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Privacy Policy

We are very pleased about your interest in our company. The management of MTC Marine Training Center Hamburg GmbH attaches great importance to data protection. It is possible to use the internet pages of MTC Marine Training Center Hamburg GmbH without providing any personal data. However, if a person concerned wishes to make use of special services offered by our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the person concerned.

The processing of personal data, for example the name, address, e-mail address or telephone number of a affected person, is always carried out in accordance with the Basic Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to MTC Marine Training Center Hamburg GmbH. By means of this data protection declaration, our company wishes to inform the public about the type, scope and purpose of the personal data collected, used and processed by us. Furthermore, this data protection declaration informs affected persons about the rights to which they are entitled.

MTC Marine Training Center Hamburg GmbH, as the person responsible for processing, has implemented numerous technical and organisational measures in order to ensure that the personal data processed via this website is protected as completely as possible. Nevertheless, Internet-based data transmissions may have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us by alternative means, such as by telephone.

1. Definitions

The data protection declaration of MTC Marine Training Center Hamburg GmbH is based on the terminology used by the European legislator for directives and regulations when the general data protection regulation (GDPR) was issued. Our data protection declaration should be easy to read and understand both for the public and for our customers and business partners. To ensure this, we would like to explain the terms used in advance.
We use the following terms, among others, in this data protection declaration:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as ‚affected person‚). 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Affected person

Affected person means any identified or identifiable natural person whose personal data are processed by the controller.

c) Data processing

Data processing is any operation or set of operations, carried out with or without the aid of automated means, concerning personal data, such as collection, recording, organisation, organisation, 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 data processing

Restriction of processing is the marking of stored personal data with the aim of restricting their future processing.

e) Profiling

Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, conduct, location or change of location of that natural person.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific affected person without the use of additional information, provided that this additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data is not attributed to an identified or identifiable natural person.

g) Data controller

Data controller shall mean the natural or legal person, public authority, agency or any 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 law or by the law of the member states, provision may be made for the controller or for the specific criteria for his or her designation in accordance with union law or the law of the member states.

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

The recipient is a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not it is a third party. However, authorities which may receive personal data in the course of a specific investigation, in accordance with Union or national law, shall not be considered as recipients.

j) Third party

A third party is any natural or legal person, public authority, agency or body other than the affected person, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorized to process the personal data.

h) Consent

Consent shall mean any informed and unequivocal expression of the affected person’s free will in a specific case, in the form of a declaration or other unequivocal affirmative act by which the affected person signifies his or her consent to the processing of personal data relating to him or her.

2. Name and address of the body responsible for processing

The person responsible within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

MTC Marine Training Center Hamburg GmbH
Schnackenburgallee 149, 22525 Hamburg, Germany

Tel.: +49 (0)40 533 07 42-0
Email: info@mtc.hamburg
Website: mtc.hamburg

3. Name and address of the Data Protection Officer

The Data Protection Officer of the controller is

Heinz Kuhlmann
MTC Marine Training Center Hamburg GmbH
Schnackenburgallee 149, 22525 Hamburg, Germany

Phone: +49 (0)40 533 07 42-0
E-mail: info@mtc.hamburg
Website: mtc.hamburg

Every person concerned can contact our data protection officer directly at any time with all questions and suggestions concerning data protection.

4. Cookies

Our website uses HTTP cookies to store user-specific data.
In the following we explain what cookies are and why they are used so that you can better understand the following privacy policy.

What exactly are cookies?
Whenever you surf the Internet, you are using a browser. Some popular browsers include Chrome, Safari, Firefox, Internet Explorer, and Microsoft Edge. Most websites store small text files in your browser. These files are called cookies.

One of them cannot be dismissed: Cookies are really useful little helpers. Almost all websites use cookies. More precisely, they are HTTP cookies, as there are other cookies for other applications. HTTP cookies are small files that are stored on your computer by our website. These cookie files are automatically stored in the cookie folder, quasi the „brain“ of your browser. A cookie consists of a name and a value. When defining a cookie, one or more attributes must also be specified.

Cookies store certain user data about you, such as language or personal page settings. When you visit our site again, your browser transmits the „user-related“ information back to our site. Thanks to the cookies, our website knows who you are and offers you your accustomed standard settings. In some browsers each cookie has its own file, in others, such as Firefox, all cookies are stored in a single file.

There are both first-party cookies and third-party cookies. First-party cookies are created directly by our site, third-party cookies are created by partner sites (e.g. Google Analytics). Each cookie is unique because each cookie stores different data. The expiration time of a cookie also varies from a few minutes to a few years. Cookies are not software programs and do not contain viruses, trojans or other „pests“. Cookies also cannot access information on your PC.

