The data controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States, as well as other data protection provisions, is:
ITQ GmbH
Parkring 4
85748 Garching near Munich
Telephone: +49 89 321 981-70
Fax: +49 89 321 981-89
Email: info@itq.de
Website: www.itq.de
Authorised representatives: Dr Rainer Stetter, Dr Bernd Spiegelberger
The data protection officer for the data controller is:
Wolfgang Steger, Solicitor, certified Data Protection Officer (DSB) – TÜV
Am Neuen Weg 21
82041 Oberhaching
Telephone: +49 178 771 4857
Email: steger@ra-steger.info
1. Scope of the processing of personal data
As a general rule, we collect and use our users’ personal data only to the extent necessary to provide a fully functional website, our content and services, and to fulfil our corporate purpose. The collection and use of our users’ personal data generally takes place only with the user’s consent. An exception applies in cases where it is not possible, for practical reasons, to obtain consent in advance and where the processing of the data is permitted by law.
2. Purposes and legal basis for the processing of personal data
We process personal data solely for the purpose of fulfilling our contractual obligations or safeguarding our overriding legitimate interests. Our legitimate interests arise from the pursuit of our corporate purpose.
Where we obtain the data subject’s consent for the processing of personal data, Article 6(1)(a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.
Where personal data is processed in order to fulfil a contract to which the data subject is a party, Article 6(1)(b) of the GDPR serves as the legal basis. This also applies to processing operations necessary for the implementation of pre-contractual measures.
Where the processing of personal data is necessary to comply with a legal obligation to which our company is subject, Article 6(1)(c) of the GDPR serves as the legal basis. Where the vital interests of the data subject or of another natural person necessitate the processing of personal data, Article 6(1)(d) of the GDPR serves as the legal basis.
If processing is necessary to safeguard a legitimate interest of our company or a third party, and the interests, fundamental rights and fundamental freedoms of the data subject do not override that interest, Article 6(1)(f) of the GDPR serves as the legal basis for the processing.
3. Categories of recipients and personal data, and the source of such data
We disclose personal data to our business partners and service providers for the purpose of carrying out our corporate objectives. To carry out our corporate objectives, we typically use the contact and address details of our customers and business partners. We usually obtain personal data directly from the data subject or, in exceptional cases and with the data subject’s consent, from third parties.
4. Transfer to third countries
In connection with the use of certain services (in particular those mentioned in this statement, such as Google Analytics, Google Maps, YouTube, Elfsight and Wordfence), personal data may be transferred to recipients in third countries, in particular the USA. Where there is no level of data protection in those countries guaranteed by an adequacy decision (e.g. the EU-U.S. Data Privacy Framework), the transfer takes place on the basis of appropriate safeguards in accordance with Article 46 of the GDPR (in particular standard contractual clauses) or an exception under Article 49(1) of the GDPR (in particular, your explicit consent). Further details can be found on the respective services’ websites.
5. Data erasure and retention period
The data subject’s personal data shall be erased or blocked as soon as the purpose for which it was stored no longer applies. Data may also be stored if this is provided for by European or national legislation in EU regulations, laws or other provisions to which the controller is subject.
Data will also be blocked or deleted when a retention period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the purpose of concluding or fulfilling a contract.
1. Hosting
Our website is hosted by ALL-INKL.COM – Neue Medien Münnich, owned by René Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany. All data generated when you access the website (in particular the server log files mentioned below and data that you submit via forms) is processed on the host’s servers in Germany. We have entered into a data processing agreement with the host in accordance with Article 28 of the GDPR. The legal basis is our legitimate interest in the secure and efficient provision of our online services (Article 6(1)(f) of the GDPR).
2. Description and scope of data processing
Every time our website is accessed, our system automatically collects data and information from the computer system of the user accessing the site. The following data is collected in the process:
• Browser type/browser version
• operating system used
• Referrer URL
• Hostname of the connecting computer
• Time of the server request
• IP address
The data is stored in our system’s log files. This data is not combined with any other personal data relating to the user.
