Privacy Policy: Your right – Our Commitment

Here you will find the privacy notices for our suppliers and service providers.
Here you will find the privacy notices for prospects and customers.

Who we are

The data controller responsible in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European Union and other data protection regulations is:

Kemény Boehme Consultants SE
Streitfeldstraße 17-19
81673 Munich
Germany

Tel: +49 (0) 89 45 20 56 – 200
Email: info@kbc-consultants.com
Web: www.kbc-consultants.com

How to contact the data protection officer

The designated data protection officer is:

DataCo GmbH
Nymphenburger Str. 86
80636 Munich
Germany
Tel: +49 (0)89 740 045 840
Web: www.dataguard.de

General information on data processing

On this page, we provide you with information regarding the processing of your personal data on our website.

How we collect and use your personal data will depend on how you interact with us or the services you use. We only collect, use or share your personal data where we have a legitimate purpose and a legal basis for doing so.

What do we mean by ‘legal basis’?

Consent (Art. 6(1) (a) GDPR)– You have given us your consent to process your personal data for the specific purpose we have explained to you. You have the right to withdraw your consent at any time. For further information on how to withdraw consent, please see the ‘Exercising your rights’ subsections in the subsequent sections of this Privacy Policy.

Contract (Art 6(1) (b) GDPR) – We need to use your data to fulfil a contract you have with us. Alternatively, it’s necessary to use your data because we have asked you to, or you have taken yourself, specific steps before entering that contract.

Legal Obligation (Art 6(1) (c) GDPR) – We need to use you’re your data to comply with the law.

Vital Interests (Art 6(1) (d) GDPR) – Processing your data is necessary to protect your vital interests or of another person. For example, to prevent you from serious physical harm.

Public Task (Art 6(1) (e) GDPR) – Using your data is necessary for the performance of a task carried out in the public interest, or because it is covered by a task set out in law, for example, for a statutory function.

Legitimate Interests (Art 6(1) (f) GDPR) – Processing your data is necessary to support a legitimate interest we or another party has, only where this is not outweighed by your own interests. Please note where your data is processed under the performance of a contract or for a legal obligation, if you do not provide the data requested, we may be unable to provide you with our app.

Please note that if your data is processed to fulfill a contract or legal obligation and you do not provide the requested data, we may not be able to provide you with our website services.

Data sharing and international transfers

As explained throughout this Privacy Policy, we use various service providers to help us deliver our services and keep your data secure. When we use these service providers, it is necessary for us to share your personal data with them.

We have agreements in place with all our service providers that we share your data with that oblige them to protect your data.

Where your personal data is shared outside the EU, we ensure that your personal data is given an equivalent level of protection, either because the jurisdiction to which your data is transferred has an ‘adequate’ data protection standard according to the European Commission, or by using another safeguard such as an enhanced contractual agreement, i.e. Standard Contractual Clauses adopted by the European Commission (SCCs).

For example, where we use US service providers, we either rely on SCCs or the EU-US Data Protection Framework, depending on the specific provider. You can request a copy of SCCs we have concluded with our service providers by sending an email to the email address provided in this Privacy Policy.

Your rights

When your personal data is processed, you are a data subject within the meaning of the GDPR and have the following rights:

1. Right of access (Art. 15 GDPR)
You may request the data controller to confirm whether your personal data is processed by them. If such processing occurs, you can request the following information from the data controller:

Purposes of processing
Categories of personal data being processed.
Recipients or categories of recipients to whom the personal data have been or will be disclosed.
Planned storage period or the criteria for determining this period
The existence of the rights of rectification, erasure or restriction or opposition.
The existence of the right to lodge a complaint with a supervisory authority.
If applicable, origin of the data (if collected from a third party).
If applicable, existence of automated decision-making including profiling with meaningful information about the logic involved, the scope and the effects to be expected.
If applicable, transfer of personal data to a third country or international organization.

2. Right to rectification (Art. 16 GDPR)
You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay.

3. Right to the restriction of processing (Art. 18 GDPR)
You may request the restriction of the processing of your personal data under the following conditions:

If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
If you have objected to the processing pursuant and it is not yet certain whether the legitimate interests of the data controller override your interests.

4. Right to erasure (“Right to be forgotten”) (Art. 17 GDPR)
If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:

Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
You withdraw your consent on which the processing is based pursuant to and where there is no other legal basis for processing the data.
You object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) GDPR.
Your personal data has been processed unlawfully.
The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject.
Your personal data was collected in relation to information society services offered pursuant to Art. 8 GDPR.

