
on
which
an
Instagram
component
(Insta
button)
was
integrated,
the
Internet
browser
on
the
information
technology
system
of
the
data
subject
is
automatically
prompted
to
the
download
of
a
display
of
the
corresponding
Instagram
component
of
Instagram.
During
the
course
of
this
technical
procedure,
Instagram
becomes
aware
of
what
specific
sub-page
of
our
website
was
visited
by
the data subject.
If
the
data
subject
is
logged
in
at
the
same
time
on
Instagram,
Instagram
detects
with
every
call-up
to
our
website
by
the
data
subject—and
for
the
entire
duration
of
their
stay
on
our
Internet
site—which
specific
sub-page
of
our
Internet
page
was
visited
by
the
data
subject.
This
information
is
collected
through
the
Instagram
component
and
is
associated
with
the
respective
Instagram
account
of
the
data
subject.
If
the
data
subject
clicks
on
one
of
the
Instagram
buttons
integrated
on
our
website, then Instagram matches this information with the personal Instagram user account of the data subject and stores the personal data.
Instagram
receives
information
via
the
Instagram
component
that
the
data
subject
has
visited
our
website
provided
that
the
data
subject
is
logged
in
at
Instagram
at
the
time
of
the
call
to
our
website.
This
occurs
regardless
of
whether
the
person
clicks
on
the
Instagram
button
or
not.
If
such
a
transmission
of
information
to
Instagram is not desirable for the data subject, then he or she can prevent this by logging off from their Instagram account before a call-up to our website is made.
Further
information
and
the
applicable
data
protection
provisions
of
Instagram
may
be
retrieved
under
https://help.instagram.com/155833707900388
and
https://www.instagram.com/about/legal/privacy/
.
8. Data protection provisions about the application and use of YouTube
On
this
website,
the
controller
has
integrated
components
of
YouTube.
YouTube
is
an
Internet
video
portal
that
enables
video
publishers
to
set
video
clips
and
other
users
free
of
charge,
which
also
provides
free
viewing,
review
and
commenting
on
them.
YouTube
allows
you
to
publish
all
kinds
of
videos,
so
you
can
access
both
full
movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal.
The operating company of YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
With
each
call-up
to
one
of
the
individual
pages
of
this
Internet
site,
which
is
operated
by
the
controller
and
on
which
a
YouTube
component
(YouTube
video)
was
integrated,
the
Internet
browser
on
the
information
technology
system
of
the
data
subject
is
automatically
prompted
to
download
a
display
of
the
corresponding
YouTube
component.
Further
information
about
YouTube
may
be
obtained
under
https://www.youtube.com/yt/about/en/.
During
the
course
of
this
technical
procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject.
If
the
data
subject
is
logged
in
on
YouTube,
YouTube
recognizes
with
each
call-up
to
a
sub-page
that
contains
a
YouTube
video,
which
specific
sub-page
of
our
Internet
site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.
YouTube
and
Google
will
receive
information
through
the
YouTube
component
that
the
data
subject
has
visited
my
website,
if
the
data
subject
at
the
time
of
the
call
to
my
website
is
logged
in
on
YouTube;
this
occurs
regardless
of
whether
the
person
clicks
on
a
YouTube
video
or
not.
If
such
a
transmission
of
this
information
to
YouTube
and
Google
is
not
desirable
for
the
data
subject,
the
delivery
may
be
prevented
if
the
data
subject
logs
off
from
their
own
YouTube
account
before
a
call-up
to our website is made.
YouTube's
data
protection
provisions,
available
at
https://www.google.com/intl/en/policies/privacy/,
provide
information
about
the
collection,
processing
and
use
of
personal data by YouTube and Google.
9. Legal basis for the processing
Art.
6(1)
lit.
a
GDPR
serves
as
the
legal
basis
for
processing
operations
for
which
we
obtain
consent
for
a
specific
processing
purpose.
If
the
processing
of
personal
data
is
necessary
for
the
performance
of
a
contract
to
which
the
data
subject
is
party,
as
is
the
case,
for
example,
when
processing
operations
are
necessary
for
the
supply
of
goods
or
to
provide
any
other
service,
the
processing
is
based
on
Article
6(1)
lit.
b
GDPR.
The
same
applies
to
such
processing
operations
which
are
necessary
for
carrying
out
pre-contractual
measures,
for
example
in
the
case
of
inquiries
concerning
my
products
or
services.
Is
André
Frey
subject
to
a
legal
obligation
by
which
processing
of
personal
data
is
required,
such
as
for
the
fulfillment
of
tax
obligations,
the
processing
is
based
on
Art.
6(1)
lit.
c
GDPR.
In
rare
cases,
the
processing
of
personal
data
may
be
necessary
to
protect
the
vital
interests
of
the
data
subject
or
of
another
natural
person.
This
would
be
the
case,
for
example,
if
a
visitor
were
injured
in
my
house
and
his
name,
age,
health
insurance
data
or
other
vital
information
would
have
to
be
passed
on
to
a
doctor,
hospital
or
other
third
party.
