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Privacy policy

This privacy policy explains the nature, scope, and purpose of processing personal data (hereinafter "data") within our online offering and the associated websites, functions, and content, as well as external online presences such as our social media profiles (hereinafter collectively referred to as the "online offering").

With regard to the terminology used, such as "processing" or "controller", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Controller

Groenewold IT Solutions GmbH
Mühlenstraße 157
26789 Leer (East Frisia), Germany
Email: info@groenewold-it.solutions
Managing director / owner: Björn Groenewold
Link to legal notice: Legal notice

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Contact data (e.g. email, phone numbers).
  • Content data (e.g. text entries, photographs, videos).
  • Usage data (e.g. pages visited, interest in content, access times).
  • Meta/communication data (e.g. device information, IP addresses).

Categories of data subjects

Visitors and users of the online offering (hereinafter we collectively refer to data subjects as "users").

Purpose of processing

  • Provision of the online offering, its functions, and content.
  • Responding to contact inquiries and communicating with users.
  • Security measures.
  • Reach measurement/marketing

Terminology used

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "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, identification number, location data, or online identifier (e.g. a cookie).

This includes one or more specific characteristics expressing the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

"Processing" means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data.

"Pseudonymization" means processing personal data in such a manner that the data can no longer be attributed to a specific data subject without the use of additional information.

Such additional information is kept separately and subject to technical and organizational measures to ensure that personal data are not attributed to an identified or identifiable natural person.

"Profiling" means any form of automated processing of personal data to evaluate certain personal aspects relating to a natural person.

This includes in particular analyzing or predicting aspects such as work performance, economic situation, health, preferences, interests, reliability, behavior, or location.

A "controller" is the natural or legal person, authority, institution, or other body which alone or jointly with others determines the purposes and means of processing personal data.

A "processor" is a natural or legal person, authority, institution, or other body which processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Article 13 GDPR, we inform you of the legal bases for our data processing. Where the legal basis is not stated in this privacy policy, the following applies:

The legal basis for obtaining consent is Article 6(1)(a) and Article 7 GDPR. Processing to fulfill our services, contractual measures, and respond to inquiries is based on Article 6(1)(b) GDPR. Fulfilling our legal obligations is governed by Article 6(1)(c) GDPR; safeguarding our legitimate interests by Article 6(1)(f) GDPR.

Where processing is necessary to protect vital interests of the data subject or another natural person, Article 6(1)(d) GDPR serves as the legal basis.

Security measures

Pursuant to Article 32 GDPR, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account the state of the art, implementation costs, nature and scope of processing, and the likelihood and severity of risks to your rights and freedoms.

This includes ensuring confidentiality, integrity, and availability – by controlling physical access, access rights, input, transmission, and separation.

We have procedures for exercising data subject rights, deletion, and responding to threats. We consider data protection when developing and selecting hardware, software, and procedures (Article 25 GDPR: data protection by design and by default).

Cooperation with processors and third parties

Disclosure, transmission, or access to data by processors or third parties occurs only on the basis of legal permission, your consent, a legal obligation, or our legitimate interests.

Examples: transmission to payment service providers for contract fulfillment (Article 6(1)(b) GDPR) or use of contractors and web hosts.

Where we commission third parties to process data on the basis of a "data processing agreement", this is done pursuant to Article 28 GDPR.

Transfers to third countries

Processing in third countries (outside the EU/EEA) or disclosure to third parties occurs only to fulfill (pre)contractual obligations, on the basis of your consent, a legal obligation, or our legitimate interests.

Subject to legal or contractual permissions, we process data in third countries only where the special requirements of Articles 44 et seq. GDPR are met – e.g. through an recognized level of data protection (e.g. the former "Privacy Shield" for the USA) or officially recognized standard contractual clauses.

Rights of data subjects

You have the right to request confirmation as to whether data concerning you is being processed and to access such data and further information and copies of the data pursuant to Article 15 GDPR.