The right to deletion does not exist if the processing is necessary to exercise the right to freedom of speech and information:

to fulfil a legal obligation required by the law of the Union or Member States to which the data controller is subject,
or to perform a task of public interest or in the exercise of public authority delegated to the representative.
for reasons of public interest in the field of public health.
for archival purposes of public interest, scientific or historical research purposes or for statistical purposes.
to enforce, exercise or defend legal claims.

5. Right to data portability
You have the right to receive your personal data given to the data controller in a structured and machinereadable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data.

6. Right to object
For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (e) or 6 (1) (f) GDPR; this also applies to profiling based on these provisions.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

7. 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 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 Art. 78 GDPR.

A list, of the locally competent supervisory authorities in Germany can be found on the website of the Federal Commissioner for Data Protection at the following link: https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html

Data processing when you load our website

1. Description and scope of data processing
Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device.

The following data is collected:

Information about the browser type and the version used
The user’s operating system
The Internet service provider of the user
Date and time of access
Websites from which the user’s system accessed our website
Websites the user’s system accessed through our website

This data is stored in the log files of our system. There is no storage of this data together with other personal data of the user.

2. Purpose of data processing
The temporary storage of the IP address by the system is necessary for the delivery of the website to the computer of the user. For this purpose, the user’s IP address must be kept for the duration of the session.

The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimize the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.

3. Legal basis for data processing
The legal basis for the temporary storage of data and logfiles is Art. 6 (1) (f) GDPR.

4. Duration of storage
The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the website is accomplished.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is not possible.

5. Exercising your rights
The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. The user can object to this. Whether the objection is successful is to be determined within the framework of a balancing of interests.

Use of cookies

1. Description and scope of data processing
When you visit our website, we use technical tools for various functions, in particular cookies, which can be stored on your device. When you visit our website for the first time and at any time later, you have the choice of whether you generally permit the setting of cookies or which individual additional functions you would like to select.

You can make changes in your browser settings or via our consent manager. Cookies are text files or information in a database that are stored on your hard drive and assigned to the browser you are using so that certain information can be passed to the entity that sets the cookie.

We use technically necessary cookies, which are required for the technical structure of the website. Without these cookies, our website cannot be displayed (completely correctly) or the support functions are not possible.

The following data is stored and transmitted in the technical necessary cookies:

Language settings
Log-in information
Bot protection (non-personalized)

We use cookies on our website that are not technically necessary. Technically unnecessary cookies are text files that are not only used for the functionality of the website, but also collect other data.

As a result, the following data will be processed:

IP-address
Internet user location
Tracking of the surfing behavior
technical information about your browser and the devices you use (e.g. language settings, screen resolution), your internet service provider, the referrer URL (which website/advertisement you came to this site from)

2. Purpose of data processing
The purpose of using technically necessary cookies is to ensure the functionality of our website. 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 need technical necessary cookies for the following purposes:

Storage of language settings
Functionality of the website
security

The use of technically not necessary cookies is carried out for the purpose of improving the quality of our website, its content and thus our reach and profitability. By setting these cookies, we learn how the website is used and can thus constantly optimize our offer. These cookies serve us particularly for the following purposes: statistical evaluations (Google Analytics).

3. Legal basis for data processing
The regulations of the Telecommunications-Telemedia Data Protection Act (TTDSG) are relevant for the storage of information in the end user’s terminal equipment and/or access to information already stored in the end user’s terminal equipment. If the setting and reading of cookies is technically necessary, this is done to ensure the functionality of our website. In this case, the storage of and access to cookies on your terminal equipment is carried out on the basis of § 25(2)(2) TTDSG. This storage of and access to the information in your terminal equipment serves to facilitate your use of our website and to be able to offer you our services as you have requested. Some functions of our website also do not work without the use of these cookies and could therefore not be offered. The cookies are generally deleted after the session ends (e.g. logging out or closing the browser) or after the expiry of a specified duration. Information on different storage periods for cookies can be found in the following sections of this data protection declaration.

As far as cookies are set that are not technically necessary, this is done on the basis of your expressed consent, which you can provide via the cookie banner. The basis for storing and accessing information in this case is § 25(1) TTDSG in conjunction with. Art. 6(1)(1)(a), Art. 7 GDPR. You can withdraw your consent at any time with effect for the future or subsequently grant it again by configuring your settings for cookies accordingly. Alternatively, you can prevent the storage of cookies by making the appropriate settings in your browser software. Please note that the browser settings you make only affect the browser you are using. If personal data is processed following the storage of and access to the information on your terminal equipment, the provisions of the GDPR are relevant. Information on this can be found in the following sections of this privacy policy.

