Privacy Policy
1. Privacy at a Glance
General Information
The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.
Data Collection on This Website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. You can find their contact details in the section “Notice on the Responsible Party” in this privacy policy.
How do we collect your data?
Your data is collected in part by you providing it to us. This may, for example, be data you enter into a contact form.
Other data is collected automatically or with your consent when you visit the website by our IT systems. This is primarily technical data (e.g. internet browser, operating system, or time of the page request). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Some of the data is collected to ensure the error-free provision of the website. Other data may be used to analyse your user behaviour.
What rights do you have regarding your data?
You have the right at any time to receive free information about the origin, recipients, and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you may revoke that consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
You may contact us at any time regarding this and other questions on the subject of data protection.
2. Hosting and Content Delivery Networks (CDN)
We host the content of our website with the following provider:
IONOS
The provider is IONOS SE, Elgendorfer Str. 57, 56410 Montabaur (hereinafter “IONOS”). When you visit our website, IONOS collects various log files including your IP addresses. For details, please refer to the IONOS privacy policy: https://www.ionos.de/terms-gtc/terms-privacy.
The use of IONOS is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable presentation of our website. Where appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.
Data Processing Agreement
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required under data protection law which ensures that the service processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.
Cloudflare
We use the service “Cloudflare”. The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter “Cloudflare”).
Cloudflare offers a globally distributed content delivery network with DNS. Technically, the transfer of information between your browser and our website is routed through Cloudflare’s network. This enables Cloudflare to analyse traffic between your browser and our website and to act as a filter between our servers and potentially malicious traffic from the internet. In doing so, Cloudflare may also use cookies or other technologies to recognise internet users, which are used solely for the purpose described here.
The use of Cloudflare is based on our legitimate interest in providing our web offering as free of errors and as secure as possible (Art. 6(1)(f) GDPR).
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details and further information on security and data protection at Cloudflare can be found here: https://www.cloudflare.com/privacypolicy/.
The company holds certification under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to complying with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5666.
Data Processing Agreement
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required under data protection law which ensures that the service processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.
3. General Notes and Mandatory Information
Data Protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
When you use this website, various personal data is collected. Personal data is data by which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this takes place.
We would like to point out that data transmission over the internet (e.g. when communicating by email) may have security vulnerabilities. Complete protection of data from access by third parties is not possible.
Notice on the Responsible Party
The party responsible for data processing on this website is:
RA Dr. Michèl Vollmerhaus LL.M.
Dornensiepen 3
58566 Kierspe
Phone: +49 (0) 23 59-29 63 18
Email: info@ra-vollmerhaus.de
The responsible party is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).
Retention Period
Unless a more specific retention period has been stated within this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you submit a legitimate request for deletion or revoke consent to data processing, your data will be deleted unless we have other legally permissible grounds for retaining your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion will take place after those grounds cease to apply.
General Notes on the Legal Bases for Data Processing on This Website
Where you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR where special categories of data are processed pursuant to Art. 9(1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. Where you have consented to the storage of cookies or to the access to information on your device (e.g. via device fingerprinting), data processing is additionally carried out on the basis of § 25(1) TDDDG. Consent may be revoked at any time. Where your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data where required to fulfil a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the specific legal bases applicable in each individual case is provided in the following sections of this privacy policy.
Recipients of Personal Data
In the course of our business activities, we work with various external parties. This sometimes also requires the transfer of personal data to those external parties. We only share personal data with external parties where this is necessary for the performance of a contract, where we are legally required to do so (e.g. disclosure of data to tax authorities), where we have a legitimate interest under Art. 6(1)(f) GDPR in the disclosure, or where another legal basis permits the transfer. When using data processors, we only share personal data of our customers on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.
Revocation of Your Consent to Data Processing
Many data processing operations are only possible with your express consent. You may revoke any consent you have already given at any time. The lawfulness of the data processing carried out prior to the revocation remains unaffected by the revocation.
Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)
WHERE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT, AT ANY TIME, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).
WHERE YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).
Right to Lodge a Complaint with the Competent Supervisory Authority
In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged breach. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.
Right to Data Portability
You have the right to have data that we process automatically on the basis of your consent or in the performance of a contract handed over to you or to a third party in a commonly used, machine-readable format. Where you request the direct transfer of data to another controller, this will only be done to the extent technically feasible.
Access, Rectification and Erasure
Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of the data processing, and, where applicable, a right to rectification or erasure of this data. You may contact us at any time regarding this and other questions on the subject of personal data.
Right to Restriction of Processing
You have the right to request the restriction of the processing of your personal data. You may contact us at any time for this purpose. The right to restriction of processing exists in the following cases:
- If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
- If the processing of your personal data was/is unlawful, you may request the restriction of data processing instead of erasure.
- If we no longer need your personal data but you require it for the exercise, defence or establishment of legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
- If you have lodged an objection pursuant to Art. 21(1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
Where you have restricted the processing of your personal data, such data may — apart from being stored — only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.
SSL and TLS Encryption
For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the browser address bar changes from “http://” to “https://” and by the padlock icon in your browser bar.
When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Objection to Promotional Emails
The use of contact data published as part of the imprint obligation for the purpose of sending unsolicited advertising and informational materials is hereby objected to. The site operators expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, for example through spam emails.
4. Data Collection on This Website
Cookies
Our websites use so-called “cookies”. Cookies are small data packets and do not cause any harm to your device. They are stored either temporarily for the duration of a session (session cookies) or permanently (persistent cookies) on your device. Session cookies are automatically deleted at the end of your visit. Persistent cookies remain stored on your device until you delete them yourself or until your web browser automatically deletes them.
Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g. cookies for processing payment services).
Cookies serve various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies may be used to analyse user behaviour or for advertising purposes.
Cookies that are required to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping cart function), or to optimise the website (e.g. cookies for measuring web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimised provision of its services. Where consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of that consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG); consent may be revoked at any time.
You can set your browser to inform you about the placing of cookies and to allow cookies only in individual cases, to exclude the acceptance of cookies for certain cases or in general, and to activate the automatic deletion of cookies when the browser is closed. If cookies are disabled, the functionality of this website may be limited.
You can find out which cookies and services are used on this website in this privacy policy.
Consent with Usercentrics
This website uses the consent technology of Usercentrics to obtain your consent to the storage of certain cookies on your device or to the use of certain technologies and to document this in a data-protection-compliant manner. The provider of this technology is Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich, website: https://usercentrics.com/de/ (hereinafter “Usercentrics”).
When you visit our website, the following personal data is transferred to Usercentrics:
- Your consent(s) or the revocation of your consent(s)
- Your IP address
- Information about your browser
- Information about your device
- The time of your visit to the website
- Geolocation
Furthermore, Usercentrics stores a cookie in your browser in order to be able to assign the consents granted or their revocation to you. The data collected in this way is stored until you request us to delete it, delete the Usercentrics cookie yourself, or until the purpose for storing the data no longer applies. Mandatory statutory retention obligations remain unaffected.
The Usercentrics banner on this website was configured with the help of eRecht24. You can recognise this by the fact that the eRecht24 logo appears in the banner. In order to display the eRecht24 logo in the banner, a connection to eRecht24’s image server is established. The IP address is also transmitted in the process, but is only stored in anonymised form in the server logs. The eRecht24 image server is located in Germany with a German provider. The banner itself is provided exclusively by Usercentrics.
Usercentrics is used to obtain the legally required consents for the use of certain technologies. The legal basis for this is Art. 6(1)(c) GDPR.
Data Processing Agreement
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required under data protection law which ensures that the service processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.
Server Log Files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
- Browser type and browser version
- Operating system used
- Referrer URL
- Hostname of the accessing computer
- Time of the server request
- IP address
This data is not merged with other data sources.
