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Privacy Policy

Name and address of the controller

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States and other data protection provisions is:

helloclearance

Großflecken 43
24534 Neumünster
Germany

Telephone: +49 4321 877 165 0
Email: pb@helloclearance.de

Commercial register: HRB 21284 KI
Register court: Kiel Local Court
Represented by the managing director authorised to represent the company individually, Mr Patrick Burwitz

I. General information on data processing

1. Scope of the processing of personal data

We generally collect and use our users’ personal data only to the extent necessary to provide a functioning website and our content and services. Our users’ personal data is normally collected and used only with the user’s consent. An exception applies where obtaining prior consent is not possible for practical reasons and processing is permitted by law.

2. Legal basis for the processing of personal data

Where we obtain the data subject’s consent to process personal data, Article 6(1)(a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

Where processing personal data is necessary for the performance of a contract to which the data subject is a party, Article 6(1)(b) GDPR serves as the legal basis. This also applies to processing necessary to take steps prior to entering into a contract.

Where processing personal data is necessary for compliance with a legal obligation to which our company is subject, Article 6(1)(c) GDPR serves as the legal basis.

Where processing personal data is necessary to protect the vital interests of the data subject or another natural person, Article 6(1)(d) GDPR serves as the legal basis.

Where processing is necessary to safeguard a legitimate interest of our company or a third party, and the data subject’s interests, fundamental rights and freedoms do not override that interest, Article 6(1)(f) GDPR serves as the legal basis for processing.

3. Erasure of data and storage period

The data subject’s personal data will be erased or blocked as soon as the purpose of storage ceases to apply. Data may also be stored where this is provided for by the European or national legislature in EU regulations, laws or other provisions to which the controller is subject. Data will also be blocked or erased when a storage period prescribed by these provisions expires, unless continued storage is necessary for entering into or performing a contract.

4. Disclosure of data

If, in the course of processing, we disclose or transmit data to other persons and companies (processors or third parties), or otherwise grant access to the data, we do so only on the basis of legal permission, a legal obligation, our legitimate interests or your consent. In the following cases, our data processing is carried out by a service provider acting on our instructions, who is bound by data protection requirements and may not use the data for any other purpose. Our processors fall into the following categories:

IT services
Personnel administration services
Billing services
Website hosting
Website design and layout

If we commission third parties to process data on the basis of a data processing agreement, this is done on the basis of Article 28 GDPR.

If we process data in a third country when using third-party services, we do so only where this is necessary to fulfil our contractual or pre-contractual duties or a legal obligation, or on the basis of our legitimate interests or your consent. Subject to legal or contractual permissions, we process data, or have it processed, in a third country only where the special requirements of Articles 44 et seq. GDPR are met, for example where processing is based on special safeguards or complies with officially recognised specific contractual obligations.

5. SSL encryption

For security reasons and to protect the transmission of confidential content (such as enquiries you send through our contact form), this website uses SSL encryption. You can recognise an encrypted connection by the browser address changing from “http://” to “https://” and by the padlock symbol in your browser address bar.

When SSL encryption is enabled, the data you transmit to us cannot be read by third parties.

II. Provision of the website and creation of log files

1. Description and scope of data processing

Whenever our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.

The following data is collected:
(1) Client IP (the user’s IP address)
(2) Timestamp (date and time of access to the website)
(3) Request line (path of the destination address without the domain)
(4) Status code (the server informs the client whether the request was processed successfully)
(5) Response body size (size of the files temporarily downloaded by the user)
(6) Referrer sent by the client (indicates the page from which the user reached this website)
(7) User agent sent by the client (for example, information about the operating system and the browser type and version)

The data is also stored in our system’s log files. This data is not stored together with other personal data relating to the user.

2. Legal basis for data processing

The legal basis for the temporary storage of the data and log files is Article 6(1)(f) GDPR.

3. Purpose of data processing

The system needs to store the IP address temporarily to deliver the website to the user’s computer. The user’s IP address must therefore remain stored for the duration of the session.

Data is stored in log files to ensure that the website functions properly. We also use the data to optimise the website and ensure the security of our information technology systems. The data is not analysed for marketing purposes in this context.

These purposes also constitute our legitimate interest in data processing under Article 6(1)(f) GDPR.

4. Storage period

The data is erased as soon as it is no longer necessary to achieve the purpose for which it was collected. For data collected to provide the website, this is the case when the relevant session ends.

For data stored in log files, this is the case after no more than seven days. Storage beyond this period is possible. In that case, users’ IP addresses are erased or altered so that the accessing client can no longer be identified.

5. Right to object and request removal

The collection of data to provide the website and the storage of data in log files are essential for operating the website. The user therefore has no right to object in this case.

III. Use of cookies

1. Description and scope of data processing

We use the consent tool “Real Cookie Banner” to manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and the related consents. Details of how “Real Cookie Banner” works can be found at https://devowl.io/de/rcb/datenverarbeitung/.