3. Legal basis and purpose of data processing
The temporary storage of the IP address is necessary to enable the website to be delivered to the user’s computer. Data is stored in log files to ensure the website functions properly, to ward off attacks and to safeguard the security of our IT systems. These purposes constitute our legitimate interest pursuant to Article 6(1)(f) of the GDPR.
4. Duration of storage
The data will be deleted as soon as it is no longer required to fulfil the purpose for which it was collected. Server log files are generally deleted or anonymised after seven days at the latest. Data will only be stored for longer than this if it is necessary to investigate a specific security incident.
5. Right to object and right to have data erased
The collection of data for the purpose of providing the website and the storage of this data in log files is essential for the operation of the website. Consequently, users have no right to object.
6. SSL or TLS encryption
This page uses SSL or TLS encryption for security reasons and to protect the transmission of confidential information, such as enquiries submitted via our forms. You can recognise an encrypted connection by the fact that the browser’s address bar begins with „https://“ and by the padlock icon in your browser’s address bar.
1. What are cookies?
Our website uses cookies and similar technologies (e.g. local storage). Cookies are small text files that are stored in, or by, the web browser on the user’s device. They may contain a unique string of characters that enables the browser to be recognised when the website is visited again. In addition to cookies that we set ourselves (first-party cookies), third-party cookies may also be set when embedded content is loaded. Transient cookies (session cookies) are deleted when the browser is closed; persistent cookies remain stored until the end of their respective storage period or until you delete them.
2. Legal basis
Information is stored on your device or accessed only to the extent that this is strictly necessary for the provision of the functions you have expressly requested (Section 25(2)(2) of the TDDDG in conjunction with Article 6(1)(f) of the GDPR) or you have given your prior consent (Section 25(1) of the TDDDG in conjunction with Article 6(1)(a) of the GDPR). You may withdraw your consent at any time with effect for the future.
3. Consent management with SureCookie
To obtain and manage your consents, we use the WordPress plugin SureCookie from Brainstorm Force (the plugin’s developer). When you first visit our website, a cookie banner will appear, allowing you to consent to or refuse the use of individual categories (functional, statistical, marketing). Only once you have given your consent will the relevant cookies be set or the relevant services (e.g. Google Analytics, Google Maps, YouTube, Elfsight) be loaded.
Your selection will be stored in the cookies surecookie_user_consent and surecookie_session_id (randomly generated identifier) is stored in your browser; both are valid for 365 days. As proof of consent (Article 7(1) of the GDPR), we also store an entry on our server containing the date and time, the categories you have consented to and those you have refused, the random identifier, a truncated IP address and the country from which the request appears to originate. These records are automatically deleted after 365 days.
In order to determine the country of origin and apply the appropriate consent rules, your IP address is transmitted to a geolocation service provided by the plugin manufacturer (library.surecookie.com). Only the country is returned; only the truncated IP address is stored. The service is hosted in Germany; however, requests are routed via a content delivery network operated by a provider based in the USA, meaning that a transfer to a third country cannot be ruled out. Your consent decision is also transmitted via Google Consent Mode to the Google services used on this website, so that they can operate accordingly. The legal basis for this is our legal obligation to obtain and document consent (Article 6(1)(c) of the GDPR in conjunction with Article 7(1) of the GDPR) as well as our legitimate interest in managing consent in accordance with the law (Article 6(1)(f) of the GDPR).
4. Withdrawal and changes to your settings
You can change or withdraw your selection at any time via the following link: Cookie Preferences. Furthermore, you can delete cookies at any time via your browser settings, and you can restrict or disable the use of cookies. If cookies are disabled for our website, you may no longer be able to make full use of all the website’s features.
