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DATA PROTECTION

Privacy Policy

We are very delighted that you have shown interest in our enterprise. Data protection is of a
particularly high priority for the management of the B. W. Necklaces Ltd.. The use of the Internet
pages of the B. W. Necklaces Ltd. is possible without any indication of personal data; however, if a
data subject wants to use special enterprise services via our website, processing of personal data
could become necessary. If the processing of personal data is necessary and there is no statutory
basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of
a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in
accordance with the country-specific data protection regulations applicable to the B. W. Necklaces
Ltd.. By means of this data protection declaration, our enterprise would like to inform the general
public of the nature, scope, and purpose of the personal data we collect, use and process.
Furthermore, data subjects are informed, by means of this data protection declaration, of the rights
to which they are entitled.
As the controller, the B. W. Necklaces Ltd. has implemented numerous technical and organizational
measures to ensure the most complete protection of personal data processed through this website.
However, Internet-based data transmissions may in principle have security gaps, so absolute
protection may not be guaranteed. For this reason, every data subject is free to transfer personal
data to us via alternative means, e.g. by telephone.

1. Definitions
The data protection declaration of the B. W. Necklaces Ltd. is based on the terms used by the
European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data
protection declaration should be legible and understandable for the general public, as well as our
customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (“data
subject”). An identifiable natural person is one who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an identification number, location data, an
online identifier or to one or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the
controller responsible for the processing.
c) Processing
Processing is any operation or set of operations which is performed on personal data or on sets of
personal data, whether or not by automated means, such as collection, recording, organisation,
structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination, restriction, erasure or
destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their
processing in the future.
e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal
data to evaluate certain personal aspects relating to a natural person, in particular to analyse or
predict aspects concerning that natural person’s performance at work, economic situation, health,
personal preferences, interests, reliability, behaviour, location or movements.
f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no
longer be attributed to a specific data subject without the use of additional information, provided
that such additional information is kept separately and is subject to technical and organisational
measures to ensure that the personal data are not attributed to an identified or identifiable natural
person.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority,
agency or other body which, alone or jointly with others, determines the purposes and means of the
processing of personal data; where the purposes and means of such processing are determined by
Union or Member State law, the controller or the specific criteria for its nomination may be provided
for by Union or Member State law.
h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes
personal data on behalf of the controller.
i) Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the personal
data are disclosed, whether a third party or not. However, public authorities which may receive
personal data in the framework of a particular inquiry in accordance with Union or Member State law
shall not be regarded as recipients; the processing of those data by those public authorities shall be
in compliance with the applicable data protection rules according to the purposes of the processing.
j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject,
controller, processor and persons who, under the direct authority of the controller or processor, are
authorised to process personal data.
k) Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the
data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies
agreement to the processing of personal data relating to him or her.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection
laws applicable in Member states of the European Union and other provisions related to data
protection is:
B. W. Necklaces Ltd.
Corner Draper and Belle Rose Ave.
00000 Quatre-Bornes Mauritius
Mauritius
Phone: 0899044542
Email: info@berndwilhelm.com
Website: www.berndwilhelm.com
3. Cookies
The Internet pages of the B. W. Necklaces Ltd. 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, the B. W. Necklaces Ltd. 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 our 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 our 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 the B. W. Necklaces Ltd. collects a series of general data and information when a data
subject or automated system calls up the website. This general data and information are stored in
the server log files. Collected may be (1) the browser types and versions used, (2) the operating
system used by the accessing system, (3) the website from which an accessing system reaches our
website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet
site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing
system, and (8) any other similar data and information that may be used in the event of attacks on
our information technology systems.
When using these general data and information, the B. W. Necklaces Ltd. does not draw any
conclusions about the data subject. Rather, this information is needed to (1) deliver the content of
our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure
the long-term viability of our information technology systems and website technology, and (4)
provide law enforcement authorities with the information necessary for criminal prosecution in case
of a cyber-attack. Therefore, the B. W. Necklaces Ltd. 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. Contact possibility via the website
The website of the B. W. Necklaces Ltd. contains information that enables a quick electronic contact
to our enterprise, as well as direct communication with us, which also includes a general address of
the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via
a contact form, the personal data transmitted by the data subject are automatically stored. Such
personal data transmitted on a voluntary basis by a data subject to the data controller are stored for
the purpose of processing or contacting the data subject. There is no transfer of this personal data to
third parties.
6. 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.
7. Rights of the data subject
a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the
controller the confirmation as to whether or not personal data concerning him or her are being
processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any
time, contact any employee of the controller.
b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the
controller free information about his or her personal data stored at any time and a copy of this
information. Furthermore, the European directives and regulations grant the data subject access to
the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed,
in particular recipients in third countries or international organisations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible,
the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data, or
restriction of processing of personal data concerning the data subject, or to object to such
processing;
the existence of the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their
source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of
the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the
significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data
are transferred to a third country or to an international organisation. Where this is the case, the data
subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any
employee of the controller.
c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the
controller without undue delay the rectification of inaccurate personal data concerning him or her.