Then
the
processing
would
be
based
on
Art.
6(1)
lit.
d
GDPR.
Finally,
processing
operations
could
be
based
on
Article
6(1)
lit.
f
GDPR.
This
legal
basis
is
used
for
processing
operations
which
are
not
covered
by
any
of
the
abovementioned
legal
grounds,
if
processing
is
necessary
for
the
purposes
of
the
legitimate
interests
pursued
by
our
company
or
by
a
third
party,
except
where
such
interests
are
overridden
by
the
interests
or
fundamental
rights
and
freedoms
of
the
data
subject
which
require
protection
of
personal
data.
Such
processing
operations
are
particularly
permissible
because
they
have
been
specifically
mentioned
by
the
European
legislator.
He
considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
10. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out my activity in favor of the well-being to third party.
11. Period for which the personal data will be stored
The
criteria
used
to
determine
the
period
of
storage
of
personal
data
is
the
respective
statutory
retention
period.
After
expiration
of
that
period,
the
corresponding
data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
12.
Provision
of
personal
data
as
statutory
or
contractual
requirement;
Requirement
necessary
to
enter
into
a
contract;
Obligation
of
the
data
subject
to
provide the personal data; possible consequences of failure to provide such data
I
clarify
that
the
provision
of
personal
data
is
partly
required
by
law
(e.g.
tax
regulations)
or
can
also
result
from
contractual
provisions
(e.g.
information
on
the
contractual
partner).
Sometimes
it
may
be
necessary
to
conclude
a
contract
that
the
data
subject
provides
me
with
personal
data,
which
must
subsequently
be
processed
by
myself.
The
data
subject
is,
for
example,
obliged
to
provide
me
with
personal
data
when
André
Frey
signs
a
contract
with
him
or
her.
The
non-provision
of
the
personal
data
would
have
the
consequence
that
the
contract
with
the
data
subject
could
not
be
concluded.
Before
personal
data
is
provided
by
the
data
subject,
the
data
subject
must
contact
mail@stenbaecken.com.
André
Frey
clarifies
to
the
data
subject
whether
the
provision
of
the
personal
data
is
required
by
law
or
contract
or
is
necessary
for
the
conclusion
of
the
contract,
whether
there
is
an
obligation
to
provide
the
personal
data
and
the
consequences
of
non-provision
of
the
personal data.
13. Existence of automated decision-making
As a responsible person, I do not use automatic decision-making or profiling.
This
Privacy
Policy
has
been
generated
by
the
Privacy
Policy
Generator
of
the
External
Data
Protection
Officers
that
was
developed
in
cooperation
with
the
Media
Law
Lawyers
from WBS-LAW.
Privacy Policy
The
use
of
the
Internet
pages
of
André
Frey
is
possible
without
any
indication
of
personal
data;
however,
if
a
data
subject
wants
to
use
special
enterprise
services
via
my
website,
processing
of
personal
data
could
become
necessary.
If
the
processing
of
personal
data
is
necessary
and
there
is
no
statutory
basis
for
such
processing,
we
generally
obtain
consent
from
the
data
subject.
The
processing
of
personal
data,
such
as
the
name,
address,
e-mail
address,
or
telephone
number
of
a
data
subject
shall
always
be
in
line
with
the
General
Data
Protection
Regulation
(GDPR),
and
in
accordance
with
the
country-specific
data
protection
regulations
applicable
to
André
Frey.
By
means
of
this
data
protection
declaration,
André
Frey
would
like
to
inform
the
general
public
of
the
nature,
scope,
and
purpose
of
the
personal
data
I
collect,
use
and
process.
Furthermore,
data
subjects
are
informed,
by
means
of
this
data
protection
declaration,
of
the
rights to which they are entitled.
André
Frey
has
implemented
numerous
technical
and
organizational
measures
to
ensure
the
most
complete
protection
of
personal
data
processed
through
this
website.
However,
Internet-based
data
transmissions
may
in
principle
have
security
gaps,
so
absolute
protection
may
not
be
guaranteed.
For
this
reason,
every
data
subject
is
free
to
transfer
personal
data
to
me via alternative means, e.g. by telephone.
1. Definitions
The
data
protection
declaration
of
André
Frey
is
based
on
the
terms
used
by
the
European
legislator
for
the
adoption
of
the
General
Data
Protection
Regulation
(GDPR).
Our
data
protection
declaration
should
be
legible
and
understandable
for
the
general
public.
To
ensure
this,
I
would
like
to
first
explain
the
terminology used.
In
this
data
protection
declaration,
I
use,
inter
alia,
the following terms:
a) Personal data
Personal
data
means
any
information
relating
to
an
identified
or
identifiable
natural
person
(“data
subject”).