5. Overview of the cookies used
The following overview is generated automatically on the basis of regular scans of our website and contains the name, purpose, retention period and domain of the cookies used:
1. Description and scope of data processing
Our website features a contact form which can be used to contact us electronically. If a user makes use of this option, the data entered in the form is transmitted to us and stored. This data comprises:
• Name
• Email address
• Companies
• Telephone number (optional)
• Subject or nature of your enquiry
• Your enquiry
At the time the message is sent, the following data is also stored:
(1) The user’s IP address
(2) Date and time of dispatch
(3) Browser and device information
We use the WordPress plugin Fluent Forms for the forms. The data entered is stored in our website’s database (on our hosting provider’s servers; see Section III) and forwarded to us by email. Your consent to the processing of your data is obtained as part of the submission process, and reference is made to this privacy policy.
Alternatively, you may contact us via the email address provided. In this case, the user’s personal data transmitted via the email will be stored. No data will be passed on to third parties in this context. The data will be used exclusively for the purpose of handling the correspondence.
2. Legal basis for data processing
Where the user has given their consent, the legal basis for the processing of the data is Article 6(1)(a) of the GDPR.
The legal basis for the processing of data transmitted when sending an email is Article 6(1)(f) of the GDPR. If the purpose of the contact is to conclude a contract, the additional legal basis for the processing is Article 6(1)(b) of the GDPR.
3. Purpose of data processing
We process the personal data provided via the input form solely for the purpose of handling your enquiry. Where contact is made by email, this also constitutes the necessary legitimate interest in processing the data.
The other personal data processed during the submission process is used to prevent misuse of the contact form and to ensure the security of our IT systems.
4. Duration of storage
The data will be deleted as soon as it is no longer required to fulfil the purpose for which it was collected. For personal data entered via the contact form and that sent by email, this is the case once the relevant conversation with the user has ended. The conversation is deemed to have ended when it is clear from the circumstances that the matter in question has been conclusively resolved. Statutory retention obligations (e.g. for business correspondence) remain unaffected.
5. Right to object and right to have data erased
The user may withdraw their consent to the processing of their personal data at any time. If the user contacts us by email, they may object to the storage of their personal data at any time. In such cases, the conversation cannot be continued.
The objection may be submitted, amongst other ways, by email to steger@ra-steger.info.
In this case, all personal data stored when you contacted us will be deleted.
On our website, we offer an online self-assessment tool to help you evaluate your organisation’s compliance with the requirements of the Cyber Resilience Act (CRA). In doing so, we process your answers to the questions in the assessment, the score calculated from these answers, the contact details you have provided (salutation, title, name, email address, company, optional telephone number and rating) and the technical data stored when you submit the form (IP address, date and time).
We use the data to provide you with the analysis and – if you wish – to contact you regarding the results and our services. The legal basis is your consent (Article 6(1)(a) of the GDPR), which you give when submitting the form, and, in the case of an enquiry regarding our services, Article 6(1)(b) of the GDPR. You may withdraw your consent at any time with effect for the future. The data will be deleted as soon as it is no longer required for these purposes and there are no statutory retention obligations to the contrary. Technically, we also use the Fluent Forms plugin for this purpose (see Section V.).
1. Description and scope of data processing
You can apply via the application form on our website or by email. In doing so, we process the data you provide, in particular your name, email address, telephone number, the position you are applying for, your message and the application documents you have uploaded (e.g. CV, certificates, cover letter). When you submit your application, your IP address, as well as the date and time, will also be recorded. The data will be stored in our website’s database and forwarded to the relevant personnel within our company responsible for the recruitment process. The data will not be passed on to third parties.
Please do not provide us with any special categories of personal data (e.g. information relating to health, religion or ethnic origin) unless this is necessary for the application. If you do, however, provide such data, we will only process it to the extent permitted under Article 9(2)(b) of the GDPR.
2. Legal basis and purpose
Data processing is carried out for the purpose of conducting the recruitment process and deciding whether to enter into an employment relationship. The legal basis is Article 6(1)(b) of the GDPR (pre-contractual measures) in conjunction with Article 88 of the GDPR and Section 26 of the BDSG. Where you also give us your consent (e.g. to be included in a candidate pool), the legal basis is Article 6(1)(a) of the GDPR.