This is how cookie data can look like, for example:

  • Name: _ga
  • Expiry period: 2 years
  • Usage: Differentiation of website visitors
  • Example value: GA1.2.1326744211.152311200023

A browser should support the following minimum sizes:

  • A cookie should be able to contain at least 4096 bytes
  • At least 50 cookies should be able to be stored per domain
  • A total of at least 3000 cookies should be able to be stored

What types of cookies are there?
The question which cookies we use in particular depends on the services used and is clarified in the following sections of the privacy policy. At this point we would like to briefly discuss the different types of HTTP cookies.

You can distinguish between 4 types of cookies:

Essential cookies
These cookies are necessary to ensure basic functions of the website. For example, these cookies are needed when a user places a product in the shopping cart, then continues surfing on other pages and only proceeds to checkout later. These cookies do not delete the shopping cart, even if the user closes his browser window.

Functional cookies
These cookies collect information about user behaviour and whether the user receives any error messages. In addition, these cookies also measure the loading time and the behaviour of the website with different browsers.

Target-oriented cookies
These cookies ensure a better user experience. For example, entered locations, font sizes or form data are stored.

Advertising cookies
These cookies are also called targeting cookies. They are used to deliver customized advertising to the user. This can be very practical, but also very annoying.

Usually, the first time you visit a website, you are asked which of these types of cookies you would like to allow. And of course this decision is also stored in a cookie.

How can I delete cookies?
How and whether you want to use cookies is up to you. Regardless of which service or website the cookies come from, you always have the option of deleting cookies, allowing them only partially or deactivating them. For example, you can block third-party cookies, but allow all other cookies.

If you want to find out which cookies are stored in your browser, if you want to change or delete cookie settings, you can find this in your browser settings:

Chrome: Delete, activate and manage cookies in Chrome
Safari: Manage cookies and website data with Safari
Firefox: Delete cookies to remove data that websites have placed on your computer
Internet Explorer: Delete and manage cookies
Microsoft Edge: Delete and manage cookies

If you do not wish to receive cookies, you can set up your browser so that it always informs you when a cookie is to be set. In this way, you can decide for each individual cookie whether you want to allow it or not. The procedure varies depending on the browser. The best thing to do is to look for the instructions in Google using the search term „Delete Chrome cookies“ or „Disable Chrome cookies“ in the case of a Chrome browser, or replace the word „Chrome“ with the name of your browser, e.g. Edge, Firefox, Safari.

What about my privacy?
Since 2009 there are the so-called „cookie guidelines“. This states that the storage of cookies requires your consent. Within the EU countries, however, there are still very different reactions to these guidelines. In Germany, the cookie guidelines have not been implemented as national law. Instead, the implementation of this directive was largely carried out in § 15 para.3 of the Telemediengesetz (TMG – German Tele Media Act).

If you want to know more about cookies and are not afraid of technical documentation, we recommend https://tools.ietf.org/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called „HTTP State Management Mechanism“.

5. Collection of general data and information

The website of MTC Marine Training Center Hamburg GmbH collects a number of general data and information every time the website is accessed by a affected person or by an automated system. These general data and information are stored in the log files of the server. The following can be recorded: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of an access to the Internet site, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information which serve to prevent danger in the event of attacks on our information technology systems.

When using this general data and information, MTC Marine Training Center Hamburg GmbH will not draw any conclusions about the affected person. This information is rather required to (1) deliver the contents of our website correctly, (2) optimise the contents of our website as well as the advertising for it, (3) ensure the permanent operability of our information technology systems and the technology of our website and (4) to provide law enforcement agencies with the information necessary for prosecution in case of a cyber attack. These anonymously collected data and information are therefore statistically evaluated by MTC Marine Training Center Hamburg GmbH on the one hand and on the other hand with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimum level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a person concerned.

6. How to contact us via the website / Tournament Registration

Due to legal regulations, the website of MTC Marine Training Center Hamburg GmbH contains information that enables a quick electronic contact to our company as well as a direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). Please note: A copy of the tournament registration send through contact form or e-mail including all personal data will be fowarded to our partner CORVEL Partnerschaft von Rechtsanwälten mbB only for the purpose of the tournament organization. Please find the privacy policy of CORVEL here https://www.corvel.de/en.

If a affected person contacts the data controller by e-mail or via a contact form, the personal data transmitted by the affected person is automatically stored. Such personal data transmitted voluntarily by a affected person to the controller are stored for the purposes of processing or contacting the affected person. Such personal data shall not be disclosed to third parties.