4. Exercising your rights
You can revoke consent to the use of cookies and manage your consent preferences at any time at the following link: You can manage cookies at any time via the consent manager (see fingerprint in the bottom left corner of the page).

Contact via Email

1. Description and scope of data processing
You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored. The data will be used exclusively for the processing of the conversation.

2. Purpose of data processing
If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

3. Legal basis for data processing
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 (1) (f) GDPR. Our legitimate interest is to optimally answer your request that you send by e-mail.

If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.

4. Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Exercising your rights
You have the possibility to withdraw consent to the processing of their personal data at any time. If you contact us via email, you can object to the storage of his personal data at any time, by the following means:
info@kbc-consultants.com
In this case, all personal data stored while establishing contact will be deleted.

Application via email and form

1. Description and scope of data processing
There is a form on our website which can be used for electronic job applications. If an applicant makes use of this possibility, the data entered in the input mask will be transmitted to us and stored. The data is:

Last name
First name
Telephone / mobile phone number
Email address
Salary expectations
Curriculum Vitae
Photo
Gender, personalized address, individual note

Alternatively, you can send us your application by email. In this case, we collect your email address and the information you provide in the email.

After sending your application, you will receive confirmation of receipt of your application documents from us by email.

Your data will not be passed on to third parties. The data will be used exclusively for processing your application.

2. Purpose of data processing
The processing of personal data from the application form serves us solely to process your application. If you contact us by email, this also constitutes the necessary legitimate interest in the processing of the data.

The other personal data processed during the sending process serve to prevent misuse of the application form and to ensure the security of our information technology systems.

3. Legal basis for data processing
The legal basis for the processing of the data is the initiation of the contractual relationship at the request of the data subject, Art. 6 (1) (b) Alt. 1 GDPR and § 26 (1) BDSG (Federal Act of Data Protection).

4. Duration of storage
After completion of the application procedure, the data will be stored for up to 6 months. Your data will be deleted after 6 months at the latest. In the event of a legal obligation, the data will be stored within the framework of the applicable provisions.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

Use of corporate profiles in professionally oriented networks

1. Scope of data processing
We use corporate profiles on professionally oriented networks. We maintain a corporate presence on the following professionally oriented networks:

LinkedIn
XING

On our site we provide information and offer users the possibility of communication.

The corporate profile is used for job applications, information, public relations, and active sourcing.

We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate profile. Further information can be found in the privacy policy of:

LinkedIn: https://www.linkedin.com/legal/privacy-policy
XING: https://privacy.xing.com/en

If you carry out an action on our company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public.

2. Legal basis for data processing
The legal basis for the processing of personal data for the purpose of communication with customers and interested parties is Art. 6 (1) (f) GDPR. Our legitimate interest is to answer your request optimally or to be able to provide the requested information.

If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.

3. Purpose of the data processing
Our corporate web profile serves to inform users about our services. Every user is free to publish personal data.

4. Duration of storage
The data generated on the company profile are not stored in our own systems.

5. Exercising your rights
You can object at any time to the processing of your personal data that we collect within the framework of your use of our corporate web profiles and assert your rights as a data subject mentioned the “Your rights” section of this privacy policy.Please send us an informal email to the email address stated in this privacy policy. You can find further information on objection and removal options here:

LinkedIn: https://www.linkedin.com/legal/privacy-policy
XING: https://privacy.xing.com/en

Hosting

The website is hosted on servers of a service provider commissioned by us. Our service provider is:
Lima City of the provider TrafficPlex GmbH

TrafficPlex GmbH
Konsul-Smidt-Str. 90
28217 Bremen
Managing Director: Phillipp Röll
USt-ID: DE274078422
HR Bremen B: 26671

For further information on the processing of personal data by Lima City please see: https://www.limacity.de/juristisches#datenschutzerklaerung

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:

Information about the browser type and the version used
The user’s operating system
The Internet service provider of the user
Date and time of access
Websites from which the user’s system accessed our website
Websites the user’s system accessed through our website

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – and server log files are therefore recorded.

The server of the website is geographically located in Germany.

Geotargeting

We use the IP address and other information provided by the user (e.g. the postal code used for registration or ordering) to approach regional target groups (so-called “geotargeting”).

