Privacy
policy.
We also use cookies on our website, which enable an analysis of the surfing behavior of users.
In this way, the following data can be transmitted:
The following is a list of the data collected. These can be, for example:
(1) Entered search terms
(2) Frequency of page views
(3) Use of website functions
(4) Recognition of users
When calling up our website, the user is informed about the use of cookies for analysis purposes and his consent to the processing of personal data used in this context is obtained. In this context, there is also a reference to this privacy policy.
2. Legal basis for data processing
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f DSGVO.
The legal basis for the processing of personal data using cookies for analysis purposes is Art. 6 para. 1 lit. a DSGVO if the user has given his consent in this regard.
3. purpose of data processing
The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.
We require cookies for the following applications:
(1) Recognition of logged-in users
(2) Adoption of language settings
(3) Remembering search terms
The user data collected through technically necessary cookies are not used to create user profiles.
The analysis cookies are used for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus constantly optimize our offer.
In these purposes, our legitimate interest lies in the processing of personal data pursuant to Art. 6 para 1 lit. f DSGVO.
4. Duration of storage and possibility of objection and removal
Cookies are stored on the user’s computer and transmitted from it to our site. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to fully use all the functions of the website.
V. Registration
1. Description and scope of data processing
On our website, we offer users the opportunity to register by providing personal data. The data is thereby entered into an input mask and transmitted to us and stored. The data is not passed on to third parties. The following data is collected during the registration process:
(1) Email address
(2) First name
(3) Last name
The following data is also stored at the time of registration:
(1) Internal User ID
(2) Status of consent to send further information
(3) Information about the browser type and version used
(4) The operating system of the user
(5) The IP address of the user
(6) Date and time of access
(7) Websites from which the user’s system reaches our website
As part of the registration process, consent is obtained from the user to process this data
2. Legal basis for data processing
The legal basis for the processing of the data, if the user has given his consent, is Art. 6 (1) lit. a DSGVO.
If the registration serves the fulfillment of a contract to which the user is a party or the implementation of pre-contractual measures, the additional legal basis for the processing of the data is Art. 6 para. 1 lit. b DSGVO.
3. Purpose of data processing
A user registration is necessary for the provision of certain content and services on our website.
ZREALITY Sphere is a cloud platform for easy creation of customized virtual reality applications. Users can choose from a variety of predefined templates and then customize them with their own content.
Registration of the user is required for the fulfillment of a contract with the user or for the performance of pre-contractual measures.
The data collected is necessary to recognize the user with whom the contract was concluded and to provide him with a protected area for his uploaded content and personalized virtual reality applications.
4. Duration of storage
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected.
This is the case for the data collected during the registration process for the performance of a contract or for the performance of pre-contractual measures when the data is no longer necessary for the performance of the contract. Even after the conclusion of the contract, there may be a need to store personal data of the contracting party in order to fulfill contractual or legal obligations.
Continuing obligations require the storage of personal data during the term of the contract. In addition, warranty periods must be observed and the storage of data for tax purposes. Which storage periods must be observed in this regard cannot be determined in a blanket manner, but must be determined on a case-by-case basis for the contracts and contracting parties concluded in each case.
5. Possibility of objection and removal
As a user, you have the option to cancel your registration at any time. You can have the data stored about you changed at any time. To do so, please send an email to support@zrealitysphere.com or datenschutz@zreality.com, making sure for authentication reasons that you send this message from the same email address you used to register.
If the data is required for the performance of a contract or for the implementation of pre-contractual measures, early deletion of the data is only possible insofar as contractual or legal obligations do not preclude deletion.
VI. Contact form and e-mail contact
1. Description and scope of data processing
On our website there is a contact form, which can be used for electronic contact. If a user takes advantage of this option, the data entered in the input mask is transmitted to us and stored. These data are your name and e-mail address.
At the time the message is sent, the following data is also stored:
(1) Information about the browser type and version used
(2) The user’s operating system
(3) The user’s IP address
(4) Date and time of access
(5) Websites from which the user’s system accesses our website
For the processing of the data, your consent is obtained during the submission process and reference is made to this privacy policy.
Alternatively, it is possible to contact us via the e-mail address provided. In this case, the personal data of the user transmitted with the e-mail will be stored.
In this context, the data will not be passed on to third parties. The data will be used exclusively for the processing of the conversation.
2. Legal basis of data processing
The legal basis for the processing of the data, if the user has given his consent, is Art. 6 (1) lit. a DSGVO.