7. Rights of affected person

The controller shall process and store personal data relating to the affected person only for the time necessary to achieve the purpose of storage or where provided for by the European Directive and Regulation or by any other law or regulation to which the controller is subject.

If the purpose of storage ceases to apply or if a storage period prescribed by the European Directive and Regulation Giver or any other competent legislator expires, the personal data will be blocked or deleted as a matter of routine and in accordance with the statutory provisions.

a) Right of confirmation

Every affected person has the right, granted by the European Directives and Regulations, to obtain confirmation from the controller as to whether personal data relating to him are being processed. If a affected person wishes to exercise this right of confirmation, he or she may at any time contact an employee of the controller.

b) Right to information

Any affected person by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain at any time and free of charge from the controller information on the personal data stored in relation to him or her and a copy thereof. Furthermore, the European Directive and Regulation Giver has granted the affected person access to the following information:

  • the purposes of processing
  • the categories of personal data processed
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular to recipients in third countries or to international organisations
  • if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
  • the existence of a right of rectification or erasure of personal data relating to him or her or of a right to have the processing limited by the controller or to object to such processing
  • the existence of a right of appeal to a supervisory authority
  • if the personal data are not collected from the affected person: All available information on the origin of the data
  • the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the DPA and, at least in these cases, meaningful information about the logic involved and the scope and intended impact of such processing on the affected person

The affected person shall also have the right to obtain information as to whether personal data have been transferred to a third country or to an international organisation. If this is the case, the affected person shall also have the right to obtain information on the appropriate safeguards in relation to the transfer.
If a affected person wishes to exercise this right of access, he or she may at any time contact a member of the staff of the controller.

c) Right of rectification

Every person concerned by the processing of personal data has the right, granted by the European legislator, to request the rectification without delay of inaccurate personal data concerning him. The affected person shall also have the right to request the completion of incomplete personal data, including by means of a supplementary declaration, having regard to the purposes of the processing.

If a affected person wishes to exercise this right of rectification, he or she may at any time contact an employee of the controller.

d) Right of cancellation (right to be forgotten)

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain from the controller the immediate erasure of personal data relating to him/her, where one of the following reasons applies and provided that the processing is not necessary:

  • The personal data have been collected or otherwise processed for purposes for which they are no longer necessary.
  • The affected person withdraws the consent on which the processing was based pursuant to Article 6(1)(a) of the DPA or Article 9(2)(a) of the DPA, and there is no other legal basis for the processing.
  • The affected person lodges an objection to the processing pursuant to Art. 21(1) DPA and there are no overriding legitimate reasons for the processing, or the affected person lodges an objection to the processing pursuant to Art. 21(2) DPA.
  • The personal data were processed unlawfully.
  • The deletion of the personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
  • The personal data were collected in relation to information society services offered, in accordance with Article 8 (1) of the DSD-REG.

If any of the above reasons apply and a affected person wishes to have personal data stored by MTC Marine Training Center Hamburg GmbH deleted, he/she may contact an employee of the data controller at any time. The employee of MTC Marine Training Center Hamburg GmbH shall ensure that the request for deletion is complied with immediately.

If the personal data has been made public by MTC Marine Training Center Hamburg GmbH and our company as the responsible party according to Art. 17 para. 1 GDPR, MTC Marine Training Center Hamburg GmbH shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform other persons responsible for data processing who process the published personal data, that the person concerned has requested these other persons responsible for data processing to delete all links to these personal data or copies or replications of these personal data, unless the processing is necessary. The employee of MTC Marine Training Center Hamburg GmbH will take the necessary steps in individual cases.

e) Right to limit processing

Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to request the controller to restrict the processing if one of the following conditions is met:

  • the accuracy of the personal data is contested by the affected person, for a period of time sufficient to enable the controller to verify the accuracy of the personal data
  • The processing is unlawful, the affected person refuses to have the personal data deleted and instead requests the restriction of the use of the personal data.
  • The controller no longer needs the personal data for the purposes of the processing, but the affected person needs them in order to assert, exercise or defend legal claims.
  • The affected person has lodged an objection to the processing in accordance with Art. 21 (1) DPA and it is not yet clear whether the controller’s legitimate reasons outweigh those of the affected person.