An
identifiable
natural
person
is
one
who
can
be
identified,
directly
or
indirectly,
in
particular
by
reference
to
an
identifier
such
as
a
name,
an
identification
number,
location
data,
an
online
identifier
or
to
one
or
more
factors
specific
to
the
physical,
physiological,
genetic,
mental,
economic,
cultural or social identity of that natural person.
b) Data subject
Data
subject
is
any
identified
or
identifiable
natural
person,
whose
personal
data
is
processed
by
the
controller responsible for the processing.
c) Processing
Processing
is
any
operation
or
set
of
operations
which
is
performed
on
personal
data
or
on
sets
of
personal
data,
whether
or
not
by
automated
means,
such
as
collection,
recording,
organisation,
structuring,
storage,
adaptation
or
alteration,
retrieval,
consultation,
use,
disclosure
by
transmission,
dissemination
or
otherwise
making
available,
alignment
or
combination,
restriction,
erasure
or
destruction.
d) Restriction of processing
Restriction
of
processing
is
the
marking
of
stored
personal
data
with
the
aim
of
limiting
their
processing
in the future.
e) Profiling
Profiling
means
any
form
of
automated
processing
of
personal
data
consisting
of
the
use
of
personal
data
to
evaluate
certain
personal
aspects
relating
to
a
natural
person,
in
particular
to
analyse
or
predict
aspects
concerning
that
natural
person's
performance
at
work,
economic
situation,
health,
personal
preferences,
interests,
reliability,
behaviour,
location
or
movements.
f) Pseudonymisation
Pseudonymisation
is
the
processing
of
personal
data
in
such
a
manner
that
the
personal
data
can
no
longer
be
attributed
to
a
specific
data
subject
without
the
use
of
additional
information,
provided
that
such
additional
information
is
kept
separately
and
is
subject
to
technical
and
organisational
measures
to
ensure
that
the
personal
data
are
not
attributed
to
an
identified or identifiable natural person.
g)
Controller
or
controller
responsible
for
the
processing
Controller
or
controller
responsible
for
the
processing
is
the
natural
or
legal
person,
public
authority,
agency
or
other
body
which,
alone
or
jointly
with
others,
determines
the
purposes
and
means
of
the
processing
of
personal
data;
where
the
purposes
and
means
of
such
processing
are
determined
by
Union
or
Member
State
law,
the
controller
or
the
specific
criteria
for
its
nomination
may
be
provided
for
by
Union
or
Member
State law.
h) Processor
Processor
is
a
natural
or
legal
person,
public
authority,
agency
or
other
body
which
processes
personal
data
on behalf of the controller.
i) Recipient
Recipient
is
a
natural
or
legal
person,
public
authority,
agency
or
another
body,
to
which
the
personal
data
are
disclosed,
whether
a
third
party
or
not.
However,
public
authorities
which
may
receive
personal
data
in
the
framework
of
a
particular
inquiry
in
accordance
with
Union
or
Member
State
law
shall
not
be
regarded
as
recipients;
the
processing
of
those
data
by
those
public
authorities
shall
be
in
compliance
with
the
applicable
data
protection
rules
according
to
the
purposes of the processing.
j) Third party
Third
party
is
a
natural
or
legal
person,
public
authority,
agency
or
body
other
than
the
data
subject,
controller,
processor
and
persons
who,
under
the
direct
authority
of
the
controller
or
processor,
are
authorised to process personal data.
k) Consent
Consent
of
the
data
subject
is
any
freely
given,
specific,
informed
and
unambiguous
indication
of
the
data
subject's
wishes
by
which
he
or
she,
by
a
statement
or
by
a
clear
affirmative
action,
signifies
agreement
to
the
processing
of
personal
data
relating
to him or her.
2. Name and Address of the controller
Controller
for
the
purposes
of
the
General
Data
Protection
Regulation
(GDPR),
other
data
protection
laws
applicable
in
Member
states
of
the
European
Union
and
other
provisions
related
to
data
protection
is:
André Frey
Zitterweg 12a
49565 Bramsche
Germany
Phone: +49 (0)173 7228967
Email:
mail@stenbaecken.com
Website:
www.stenbaecken.com
3. Cookies
The
Internet
pages
of
André
Frey
use
cookies.
Cookies
are
text
files
that
are
stored
in
a
computer
system
via
an Internet browser.
Many
Internet
sites
and
servers
use
cookies.
Many
cookies
contain
a
so-called
cookie
ID.
A
cookie
ID
is
a
unique
identifier
of
the
cookie.
It
consists
of
a
character
string
through
which
Internet
pages
and
servers
can
be
assigned
to
the
specific
Internet
browser
in
which
the
cookie
was
stored.
This
allows
visited
Internet
sites
and
servers
to
differentiate
the
individual
browser
of
the
dats
subject
from
other
Internet
browsers
that
contain
other
cookies.
A
specific
Internet
browser
can
be
recognized
and
identified using the unique cookie ID.
Through
the
use
of
cookies,
André
Frey
can
provide
the
users
of
this
website
with
more
user-friendly
services
that
would
not
be
possible
without
the
cookie
setting.