The collection of this data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website — for this purpose, the server log files must be collected.
Contact Form
If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in case of follow-up questions. We do not share this data without your consent.
The processing of this data is based on Art. 6(1)(b) GDPR, provided your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent may be revoked at any time.
The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to storage, or the purpose for storing the data no longer applies (e.g. after the processing of your enquiry has been completed). Mandatory statutory provisions — in particular retention periods — remain unaffected.
Enquiries by Email, Phone or Fax
If you contact us by email, phone or fax, your enquiry, including all resulting personal data (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not share this data without your consent.
The processing of this data is based on Art. 6(1)(b) GDPR, provided your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent may be revoked at any time.
The data you send us via contact requests will remain with us until you request us to delete it, revoke your consent to storage, or the purpose for storing the data no longer applies (e.g. after the processing of your request has been completed). Mandatory statutory provisions — in particular statutory retention periods — remain unaffected.
5. Plugins and Tools
Google Fonts (Local Hosting)
This site uses so-called Google Fonts for the uniform display of fonts, provided by Google. The Google Fonts are installed locally. A connection to Google’s servers does not take place.
Further information on Google Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=de.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
reCAPTCHA is used to check whether the data entry on this website (e.g. in a contact form) is made by a human or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, time spent by the website visitor on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to Google.
The reCAPTCHA analyses run entirely in the background. Website visitors are not informed that an analysis is taking place.
The storage and analysis of the data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting its web offerings from abusive automated spying and from spam. Where appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.
For further information on Google reCAPTCHA, please refer to Google’s privacy policy and Google’s Terms of Service at the following links: https://policies.google.com/privacy?hl=de and https://policies.google.com/terms?hl=de.
The company holds certification under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to complying with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.
6. Our Own Services
Handling of Applicant Data
We offer you the opportunity to apply to us (e.g. by email, by post, or via an online application form). The following provides information on the scope, purpose, and use of your personal data collected during the application process. We assure you that the collection, processing, and use of your data will be carried out in compliance with applicable data protection law and all other statutory provisions and that your data will be treated in strict confidence.
Scope and Purpose of Data Collection
When you send us an application, we process the associated personal data (e.g. contact and communication data, application documents, notes made during interviews, etc.) to the extent necessary to decide on the establishment of an employment relationship. The legal basis for this is § 26 BDSG under German law (initiation of an employment relationship), Art. 6(1)(b) GDPR (general pre-contractual measures), and — where you have given consent — Art. 6(1)(a) GDPR. Consent may be revoked at any time. Within our company, your personal data is only shared with persons involved in processing your application.
Where the application is successful, the data you submitted will be stored in our data processing systems on the basis of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of carrying out the employment relationship.
Retention Period for Data
If we are unable to make you a job offer, you decline a job offer, or you withdraw your application, we reserve the right to retain the data you submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the conclusion of the application process (rejection or withdrawal of the application). The data will then be deleted and the physical application documents destroyed. The retention serves in particular as evidence in the event of a legal dispute. If it is apparent that the data will be required after the 6-month period has expired (e.g. due to an impending or pending legal dispute), deletion will only take place once the purpose for further retention has ceased to apply.
Longer retention may also take place if you have given your consent (Art. 6(1)(a) GDPR) or if statutory retention obligations prevent deletion.
Inclusion in the Applicant Pool
If we are unable to make you a job offer, there may be the possibility of including you in our applicant pool. In the event of inclusion, all documents and information from the application will be transferred to the applicant pool in order to contact you in the event of suitable vacancies.
Inclusion in the applicant pool takes place exclusively on the basis of your express consent (Art. 6(1)(a) GDPR). Giving consent is voluntary and has no bearing on the current application process. The data subject may revoke their consent at any time. In that case, the data will be irrevocably deleted from the applicant pool, unless there are statutory grounds for retention.
The data in the applicant pool will be irrevocably deleted no later than two years after the consent was given.