If one of the above-mentioned conditions is met and a affected person wishes to request the restriction of personal data stored at MTC Marine Training Center Hamburg GmbH, he/she may contact an employee of the data controller at any time. The employee of MTC Marine Training Center Hamburg GmbH will arrange for the restriction of the processing.affected person

f) Right to data portability

Every person concerned by the processing of personal data has the right, granted by the European Directives and Regulations, to receive the personal data concerning him/her which have been provided by the affected person to a controller in a structured, common and machine-readable format. He/she also has the right to have this data communicated to another controller without hindrance by the controller to whom the personal data has been made available, provided that the processing is based on the consent pursuant to Art. 6(1)(a) DPA or Art. 9(2)(a) DPA or on a contract pursuant to Art. 6(1)(b) DPA and that the processing is carried out by means of automated procedures, unless the processing is 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, when exercising their right to data transferability in accordance with Art. 20 Paragraph 1 FDPIC, the affected person has the right to obtain that personal data be transferred directly from one controller to another controller, insofar as this is technically feasible and provided that this does not adversely affect the rights and freedoms of other persons.

In order to assert the right to data transfer, the person concerned may contact an employee of MTC Marine Training Center Hamburg GmbH at any time.

g) Right of appeal​

Every person concerned by the processing of personal data has the right, granted by the European legislator for directives and regulations, to object at any time, for reasons arising from his or her particular situation, to the processing of personal data concerning him or her that is carried out on the basis of Article 6(1)(e) or (f) of the DPA. This also applies to profiling based on these provisions.

In the event of an objection, MTC Marine Training Center Hamburg GmbH shall no longer process the personal data, unless we can prove compelling reasons for processing worthy of protection, which outweigh the interests, rights and freedoms of the person concerned, or the processing serves the assertion, exercise or defence of legal claims.

If MTC Marine Training Center Hamburg GmbH processes personal data in order to carry out direct advertising, the person concerned has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling, insofar as it is connected with such direct marketing. If the affected person objects to MTC Marine Training Center Hamburg GmbH processing for the purpose of direct marketing, MTC Marine Training Center Hamburg GmbH will no longer process the personal data for these purposes.

In addition, the affected person has the right to object, for reasons arising from his or her particular situation, to the processing of personal data concerning him or her which is carried out at MTC Marine Training Center Hamburg GmbH for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 GDPR, unless such processing is necessary for the fulfilment of a task in the public interest.

In order to exercise the right of objection, the person concerned may directly contact any employee of MTC Marine Training Center Hamburg GmbH or any other employee. The affected person is also free to exercise his right of objection in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures involving technical specifications.affected person

h) Automated case-by-case decisions including profiling

Every person concerned by the processing of personal data has the right, as granted by the European Directives and Regulations, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects him or her in a similar way, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the affected person and the controller, or (2) is authorised by Union or national legislation to which the controller is subject and that such legislation provides for adequate safeguards of the rights and freedoms and legitimate interests of the affected person, or (3) is taken with the explicit consent of the affected person.

Where the decision is (1) necessary for the conclusion or performance of a contract between the affected person and the data controller, or (2) is taken with the express consent of the affected person, MTC Marine Training Center Hamburg GmbH shall take appropriate measures to safeguard the rights and freedoms and legitimate interests of the affected person, including at least the right to obtain the intervention of a person from the data controller, to put forward his point of view and to challenge the decision.

If the affected person wishes to exercise rights relating to automated decisions, he or she may at any time contact a member of the staff of the controller.

i) Right to revoke a data protection consent

Every person affected by the processing of personal data has the right, granted by the European Directive and Regulation Giver, to revoke his or her consent to the processing of personal data at any time.

If the affected person wishes to exercise his or her right to withdraw consent, he or she may at any time contact an employee of the controller.

8. Data protection for applications and the application process

The controller collects and processes the personal data of applicants for the purpose of processing the application procedure. The processing may also be carried out by electronic means. This is particularly the case if an applicant submits the relevant application documents to the controller electronically, for example by e-mail or via a web form on the website. If the data controller concludes an employment contract with an applicant, the transmitted data is stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents shall be automatically deleted two months after notification of the rejection decision, unless deletion is contrary to any other legitimate interests of the controller. Other legitimate interests in this sense include, for example, a duty of proof in proceedings under the German General Equal Treatment Act (AGG).

9. Privacy policy on the use and application of Google Maps

We use Google Maps from Google Inc. for our website, and Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services in Europe. With Google Maps we can show you locations better and thus adapt our service to your needs. By using Google Maps, data is transferred to Google and stored on Google’s servers. Here we will go into more detail about what Google Maps is, why we use this Google service, what data is stored and how you can stop it.

