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 S&S Consult GmbH. The use of the Internet pages of the S&S Consult GmbH 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 S&S Consult GmbH. 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 S&S Consult GmbH 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 S&S Consult GmbH 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:

S&S Consult GmbH

Tölzer Straße 1

82031 Grünwald

Deutschland

Phone: +4915129453729

Email: contact@sandsconsult.com

Website: www.sandsconsult.com

3. Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1) lit. e or lit. f GDPR, including profiling based on those provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object to that processing at any time and without giving any reason.

If you object, the S&S Consult GmbH will no longer process the personal data concerned, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or unless the processing serves the establishment, exercise or defence of legal claims. Where the objection is directed against processing for direct marketing purposes, the personal data will no longer be processed for those purposes in any event.

An objection is not subject to any particular form. It is sufficient to send it to contact@sandsconsult.com or to the postal address of the controller given above. Notwithstanding Directive 2002/58/EC, you may also exercise your right to object by automated means using technical specifications.

The remaining rights of the data subject are set out below, in the section "Rights of the data subject".

4. Data protection officer

The S&S Consult GmbH has not appointed a Datenschutzbeauftragter (data protection officer), and is not obliged to appoint one. Fewer than 20 persons are permanently engaged in the automated processing of personal data at our enterprise, and none of the further conditions of § 38 Abs. 1 Bundesdatenschutzgesetz (BDSG) is met.

Data protection matters are handled by the management of the controller. All enquiries about this data protection declaration, and all requests to exercise the rights described in it, may be addressed to:

Email: contact@sandsconsult.com

Postal address: as stated for the controller above.

5. Cookies

The Internet pages of the S&S Consult GmbH 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 S&S Consult GmbH 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.

6. Collection of general data and information

The website of the S&S Consult GmbH 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 this general data and information, the S&S Consult GmbH does not draw any conclusions about the data subject. This information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website, (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 the event of a cyber-attack. The S&S Consult GmbH evaluates this data statistically, with the aim of increasing the data protection and data security of our enterprise.

The IP address contained in the server log files is personal data. A visitor can be identified with the help of third parties, in particular the Internet service provider, so we do not describe this data as anonymous and we do not treat it as anonymous.

This website is hosted on Firebase Hosting, a service of Google. The server log files are therefore created and stored by Google as our hosting provider, which is a recipient of this data. Details of this service and of the transfer of data to Google are set out below, in the section on Firebase.

The legal basis for the processing of the server log files is Art. 6(1) lit. f GDPR. Our legitimate interest is the secure and reliable delivery of this website and the protection of our information technology systems against misuse and attack. The log data is stored separately from any personal data that a data subject provides to us through a form or by e-mail.

7. Contact possibility via the website

You can contact us by e-mail, by telephone or via the forms on this website. The data you provide (for example name, e-mail address, telephone number, company, the content of your message and any attachments) is processed in order to handle your enquiry. Messages submitted via the forms are received by our own server function and forwarded to us by e-mail, and you receive a confirmation e-mail (see the section on contact forms and e-mail delivery below). Depending on the language or subject of your enquiry, it is also sent to a specialist partner who works with us on that market. The legal basis is Art. 6(1) lit. b GDPR where the enquiry relates to a contract or to pre-contractual measures, and otherwise Art. 6(1) lit. f GDPR; our legitimate interest is answering enquiries addressed to us. We delete the data once the enquiry has been dealt with in full, unless statutory retention obligations apply.

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 S&S Consult GmbH, he or she may, at any time, contact any employee of the controller. An employee of S&S Consult GmbH 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 S&S Consult GmbH 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 S&S Consult GmbH, he or she may at any time contact any employee of the controller. The employee of the S&S Consult GmbH 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 S&S Consult GmbH.

g) Right to object

Because of its importance, the right to object is set out separately at the beginning of this data protection declaration, in the section "Right to object". It covers in particular processing based on Art. 6(1) lit. e or lit. f GDPR, profiling based on those provisions, and processing for direct marketing purposes.

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 S&S Consult GmbH 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 S&S Consult GmbH.

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 S&S Consult GmbH.

10. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, every data subject has the right under Art. 77 GDPR to lodge a complaint with a supervisory authority if the data subject considers that the processing of personal data relating to him or her infringes the GDPR.