3. Duration of storage
If you are offered a position, your data will be transferred to your personnel file for the purposes of administering the employment relationship. If your application is unsuccessful, your application data will be deleted no later than six months after the application process has been completed, unless longer retention is necessary to defend against legal claims (e.g. under the General Equal Treatment Act) (Article 6(1)(f) of the GDPR) or you have consented to such retention.
We use the WordPress plugin Gravity Forms for online registration for our events (e.g. the Smart Green Island Makeathon). The information you provide is sent to us by email and – depending on the form – stored in our website’s database.
We use the personal data you provide in the online registration form for our event solely for the purposes of planning, organising and following up on our events. The processing of your personal data is, as a general rule, based on your consent, which is given voluntarily and may be withdrawn at any time by emailing steger@ra-steger.info may be withdrawn. Data processing up until the point of withdrawal remains lawful. If you do not give your consent or subsequently withdraw it, we will generally not be able to admit you to the event or will generally have to exclude you from the event upon receipt of your withdrawal. The data will not be passed on to third parties. Nor will the data be transferred to a third country. As a general rule, the data will only be stored for as long as we require it for the purposes set out above. The legal basis for the processing of your personal data is your consent (Article 6(1)(a) of the GDPR).
We also occasionally take photographs and make video recordings at our events. In doing so, we ensure that the person depicted is not portrayed in a derogatory manner. We use these images for corporate PR material and brochures, publications on our company’s website and intranet, on other corporate websites and portals – in particular our company’s social media channels – as well as in other corporate communications for internal and external purposes. Furthermore, the photographs and video footage are not disclosed to third parties. The legal basis for the use of these images is your consent (Article 6(1)(a) of the GDPR), which you provided when registering for the event. Our events are free of charge; however, by giving your aforementioned consent to the processing of your personal data for the purpose of taking photographs and film footage relating to you, you are, in a sense, paying for the event.
This means that, as a general rule, we can only admit you to the event if you have given your consent to the taking of photographs and filming. You can give your consent at any time by email at steger@ra-steger.info withdraw. However, the consequence of such withdrawal is that we will, as a rule, not admit you to the event; or, should the withdrawal be made during an event, we will, as a rule, have to exclude you from the event. We will retain the photographs and video recordings for as long as they can reasonably be used for the purposes mentioned above, whilst they remain relevant.
Please note that, in the event of the withdrawal of consent, we are entitled to rely on another legal basis for the processing of your personal data, provided that such a basis is applicable. In particular, it is conceivable that our legitimate interests in pursuing our corporate purpose may override your rights to informational self-determination, in which case the legal basis set out in Article 6(1)(f) of the GDPR would apply.
This website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland („Google“). It is integrated via the Google tag (gtag.js) using the WordPress plugin „Site Kit by Google“. Google Analytics is only loaded if you have given your consent to the „Statistics“ category via our cookie banner. The legal basis is your consent in accordance with Section 25(1) of the TDDDG in conjunction with Article 6(1)(a) of the GDPR. You may withdraw your consent at any time via the cookie settings.
Google Analytics enables us to analyse visitor behaviour on our website in order to improve our service. The following data, amongst others, is processed in the process:
• pages visited, time spent on site and interactions (e.g. clicks, scroll depth)
• Referrer URL (the page visited previously)
• approximate location (country, region, town)
• technical information (browser type/version, operating system, device type, screen resolution)
• truncated IP address
• a randomly generated client ID
To this end, Google uses cookies (in particular _ga and _ga_) with a retention period of up to two years. In Google Analytics 4, IP addresses are neither logged nor stored; they are truncated within the EU. The data collected is automatically deleted once the retention period set in Google Analytics has expired.
We use Google Consent Mode: no Analytics cookies will be set without your consent. Your selection in the cookie banner is transmitted to Google so that Google’s services can operate accordingly.
It cannot be ruled out that data may be transferred to Google LLC in the USA. Google LLC is registered under the EU-US Data Privacy Framework certified. An adequacy decision has therefore been issued by the European Commission in accordance with Article 45 of the GDPR regarding the transfer of data. We have also entered into a data processing agreement with Google.