The regional target group approach is used, for example, to automatically display regional offers or advertisements that often are more relevant to users. The legal basis for the use of the IP address and any other information provided by the user (e.g. postal code) is Art. 6 (1) (f) GDPR, based on our legitimate interest in ensuring a more precise target group approach and thus providing offers and advertising with greater relevance for our users.

Part of the IP address and the additional information provided by the user (e.g. postal code) are merely processed and not stored separately.

You can prevent geotargeting by, for example, using a VPN or proxy server that prevents accurate localisation. In addition, depending on the browser you are using, you can also deactivate a location localisation in the corresponding browser settings (as far as this is supported by the respective browser).

We use geotargeting on our website for the following purposes: Google Analytics

Integrated third-party services

We use various service providers to deliver the service we offer through the app.

Generally, where such services are essential to providing the basic service offered by the website, we have a legitimate interest in sharing your data with the relevant service providers in order to provide the relevant website service.

Where such services are required for additional services, enhanced functionalities, or additional purposes, your personal data will only be transferred to service providers if you provide consent.

You can manage your consent preferences at any time here: You can manage cookies at any time via the consent manager (see fingerprint in the bottom left corner of the page).

Use of Google Ads Remarketing

1. Scope of processing of personal data
We use Google Ads Remarketing of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). Google Remarketing is used for the renewed addressing of visitors to the online presence for advertising purposes via Google Ads ads. Google Ads Remarketing can be used to create target groups (“similar target groups”) who, for example, have visited certain pages. This makes it possible to identify the user on other online presences and to display targeted advertising. Google places a cookie on the user’s computer. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and operating system), data about the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data from advertising partners (in particular pseudonymised user IDs). Further information on the collection and storage of data by Google can be found here: https://policies.google.com/privacy?hl=en-GB

2. Purpose of data processing
The purpose of processing personal data is to specifically address a target group. The cookies stored on the user’s terminal device recognise the user when visiting an online presence and can therefore display advertisements in line with the user’s interests.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.

5. Exercising your rights
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You may prevent the collection and processing of your personal data by Google by preventing the storage of cookies by third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.
You can also prevent the collection of data generated by the cookie and related to your use of the online presence (incl. your IP address) to Google and to prevent the processing of this data by Google by downloading and installing the browser plug-in available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en
With the following link you can deactivate the use of your personal data by Google: https://adssettings.google.com.
Further information on objection and removal options against Google can be found at:
https://policies.google.com/privacy?hl=en-GB.

Use of Google Analytics 4

1. Description and scope of data processing
We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google).

Google Analytics examines, among other things, how website visitors use our site. Google sets cookies on your terminal device. During the visit, user behaviour is recorded in the form of “events”. As a result, personal data can be stored and analysed, including:

First visit to the website
Interaction with the website, usage path
Clicks on external links
Video usage
File downloads
Advertising impressions and clicks
Scroll behaviour (if to end of page)
Searches on the website
Language selection
Page visits
Location (region)
Your IP address (in shortened form)
Technical information about your browser and the end devices you use (e.g. language setting, screen resolution)
Your internet provider
Referrer URL

We use the User ID feature. User ID allows us to assign a unique, persistent ID to one or more sessions (and the activities within those sessions) and analyse user behaviour across devices.

By default, GA 4 has IP address anonymisation enabled. This means that your IP address is shortened by Google within the member states of the European Union or other contracting states to the Agreement on the European Economic Area. Exceptionally, only in rare cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google states that the IP address transmitted by your browser will not be merged with other Google data within the scope of Google Analytics.

You can obtain further information on the processing of data by Google here:
https://policies.google.com/privacy

2. Purpose of the data processing
We use GA 4 to evaluate the use of our online presence and to generate reports about the activities on our website. The reports are used to analyse the performance of our website and to target advertising to those people who have already expressed an initial interest by visiting our site.

3. Legal basis for the processing of personal data
The legal basis for the processing of the users’ personal data is, in principle, the user’s consent in accordance with Art. 6(1) (a) GDPR.

4. Duration of the storage
After 2 months your personal data will be deleted. This deletion takes place automatically once a month.

