INTRODUCTION AND TERMS
By operating our website https://atdigitalservices.com (hereinafter referred to as “website”), we process personal data. These are treated confidentially by us and processed in accordance with the applicable laws – in particular the German Data Protection Regulation (DSGVO) and the German Federal Data Protection Act (BDSG-neu). With our data protection regulations, we want to inform you which personal data we collect from you, for which purposes and on which legal basis we use it and, if applicable, to whom we disclose it. In addition, we will explain what rights you have to protect and enforce your data privacy.
2.1 Personal data
“Personal data” is any information relating to an identified or identifiable individual (Art. 4 No. 1 DSGVO). Information of an identified person can be e.g. the name or the e-mail address. However, personal data is also data for which the identity is not immediately apparent, but can be determined by combining one’s own or third-party information and thus learning who the person is. A person can be identified, for example, by providing his or her address or bank details, date of birth or user name, IP addresses and/or location data. Relevant here is all information that in any way allows a conclusion to be drawn about a person.
A “processing” is understood by Art. 4 No. 2 DSGVO to mean any operation in connection with personal data. This applies in particular to the collection, recording, organization, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure, transmission, dissemination or other form of making available, alignment or combination, restriction, erasure or destruction of personal data.
RESPONSIBLE COMPANY AND DATA PROTECTION OFFICER
3. RESPONSIBLE PARTY
Responsible for data processing is:
AT Digital Services GmbH
20359 Hamburg – Germany
4. DATA PROTECTION OFFICER
We have not appointed a data protection officer for our company.
5. PROCESSING FRAMEWORK: WEBSITE
Within the framework of the website with the URL https://atdigitalservices.com, we process the personal data from you listed in detail below under points 6-14. We only process data from you that you actively provide on our website (e.g. by filling out forms) or that you automatically provide when using our offer.
Your data will be processed exclusively by us and will not be sold, lent or passed on to third parties. If we use the help of external service providers to process your personal data, this is done within the framework of so-called order processing, in which we as the client are authorized to issue instructions to our contractors. For the operation of our website, we use external service providers for hosting, as well as for maintenance, care and further development. If further external service providers are used for individual processing operations listed in sections 6-14, they will be named there.
Data transfer to third countries does not take place and is not planned. We will provide information about exceptions to this principle in the processing operations described below.
THE PROCESSING IN DETAIL
6. PROVISION OF THE WEBSITE AND SERVER LOG FILES
6.1 Description of the processing
Each time you access the website, we automatically collect information that your browser transmits to our server. This information is also stored in the so-called log files of our system. This involves the following data:
Your IP address
the browser software you use, as well as its version and language
the operating system you are using
the website from which you came to our website (so-called referrer)
the subpages you called up on our website
the date and time of your visit to our website
your internet service provider
The amount of data transferred
Country and place from which you visited our website
Your duration of stay on our website
The temporary storage of your IP address by the system is necessary in order to deliver our website to a user’s terminal device. For this purpose, the user’s IP address must remain stored for the duration of the session. However, your IP address is not recorded in our log files.
The processing is carried out to enable the website to be called up and to ensure its stability and security. In addition, the processing serves the statistical evaluation and improvement of our online offer.
6.3 Legal basis
The processing is necessary to protect the overriding legitimate interests of the controller (Art. 6 para. 1 lit. f DSGVO). Our legitimate interest lies in the purpose named in section 6.2.
6.4 Storage period
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. Deletion of the log files takes place after 30 days.
7. CONTACT FORM AND CONTACT BY E-MAIL
7.1 Description of processing
By providing a contact form on our website, we want to offer you a convenient way to contact us. The data transmitted with and in the contact form or your e-mail will be used exclusively for the purpose of processing and responding to your request.
7.3 Legal basis
The processing is necessary to protect the overriding legitimate interests of the controller (Art. 6 para. 1 lit. f DSGVO). Our legitimate interest lies in the purpose named in section 7.2. If the e-mail contact is aimed at the conclusion or fulfillment of a contract, the data processing is carried out for the fulfillment of the contract (Art. 6 para. 1 lit. b DSGVO).
7.4 Storage period
We delete the data as soon as they are no longer required to achieve the purpose for which they were collected. This is usually the case when the respective communication with you has ended. The communication is terminated when it can be inferred from the circumstances that your concern has been conclusively clarified. If legal retention periods prevent deletion, the data will be deleted immediately after the expiry of the legal retention period.
8.1 Description of processing
8.3 Legal basis
The processing is necessary to protect the overriding legitimate interests of the controller (Art. 6 (1) lit. f DSGVO). Our legitimate interest lies in the purpose named in section 8.2.