The supervisory authority responsible for the S&S Consult GmbH is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)

Promenade 18

91522 Ansbach

Deutschland

Website: www.lda.bayern.de

A complaint does not have to be lodged with that authority. Under Art. 77(1) GDPR, a data subject may instead lodge the complaint with the supervisory authority of the Member State of his or her habitual residence or place of work, or of the place of the alleged infringement. Data subjects who live or work outside Germany are therefore free to turn to the data protection authority of their own country.

11. Data protection provisions about contact forms and e-mail delivery (Firebase Cloud Functions, Lettermint)

Enquiries submitted through the forms on this website are received by a server function that we operate on Cloud Functions for Firebase in the Frankfurt region (Germany). The function checks the submission and forwards it by e-mail; it does not store the enquiry. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. In individual cases data may be processed by Google LLC in the United States, which is certified under the EU-U.S. Data Privacy Framework.

The e-mails are sent via Lettermint, a service of Lettermint B.V., Willemsvaart 16B, Unit 1.08, 8019 AB Zwolle, the Netherlands, which processes the data on our behalf on servers in the European Union under a data processing agreement. The e-mails contain no tracking pixels and no tracked links.

The data processed is the content of the submitted form, which may include name, e-mail address, telephone number, company name, website, country or region, the subject of the enquiry, any free-text message and any attached file, together with the technical data needed to process the request, such as the IP address, which is used briefly to protect the forms against abuse. To help us understand how visitors find us, the form also transmits the page it was sent from, the first page you opened during the visit, the address of the website that referred you (if your browser transmits it) and any campaign parameters contained in the link you followed (for example utm_source); for ad clicks only the name of the ad network is transmitted, not the click ID. This information is held only in the memory of your browser for the duration of the visit and is not stored on your device.

The legal basis is Art. 6(1) lit. b GDPR where the enquiry concerns the initiation or performance of a contract, and otherwise Art. 6(1) lit. f GDPR; our legitimate interest is answering enquiries addressed to us and protecting the forms against abuse. Providing the data is voluntary; without it, however, the enquiry cannot be answered. The e-mails are deleted once the enquiry has been dealt with in full and no statutory retention obligations prevent erasure. The privacy policy of Lettermint is available at https://lettermint.co/privacy.

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

The controller has integrated a booking calendar operated by Calendly on the appointment page of this website. Calendly is a scheduling service that allows a data subject to select an available appointment slot.

The operating company is Calendly LLC, 271 17th St NW, Atlanta, GA 30363, UNITED STATES.

The Calendly calendar is not loaded automatically. It is embedded only after the data subject has given consent for this category, or has actively clicked to load the calendar on the page in question. Until that point no connection to Calendly is established and no data is transmitted to Calendly.

Once the calendar is loaded, the data subject's IP address is transmitted to Calendly, and Calendly may store information on the data subject's device. If the data subject books an appointment, the data entered for that purpose — in particular name, e-mail address and the chosen time — is processed by Calendly and made available to the controller.

The legal basis for loading the calendar and for the associated storage of and access to information on the data subject's device is the data subject's consent under Art. 6(1) lit. a GDPR in conjunction with § 25(1) TDDDG. Consent may be withdrawn at any time with effect for the future. The legal basis for processing an appointment that has actually been booked is Art. 6(1) lit. b GDPR. As Calendly processes data in the United States, the transfer is based primarily on the European Commission's adequacy decision of 10 July 2023 on the EU-US Data Privacy Framework, under which Calendly LLC is certified, and additionally, as a fallback, on the EU standard contractual clauses pursuant to Art. 46(2)(c) GDPR. The applicable privacy policy of Calendly is available at https://calendly.com/privacy.

13. Data protection provisions about the application and use of Trustpilot

The controller has integrated a review widget operated by Trustpilot on this website, which displays reviews of the controller published on Trustpilot.

The operating company is Trustpilot A/S, Pilestræde 58, 5th floor, 1112 Copenhagen, Denmark.

The Trustpilot widget is not loaded automatically. The script required to display it is loaded only after the data subject has given consent for this category. Until that point the website displays a plain hyperlink to the controller's Trustpilot profile, and no connection to Trustpilot is established unless the data subject clicks that link.

Once the widget is loaded, the data subject's IP address is transmitted to Trustpilot, and Trustpilot may store information on the data subject's device.