5. Exercising your rights
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.
You may prevent the collection and processing of your personal data by Google by preventing the storage of cookies by third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.
You can find further information on objection and removal options vis-à-vis Google at: https://policies.google.com/technologies/partner-sites.
You can also prevent the collection of data generated by the cookie and related to your use of the online presence (incl. your IP address) by Google, as well as 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=en.
You can deactivate the use of your personal data by Google using the following link: https://adssettings.google.de/anonymous?hl=en

Use of Vimeo

1. Scope of processing of personal data
We use the plugin of the Video portal Vimeo, Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA. Vimeo is an online video streaming portal. When you visit our website, your browser connects to Vimeo’s servers in the USA. Information about your online presence visit and your IP address will be forwarded to Vimeo.
This happens regardless of whether you have a Vimeo account and whether you are logged in to it. When you are logged in, Vimeo may link the information collected to your account.
For more information about Vimeo’s collection and storage of information, please visit: https://vimeo.com/privacy

2. Purpose of data processing
The provision of the Vimeo PlugIn serves the provision and embedding of videos.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law.

Use of Wordfence Security

1. Scope of processing of personal data
Our online presence uses functions of Defiant Inc., 800 5th Ave., Suite 4100, Seattle, WA 98104, USA (Hereinafter referred to as Defiant). Wordfence Security secures our online presence and protects visitors from viruses and malware. When you visit a page with a plugin, a direct connection is established between your computer and the Defiant Server. In order to recognize whether the visitor is a human or a bot, the plug-in sets cookies. Additional personal data may be stored and evaluated, in particular device and browser information (in particular IP address and operating system).
It is possible to evaluate the behaviour from the sent notifications (e.g. how often a page is called up). To protect against brute force and DDoS attacks or comment spam, IP addresses are stored on the Wordfence servers. IP addresses that are classified as acceptable are placed on a white list.
Further information on the collection and storage of data by Defiant can be found here:
https://www.wordfence.com/privacy-policy/.

2. Purpose of data processing
The online presence uses the plug-in to protect against viruses and malware and to ward off attacks by computer criminals.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

Use of WPML

1. Scope of processing of personal data
We use WPML of OnTheGoSystems Limited, 22/F 3 Lockhart Road, Wanchai, Hong Kong (Hereinafter referred to as WPML). WPML is a multilingual plugin for WordPress. We use WPML to present our online presence in different languages. When you visit our online presence, WPML stores a cookie on your device to store the language setting you have selected. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on) as well as device and browser information (in particular the IP address and the operating system).
Further information on the collection and storage of data by WPML can be found here:
https://wpml.org/de/documentation-3/privacy-policy-and-gdpr-compliance/

2. Purpose of the data processing of personal data
The use of WPML serves to be able to represent our online presence multilingually.

3. Legal basis for the processing of personal data
The legal basis for data processing is Art. 6 (1) (f) GDPR. Our legitimate interest lies in addressing visitors to our online presence in their native language.

4. Duration of storage
WPML stores cookies on your terminal. You can find information on the storage duration of cookies at: https://wpml.org/documentation/privacy-policy-and-GDPR-compliance

5. Exercising your rights
You can prevent WPML from collecting and processing your personal data by preventing the storage of thirdparty cookies on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser, or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.
You can find further information on objection and removal options against WPML at:
https://wpml.org/de/documentation-3/privacy-policy-and-gdpr-compliance/.

Use of Google Tag Manager

1. Scope of processing of personal data
We use the Google Tag Manager (https://www.google.com/intl/de/tagmanager/) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). With Google Tag Manager, tags from Google and third-party services can be managed and bundled and embedded on an online presence. Tags are small code elements on an online presence that are used, among other things, to measure visitor numbers and behavior, capture the impact of online advertising and social channels, use remarketing and targeting, and test and optimize online presences. When a user visits the online presence, the current tag configuration is sent to the user’s browser. It contains statements about which tags are to be triggered. Google Tag Manager triggers other tags that may themselves collect data.
For more information about the Google Tag Manager, please visit https://www.google.com/intl/de/tagmanager/faq.html and see Google’s privacy policy: https://policies.google.com/privacy?hl=en

2. Purpose of data processing
The purpose of the processing of personal data lies in the collected and clear administration as well as an efficient integration of the services of third parties.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law. Advertising data in server logs is anonymized by Google’s own statements to delete parts of the IP address and cookie information after 9 and 18 months respectively.

5. Exercising your rights
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You may prevent the collection and processing of your personal data by Google by preventing the storage of cookies by third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. You can also prevent the collection of data generated by the cookie and related to your use of the online presence (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
With the following link you can deactivate the use of your personal data by Google: https://adssettings.google.de/anonymous?hl=en
Further information on objection and removal options against Google can be found at: https://policies.google.com/privacy?gl=EN&hl=en.