What is Google Maps?
Google Maps is an internet map service of the company Google. With Google Maps, you can search online for exact locations of cities, places of interest, accommodations or businesses using a PC, tablet or app. If companies are represented on Google My Business, additional information about the company is displayed next to the location. To display directions, map sections of a location can be embedded into a website using HTML code. Google Maps shows the surface of the earth as a road map or as an aerial or satellite image. Thanks to the Street View images and the high-quality satellite images, very accurate representations are possible.

Why do we use Google Maps on our website?
All our efforts on this site are aimed at providing you with a useful and meaningful time on our website. By integrating Google Maps, we can provide you with the most important information about various locations. You can see at a glance where we have our headquarters. The route description always shows you the best or fastest way to reach us. You can call up the directions for routes by car, public transport, on foot or by bicycle. For us the provision of Google Maps is part of our customer service.

Which data is stored by Google Maps?
In order for Google Maps to offer its service in its entirety, the company must collect and store data about you. This includes the search terms you enter, your IP address and also the latitude and longitude coordinates. If you use the route planner function, the start address entered will also be saved. However, this data storage happens on the websites of Google Maps. We can only inform you about it, but we cannot influence it. Since we have integrated Google Maps into our website, Google sets at least one cookie (name: NID) in your browser. This cookie stores data about your user behaviour. Google uses this data primarily to optimise its own services and to provide individual, personalised advertising for you.

The following cookie is set in your browser due to the integration of Google Maps:
Name: NID
Value: 188=h26c1Ktha7fCQTx8rXgLyATyITJ311200023-5

Purpose: NID is used by Google to adapt advertisements to your Google search. Google uses the cookie to „remember“ your most frequently entered search queries or your previous interaction with ads. So you always get customized ads. The cookie contains a unique ID that Google uses to collect your personal preferences for advertising purposes.

Expiration date: after 6 months

Note: We cannot guarantee the completeness of the data stored. Especially when using cookies, changes can never be ruled out. In order to identify the cookie NID, a separate test page was created where only Google Maps was integrated.

How long and where is the data stored?
The Google servers are located in data centers around the world. However, most servers are located in America. For this reason, your data is also increasingly stored in the USA. Here you can find out exactly where the Google data centers are located: https://www.google.com/about/datacenters/inside/locations/?hl=de
Google distributes the data on different data carriers. This means that the data can be accessed more quickly and is better protected against any attempts at manipulation. Each data center also has special emergency programs. If, for example, there are problems with the Google hardware or a natural disaster paralyses the servers, the data is still protected.
Some data is stored by Google for a set period of time. For other data, Google only offers the option to delete it manually. The company also anonymizes information (such as advertising data) in server logs by deleting part of the IP address and cookie information after 9 and 18 months respectively.

How can I delete my data or prevent data storage?
With the automatic deletion of location and activity data introduced in 2019, location and web/app activity information is stored for either 3 or 18 months, depending on your decision, and then deleted. You can also manually delete this data from your history at any time using your Google Account. If you want to completely stop your location tracking, you’ll need to pause the Web and App activity section of your Google Account. Click ‚Data and personalization‘ and then click the ‚Activity setting‘ option. Here you can turn activity on or off.

You can also disable, delete or manage individual cookies in your browser. Depending on which browser you use, this always works slightly differently. The following instructions show you how to manage cookies in your browser:

Chrome: Delete, activate and manage cookies in Chrome 
Safari: Manage cookies and website data with Safari 
Firefox: Delete cookies to remove data that websites have placed on your computer 
Internet Explorer: Delete and manage cookies 
Microsoft Edge: Delete and manage cookies

If you do not wish to receive cookies, you can set up your browser so that it always informs you when a cookie is to be set. In this way, you can decide for each individual cookie whether you want to allow it or not.
Google is an active participant in the EU-U.S. Privacy Shield Framework, which regulates the correct and secure transfer of personal data. You can find more information on this at https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI. If you want to learn more about Google’s data processing, we recommend that you read the company’s own privacy policy at https://policies.google.com/privacy?hl=de.

10. Privacy policy on the use and application of Google reCAPTCHA

Our primary goal is to secure and protect our website for you and for us in the best possible way. To ensure this, we use Google reCAPTCHA from Google Inc. For the European region, the company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services. With reCAPTCHA we can determine whether you are really a flesh and blood human being and not a robot or other spam software. By spam, we mean any unsolicited information sent to us by electronic means. With the classic CAPTCHAS, you usually had to solve text or image puzzles to check. With reCAPTCHA from Google we usually do not have to bother you with such puzzles. In most cases it is sufficient to simply check the box and confirm that you are not a bot. With the new Invisible reCAPTCHA version, you don’t even have to put a check mark. How this works exactly and especially which data is used for this purpose, you will learn in the course of this privacy policy.