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f DSGVO. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO.
3. Purpose of data processing
The processing of personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this is also the necessary legitimate interest in processing the data.
The other personal data processed during the submission process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
4. Duration of storage
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter concerned has been conclusively clarified.
5. Possibility of objection and removal
The user has the option to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.
If you wish to exercise your right of revocation or objection, an e-mail to datenschutz@zreality.com is sufficient.
All personal data stored in the course of contacting us will be deleted in this case.
VII. Newsletter
On our website there is the possibility to subscribe to a free newsletter. In doing so, the data from the input mask is transmitted to us when you register for the newsletter. For this purpose, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the specified e-mail address and agree to receive the newsletter (IP address and date and time of registration). No further data is collected or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.
The processing of the data entered in the newsletter registration form is based exclusively on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke your consent to the storage of the data, the e-mail address and their use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.
The data you have deposited with us for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and deleted after unsubscribing from the newsletter. Data that has been stored by us for other purposes (e.g. e-mail addresses for the member area) remains unaffected by this.
VIII. Engaging Processors for Hosting, Platform Security, Administrative, Troubleshooting and Support Services
To provide our services, we use contract processors, which we list below. The legal basis for the use of these processors is a legitimate interest according to Art. 6 (1) lit. f DSGVO. The legitimate interest is the pursuit of our business purposes, in particular to provide the services otherwise described in this Privacy Policy. A conflicting interest is not apparent because we have concluded a contract with the respective contractors in accordance with Art. 28 DSGVO.
1. hosting & platform security
For purposes of hosting our platforms and back-up services, we use processors, so personal data stored on our platforms is transferred to these processors. These processors are Amazon Web Services, Inc, 410 Terry Drive Ave North, WA 98109-5210 Seattle, USA, and Telekom Deutschland GmbH, Landgrabenweg 151 53227 Bonn, Germany. These processors will store personal data for as long as the data is stored on our platforms based on the purposes defined in this privacy policy. Amazon Web Services Inc. is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with European data protection law. All data is processed exclusively in Germany (AWS region Frankfurt/Main). You can find more information about data protection at Amazon Web Services at the following address: https://aws.amazon.com/de/compliance/gdpr-center/.
We have concluded an order data processing agreement with both Amazon Web Services Inc. and Telekom Deutschland GmbH and fully implement the strict requirements of the German data protection authorities when using these services.
2. Administrative, troubleshooting and support services
For administrative, troubleshooting and support services, we use services provided by Atlassian Pty Ltd, c/o Atlassian, Inc, 1098 Harrison Street, San Francisco, CA 94103, USA, which may thus also have access to your personal data. In principle, Atlassian does not store your personal data. Only in exceptional cases, for example, if this should be necessary in connection with the elimination of technical problems or support requests. In these cases, storage will only take place to the extent and for the duration required. Atlassian Pty Ltd is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law. You can find more information about data protection at Atlassian at the following address: https://www.atlassian.com/trust/privacy.
We have entered into a contract for commissioned data processing with Atlassian Pty Ltd and fully implement the strict requirements of the German data protection authorities when using Atlassian services.
3. Sending emails and other messages
To send emails and messages on other electronic channels, we use services of Telekom Deutschland GmbH, Landgrabenweg 151, 53227 Bonn, Germany, as part of an order processing. Accordingly, this company may receive your personal data as part of the order processing that exists with us. Storage there takes place for the duration for which storage is otherwise lawful for purposes according to this data protection declaration, i.e. in particular for the purposes of contractual communication within the scope of contracts existing with you or, incidentally, for advertising communication. Further information on data protection at Atlassian can be found at the following address: https://cloud.telekom.de/infrastruktur/open-telekom-cloud/compliance/.
We have concluded a contract with Telekom Deutschland GmbH for the processing of commissioned data and fully implement the strict requirements of the German data protection authorities when using their services.
IX. Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and enable an analysis of your use of the website. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States.
The storage of Google Analytics cookies is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its web offering and its advertising.
Browser plugin
You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
Objection to data collection
You can prevent Google Analytics from collecting your data by clicking on the following link. An opt-out cookie will be set that will prevent the collection of your data during future visits to this website: Google Analytics deactivate.
More information on how Google Analytics handles user data can be found in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.