Pursuant to Article 16 GDPR, you have the right to request completion of data concerning you or correction of inaccurate data concerning you.

Pursuant to Article 17 GDPR, you have the right to request erasure of data concerning you without undue delay, or alternatively pursuant to Article 18 GDPR to request restriction of processing.

You have the right pursuant to Article 20 GDPR to receive data concerning you that you have provided to us and to request transmission to another controller.

You also have the right pursuant to Article 77 GDPR to lodge a complaint with the competent supervisory authority.

Right to withdraw consent

You have the right to withdraw consent granted pursuant to Article 7(3) GDPR with effect for the future.

Right to object

You may object at any time to future processing of data concerning you pursuant to Article 21 GDPR. The objection may in particular be made against processing for direct marketing purposes.

Cookies and right to object to direct advertising

"Cookies" are small files stored on users' computers. A cookie stores information about a user (or their device) during or after visiting an online offering.

Session cookies (transient cookies): These are deleted after the user leaves the offering and closes the browser. They may store e.g. shopping cart contents or login status.

Persistent cookies: These remain stored after the browser is closed – e.g. for login status on return visits or for reach measurement and marketing.

First-party and third-party cookies: First-party cookies are set by the operator of the online offering. Third-party cookies are set by other providers.

We may use temporary and persistent cookies and explain this within our privacy policy.

If users do not want cookies stored on their computer, they are asked to disable the corresponding option in their browser system settings. Stored cookies can be deleted in browser settings. Excluding cookies may lead to functional limitations of this online offering.

A general objection to cookies used for online marketing purposes can be declared for many services, especially in the case of tracking, via the EU site http://www.youronlinechoices.com/. Furthermore, cookie storage can be prevented by disabling them in browser settings. Please note that not all functions of this online offering may then be available.

Deletion of data

Data is deleted or processing restricted pursuant to Articles 17 and 18 GDPR. Unless stated otherwise here, we delete stored data when it is no longer required for its purpose and no retention obligations apply.

Where data is required for other legally permissible purposes, processing is restricted (data is blocked) – e.g. for commercial or tax retention obligations.

Germany: Retention e.g. 10 years pursuant to Sections 147(1) AO, 257(1) nos. 1 and 4, (4) HGB (books, records, accounting documents, etc.) and 6 years pursuant to Section 257(1) nos. 2 and 3, (4) HGB (commercial letters).

Austria: E.g. 7 years pursuant to Section 132(1) BAO (accounting, documents, etc.), 22 years for real estate, 10 years for MOSS-relevant documents.

Business-related processing

Additionally, we process contract data (e.g. subject matter, term, customer category) and payment data (e.g. bank details, payment history) of our customers, prospects, and business partners for contractual services, customer service, marketing, advertising, and market research.

Agency services

We process customer data in the context of our contractual services – including conceptual and strategic consulting, campaign planning, software and design development/maintenance, implementation of campaigns and processes, server administration, data analysis, and training.

We process inventory, contact, content, contract, and payment data as well as usage and metadata (e.g. for performance measurement). We generally do not process special categories of personal data except within commissioned processing. Affected parties include our customers, prospects, their customers, users, website visitors, employees, and third parties.

Purpose: provision of contractual services, billing, and customer service. Legal bases: Article 6(1)(b) GDPR (contract), Article 6(1)(f) GDPR (analysis, statistics, security). We process only necessary data and indicate necessity; disclosure to external parties only when required by the assignment.

For data entrusted to us on behalf of clients, we act on client instructions and pursuant to Article 28 GDPR – no processing for purposes other than those specified in the assignment.

We delete data after statutory warranty and comparable obligations expire. The necessity of retention is reviewed every three years; where statutory archiving obligations apply, deletion occurs after they expire (6 years pursuant to Section 257(1) HGB, 10 years pursuant to Section 147(1) AO). For data disclosed to us by clients within an assignment, we delete data according to assignment requirements, generally after the assignment ends.