Use of Cookiebot

1. Scope of processing of personal data
We use functionalities of the Cookie Content solution Cookiebot from Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter referred to as Cybot).
Cookiebot offers a software solution that takes care of the collection of consent about cookie usage and the tracking of online users. Cookiebot informs the users of our website about the cookies used on our website. You also have the possibility to deactivate cookie groups except for functional cookies (which are necessary for the smooth display of our website). We are obliged to document your consent or refusal in accordance with Art. 7 para. 1 GDPR.
The following personal data will be processed by Cybot:

The IP-number of the end user in anonymized form (the last three digits are set to ‘0’)..
Date and time of consent given.
Browser of the user.
The URL where consent was given.
An anonymous, random and encrypted key.
The consent status of the end user, which serves as proof of consent..

Cookies of Cybot are stored on your device.
The key and consent status are also stored in the user’s browser in the cookie of Cybot called “CookieConsent”. This enables the website to automatically read and follow the end user’s consent in all subsequent page requests and future user sessions for up to 12 months. The key will be used for the proof of consent and for an additional option to check if the consent status stored in the user’s browser is unmodified compared to the original consent sent to Cybot.
If the “Collective Consent-feature” is enabled to control the consent for multiple web pages through a single user consent, Cybot will also store another separate, random, unique ID with the user’s consent. If all the following criteria are met, this key will be stored in an encrypted form in the cookie “CookieConsentBulkTicket” in the user’s browser.
All data is hosted in an Azure data centre of the cloud provider Microsoft Ireland Operations Ltd, South County Business Park, One Microsoft Court, Carmanhall and Leopardstown, Dublin, D18 P521, Ireland.
For further information on the processing of data by Cybot, please click here:
https://www.cookiebot.com/en/privacy-policy/.

2. Purpose of data processing
We use Cookiebot to create and display cookie statements for users and to store and display cookie scan reports in the privacy policy. This enables us to comply with our information obligations towards the users of our website in accordance with Art. 13, 14 GDPR and to obtain and document consents to the use of cookies in compliance with the data protection laws.
Furthermore, we use Cookiebot to obtain aggregated information about the selection decisions of users regarding accepted cookie types and to create a graphical representation of these in the Service-Manager.

3. Legal basis for the processing of personal data
The legal basis for data processing is Art. 6 (1) (f) GDPR. Our legitimate interest here lies in the data processing purposes mentioned under 2. The interests and rights of users are considered accordingly by anonymising the IP address.

4. Duration of storage
Your personal information will be stored by Cybot for as long as necessary to fulfill the purposes described in this privacy policy or as required by law, e.g. for tax and accounting purposes.
The cookies used by Cookiebot are stored on the users’ device for up to 12 months.

5. Exercising your rights
You can prevent the collection and processing of your personal data by Cybot by preventing the storage of third party cookies on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.
For more information on how to object and remove a complaint against Cybot, please see:
https://www.cookiebot.com/en/privacy-policy/.

Use of Borlabs Cookie

1. Scope of Processing of Personal Data
We use Borlabs Cookie, a cookie consent management tool provided by Borlabs GmbH, 22305 Hamburg, Germany. Borlabs Cookie helps manage and document the consent of website visitors to cookies and similar technologies. When visitors interact with the consent banner, Borlabs Cookie processes data including their cookie preferences, device and browser information, IP address, and consent history. This data is essential for us to comply with legal requirements and to respect the privacy preferences of our visitors.

2. Purpose of Data Processing
The primary purpose of using Borlabs Cookie is to enable our website to meet legal obligations under the GDPR and TTDSG. By managing cookie consents effectively, we ensure that our website respects the choices of our visitors regarding privacy and the use of cookies and related technologies.

3. Legal Basis for the Processing of Personal Data
The processing of personal data through Borlabs Cookie is based on the legal requirement to obtain and document the consent of website visitors for the use of cookies and similar technologies, in accordance with Art. 6 (1) (c) GDPR and Section 25 of the TTDSG.

4. Duration of Storage
The personal data collected through Borlabs Cookie is stored for as long as necessary to document consent and comply with legal obligations. The retention period is determined by legal requirements for consent documentation. Data is securely deleted once it is no longer required for its intended purpose or when legal retention periods expire.

5. Exercising Your Rights
For more information about how Borlabs Cookie processes personal data and the rights of visitors, please refer to the privacy policy of Borlabs Cookie at: Borlabs Privacy Policy.

This privacy policy has been created with the assistance of DataGuard.