Commissioned data processing
We have concluded a contract with Google for order data processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
Demographic characteristics in Google Analytics
This website uses the “demographic characteristics” function of Google Analytics. This allows reports to be generated that contain statements about the age, gender and interests of site visitors. This data comes from interest-based advertising from Google as well as visitor data from third-party providers. This data cannot be assigned to a specific person. You can deactivate this function at any time via the ad settings in your Google account or generally prohibit the collection of your data by Google Analytics as shown in the item “Objection to data collection”
X. Google Analytics Remarketing
Our websites use the functions of Google Analytics Remarketing in conjunction with the cross-device functions of Google AdWords and Google DoubleClick. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
This function makes it possible to link the advertising target groups created with Google Analytics Remarketing with the cross-device functions of Google AdWords and Google DoubleClick. In this way, interest-based, personalized advertising messages that have been adapted to you depending on your previous usage and surfing behavior on one end device (e.g. cell phone) can also be displayed on another of your end devices (e.g. tablet or PC).
If you have given corresponding consent, Google will link your web and app browsing history with your Google account for this purpose. In this way, the same personalized advertising messages can be served on each end device on which you log in with your Google account.
To support this feature, Google Analytics collects Google-authenticated IDs of users, which are temporarily linked to our Google Analytics data to define and create target groups for cross-device ad advertising.
You can permanently object to cross-device remarketing/targeting by deactivating personalized advertising in your Google account; follow this link: https://www.google.com/settings/ads/onweb/.
The aggregation of the collected data in your Google account is based solely on your consent, which you can give or revoke at Google (Art. 6 para. 1 lit. a DSGVO). In the case of data collection processes that are not merged in your Google Account (e.g. because you do not have a Google Account or have objected to the merger), the collection of data is based on Art. 6 (1) lit. f DSGVO. The legitimate interest arises from the fact that the website operator has an interest in the anonymized analysis of website visitors for advertising purposes.
For further information and the privacy policy, please refer to Google’s privacy policy at: https://www.google.com/policies/technologies/ads/.
XI. Google AdWords and Google Conversion Tracking
This website uses Google AdWords. AdWords is an online advertising program of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).
As part of Google AdWords, we use the so-called conversion tracking. When you click on an ad placed by Google, a cookie is set for conversion tracking. Cookies are small text files that the Internet browser stores on the user’s computer. These cookies lose their validity after 30 days and are not used to personally identify the user. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize that the user clicked on the ad and was redirected to this page.
Each Google AdWords customer receives a different cookie. The cookies cannot be tracked through the websites of AdWords customers. The information obtained using the conversion cookie is used to create conversion statistics for AdWords customers who have opted in to conversion tracking. Customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive information that personally identifies users. If you do not wish to participate in the tracking, you can object to this use by easily deactivating the Google conversion tracking cookie via your internet browser under user settings. You will then not be included in the conversion tracking statistics.
The storage of “conversion cookies” is based on Art. 6 (1) lit. f DSGVO. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its web offering and its advertising.
More information on Google AdWords and Google conversion tracking can be found in Google’s privacy policy: https://www.google.de/policies/privacy/.
You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, as well as activate the automatic deletion of cookies when closing the browser. When disabling cookies, the functionality of this website may be limited.
XII. Facebook Pixel
Our website uses the visitor action pixel from Facebook, Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) for conversion measurement.
This makes it possible to track the behavior of page visitors after they have been redirected to the provider’s website by clicking on a Facebook ad. This allows the effectiveness of Facebook ads to be evaluated for statistical and market research purposes, and future advertising measures to be optimized.
The data collected is anonymous for us as the operator of this website, we can not draw any conclusions about the identity of users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, according to the Facebook Data Use Policy. This allows Facebook to enable the placement of advertisements on Facebook pages as well as outside of Facebook. This use of the data cannot be influenced by us as page operators.
In Facebook’s privacy notices, you can find more information about protecting your privacy: https://www.facebook.com/about/privacy/.
You can also disable the Custom Audiences remarketing feature in the Ads Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do so, you must be logged in to Facebook.
If you do not have a Facebook account, you can disable usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website at http://www.youronlinechoices.com/de/praferenzmanagement/.
XIII Matomo
Our products ZREALITY Grids (https://grids.zreality.com, https://gridslight.zreality.com), https://my.zrealitysphere.com use the open source software tool Matomo to analyze the browsing behavior of our users.
The software runs thereby exclusively on servers operated by us, a storage of these data takes place only there and there is no transmission to Matomo or other third parties. The software is set so that IP addresses are not stored in full, but the last two bytes of the IP address are masked (Ex: 192.168.xxx.xxx). In this way, an assignment of the shortened IP address to the calling computer is no longer possible.