Contractual services

We process data of our contractual partners and prospects as well as other clients, customers, or contractual partners (collectively "contractual partners") pursuant to Article 6(1)(b) GDPR to provide contractual or pre-contractual services. The data processed, its nature, scope, purpose, and necessity are determined by the underlying contractual relationship.

Processed data includes master data of contractual partners (e.g. names and addresses), contact data (e.g. email addresses and phone numbers), contract data (e.g. services used, contract content, contractual communication, contact person names), and payment data (e.g. bank details, payment history).

We generally do not process special categories of personal data unless they are part of commissioned or contractual processing.

We process data necessary to establish and fulfill contractual services and indicate the necessity of providing it where this is not evident to contractual partners. Disclosure to external persons or companies occurs only when required under a contract. When processing data entrusted to us within an assignment, we act according to client instructions and legal requirements.

When using our online services, we may store IP address and time of user action – based on our legitimate interests and user interest in protection against misuse. Disclosure to third parties generally does not occur except to pursue claims (Article 6(1)(f) GDPR) or where legally required (Article 6(1)(c) GDPR).

Data is deleted when no longer required to fulfill contractual or statutory care obligations and for handling warranty and comparable obligations; the necessity of retention is reviewed every three years; otherwise statutory retention obligations apply.

Administration, accounting, office organization, contact management

We process data for administration, business organization, accounting, and legal obligations (e.g. archiving). The same data as for contractual services is processed. Legal bases: Article 6(1)(c) and (f) GDPR.

Affected parties include customers, prospects, business partners, and website visitors. Purpose: administration, accounting, office organization, and archiving – to maintain our business operations and provide our services. Deletion follows the information for respective processing activities.

We disclose or transmit data to tax authorities, advisors such as tax advisors or auditors, and other fee offices and payment service providers.

Furthermore, based on our business interests, we store information about suppliers, organizers, and other business partners, e.g. for later contact. We generally store this predominantly company-related data permanently.

Contact

When contacting us (e.g. via contact form, email, phone, or social media), user information is processed to handle and respond to the contact request pursuant to Article 6(1)(b) GDPR. User information may be stored in a customer relationship management system ("CRM system") or comparable inquiry organization. We delete inquiries when no longer required. We review necessity every two years; statutory archiving obligations also apply.

Hosting and email delivery

Our hosting services include infrastructure, platform, computing capacity, storage, databases, email delivery, security, and maintenance for operating this online offering.

We or our hosting provider process inventory, contact, content, contract, usage, and metadata of customers, prospects, and visitors. Legal basis: legitimate interest in efficient and secure provision (Article 6(1)(f) GDPR) in conjunction with Article 28 GDPR (data processing agreement).

Google Analytics

We use Google Analytics – a web analytics service of Google LLC – only after your explicit consent via our cookie notice (Article 6(1)(a) GDPR). Evaluation is performed server-side via the Google Measurement Protocol. In the browser, we only send lightweight first-party beacons (small requests to our own domain) – no Google JavaScript. For recognition, we set technical cookies (_rf_ga_cid, _rf_ga_sid) once you accept statistics cookies.

You can withdraw your consent at any time via "Cookie settings" in the footer. Usage information generated by the cookie is generally transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield framework and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google evaluates use of our online offering, creates reports, and provides other services related to usage and internet use. Pseudonymous usage profiles may be created from the data.

We use Google Analytics only with IP anonymization enabled: Google truncates the IP within the EU/EEA; only in exceptional cases is the full IP transmitted to a US server and truncated there.

The IP transmitted by the browser is not merged with other Google data. Users can disable cookies in browser settings or prevent collection and processing by Google by installing the browser plugin at: http://tools.google.com/dlpage/gaoptout?hl=en.

Further information on Google's use of data, settings, and objection options is available in Google's privacy policy (https://policies.google.com/technologies/ads) and in settings for Google ad display (https://adssettings.google.com/authenticated).

Users' personal data is deleted or anonymized after 14 months.