8.4 Storage period
9. SOCIAL NETWORKS
9.1 Description of processing
Certain subpages of our website contain so-called social plugins offered by the external social networks Facebook, Twitter, Instagram and Google+. When you call up a page that contains such a plugin, your browser establishes a direct connection with the servers of the social network. The content of the respective social plugin is transmitted by the social network directly to your browser and displayed on our website. To prevent this, we use the so-called two-click solution. For this purpose, we have integrated the social plugins on our website in such a way that the connection of the social plugins with the servers of the social networks is interrupted by default. If you want to communicate directly with a social network on our website via the social plugin and enable data exchange, you must click on the respective desired social plugin and thereby activate it.
After activating a social plugin, we no longer have any influence on the scope of the data that the respective social network collects. We therefore inform you according to our level of knowledge.
By activating a social plugin, your IP address is transmitted to the respective social network in connection with the address of our website. If you are logged into the social network when visiting our website, this information will be assigned to your user account there. If you interact with an activated social plugin, e.g. “share”, “like” or “retweet” a post by means of the social plugin, this information is also transmitted directly to the respective social network and also stored there in your user account.
The social networks with which you communicate store your data as user profiles and also use them for advertising purposes, for market research and/or for the needs-based design of their websites. You have the right to object to the creation of these user profiles, for the exercise of which you must contact the social networks directly.
The processing is carried out in order to provide you with convenient user-friendly communication with the social networks.
9.3 Legal basis
The processing is necessary to protect the overriding legitimate interests of the controller (Art. 6(1)(f) DSGVO). Our legitimate interest lies in the purpose named in section 10.2.
By activating a social plugin, your data will be transmitted to one of the following social networks.
Facebook: Facebook Inc, 1601 S California Ave, Palo Alto, California 94304, USA. Further information on data protection at Facebook can be found at http://www.facebook.com/policy.php; http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications as well as http://www.facebook.com/about/privacy/your-info#everyoneinfo.
Twitter, Twitter Inc, 1355 Market St, Suite 900, San Francisco, California 94103, USA; For more information on Twitter privacy, please visit https://twitter.com/privacy.
Instagram: Instagram LLC, 1601 Willow Rd, Menlo Park, California 94025, USA; For more information on Instagram privacy, please visit https://help.instagram.com/155833707900388/.
Google+: Google Inc, 1600 Amphitheater Parkway, Mountainview, California 94043, USA; For more information on Google privacy, please visit https://www.google.com/policies/privacy/partners/?hl=de.
Pinterest: Pinterest Europe Ltd, Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland. Data may be passed on to the group company Pinterest Inc., 808 Brannan Street, San Francisco, California, 94103, USA and processed there. Further information on data protection at Pinterest can be found at https://policy.pinterest.com/de/privacy-policy.
The social networks also process your personal data in the USA and have submitted to the EU-US Privacy Shield. For more information on the EU-US Privacy Shield, please visit https://www.privacyshield.gov/EU-US-Framework.
10. YOUTUBE VIDEOS
10.1 Description of processing
Our website uses services from “YouTube” a video platform operated by YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA. YouTube is represented by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. We use YouTube by embedding individual videos from the platform on our website as a so-called iFrame, so that they can be played directly on our website. The videos are embedded in the “extended data protection mode” offered on YouTube, i.e. no personal data will be transferred from you to Google as long as you do not play the videos. Only when you play a video will data be transmitted to Google, over which we have no control. If you play a video embedded on a subpage of our website, Google will be informed which subpage you have visited and which video you have viewed. If applicable, your IP address will also be transmitted to Google. If you are logged in as a YouTube or Google user, Google assigns this information to your user account. Google stores your data as user profiles and uses them for advertising purposes, for market research and/or for the needs-based design of Google websites. You have the right to object to the creation of these user profiles. To exercise this right, you must contact Google directly. Further information on data protection at Google can be found at http://www.google.com/intl/de-DE/policies/privacy/.
The processing takes place in order to be able to show you videos on our website.
10.3 Legal basis
The processing is necessary to protect the overriding legitimate interests of the controller (Art. 6(1)(f) DSGVO). Our legitimate interest lies in the purpose named in section 11.2.
10.4 Recipients and transfer to third countries
Through the integration of YouTube, personal data may be transmitted to YouTube LLC or Google. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield. For more information on the EU-US Privacy Shield, please visit https://www.privacyshield.gov/EU-US-Framework.