Further information: Terms of Use marketingplatform.google.com/about/analytics/terms/de/, Google’s Privacy Policy policies.google.com/privacy, browser add-on for deactivation tools.google.com/dlpage/gaoptout.
We also use the WordPress plugin Independent Analytics to analyse page views statistically. This analysis takes place exclusively on our own server; no data is transferred to third parties and no cookies are set on your device. The data processed includes pages visited, referrers, time of visit, browser, operating system, device type and the approximate country of origin. Your IP address is not stored, but is used only temporarily to generate a pseudonymous identifier that changes daily. The legal basis for this is our legitimate interest in data-minimal reach measurement to improve our service (Article 6(1)(f) of the GDPR). You may object to this processing at any time (see Section XVII.).
On certain pages (e.g. Contact, Events), we embed maps from the Google Maps service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The maps are only loaded once you have given your consent to the „Marketing“ category via our cookie banner. The legal basis is your consent in accordance with Section 25(1) of the TDDDG in conjunction with Article 6(1)(a) of the GDPR, which you may withdraw at any time via the cookie settings.
When the map is loaded, a connection is established with Google’s servers. In doing so, Google receives information that you have accessed the relevant subpage of our website, as well as the data specified in Section III. 2, in particular your IP address. To display the map, Google also loads fonts (Google Fonts) from its servers. Google may use cookies (e.g. NID) are set. This happens regardless of whether you have a Google account and are logged in. If you are logged in, the data may be associated with your account. Google may also use this data for its own purposes, such as advertising and market research.
It cannot be ruled out that data may be transferred to Google LLC in the USA. Google LLC is registered under the EU-US Data Privacy Framework certified; an adequacy decision by the European Commission pursuant to Article 45 of the GDPR therefore applies to the transfer.
Further information: Terms of Use www.google.com/intl/de_de/help/terms_maps/, Privacy Policy policies.google.com/privacy.
We have embedded YouTube videos into our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The videos are only loaded once you have given your consent to the „Marketing“ category via our cookie banner. The legal basis is your consent in accordance with Section 25(1) of the TDDDG in conjunction with Article 6(1)(a) of the GDPR, which you may withdraw at any time via the cookie settings.
Where possible, we embed the videos in „enhanced privacy mode“ (youtube-nocookie.com). However, data is transmitted to YouTube at the latest when a video is played. When you visit our website, YouTube receives information that you have accessed the relevant subpage of our website, as well as the data specified in section III. 2, in particular your IP address. YouTube may set cookies and similar technologies (e.g. YSC, VISITOR_INFO1_LIVE, VISITOR_PRIVACY_METADATA), to compile statistics, optimise playback and prevent attempts at fraud. This happens regardless of whether you have a Google account and are signed in. If you are signed in, the data can be linked directly to your account. If you do not wish this to happen, you must log out before playing the video.
YouTube stores your data in the form of user profiles and uses it for the purposes of advertising, market research and/or tailoring its website to your needs. You have the right to object to the creation of these user profiles; to exercise this right, you must contact YouTube.
It cannot be ruled out that data may be transferred to Google LLC in the USA. Google LLC is registered under the EU-US Data Privacy Framework certified; an adequacy decision by the European Commission pursuant to Article 45 of the GDPR therefore applies to the transfer.
Further information: policies.google.com/privacy.
On our Newsroom page, we display a feed of posts from our social media channels. To do this, we use a widget provided by Elfsight (elfsight.com). The feed will only be loaded once you have consented to the „Functional“ category via our cookie banner. The legal basis is your consent in accordance with Section 25(1) of the TDDDG in conjunction with Article 6(1)(a) of the GDPR, which you may withdraw at any time via the cookie settings.
When the feed is loaded, a connection is established with Elfsight’s servers (including static.elfsight.com and core.service.elfsight.com). In the process, technical data such as your IP address, browser type, operating system, the page accessed and the time of access are transmitted. Elfsight or its infrastructure service provider (Cloudflare) may set cookies (e.g. elfsight_viewed_recently, _cfuvid). The widget does not, as a rule, establish a direct connection between your browser and the servers of the relevant social network; however, the images and content displayed may be loaded from the networks’ servers.