By
means
of
a
cookie,
the
information
and
offers
on
my
website
can
be
optimized
with
the
user
in
mind.
Cookies
allow
us,
as
previously
mentioned,
to
recognize
our
website
users.
The
purpose
of
this
recognition
is
to
make
it
easier
for
users
to
utilize
our
website.
The
website
user
that
uses
cookies,
e.g.
does
not
have
to
enter
access
data
each
time
the
website
is
accessed,
because
this
is
taken
over
by
the
website,
and
the
cookie
is
thus
stored
on
the
user's
computer
system.
Another
example
is
the
cookie
of
a
shopping
cart
in
an
online
shop.
The
online
store
remembers
the
articles
that
a
customer
has
placed
in
the
virtual
shopping cart via a cookie.
The
data
subject
may,
at
any
time,
prevent
the
setting
of
cookies
through
my
website
by
means
of
a
corresponding
setting
of
the
Internet
browser
used,
and
may
thus
permanently
deny
the
setting
of
cookies.
Furthermore,
already
set
cookies
may
be
deleted
at
any
time
via
an
Internet
browser
or
other
software
programs.
This
is
possible
in
all
popular
Internet
browsers.
If
the
data
subject
deactivates
the
setting
of
cookies
in
the
Internet
browser
used,
not
all
functions of our website may be entirely usable.
4. Collection of general data and information
The
website
of
André
Frey
collects
a
series
of
general
data
and
information
when
a
data
subject
or
automated
system
calls
up
the
website.
This
general
data
and
information
are
stored
in
the
server
log
files.
Collected
may
be
(1)
the
browser
types
and
versions
used,
(2)
the
operating
system
used
by
the
accessing
system,
(3)
the
website
from
which
an
accessing
system
reaches
our
website
(so-called
referrers),
(4)
the
sub-websites,
(5)
the
date
and
time
of
access
to
the
Internet
site,
(6)
an
Internet
protocol
address
(IP
address),
(7)
the
Internet
service
provider
of
the
accessing
system,
and
(8)
any
other
similar
data
and
information
that
may
be
used
in
the
event
of
attacks
on our information technology systems.
When
using
these
general
data
and
information,
André
Frey
does
not
draw
any
conclusions
about
the
data
subject.
Rather,
this
information
is
needed
to
(1)
deliver
the
content
of
our
website
correctly,
(2)
optimize
the
content
of
our
website
as
well
as
its
advertisement,
(3)
ensure
the
long-term
viability
of
our
information
technology
systems
and
website
technology,
and
(4)
provide
law
enforcement
authorities
with
the
information
necessary
for
criminal
prosecution
in
case
of
a
cyber-attack.
Therefore,
André
Frey
analyzes
anonymously
collected
data
and
information
statistically,
with
the
aim
of
increasing
the
data
protection
and
data
security
of
our
enterprise,
and
to
ensure
an
optimal
level
of
protection
for
the
personal
data
we
process.
The
anonymous
data
of
the
server
log
files
are
stored
separately
from
all
personal
data
provided
by
a
data
subject.
5. Routine erasure and blocking of personal data
The
data
controller
shall
process
and
store
the
personal
data
of
the
data
subject
only
for
the
period
necessary
to
achieve
the
purpose
of
storage,
or
as
far
as
this
is
granted
by
the
European
legislator
or
other
legislators
in
laws
or
regulations
to
which
the
controller is subject to.
If
the
storage
purpose
is
not
applicable,
or
if
a
storage
period
prescribed
by
the
European
legislator
or
another
competent
legislator
expires,
the
personal
data
are
routinely
blocked
or
erased
in
accordance
with legal requirements.
6. Rights of the data subject
a) Right of confirmation
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
obtain
from
the
controller
the
confirmation
as
to
whether
or
not
personal
data
concerning
him
or
her
are
being
processed.
If
a
data
subject
wishes
to
avail
himself
of
this
right
of
confirmation,
he
or
she
may,
at
any
time,
contact
mail@stenbaecken.com.
b) Right of access
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
obtain
from
the
controller
free
information
about
his
or
her
personal
data
stored
at
any
time
and
a
copy
of
this
information.
Furthermore,
the
European
directives
and
regulations
grant
the
data
subject access to the following information:
•
the purposes of the processing;
•
the categories of personal data concerned;
•
the
recipients
or
categories
of
recipients
to
whom
the
personal
data
have
been
or
will
be
disclosed,
in
particular
recipients
in
third
countries
or
international organisations;
•
where
possible,
the
envisaged
period
for
which
the
personal
data
will
be
stored,
or,
if
not
possible,
the
criteria used to determine that period;
•
the
existence
of
the
right
to
request
from
the
controller
rectification
or
erasure
of
personal
data,
or
restriction
of
processing
of
personal
data
concerning
the
data
subject,
or
to
object
to
such
processing;
•
the
existence
of
the
right
to
lodge
a
complaint
with
a supervisory authority;
•
where
the
personal
data
are
not
collected
from
the
data
subject,
any
available
information
as
to
their
source;
•
the
existence
of
automated
decision-making,
including
profiling,
referred
to
in
Article
22(1)
and
(4)
of
the
GDPR
and,
at
least
in
those
cases,
meaningful
information
about
the
logic
involved,
as
well
as
the
significance
and
envisaged
consequences
of
such
processing
for
the
data
subject.