11. VIMEO VIDEOS
11.1 Description of processing
Our website uses services from “Vimeo” a video platform operated by Vimeo LCC, 555 West 18th Street, New York, New York 10011, USA. We use Vimeo by embedding individual videos from the platform on our website as a so-called iFrame, so that they can be played directly on our website. When you visit a subpage of our website on which a video is embedded, a connection is established to the Vimeo servers and the video is displayed within our website. This transmits to Vimeo which website you have visited. If applicable, your IP address will also be transmitted to Vimeo. If you play an embedded video, this information is also passed on to Vimeo. If you are logged in as a Vimeo user, Vimeo assigns this data to your user account. Further information on data protection at Vimeo can be found at http://vimeo.com/privacy.
The processing takes place in order to be able to show you videos on our website.
11.3 Legal basis
The processing is necessary to protect the overriding legitimate interests of the controller (Art. 6(1)(f) DSGVO). Our legitimate interest lies in the purpose named in section 12.2.
11.4 Recipients and transfer to third countries
Vimeo also processes data in the USA.
12. GOOGLE ANALYTICS
12.1 Description of the processing
The processing takes place in order to be able to evaluate the use of our website. The information thus obtained is used to improve our online presence and to design it in line with requirements.
12.3 Legal basis
The processing is necessary to protect the overriding legitimate interests of the controller (Art. 6 para. 1 lit. f DSGVO). Our legitimate interest lies in the purpose named in section 14.2.
12.4 Storage period and right to object
We have explained the storage period and your control and setting options for cookies in section 8. You can object to the data processing by Google Analytics at any time by downloading and installing the browser add-on offered by Google at https://tools.google.com/dlpage/gaoptout?hl=de. Alternatively, you have the option of clicking on the following link. This will set an opt-out cookie on your terminal device, which will prevent the collection of your data during future visits to this website. The analysis data processed and stored with Google Analytics will be automatically deleted by us after 14 months.
12.5 Recipients and transmission to third countries
Google Analytics acts as a service provider for us within the scope of order processing. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield. For more information on the EU-US Privacy Shield, please visit https://www.privacyshield.gov/EU-US-Framework.
13. DATA SUBJECT RIGHTS
With regard to the data processing by our company described above, you are entitled to the following data subject rights:
13.1 Information (Art. 15 DSGVO).
You have the right to request confirmation from us as to whether we are processing personal data relating to you. If this is the case, you have a right to information about this personal data and to the further information listed in Art. 15 DSGVO under the conditions specified in Art. 15 DSGVO.
13.2 Correction (Art. 16 DSGVO).
You have the right to demand that we correct any inaccurate personal data concerning you and, if necessary, complete any incomplete personal data without undue delay.
13.3 Deletion (Art. 17 DSGVO).
You have the right to demand that we delete personal data concerning you without undue delay, provided that one of the reasons listed in detail in Art. 17 DSGVO applies, e.g. if your data is no longer required for the purposes we pursue.
13.4 Restriction of data processing (Art. 18 DSGVO).
You have the right to request us to restrict processing if one of the conditions listed in Art. 18 DSGVO applies, e.g. if you dispute the accuracy of your personal data, data processing will be restricted for the period of time that allows us to verify the accuracy of your data.
13.5 Data portability (Art. 20 DSGVO).
You have the right, under the conditions set out in Art. 20 DSGVO, to request the surrender of the data concerning you in a structured, common and machine-readable format.
13.6 Withdrawal of Consent (Art. 7(3) DSGVO).
You have the right to revoke your consent at any time in the case of processing based on consent. The revocation applies from the time it is asserted. In other words, it has effect for the future. The processing therefore does not become unlawful retroactively as a result of the revocation of consent.
13.7 Complaint (Art. 77 GDPR).
If you believe that the processing of personal data concerning you violates the GDPR, you have the right to lodge a complaint with a supervisory authority. You can exercise this right at a supervisory authority in the EU member state of your residence, workplace or the place of the alleged infringement.
13.8 Prohibition of automated decisions/profiling (Art. 22 GDPR).
Decisions which have legal effects concerning you or which significantly affect you must not be based solely on automated processing of personal data – including profiling. We inform you that we do not use automated decision-making including profiling with regard to your personal data.
13.9 Objection (Art. 21 DSGVO).
If we process personal data from you on the basis of Art. 6(1)(f) DSGVO (to protect overriding legitimate interests), you have the right to object to this under the conditions listed in Art. 21 DSGVO. However, this only applies insofar as there are reasons arising from your particular situation. After an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms. We also do not have to stop processing if it serves the assertion, exercise or defense of legal claims. In any case – also regardless of a specific situation – you have the right to object at any time to the processing of your personal data for direct marketing.
Status: February 2021