Taking into account the purposes of the processing, the data subject shall have the right to have
incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any
employee of the controller.
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the
controller the erasure of personal data concerning him or her without undue delay, and the
controller shall have the obligation to erase personal data without undue delay where one of the
following grounds applies, as long as the processing is not necessary:
The personal data are no longer necessary in relation to the purposes for which they were collected
or otherwise processed.
The data subject withdraws consent to which the processing is based according to point (a) of Article
6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground
for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no
overriding legitimate grounds for the processing, or the data subject objects to the processing
pursuant to Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State
law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred
to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of
personal data stored by the B. W. Necklaces Ltd., he or she may, at any time, contact any employee
of the controller. An employee of B. W. Necklaces Ltd. shall promptly ensure that the erasure request
is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase
the personal data, the controller, taking account of available technology and the cost of
implementation, shall take reasonable steps, including technical measures, to inform other
controllers processing the personal data that the data subject has requested erasure by such
controllers of any links to, or copy or replication of, those personal data, as far as processing is not
required. An employees of the B. W. Necklaces Ltd. will arrange the necessary measures in individual
cases.
e) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the
controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the
controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and
requests instead the restriction of their use instead.
The controller no longer needs the personal data for the purposes of the processing, but they are
required by the data subject for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the
verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction
of the processing of personal data stored by the B. W. Necklaces Ltd., he or she may at any time
contact any employee of the controller. The employee of the B. W. Necklaces Ltd. will arrange the
restriction of the processing.
f) Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal
data concerning him or her, which was provided to a controller, in a structured, commonly used and
machine-readable format. He or she shall have the right to transmit those data to another controller
without hindrance from the controller to which the personal data have been provided, as long as the
processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article
9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the
processing is carried out by automated means, as long as the processing is not necessary for the
performance of a task carried out in the public interest or in the exercise of official authority vested
in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR,
the data subject shall have the right to have personal data transmitted directly from one controller to
another, where technically feasible and when doing so does not adversely affect the rights and
freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any
employee of the B. W. Necklaces Ltd..
g) Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds
relating to his or her particular situation, at any time, to processing of personal data concerning him
or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling
based on these provisions.
The B. W. Necklaces Ltd. shall no longer process the personal data in the event of the objection,
unless we can demonstrate compelling legitimate grounds for the processing which override the
interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of
legal claims.
If the B. W. Necklaces Ltd. processes personal data for direct marketing purposes, the data subject
shall have the right to object at any time to processing of personal data concerning him or her for
such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the
data subject objects to the B. W. Necklaces Ltd. to the processing for direct marketing purposes, the
B. W. Necklaces Ltd. 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 B. W. Necklaces Ltd. for scientific
or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR,
unless the processing is necessary for the performance of a task carried out for reasons of public
interest.
In order to exercise the right to object, the data subject may contact any employee of the B. W.
Necklaces Ltd.. In addition, the data subject is free in the context of the use of information society
services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated
means using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a
decision based solely on automated processing, including profiling, which produces legal effects
concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is
necessary for entering into, or the performance of, a contract between the data subject and a data
controller, or (2) is not authorised by Union or Member State law to which the controller is subject
and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and
legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data
subject and a data controller, or (2) it is based on the data subject’s explicit consent, the B. W.
Necklaces Ltd. shall implement suitable measures to safeguard the data subject’s rights and
freedoms and legitimate interests, at least the right to obtain human intervention on the part of the
controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he
or she may, at any time, contact any employee of the B. W. Necklaces Ltd..
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her
consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time,
contact any employee of the B. W. Necklaces Ltd..
8. Data protection provisions about the application and use of Facebook
On this website, the controller has integrated components of the enterprise Facebook. Facebook is a
social network.
A social network is a place for social meetings on the Internet, an online community, which usually
allows users to communicate with each other and interact in a virtual space. A social network may
serve as a platform for the exchange of opinions and experiences, or enable the Internet community
to provide personal or business-related information. Facebook allows social network users to include
the creation of private profiles, upload photos, and network through friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United
States. If a person lives outside of the United States or Canada, the controller is the 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 website, which is operated by the
controller and into which a Facebook component (Facebook plug-ins) was integrated, the web
browser on the information technology system of the data subject is automatically prompted to
download display of the corresponding Facebook component from Facebook through the Facebook
component. An overview of all the Facebook Plug-ins may be accessed under
https://developers.facebook.com/docs/plugins/. During the course of this technical procedure,
Facebook is made aware of what specific sub-site of our website was visited by the data subject.
If the data subject is logged in at the same time on Facebook, Facebook 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-site of our Internet page was visited by the data subject. This information is collected
through the Facebook component and associated with the respective Facebook account of the data
subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g.
the “Like” button, or if the data subject submits a comment, then Facebook matches this information
with the personal Facebook user account of the data subject and stores the personal data.