What is reCAPTCHA?
reCAPTCHA is a free Captcha service from Google that protects websites from spam software and abuse by non-human visitors. This service is most commonly used when you fill out forms on the Internet. A captcha service is a kind of automatic turing test, which is supposed to ensure that an action on the internet is done by a human and not by a bot. In the classic Turing test (named after the computer scientist Alan Turing) a human being determines the difference between a bot and a human being. With Captchas this is also done by the computer or a software program. Classical Captchas work with small tasks that are easy to solve for humans, but have considerable difficulties for machines. With reCAPTCHA you don’t have to actively solve puzzles anymore. The tool uses modern risk techniques to distinguish humans from bots. Here you only have to tick the text field „I am not a robot“ or with Invisible reCAPTCHA even this is no longer necessary. With reCAPTCHA, a JavaScript element is integrated into the source code and then the tool runs in the background and analyses your user behaviour. From these user actions, the software calculates a so-called captcha score. Google uses this score to calculate the probability that you are a human being even before you enter the captcha. reCAPTCHA or captchas in general are used whenever bots could manipulate or abuse certain actions (such as registrations, surveys, etc.).

Why do we use reCAPTCHA on our website?
We only want to welcome people of flesh and blood on our site. Bots or spam-software of different kinds can stay at home. That’s why we do everything possible to protect ourselves and offer the best possible user-friendliness for you. For this reason we use Google reCAPTCHA from the company Google. So we can be pretty sure that we remain a „bot-free“ website. Through the use of reCAPTCHA, data is transmitted to Google to determine whether you are really a human being. reCAPTCHA serves the security of our website and consequently your security. For example, without reCAPTCHA, it could happen that a bot registers as many e-mail addresses as possible during registration, in order to „spam“ forums or blogs with unwanted advertising content. With reCAPTCHA we can avoid such bot attacks.

Which data is stored by reCAPTCHA?
reCAPTCHA collects personal data from users to determine whether the actions on our website really originate from people. This means that the IP address and other data that Google requires for the reCAPTCHA service can be sent to Google. IP addresses are almost always shortened within the member states of the EU or other signatory states to the Agreement on the European Economic Area before the data lands on a server in the USA. The IP address is not combined with any other data held by Google unless you are signed in with your Google Account while using reCAPTCHA. First, the reCAPTCHA algorithm checks whether Google cookies from other Google services (YouTube, Gmail, etc.) are already placed on your browser. Then reCAPTCHA sets an additional cookie in your browser and takes a snapshot of your browser window.

The following list of collected browser and user data does not claim to be complete. Rather, they are examples of data which, to our knowledge, are processed by Google.

  • Referrer URL (the address of the page the visitor comes from)
  • IP address (e.g. 256.123.123.1)
  • Information about the operating system (the software that enables your computer to operate. Known operating systems are Windows, Mac OS X or Linux)
  • Cookies (small text files that store data in your browser)
  • Mouse and keyboard behavior (every action you perform with the mouse or keyboard is stored)
  • Date and language settings (which language or date you have preset on your PC is stored)
  • All Javascript objects (JavaScript is a programming language that allows websites to adapt to the user. JavaScript objects can collect all kinds of data under one name)
  • Screen resolution (shows how many pixels the image consists of)

It is indisputable that Google uses and analyzes this data even before you click on the checkbox „I am not a robot“. With the Invisible reCAPTCHA version even the ticking is omitted and the whole recognition process runs in the background. How much and what kind of data Google exactly stores is not known by Google in detail.

The following cookies are used by reCAPTCHA: Here we refer to the reCAPTCHA demo version from Google at https://www.google.com/recaptcha/api2/demo. All these cookies require a unique identifier for tracking purposes. Here is a list of cookies that Google reCAPTCHA has set on the demo version

Name: IDE
Value: WqTUmlnmv_qXyi_DGNPLESKnRNrpgXoy1K-pAZtAkMbHI-311200023-8
Purpose: This cookie is set by the company DoubleClick (also owns Google) to register and report the actions of a user on the website in dealing with advertisements. In this way the advertising effectiveness can be measured and appropriate optimisation measures can be taken. IDE is stored in browsers under the domain doubleclick.net.
Expiration date: after one year

Name: 1P_JAR
Value: 2019-5-14-12
Purpose: This cookie collects statistics on website usage and measures conversions. A conversion occurs, for example, when a user becomes a buyer. The cookie is also used to show users relevant advertisements. Furthermore, the cookie can be used to prevent a user from seeing the same ad more than once.
Expiration date: after one month