The legal basis for loading the widget and for the associated storage of and access to information on the data subject's device is the data subject's consent under Art. 6(1) lit. a GDPR in conjunction with § 25(1) TDDDG. Consent may be withdrawn at any time with effect for the future. The applicable privacy policy of Trustpilot is available at https://legal.trustpilot.com/end-user-privacy-terms.

14. Data protection provisions about the application and use of Firebase

This website is hosted on Firebase Hosting and, subject to consent, uses Firebase Analytics for reach measurement. Both are services of Google. Firebase Analytics is the measurement component of Google Analytics 4 (GA4). No separate Google Analytics tag, no gtag.js and no Google Tag Manager container is used on this website.

The operating company is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, for data subjects in the European Economic Area, and Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, UNITED STATES.

As the website is hosted on Firebase Hosting, technical data required to deliver the website, in particular the IP address of the requesting device, the time of the request, the pages requested and the browser and operating system used, is processed on delivery of each page. This processing is necessary in order to deliver the website and is based on Art. 6(1) lit. f GDPR.

Firebase Analytics is not loaded when the website is called up. The Firebase script is requested from Google's servers, and an identifier is stored on the data subject's device, only after the data subject has actively switched on the analytics category in the cookie settings of this website and saved that choice. Until that moment no analytics data is collected and no connection to Google is established for analytics purposes. The analytics category is switched off by default and is never pre-selected, because a pre-ticked box would not constitute valid consent. Firebase Analytics is additionally never loaded when this website is called up from a local development environment.

Once it has been loaded, Firebase Analytics processes in particular the pages called up, the time and duration of use, an approximate location derived from the IP address, and the browser, device and operating system used, and it stores an identifier on the data subject's device. This data may be transmitted to Google in the United States of America and processed there. The transfer is based primarily on the European Commission's adequacy decision of 10 July 2023 on the EU-US Data Privacy Framework, under which Google LLC is certified, and additionally, as a fallback, on the EU standard contractual clauses pursuant to Art. 46(2)(c) GDPR.

The legal basis for loading Firebase Analytics and for the associated storage of and access to information on the data subject's device is the data subject's consent under Art. 6(1) lit. a GDPR in conjunction with § 25(1) TDDDG. The legal basis for the hosting of this website is Art. 6(1) lit. f GDPR.

Consent may be withdrawn at any time with effect for the future. To withdraw it, the data subject does not have to change any browser setting: it is sufficient to reopen the cookie settings of this website, switch the analytics category off and save that choice, which stops any further collection. Deleting the site data stored by this website in the browser also removes the stored choice, after which the cookie banner is displayed again.

The applicable privacy policy of Google is available at https://policies.google.com/privacy.

15. 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).

16. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Art. 6(1) lit. f GDPR, the legitimate interests we pursue are the following:

• the secure and reliable delivery of this website and the protection of our information technology systems against misuse and attack;
• responding to business enquiries addressed to us and maintaining the resulting business relationship;
• the establishment, exercise or defence of legal claims.

We do not rely on Art. 6(1) lit. f GDPR for reach measurement. Firebase Analytics is loaded only where the data subject has consented to it.

17. Period for which the personal data will be stored

Personal data is erased as soon as the purpose for which it was stored ceases to apply and no statutory retention obligation prevents erasure. In detail, the following periods apply:

• Website enquiries and form submissions: erased 6 months after the enquiry has been closed, unless a contract results from the enquiry.
• Contract, invoicing and tax records: retained for 6 years under § 257 Handelsgesetzbuch (HGB) or for 10 years under § 147 Abgabenordnung (AO), whichever applies. The period runs from the end of the calendar year in which the document was created.
• Records of consent given and withdrawn: retained for as long as the consent is in force, and for a further 3 years after it has been withdrawn, so that the lawfulness of the processing can be demonstrated.
• Appointment bookings: erased 6 months after the appointment has taken place or has been cancelled.
• Firebase Analytics / Google Analytics 4: Event data is retained for a maximum of 14 months, the longest period Google offers for standard properties. Aggregated reporting data is retained by Google independently of this setting.
• Hosting server logs: stored for the retention period applied by Google to Firebase Hosting request logs.

Where personal data has to be kept in order to comply with a statutory retention obligation, its processing is restricted for the remainder of that period instead of the data being used further. After the period has expired, the data is erased routinely.

18. 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.

19. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.