A collection of other personal data does not take place. Also, no user recognition methods (e.g. cookies) are used for analysis purposes.
If you nevertheless do not agree to the use of Matomo, you can deactivate tracking for all ZREALITY services via the following link (opt-out).
XIV Youtube Videos
For integration and display of video content, our website uses plugins from YouTube. The provider of the video portal is YouTube, LLC Headquarters at 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is represented by Google Inc. with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
When a page with an integrated YouTube plugin is called up, a connection to the YouTube servers is established. YouTube thereby learns which of our pages you have called up.
If you are logged in as a member of YouTube, YouTube assigns this information to your personal user account. When using the plugin, such as clicking on the start button of a video, this information is also assigned to your user account.
The use of YouTube is in the interest of an appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO.
You can prevent this assignment by logging out of your YouTube user account and other user accounts of the companies YouTube LLC and Google Inc. before using our website and deleting the corresponding cookies of the companies.
For details on how we handle user data, please see YouTube’s privacy policy at: https://www.google.de/intl/de/policies/privacy.
Further settings and objections to YouTube’s use of data are possible through the opt-out function: https://adssettings.google.com/authenticated.
XV. Use of Google Maps
This website integrates maps of the service “Google Maps” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, in order to visually display geographical information.
When using Google Maps, Google also collects, processes and uses data about the use of the map functions by visitors. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed in the context of the settings of their mobile devices). The data may be processed in the U.S.
More detailed information about data processing by Google can be found in the corresponding privacy policy: https://www.google.com/policies/privacy/,
Where you can also change your personal privacy settings in the Privacy Center. Instructions for managing your own data in connection with Google products can be found here.
XVIII. Facebook Plugin
Our websites use social plugins from the company Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
The plugins can display interaction elements or content (e.g. videos, graphics or text posts) and are recognizable by one of the Facebook logos (white “f” on blue tile or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of Facebook social plugins can be viewed here:
https://developers.facebook.com/docs/plugins/.
The basis for data processing is our legitimate interest, i.e. interest in the analysis, optimization and economic operation of our online offer in accordance with Art. 6 para.1lit. f. DSGVO.
By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the offer. If the user is logged into Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted directly from your browser to Facebook and stored there. We do not know what data Facebook links to the personal data received and for what purposes Facebook uses this data. For more information, please see Facebook’s privacy policy (https://www.facebook.com/about/privacy/).
If a user is not a member of Facebook, there is still the possibility that Facebook will learn and store his or her IP address. According to Facebook, only an anonymized IP address is stored in Germany.
The purpose and scope of data collection and the further processing and use of data by Facebook, as well as the related rights and settings options for protecting the privacy of users, can be found in the privacy notices of Facebook:
https://www.facebook.com/about/privacy/.
If you do not want Facebook to be able to associate your visit to our website with your Facebook account, please log out of your Facebook user account, delete your corresponding cookies and block the execution of script content from Facebook in your browser, e.g. with the script blockers from www.noscript.net or www.ghostery.com.
Facebook is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
Further settings and objections to the use of data for advertising purposes, are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the U.S. page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, meaning they are applied to all devices, such as desktop computers or mobile devices.
XvI. XING Plugin
Our website uses functions of the XING network. The provider is XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany.
When a page with integrated Xing functions is called up, a connection to Xing’s servers is established. To the best of our knowledge, no personal data is stored. IP addresses are not stored, nor is there any evaluation of usage behavior.
If the users are members of the Xing platform, Xing can assign the call-up of the above-mentioned content and functions to the profiles of the users there.
For details on data protection and the XING Share button, please refer to the XING privacy policy at:
https://www.xing.com/app/share?op=data_protection.
XVII LinkedIn
Within our online offer, functions and content of the service LinkedIn, Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can make known their liking regarding the content, the authors of the content or subscribe to our posts.
If users like the content, they can subscribe to it.
If the users are members of the platform LinkedIn, LinkedIn can assign the call of the above content and functions to the profiles of the users there.
LinkedIn is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active).
The purpose and scope of the data collection and the further processing and use of the data by LinkedIn, as well as your rights and settings options in this regard, can be found in the corresponding privacy policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy.
Further settings and objections to the use of data by LinkedIn are possible through the opt-out function: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
XVIII Rights of the Data Subject
If personal data of you are processed, you are a data subject within the meaning of the GDPR and you have the following rights against the controller:
1. right to information
You may request confirmation from the controller as to whether personal data concerning you are being processed by us.