Name: ANID
Value: U7j1v3dZa3112000230xgZFmiqWppRWKOr
Purpose: We could not find out much information about this cookie. In Google’s privacy policy, the cookie is mentioned in connection with „advertising cookies“ such as „DSID“, „FLC“, „AID“, „TAID“. ANID is stored at domain google.com.
Expiration date: after 9 months

Name: CONSENT
Value: YES+AT.de+20150628-20-0
Purpose: The cookie stores the status of a user’s consent to use various Google services. CONSENT is also used for security purposes, to verify users, to prevent fraudulent use of credentials and to protect user data from unauthorized attacks.
Expiration date: after 19 years

Name: NID
Value: 0WmuWqy311200023zILzqV_nmt3sDXwPeM5Q
Purpose: NID is used by Google to adapt advertisements to your Google search. Google uses the cookie to „remember“ your most commonly entered search queries or your previous interaction with ads. So you always get customized ads. The cookie contains a unique ID to collect user preferences for advertising purposes.
Expiration date: after 6 months

Name: DV
Value: gEAABBCjJMXcI0dSAAAANbqc311200023-4
Purpose: As soon as you have checked the „I am not a robot“ checkbox, this cookie will be set. The cookie is used by Google Analytics for personalized advertising. DV collects information in anonymous form and is also used to make user distinctions.
Expiration date: after 10 minutes

Note: This list cannot claim to be exhaustive, as experience has shown that Google always changes the choice of its cookies.

How long and where is the data stored?
By inserting reCAPTCHA, data is transferred from you to the Google server. Where exactly this data is stored is not clearly shown by Google, even after repeated requests. Without having received confirmation from Google, it can be assumed that data such as mouse interaction, time spent on the website or language settings are stored on Google’s European or American servers. The IP address that your browser transmits to Google is generally not merged with other Google data from other Google services. However, if you are logged into your Google account while using the reCAPTCHA plug-in, the data will be merged. Google’s different privacy policies apply.

How can I delete my data or prevent data storage?
If you do not want any information about you or your behavior to be sent to Google, you must completely log out of Google and delete all Google cookies before you visit our website or use the reCAPTCHA software. In principle, the data is automatically transmitted to Google as soon as you visit our website. To delete this data again, you must contact Google support at https://support.google.com/?hl=de&tid=311200023.

Therefore, when you use our website, you agree that Google LLC and its representatives automatically collect, process and use data.

You can learn more about reCAPTCHA on Google’s web development page at https://developers.google.com/recaptcha/. Google will go into more detail about the technical development of reCAPTCHA here, but you will search in vain for precise information about data storage and data protection issues. A good overview of the basic use of data at Google can be found in the company’s own privacy policy at https://www.google.com/intl/de/policies/privacy/.

11. Privacy policy on the use and application of jQuery CDN

In order to deliver our website or all our individual sub-pages (web pages) to you quickly and easily on different devices, we use services from jQuery CDN of the jQuery Foundation company. jQuery is distributed via the Content Delivery Network (CDN) of the American software company StackPath (LCC 2012 McKinney Ave. Suite 1100, Dallas, TX 75201, USA). This service stores, manages and processes personal information about you.

A Content Delivery Network (CDN) is a network of regionally distributed servers that are connected to each other via the Internet. Through this network, content, especially very large files, can be delivered quickly, even during large load peaks.

jQuery uses JavaScript libraries to deliver our website content quickly. A CDN server loads the necessary files. As soon as a connection to the CDN server is established, your IP address is recorded and saved. This only happens if this data has not already been saved in your browser as a result of a previous website visit.

StackPath’s privacy policy explicitly mentions that StackPath uses aggregated and anonymized data from various services (such as jQuery) to enhance security and for its own services. However, this data cannot identify you as a person.

If you do not want this data transfer to occur, you always have the option of installing Java Script blockers such as ghostery.com or noscript.net. You can also simply deactivate the execution of JavaScript codes in your browser. If you decide to deactivate JavaScript codes, the usual functions will also change. For example, a website will no longer load as quickly.

StackPath is an active participant in the EU-U.S. Privacy Shield Framework, which regulates the correct and secure transfer of personal data. You can find more information on this at https://www.privacyshield.gov/participant?id=a2zt0000000CbahAAC&status=Active.

For more information about StackPath’s privacy policy, please visit https://www.stackpath.com/legal/privacy-statement/ and for jQuery, please visit https://openjsf.org/wp-content/uploads/sites/84/2019/11/OpenJS-Foundation-Privacy-Policy-2019-11-15.pdf.