Elfsight is based outside the European Union. There is no adequacy decision from the European Commission regarding the recipient country. The transfer is carried out on the basis of your explicit consent in accordance with Article 49(1)(a) of the GDPR. There is a risk that authorities in the third country may access the data and that you may not have effective legal remedies available to you.
On our website, we provide links to our profiles on social media platforms (Facebook, Instagram, LinkedIn and YouTube). These are simple links; no social media plugins are embedded. Data is only transferred to the relevant provider once you click on a link and are thereby redirected to that provider’s page. The relevant provider is responsible for data processing on these platforms:
a) Facebook and Instagram: Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, D04 X2K5, Ireland – www.facebook.com/privacy/policy/, privacycenter.instagram.com/policy
b) LinkedIn: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland – www.linkedin.com/legal/privacy-policy
(c) YouTube: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland – policies.google.com/privacy
Where we operate our own pages on these platforms and process personal data there (e.g. in comments or messages), this is done on the basis of our legitimate interest in modern corporate communication (Article 6(1)(f) of the GDPR). In the case of Facebook pages, we are jointly responsible with Meta for the processing of page insights (Article 26 of the GDPR).
To protect our website from attacks, spam and misuse, we use the Wordfence security plugin from Defiant Inc., 1700 Westlake Ave N Ste 200, Seattle, WA 98109, USA. Wordfence analyses visits to our website (in particular the IP address, URL accessed, time and browser information) and blocks suspicious requests. To cross-reference this data with the latest threat intelligence, the IP address may be transmitted to Defiant Inc.’s servers in the USA. To this end, we have agreed standard contractual clauses with the provider in accordance with Article 46(2)(c) of the GDPR. The legal basis is our legitimate interest in the security and functionality of our website (Article 6(1)(f) of the GDPR). The data will be deleted as soon as it is no longer required for this purpose. Further information: www.wordfence.com/privacy-policy/
For reports made under the Whistleblower Protection Act (HinSchG), we provide a link to our external whistleblower portal (itq.whistleblowerportal.de). The processing of personal data in connection with this portal is governed by the privacy policy provided on the portal.
If your personal data is processed, you are a data subject within the meaning of the GDPR and you are entitled to the following rights vis-à-vis the controller:
1. Right of access
You may request confirmation from the data controller as to whether we are processing personal data relating to you.
If such processing is taking place, you may request the following information from the data controller:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data that are processed;
(3) the recipients or categories of recipients to whom your personal data has been or will be disclosed;
(4) the envisaged period for which your personal data will be stored or, where it is not possible to provide specific details in this regard, the criteria used to determine that period;
(5) the existence of a right to have personal data concerning you rectified or erased, a right to restrict 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 regarding the origin of the data, where the personal data are not collected from the data subject;
(8) the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the GDPR and – at least in such cases – meaningful information about the logic involved, as well as the scope and intended consequences of such processing for the data subject.
You have the right to request information as to whether your personal data is being transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate safeguards in accordance with Article 46 of the GDPR in relation to the transfer.
2. Right to rectification
You have the right to request that the data controller rectify and/or complete your personal data if the personal data being processed concerning you is inaccurate or incomplete. The data controller must rectify the data without delay.
3. Right to restriction of processing
You may request that the processing of your personal data be restricted under the following circumstances:
(1) where you contest the accuracy of the personal data relating to you for a period that enables 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 instead request that the use of the personal data be restricted;
(3) the controller no longer requires the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims, or
(4) if you have objected to the processing in accordance with Article 21(1) of the GDPR and it has not yet been determined whether the controller’s legitimate grounds override your grounds.
Where the processing of your personal data has been restricted, such data – apart from its storage – may only be processed with your consent or for the purposes of asserting, exercise or defence of legal claims, or to protect the rights of another natural or legal person, or for reasons of an important public interest of the European Union or a Member State. If the restriction on processing has been imposed 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 that the data controller erases your personal data without delay, and the data controller is obliged to erase such data without delay if any of the following grounds apply:
(1) The personal data relating to you is no longer necessary for the purposes for which it was collected or otherwise processed.