Furthermore,
the
data
subject
shall
have
a
right
to
obtain
information
as
to
whether
personal
data
are
transferred
to
a
third
country
or
to
an
international
organisation.
Where
this
is
the
case,
the
data
subject
shall
have
the
right
to
be
informed
of
the
appropriate
safeguards relating to the transfer.
If
a
data
subject
wishes
to
avail
himself
of
this
right
of
access,
he
or
she
may,
at
any
time,
contact
mail@stenbaecken.com.
c) Right to rectification
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
obtain
from
the
controller
without
undue
delay
the
rectification
of
inaccurate
personal
data
concerning
him
or
her.
Taking
into
account
the
purposes
of
the
processing,
the
data
subject
shall
have
the
right
to
have
incomplete
personal
data
completed,
including
by
means
of
providing a supplementary statement.
If
a
data
subject
wishes
to
exercise
this
right
to
rectification,
he
or
she
may,
at
any
time,
contact
mail@stenbaecken.com.
d) Right to erasure (Right to be forgotten)
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
obtain
from
the
controller
the
erasure
of
personal
data
concerning
him
or
her
without
undue
delay,
and
the
controller
shall
have
the
obligation
to
erase
personal
data
without
undue
delay
where
one
of
the
following
grounds
applies,
as
long
as
the processing is not necessary:
•
The
personal
data
are
no
longer
necessary
in
relation
to
the
purposes
for
which
they
were
collected or otherwise processed.
•
The
data
subject
withdraws
consent
to
which
the
processing
is
based
according
to
point
(a)
of
Article
6(1)
of
the
GDPR,
or
point
(a)
of
Article
9(2)
of
the
GDPR,
and
where
there
is
no
other
legal
ground
for
the processing.
•
The
data
subject
objects
to
the
processing
pursuant
to
Article
21(1)
of
the
GDPR
and
there
are
no
overriding
legitimate
grounds
for
the
processing,
or
the
data
subject
objects
to
the
processing
pursuant
to Article 21(2) of the GDPR.
•
The personal data have been unlawfully processed.
•
The
personal
data
must
be
erased
for
compliance
with
a
legal
obligation
in
Union
or
Member
State
law to which the controller is subject.
•
The
personal
data
have
been
collected
in
relation
to
the
offer
of
information
society
services
referred
to in Article 8(1) of the GDPR.
If
one
of
the
aforementioned
reasons
applies,
and
a
data
subject
wishes
to
request
the
erasure
of
personal
data
stored
by
André
Frey,
he
or
she
may,
at
any
time,
contact
mail@stenbaecken.com.
André
Frey
shall
promptly
ensure
that
the
erasure
request
is
complied
with immediately.
Where
the
controller
has
made
personal
data
public
and
is
obliged
pursuant
to
Article
17(1)
to
erase
the
personal
data,
the
controller,
taking
account
of
available
technology
and
the
cost
of
implementation,
shall
take
reasonable
steps,
including
technical
measures,
to
inform
other
controllers
processing
the
personal
data
that
the
data
subject
has
requested
erasure
by
such
controllers
of
any
links
to,
or
copy
or
replication
of,
those
personal
data,
as
far
as
processing
is
not
required.
André
Frey
will
arrange
the
necessary measures in individual cases.
e) Right of restriction of processing
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
obtain
from
the
controller
restriction
of
processing
where
one
of
the
following
applies:
•
The
accuracy
of
the
personal
data
is
contested
by
the
data
subject,
for
a
period
enabling
the
controller
to
verify
the
accuracy
of
the
personal
data.
•
The
processing
is
unlawful
and
the
data
subject
opposes
the
erasure
of
the
personal
data
and
requests instead the restriction of their use instead.
•
The
controller
no
longer
needs
the
personal
data
for
the
purposes
of
the
processing,
but
they
are
required
by
the
data
subject
for
the
establishment,
exercise or defence of legal claims.
•
The
data
subject
has
objected
to
processing
pursuant
to
Article
21(1)
of
the
GDPR
pending
the
verification
whether
the
legitimate
grounds
of
the
controller override those of the data subject.
If
one
of
the
aforementioned
conditions
is
met,
and
a
data
subject
wishes
to
request
the
restriction
of
the
processing
of
personal
data
stored
by
André
Frey,
he
or
she
may
at
any
time
contact
mail@stenbaecken.com.
