Политика за сигурност и поверителност

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 Budilnik Ltd. The use of the Internet pages of the Budilnik
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 Budilnik 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 Budilnik 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 Budilnik
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:

Budilnik Ltd

637 Green
Lanes

London, N8
0RE, UK

Phone: 07425106442

Email: erusanov@budilnik.com

Website:www.budilnik.com

3. Cookies

The Internet pages of the Budilnik 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 Budilnik
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 Budilnik 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 Budilnik 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 Budilnik 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. Registration on our website

The data subject has the possibility to
register on the website of the controller with the indication of personal data.
Which personal data are transmitted to the controller is determined by the
respective input mask used for the registration. The personal data entered by
the data subject are collected and stored exclusively for internal use by the
controller, and for his own purposes. The controller may request transfer to
one or more processors (e.g. a parcel service) that also uses personal data for
an internal purpose which is attributable to the controller.

By registering on the website of the
controller, the IP address—assigned by the Internet service provider (ISP) and
used by the data subject—date, and time of the registration are also stored.
The storage of this data takes place against the background that this is the
only way to prevent the misuse of our services, and, if necessary, to make it
possible to investigate committed offenses. Insofar, the storage of this data
is necessary to secure the controller. This data is not passed on to third
parties unless there is a statutory obligation to pass on the data, or if the
transfer serves the aim of criminal prosecution.

The registration of the data subject, with
the voluntary indication of personal data, is intended to enable the controller
to offer the data subject contents or services that may only be offered to
registered users due to the nature of the matter in question. Registered
persons are free to change the personal data specified during the registration
at any time, or to have them completely deleted from the data stock of the
controller.

The data controller shall, at any time,
provide information upon request to each data subject as to what personal data
are stored about the data subject. In addition, the data controller shall
correct or erase personal data at the request or indication of the data
subject, insofar as there are no statutory storage obligations. The entirety of
the controller’s employees are available to the data subject in this respect as
contact persons.

6. Contact possibility via the website

The website of the Budilnik 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.

7. Comments function in the blog on the
website

The Budilnik ltd offers users the
possibility to leave individual comments on individual blog contributions on a
blog, which is on the website of the controller. A blog is a web-based,
publicly-accessible portal, through which one or more people called bloggers or
web-bloggers may post articles or write down thoughts in so-called blogposts.
Blogposts may usually be commented by third parties.

If a data subject leaves a comment on the
blog published on this website, the comments made by the data subject are also
stored and published, as well as information on the date of the commentary and
on the user’s (pseudonym) chosen by the data subject. In addition, the IP
address assigned by the Internet service provider (ISP) to the data subject is
also logged. This storage of the IP address takes place for security reasons,
and in case the data subject violates the rights of third parties, or posts
illegal content through a given comment. The storage of these personal data is,
therefore, in the own interest of the data controller, so that he can exculpate
in the event of an infringement. This collected personal data will not be
passed to third parties, unless such a transfer is required by law or serves
the aim of the defense of the data controller.

8. 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.

9. 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 Budilnik Ltd, he or she may, at any
time, contact any employee of the controller. An employee of Budilnik 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 Budilnik 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 Budilnik Ltd, he
or she may at any time contact any employee of the controller. The employee of
the Budilnik 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 Budilnik 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 Budilnik 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 Budilnik
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 Budilnik Ltd to the processing for direct marketing purposes, the Budilnik
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 Budilnik 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 Budilnik
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 Budilnik 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 Budilnik
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 Budilnik Ltd.

10. 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.

11. 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/.

12. Data protection provisions about the
application and use of Twitter

On this website, the controller has
integrated components of Twitter. Twitter is a multilingual,
publicly-accessible microblogging service on which users may publish and spread
so-called ‘tweets,’ e.g. short messages, which are limited to 280 characters.
These short messages are available for everyone, including those who are not
logged on to Twitter. The tweets are also displayed to so-called followers of
the respective user. Followers are other Twitter users who follow a user’s tweets.
Furthermore, Twitter allows you to address a wide audience via hashtags, links
or retweets.

The operating company of Twitter is
Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, 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
Twitter component (Twitter button) was integrated, the Internet browser on the
information technology system of the data subject is automatically prompted to
download a display of the corresponding Twitter component of Twitter. Further
information about the Twitter buttons is available under
https://about.twitter.com/de/resources/buttons. During the course of this
technical procedure, Twitter gains knowledge of what specific sub-page of our
website was visited by the data subject. The purpose of the integration of the
Twitter component is a retransmission of the contents of this website to allow
our users to introduce this web page to the digital world and increase our
visitor numbers.

If the data subject is logged in at the
same time on Twitter, Twitter 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 Twitter component and associated with
the respective Twitter account of the data subject. If the data subject clicks
on one of the Twitter buttons integrated on our website, then Twitter assigns
this information to the personal Twitter user account of the data subject and
stores the personal data.

Twitter receives information via the
Twitter component that the data subject has visited our website, provided that
the data subject is logged in on Twitter at the time of the call-up to our
website. This occurs regardless of whether the person clicks on the Twitter
component or not. If such a transmission of information to Twitter is not
desirable for the data subject, then he or she may prevent this by logging off
from their Twitter account before a call-up to our website is made.

The applicable data protection provisions
of Twitter may be accessed under https://twitter.com/privacy?lang=en.

13. 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).

14. 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.

15. 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.

16. 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.

17. 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
DGD – Your
External DPO

that was developed in cooperation with
German Lawyers from WILDE BEUGER SOLMECKE, Cologne.