(2) You withdraw your consent on which the processing was based in accordance with Article 6(1)(a) or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing.
(3) You object to the processing in accordance with Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing in accordance with Article 21(2) of the GDPR.
(4) The personal data relating to you has been processed unlawfully.
(5) The erasure of your personal data is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the controller is subject.
(6) The personal data relating to you was collected in connection with the information society services offered, in accordance with Article 8(1) of the GDPR.
(b) Disclosure of information to third parties
Where the controller has made the personal data relating to you public and is obliged to erase it in accordance with Article 17(1) of the GDPR, it shall take appropriate measures, including technical measures, taking into account the available technology and the costs of implementation, to inform the controllers who are processing the personal data that you, as the data subject, have requested the erasure of all links to that personal data, or of copies or replicas of that personal data.
(c) Exceptions
The right to erasure does not apply where the processing is necessary:
(1) to exercise the right to freedom of expression and information;
(2) for the purposes of 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) on grounds of public interest in the area of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes, or for statistical purposes in accordance with Article 89(1) of the GDPR, insofar as the right referred to in subparagraph (a) is likely to render impossible or seriously impair the achievement of the objectives of such processing, or
(5) to assert, exercise or defend legal claims.
5. Right to information
If you have exercised your right to rectification, erasure or restriction of processing vis-à-vis the controller, the controller is obliged to notify all recipients to whom your personal data has been disclosed of this rectification, erasure or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed by the data controller of the identity of these recipients.
6. Right to data portability
You have the right to receive the personal data concerning you, which you have provided to the data controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another data controller without hindrance from the data controller to whom the personal data was provided, provided that
(1) the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR, or on a contract pursuant to Article 6(1)(b) of the GDPR, and
(2) the processing is carried out using automated means.
In exercising this right, you also have the right to have your personal data transferred directly from one data controller to another, in so far as this is technically feasible. This must not adversely affect the freedoms and rights of other individuals. The right to data portability does not apply to the processing of personal data which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
7. Right to object
You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions.
The data controller will no longer process your personal data unless they can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.
If your personal data is processed for the purposes of direct marketing, you have the right to object at any time to the processing of your personal data for the purposes of such marketing; this also applies to profiling in so far as it is related to such direct marketing.
If you object to the processing of your personal data for the purposes of direct marketing, your personal data will no longer be processed for these purposes. In connection with the use of information society services – notwithstanding Directive 2002/58/EC – you have the option of exercising your right to object by means of automated procedures using technical specifications.
8. Right to withdraw consent under data protection law
You have the right to withdraw your consent under data protection law at any time. Withdrawing your consent does not affect the lawfulness of any processing carried out on the basis of that consent prior to its withdrawal.
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 data controller,
(2) is permitted under Union or Member State law to which the controller is subject, and that law provides for appropriate measures to safeguard your rights and freedoms and your legitimate interests; or
(3) takes place with your express consent.
However, these decisions must not be based on special categories of personal data as referred to in Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) applies and appropriate measures have been taken to safeguard your rights and freedoms as well as your legitimate interests.
With regard to the cases referred to in (1) and (3), the controller shall take appropriate measures to safeguard your rights and freedoms as well as your legitimate interests, including at least the right to request that the controller arrange for a person to be involved, to state your own position and to challenge the decision.
10. Right to lodge a complaint with 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 where you reside, where you work or where the alleged infringement took place, if you consider that the processing of your personal data infringes the GDPR.
The supervisory authority to which the complaint was 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.
The supervisory authority responsible for us is:
Bavarian State Office for Data Protection Supervision (BayLDA)
Promenade 18, 91522 Ansbach
Website: www.lda.bayern.de
This privacy policy is currently in force and is dated November 2026. It may become necessary to amend this privacy policy as a result of further developments to our website or changes to legal or regulatory requirements. The latest version is available on this page at any time.