If such processing is taking place, you may request the controller to provide you with the following information:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data which are processed;
(3) the recipients or the categories of recipients to whom the personal data relating to you have been or will be disclosed;
(4) the planned duration of the storage of the personal data relating to you or, if specific information on this is not possible, criteria for determining the storage period;
(5) the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
(6) the existence of a right to lodge a complaint with a supervisory authority;
(7) any available information on the origin of the data if the personal data are not collected from the data subject;
(8) the existence of automated decision-making including profiling pursuant to Art. 22 (1) and (4) DSGVO and – at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information about whether the personal data concerning you are transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer.
2. Right to rectification
You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
3. Right to restriction of processing
Under the following conditions, you may request the restriction of the processing of personal data concerning you:
(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
(3) the controller no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defense of legal claims, or
(4) if you object to the processing pursuant to Art. 21 (1) DSGVO and it has not yet been determined whether the legitimate grounds of the controller override your grounds.
If the processing of personal data relating to you has been restricted, such data may – apart from being stored – only be processed with your consent or for the purpose of asserting, exercising or defending legal claims or for the purpose of protecting the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
4. Right to erasure
a) Obligation to delete
You may request from the controller that the personal data concerning you be erased without undue delay, and the controller is obliged to erase such data without undue delay, if one of the following reasons applies:
(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You revoke your consent on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a DSGVO and there is no other legal basis for the processing.
(3) You object to the processing pursuant to Art. 21 para. 1 DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO.
(4) The personal data concerning you have been processed unlawfully.
(5) The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
(6) The personal data concerning you was collected in relation to information society services offered pursuant to Art. 8(1) DSGVO.
b) Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.
c) Exceptions
The right to erasure does not exist to the extent that the processing is necessary
(1) for the exercise of the right to freedom of expression and information;
(2) for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the field of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) of the GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) of the GDPR, insofar as the right referred to in section (a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
(5) for the establishment, exercise or defense of legal claims.
5. Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right vis-à-vis the controller to be informed about these recipients.
6. Right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. In addition, you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided
(1) the processing is based on consent pursuant to Article 6(1)(a) DSGVO or Article 9(2)(a) DSGVO or on a contract pursuant to Article 6(1)(b) DSGVO and
(2) the processing is carried out with the help of automated procedures.
In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.
The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7. 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 Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.
If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
If you object to processing for the purposes of direct marketing, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.
8. Right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
9. Automated decision-making in individual cases, including profiling
You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision
(1) is necessary for the conclusion or performance of a contract between you and the controller,
(2) is permitted by legislation of the Union or the Member States to which the controller is subject, and that legislation contains appropriate measures to safeguard your rights and freedoms and your legitimate interests, or
(3) is done with your explicit consent.
However, these decisions must not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.
In the cases referred to in (1) and (3), the controller shall take reasonable steps to safeguard the rights and freedoms as well as your legitimate interests, including at least the right to obtain the intervention of a person on the part of the controller, to express his own point of view and to contest the decision.
10. Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 of the GDPR.
Provisions for adding further elements
The addition of further elements to the model data protection declaration must state the type, scope, purpose, duration and revocation options of the respective data processing. The structure could be designed as follows:
11. Scope of the processing of personal data
This describes in as much detail as possible what personal data is processed on the website by whom and in what way.
12. legal basis for the processing of personal data
Here the legal basis for the processing of personal data is stated. As a rule, this will come from the catalog of Art. 6 para. 1 DSGVO.
13. purpose of data processing
Here it is described in detail which purposes the website operator aims at with the processing of the personal data. If the processing is based on the norm of Art. 6 (1) lit. f DSGVO, the legitimate interest in the processing will usually also be seen in this. In this case, however, it must always be examined whether, in order to achieve the purpose, milder means are also evident that are less detrimental to the interests of users in the protection of their personal data.
14 Duration of storage
In principle, data is deleted as soon as the purpose of its collection has been fulfilled. However, it must be specified in more detail in each individual case when this is given for the specific case of use. If no precise details can be given, at least criteria must be stated that make it easier for the user to determine the time of deletion.
15. Possibility of objection and elimination
For each data processing, the user shall be provided with information on the manner in which the processing of the data can be prevented or data that has already been processed can be deleted ahead of time. If the user has given consent to the processing, it must be possible to revoke this consent at any time. The revocation must not be more difficult than giving consent. The procedure for giving the revocation must be described.
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