André
Frey
will
arrange
the
restriction of the processing.
f) Right to data portability
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator,
to
receive
the
personal
data
concerning
him
or
her,
which
was
provided
to
a
controller,
in
a
structured,
commonly
used
and
machine-readable
format.
He
or
she
shall
have
the
right
to
transmit
those
data
to
another
controller
without
hindrance
from
the
controller
to
which
the
personal
data
have
been
provided,
as
long
as
the
processing
is
based
on
consent
pursuant
to
point
(a)
of
Article
6(1)
of
the
GDPR
or
point
(a)
of
Article
9(2)
of
the
GDPR,
or
on
a
contract
pursuant
to
point
(b)
of
Article
6(1)
of
the
GDPR,
and
the
processing
is
carried
out
by
automated
means,
as
long
as
the
processing
is
not
necessary
for
the
performance
of
a
task
carried
out
in
the
public
interest
or
in
the
exercise
of
official
authority vested in the controller.
Furthermore,
in
exercising
his
or
her
right
to
data
portability
pursuant
to
Article
20(1)
of
the
GDPR,
the
data
subject
shall
have
the
right
to
have
personal
data
transmitted
directly
from
one
controller
to
another,
where
technically
feasible
and
when
doing
so
does
not
adversely affect the rights and freedoms of others.
In
order
to
assert
the
right
to
data
portability,
the
data subject may at any time mail@stenbaecken.com.
g) Right to object
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
object,
on
grounds
relating
to
his
or
her
particular
situation,
at
any
time,
to
processing
of
personal
data
concerning
him
or
her,
which
is
based
on
point
(e)
or
(f)
of
Article
6(1)
of
the
GDPR.
This
also
applies
to
profiling
based
on
these
provisions.
André
Frey
shall
no
longer
process
the
personal
data
in
the
event
of
the
objection,
unless
we
can
demonstrate
compelling
legitimate
grounds
for
the
processing
which
override
the
interests,
rights
and
freedoms
of
the
data
subject,
or
for
the
establishment,
exercise
or
defence of legal claims.
If
André
Frey
processes
personal
data
for
direct
marketing
purposes,
the
data
subject
shall
have
the
right
to
object
at
any
time
to
processing
of
personal
data
concerning
him
or
her
for
such
marketing.
This
applies
to
profiling
to
the
extent
that
it
is
related
to
such
direct
marketing.
If
the
data
subject
objects
to
André
Frey
to
the
processing
for
direct
marketing
purposes,
André
Frey
will
no
longer
process
the
personal data for these purposes.
In
addition,
the
data
subject
has
the
right,
on
grounds
relating
to
his
or
her
particular
situation,
to
object
to
processing
of
personal
data
concerning
him
or
her
by
the
André
Frey
for
scientific
or
historical
research
purposes,
or
for
statistical
purposes
pursuant
to
Article
89(1)
of
the
GDPR,
unless
the
processing
is
necessary
for
the
performance
of
a
task
carried
out
for reasons of public interest.
In
order
to
exercise
the
right
to
object,
the
data
subject
may
contact
mail@stenbaecken.com.
In
addition,
the
data
subject
is
free
in
the
context
of
the
use
of
information
society
services,
and
notwithstanding
Directive
2002/58/EC,
to
use
his
or
her
right
to
object
by
automated
means
using
technical specifications.
h)
Automated
individual
decision-making,
including
profiling
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
not
to
be
subject
to
a
decision
based
solely
on
automated
processing,
including
profiling,
which
produces
legal
effects
concerning
him
or
her,
or
similarly
significantly
affects
him
or
her,
as
long
as
the
decision
(1)
is
not
is
necessary
for
entering
into,
or
the
performance
of,
a
contract
between
the
data
subject
and
a
data
controller,
or
(2)
is
not
authorised
by
Union
or
Member
State
law
to
which
the
controller
is
subject
and
which
also
lays
down
suitable
measures
to
safeguard
the
data
subject's
rights
and
freedoms
and
legitimate
interests,
or
(3)
is
not
based
on the data subject's explicit consent.
If
the
decision
(1)
is
necessary
for
entering
into,
or
the
performance
of,
a
contract
between
the
data
subject
and
a
data
controller,
or
(2)
it
is
based
on
the
data
subject's
explicit
consent,
André
Frey
shall
implement
suitable
measures
to
safeguard
the
data
subject's
rights
and
freedoms
and
legitimate
interests,
at
least
the
right
to
obtain
human
intervention
on
the
part
of
the
controller,
to
express
his
or
her
point
of
view
and
contest the decision.
If
the
data
subject
wishes
to
exercise
the
rights
concerning
automated
individual
decision-making,
he
or
she
may,
at
any
time,
contact
mail@stenbaecken.com.
i) Right to withdraw data protection consent
Each
data
subject
shall
have
the
right
granted
by
the
European
legislator
to
withdraw
his
or
her
consent
to
processing of his or her personal data at any time.