Facebook always receives, through the Facebook component, information about a visit to our
website by the data subject, whenever the data subject is logged in at the same time on Facebook
during the time of the call-up to our website. This occurs regardless of whether the data subject
clicks on the Facebook component or not. If such a transmission of information to Facebook is not
desirable for the data subject, then he or she may prevent this by logging off from their Facebook
account before a call-up to our website is made.
The data protection guideline published by Facebook, which is available at
https://facebook.com/about/privacy/, provides information about the collection, processing and use
of personal data by Facebook. In addition, it is explained there what setting options Facebook offers
to protect the privacy of the data subject. In addition, different configuration options are made
available to allow the elimination of data transmission to Facebook. These applications may be used
by the data subject to eliminate a data transmission to Facebook.
9. Data protection provisions about the application and use of Google Analytics (with anonymization
function)
On this website, the controller has integrated the component of Google Analytics (with the
anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection,
gathering, and analysis of data about the behavior of visitors to websites. A web analysis service
collects, inter alia, data about the website from which a person has come (the so-called referrer),
which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web
analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit
analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain
View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the application “_gat.
_anonymizeIp”. By means of this application the IP address of the Internet connection of the data
subject is abridged by Google and anonymised when accessing our websites from a Member State of
the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses
the collected data and information, inter alia, to evaluate the use of our website and to provide
online reports, which show the activities on our websites, and to provide other services concerning
the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The
definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze
the use of our website. With each call-up to one of the individual pages of this Internet site, which is
operated by the controller and into which a Google Analytics component was integrated, the
Internet browser on the information technology system of the data subject will automatically submit
data through the Google Analytics component for the purpose of online advertising and the
settlement of commissions to Google. During the course of this technical procedure, the enterprise
Google gains knowledge of personal information, such as the IP address of the data subject, which
serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create
commission settlements.
The cookie is used to store personal information, such as the access time, the location from which
the access was made, and the frequency of visits of our website by the data subject. With each visit
to our Internet site, such personal data, including the IP address of the Internet access used by the
data subject, will be transmitted to Google in the United States of America. These personal data are
stored by Google in the United States of America. Google may pass these personal data collected
through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any
time by means of a corresponding adjustment of the web browser used and thus permanently deny
the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google
Analytics from setting a cookie on the information technology system of the data subject. In addition,
cookies already in use by Google Analytics may be deleted at any time via a web browser or other
software programs.
In addition, the data subject has the possibility of objecting to a collection of data that are generated
by Google Analytics, which is related to the use of this website, as well as the processing of this data
by Google and the chance to preclude any such. For this purpose, the data subject must download a
browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser
add-on tells Google Analytics through a JavaScript, that any data and information about the visits of
Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is
considered an objection by Google. If the information technology system of the data subject is later
deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to
disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other
person who is attributable to their sphere of competence, or is disabled, it is possible to execute the
reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under
https://www.google.com/intl/en/policies/privacy/ and under
http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the
following Link https://www.google.com/analytics/.
10. 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 YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED
STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View,
CA 94043-1351, UNITED STATES.
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 our website, if the data subject at the time of the call to our 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 callup
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.
11. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent
for a specific processing purpose. If the processing of personal data is necessary for the performance
of a contract to which the data subject is party, as is the case, for example, when processing
operations are necessary for the supply of goods or to provide any other service, the processing is
based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary
for carrying out pre-contractual measures, for example in the case of inquiries concerning our
products or services. Is our company subject to a legal obligation by which processing of personal
data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c
GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of
the data subject or of another natural person. This would be the case, for example, if a visitor were
injured in our company and his name, age, health insurance data or other vital information would
have to be passed on to a doctor, hospital or other third party. Then the processing would be based
on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This
legal basis is used for processing operations which are not covered by any of the abovementioned
legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our
company or by a third party, except where such interests are overridden by the interests or
fundamental rights and freedoms of the data subject which require protection of personal data. Such
processing operations are particularly permissible because they have been specifically mentioned by
the European legislator. He considered that a legitimate interest could be assumed if the data subject
is a client of the controller (Recital 47 Sentence 2 GDPR).
12. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to
carry out our business in favor of the well-being of all our employees and the shareholders.
13. 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.
14. Provision of personal data as statutory or contractual requirement; Requirement necessary to
enter into a contract; Obligation of the data subject to provide the personal data; possible
consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can
also result from contractual provisions (e.g. information on the contractual partner). Sometimes it
may be necessary to conclude a contract that the data subject provides us with personal data, which
must subsequently be processed by us. The data subject is, for example, obliged to provide us with
personal data when our company signs a contract with him or her. The non-provision of the personal
data would have the consequence that the contract with the data subject could not be concluded.
Before personal data is provided by the data subject, the data subject must contact any employee.
The employee clarifies to the data subject whether the provision of the personal data is required by
law or contract or is necessary for the conclusion of the contract, whether there is an obligation to
provide the personal data and the consequences of non-provision of the personal data.
15. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
This Privacy Policy has been generated by the Privacy Policy Generator of the External Data
Protection Officers that was developed in cooperation with the Media Law Lawyers from WBS-LAW.