12. Privacy policy on the use and application of matomo

This website uses Matomo, an open source, self-hosted software to collect anonymous usage data for this website.

The data on visitor behaviour is collected to find out about any problems such as pages not found, search engine problems or unpopular pages. Once the data (number of visitors seeing error pages or only seeing one page, etc.) is processed, Matomo generates reports for the website owners to respond to. (layout changes, new content, etc.)

Matomo processes the following data:

    • Cookies
    • Anonymised IP addresses by removing the last 2 bytes (i.e. 198.51.0.0 instead of 198.51.100.54)
    • Pseudo-anonymised location (based on the anonymised IP address)
    • Date and time
    • Title of the accessed page
    • URL of the page accessed
    • URL of the previous page (if allowed)
    • Screen resolution
    • Local time
    • Files clicked and downloaded
    • External links
    • Duration of page load
    • Country, region, city (with low accuracy due to IP address)
    • Main language of browser
    • User agent of the browser
    • Interactions with forms (but not their content)

Indirect data collection

Server Logs

When you use this website, the host of the website (Hosteurope) logs your visit. This log contains your IP address, which indirectly identifies you through your internet service provider. The recording of this data is required by law and necessary for security. There is no possibility to opt-out, but the data will never be used for other purposes.

Web fonts

This website uses fonts from Google Fonts, which are loaded by Google servers when the page is called up. More information on data protection can be found in the FAQs.

Basis of legitimate interest

Data processing is based on the principle of legitimate interest.

Processing data helps us to find out what works on our site and what does not. For example, it helps us find out if the content is well received or how we can improve the structure of the website. Our team benefits from this and can react to it. As a result of the data processing, you benefit from a website that is constantly improving.

Without the data, we would not be able to provide the service. Your data will only be used to improve the use of the website.

Recipient of the data

The personal data will be sent to:

Details on transfer to third countries

The data on this website and Matomo are hosted in Germany. The data never leaves the EU.

Rights of affected persons

As Matomo collects data based on legitimate interest, you can exercise the following rights:

  • Right of access and data portability: you can request all your data at any time.
  • Right to erasure and rectification: you can request that we erase all your data completely at any time.
  • Right to object and restriction of processing: you can object to data collection at any time by checking DoNotTrack in your browser or clicking this button below.

The right to lodge a complaint with the data protection authority

If you think that the way we process your data with Matomo is against the law, you have the right to lodge a complaint with the Data Protection Authority.

Licence

This privacy policy is based on the privacy policy of the Matomo Project and is licensed under a Creative Commons Licence, so you can change and reuse it yourself.

13. Legal basis of the data processing

Art. 6 I lit. a GDPR serves our company as a 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 affected person is a party, as is the case, for example, with processing operations necessary for the supply of goods or the provision of another service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations which are necessary for the implementation of pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation which makes it necessary to process personal data, for example to fulfil tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the affected person or another natural person. This would be the case, for example, if a visitor to our company was injured and his or her name, age, health insurance details or other vital information had to be disclosed to a doctor, hospital or other third party. The processing would then be based on Art. 6 I lit. d GDPR. Finally, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations which are not covered by any of the above legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or of a third party, provided that the interests, fundamental rights and freedoms of the affected person do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the affected person is a customer of the controller (Recital 47 sentence 2 GDPR).

14. Legitimate interests in data processing pursued by the controller or a third party

If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is to carry out our business activities for the benefit of the well-being of all our employees and our shareholders.

15. Duration for which the personal data are stored

The criterion for the duration of storage of personal data is the respective legal retention period. After expiry of this period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfilment of the contract or the initiation of a contract.

16. Legal or contractual provisions making the personal data available; necessity for the conclusion of the contract; obligation of the affected person to provide the personal data; possible consequences of not providing the data

We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded that a affected person provides us with personal data, which must subsequently be processed by us. For example, the person concerned is obliged to provide us with personal data if our company concludes a contract with him/her. Failure to provide the personal data would mean that the contract with the person concerned could not be concluded. Before the person concerned makes personal data available, he or she must contact one of our employees. Our employee will inform the affected person on a case-by-case basis 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 what the consequences would be if the personal data were not provided.

17. Existence of automated decision making

As a responsible company, we avoid automatic decision making or profiling.

This privacy policy has been conducted with help by the privacy policy generator of Deutschen Gesellschaft für Datenschutz in cooperation with the
lawyers of Kanzlei WILDE BEUGER SOLMECKE | Rechtsanwälte and by the privacy policy generator of AdSimple in cooperation with 123familie.de.