If
the
data
subject
wishes
to
exercise
the
right
to
withdraw
the
consent,
he
or
she
may,
at
any
time,
contact
mail@stenbaecken.com
.
7.
Data
protection
provisions
about
the
application
and use of Instagram
On
this
website,
the
controller
has
integrated
components
of
the
service
Instagram.
Instagram
is
a
service
that
may
be
qualified
as
an
audiovisual
platform,
which
allows
users
to
share
photos
and
videos,
as
well
as
disseminate
such
data
in
other
social
networks.
The
operating
company
of
the
services
offered
by
Instagram
is
Facebook
Ireland
Ltd.,
4
Grand
Canal
Square, Grand Canal Harbour, Dublin 2 Ireland.
With
each
call-up
to
one
of
the
individual
pages
of
this
Internet
site,
which
is
operated
by
the
controller
and
on
which
an
Instagram
component
(Insta
button)
was
integrated,
the
Internet
browser
on
the
information
technology
system
of
the
data
subject
is
automatically
prompted
to
the
download
of
a
display
of
the
corresponding
Instagram
component
of
Instagram.
During
the
course
of
this
technical
procedure,
Instagram
becomes
aware
of
what
specific
sub-page
of
our website was visited by the data subject.
If
the
data
subject
is
logged
in
at
the
same
time
on
Instagram,
Instagram
detects
with
every
call-up
to
our
website
by
the
data
subject—and
for
the
entire
duration
of
their
stay
on
our
Internet
site—which
specific
sub-page
of
our
Internet
page
was
visited
by
the
data
subject.
This
information
is
collected
through
the
Instagram
component
and
is
associated
with
the
respective
Instagram
account
of
the
data
subject.
If
the
data
subject
clicks
on
one
of
the
Instagram
buttons
integrated
on
our
website,
then
Instagram
matches
this
information
with
the
personal
Instagram
user
account
of
the
data
subject
and
stores
the
personal data.
Instagram
receives
information
via
the
Instagram
component
that
the
data
subject
has
visited
our
website
provided
that
the
data
subject
is
logged
in
at
Instagram
at
the
time
of
the
call
to
our
website.
This
occurs
regardless
of
whether
the
person
clicks
on
the
Instagram
button
or
not.
If
such
a
transmission
of
information
to
Instagram
is
not
desirable
for
the
data
subject,
then
he
or
she
can
prevent
this
by
logging
off
from
their
Instagram
account
before
a
call-up
to
our
website is made.
Further
information
and
the
applicable
data
protection
provisions
of
Instagram
may
be
retrieved
under
https://help.instagram.com/155833707900388
a
n
d
https://www.instagram.com/about/legal/privacy/
.
8.
Data
protection
provisions
about
the
application
and use of YouTube
On
this
website,
the
controller
has
integrated
components
of
YouTube.
YouTube
is
an
Internet
video
portal
that
enables
video
publishers
to
set
video
clips
and
other
users
free
of
charge,
which
also
provides
free
viewing,
review
and
commenting
on
them.
YouTube
allows
you
to
publish
all
kinds
of
videos,
so
you
can
access
both
full
movies
and
TV
broadcasts,
as
well
as
music
videos,
trailers,
and
videos
made
by
users via the Internet portal.
The
operating
company
of
YouTube
is
Google
Ireland
Limited,
Gordon
House,
Barrow
Street,
Dublin,
D04
E5W5, Ireland.
With
each
call-up
to
one
of
the
individual
pages
of
this
Internet
site,
which
is
operated
by
the
controller
and
on
which
a
YouTube
component
(YouTube
video)
was
integrated,
the
Internet
browser
on
the
information
technology
system
of
the
data
subject
is
automatically
prompted
to
download
a
display
of
the
corresponding
YouTube
component.
Further
information
about
YouTube
may
be
obtained
under
https://www.youtube.com/yt/about/en/.
During
the
course
of
this
technical
procedure,
YouTube
and
Google
gain
knowledge
of
what
specific
sub-page
of
our website was visited by the data subject.
If
the
data
subject
is
logged
in
on
YouTube,
YouTube
recognizes
with
each
call-up
to
a
sub-page
that
contains
a
YouTube
video,
which
specific
sub-page
of
our
Internet
site
was
visited
by
the
data
subject.
This
information
is
collected
by
YouTube
and
Google
and
assigned
to
the
respective
YouTube
account
of
the
data subject.
YouTube
and
Google
will
receive
information
through
the
YouTube
component
that
the
data
subject
has
visited
my
website,
if
the
data
subject
at
the
time
of
the
call
to
my
website
is
logged
in
on
YouTube;
this
occurs
regardless
of
whether
the
person
clicks
on
a
YouTube
video
or
not.
If
such
a
transmission
of
this
information
to
YouTube
and
Google
is
not
desirable
for
the
data
subject,
the
delivery
may
be
prevented
if
the
data
subject
logs
off
from
their
own
YouTube
account
before a call-up to our website is made.
YouTube's
data
protection
provisions,
available
at
h
t
t
p
s
:
/
/
w
w
w
.
g
o
o
g
l
e
.
c
o
m
/
i
n
t
l
/
e
n
/
p
o
l
i
c
i
e
s
/
p
r
i
v
a
c
y
/
,
provide
information
about
the
collection,
processing
and use of personal data by YouTube and Google.
9. Legal basis for the processing
Art.
6(1)
lit.
a
GDPR
serves
as
the
legal
basis
for
processing
operations
for
which
we
obtain
consent
for
a
specific
processing
purpose.
If
the
processing
of
personal
data
is
necessary
for
the
performance
of
a
contract
to
which
the
data
subject
is
party,
as
is
the
case,
for
example,
when
processing
operations
are
necessary
for
the
supply
of
goods
or
to
provide
any
other
service,
the
processing
is
based
on
Article
6(1)
lit.
b
GDPR.
The
same
applies
to
such
processing
operations
which
are
necessary
for
carrying
out
pre-
contractual
measures,
for
example
in
the
case
of
inquiries
concerning
my
products
or
services.
Is
André
Frey
subject
to
a
legal
obligation
by
which
processing
of
personal
data
is
required,
such
as
for
the
fulfillment
of
tax
obligations,
the
processing
is
based
on
Art.
6(1)
lit.
c
GDPR.
In
rare
cases,
the
processing
of
personal
data
may
be
necessary
to
protect
the
vital
interests
of
the
data
subject
or
of
another
natural
person.
This
would
be
the
case,
for
example,
if
a
visitor
were
injured
in
my
house
and
his
name,
age,
health
insurance
data
or
other
vital
information
would
have
to
be
passed
on
to
a
doctor,
hospital
or
other
third
party.
Then
the
processing
would
be
based
on
Art.
6(1)
lit.
d
GDPR.
Finally,
processing
operations
could
be
based
on
Article
6(1)
lit.
f
GDPR.
This
legal
basis
is
used
for
processing
operations
which
are
not
covered
by
any
of
the
abovementioned
legal
grounds,
if
processing
is
necessary
for
the
purposes
of
the
legitimate
interests
pursued
by
our
company
or
by
a
third
party,
except
where
such
interests
are
overridden
by
the
interests
or
fundamental
rights
and
freedoms
of
the
data
subject
which
require
protection
of
personal
data.
Such
processing
operations
are
particularly
permissible
because
they
have
been
specifically
mentioned
by
the
European
legislator.
He
considered
that
a
legitimate
interest
could
be
assumed
if
the
data
subject
is
a
client
of
the
controller (Recital 47 Sentence 2 GDPR).
10.
The
legitimate
interests
pursued
by
the
controller or by a third party
Where
the
processing
of
personal
data
is
based
on
Article
6(1)
lit.
f
GDPR
our
legitimate
interest
is
to
carry
out
my
activity
in
favor
of
the
well-being
to
third party.
11.
Period
for
which
the
personal
data
will
be
stored
The
criteria
used
to
determine
the
period
of
storage
of
personal
data
is
the
respective
statutory
retention
period.
After
expiration
of
that
period,
the
corresponding
data
is
routinely
deleted,
as
long
as
it
is
no
longer
necessary
for
the
fulfillment
of
the
contract
or the initiation of a contract.
12.
Provision
of
personal
data
as
statutory
or
contractual
requirement;
Requirement
necessary
to
enter
into
a
contract;
Obligation
of
the
data
subject
to
provide
the
personal
data;
possible
consequences
of failure to provide such data
I
clarify
that
the
provision
of
personal
data
is
partly
required
by
law
(e.g.
tax
regulations)
or
can
also
result
from
contractual
provisions
(e.g.
information
on
the
contractual
partner).
Sometimes
it
may
be
necessary
to
conclude
a
contract
that
the
data
subject
provides
me
with
personal
data,
which
must
subsequently
be
processed
by
myself.
The
data
subject
is,
for
example,
obliged
to
provide
me
with
personal
data
when
André
Frey
signs
a
contract
with
him
or
her.
The
non-provision
of
the
personal
data
would
have
the
consequence
that
the
contract
with
the
data
subject
could
not
be
concluded.
Before
personal
data
is
provided
by
the
data
subject,
the
data
subject
must
contact
mail@stenbaecken.com.
André
Frey
clarifies
to
the
data
subject
whether
the
provision
of
the
personal
data
is
required
by
law
or
contract
or
is
necessary
for
the
conclusion
of
the
contract,
whether
there
is
an
obligation
to
provide
the
personal
data
and
the
consequences
of
non-provision
of the personal data.
13. Existence of automated decision-making
As
a
responsible
person,
I
do
not
use
automatic
decision-making or profiling.
This
Privacy
Policy
has
been
generated
by
the
Privacy
Policy
Generator
of
the
External
Data
Protection
Officers
that
was
developed
in
cooperation
with
the
Media Law Lawyers
from WBS-LAW.