The legal bases for processing personal data in this context are Article 6(1)(c) GDPR and Article 6(1)(f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

Providing personal data is neither contractually required nor necessary to enter into a contract. You are not obliged to provide personal data. If you do not provide the personal data, we cannot manage your consents.

2. Legal basis for data processing

The legal basis for processing personal data using cookies is Article 6(1)(f) GDPR.

3. Purpose of data processing

The purpose of technically necessary cookies is to make websites easier for users to use. Some functions of our website cannot be provided without cookies. These functions require the browser to be recognised even after the user changes pages.

User data collected through technically necessary cookies is not used to create user profiles.

These purposes also constitute our legitimate interest in processing personal data under Article 6(1)(f) GDPR.

4. Storage period, right to object and request removal

Cookies are stored on the user’s computer and transmitted from there to our website. As a user, you therefore have full control over the use of cookies. You can disable or restrict the transmission of cookies by changing your browser settings. Cookies already stored can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, you may no longer be able to use all website functions in full.

IV. Contact form and email contact

1. Description and scope of data processing

Our website provides a contact form that 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:

  • Title
  • First name
  • Surname
  • Telephone
  • Customer number
  • Email

The following data is also stored when the message is sent:

  • The user’s IP address
  • Date and time of the message

Your consent to data processing is obtained during the submission process, and reference is made to this privacy policy.

Alternatively, you can contact us using the email address provided. In that case, the user’s personal data transmitted with the email is stored.

No data is disclosed to third parties in this context. The data is used solely to process the correspondence.

2. Legal basis for data processing

Where the user has given consent, the legal basis for processing the data is Article 6(1)(a) GDPR.

The legal basis for processing data transmitted when sending an email is Article 6(1)(f) GDPR. If the email contact is aimed at entering into a contract, Article 6(1)(b) GDPR provides an additional legal basis for processing.

3. Purpose of data processing

We process the personal data entered in the form solely to handle the enquiry. In the case of contact by email, this also constitutes the necessary legitimate interest in processing the data.

Other personal data processed during submission is used to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Storage period

The data is erased as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data entered in the contact form and data sent by email, this is the case when the relevant correspondence with the user has ended. Correspondence is considered to have ended when it is clear from the circumstances that the matter concerned has been conclusively resolved.

Additional personal data collected during submission is erased after no more than seven days.

5. Right to object and request removal

The user may withdraw consent to the processing of 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 a case, the correspondence cannot be continued.

The user may notify us at any time of a withdrawal of consent or an objection to the storage of their data, in particular using the following contact details:

Email:
pb@helloclearance.de

By post:
helloclearance
Data Protection
Großflecken 43
24534 Neumünster

In that case, all personal data stored in the course of the contact will be erased.

V. Google Web Fonts

This website uses web fonts provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, to ensure consistent font presentation. When you access a page, your browser loads the required web fonts into its cache to display text and fonts correctly.

For this purpose, your browser must connect to Google’s servers. Google thereby becomes aware that our website has been accessed via your IP address. An adequate level of data protection is also ensured here by Google LLC’s certification under the “EU-US Privacy Shield”. Google Web Fonts are used in the interest of presenting our online services consistently and attractively. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR. If your browser does not support web fonts, a standard font from your computer is used.

Further information about Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://www.google.com/policies/privacy/.

Opt-out: https://adssettings.google.com/authenticated.

VII. Rights of data subjects

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

1. Right of access

You may ask the controller to confirm whether we process personal data concerning you.

If such processing takes place, you may request information from the controller about:

  1. the purposes for which the personal data is processed;
  2. the categories of personal data being processed;
  3. the recipients or categories of recipients to whom your personal data has been or will be disclosed;
  4. the envisaged storage period for your personal data or, if specific information is not possible, the criteria used to determine that period;
  5. the existence of a right to rectification or erasure of your personal data, a right to restriction of processing by the controller, or a right to object to such processing;
  6. the existence of a right to lodge a complaint with a supervisory authority;
  7. all available information about the source of the data where the personal data was not collected from the data subject;
  8. the existence of automated decision-making, including profiling, under Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved and the significance and envisaged consequences of such processing for the data subject.

You have the right to request information about whether your personal data is transferred to a third country or an international organisation. In this context, you may request information about the appropriate safeguards under Article 46 GDPR relating to the transfer.

2. Right to rectification

You have a right to rectification and/or completion by the controller if your personal data being processed is inaccurate or incomplete. The controller must rectify the data without undue delay.

3. Right to restriction of processing

You may request restriction of the processing of your personal data under the following conditions:

  1. if you contest the accuracy of your personal data, for a period enabling the controller to verify its accuracy;
  2. if the processing is unlawful and you oppose erasure of the personal data and request restriction of its use instead;
  3. if the controller no longer needs the personal data for the purposes of processing, but you need it for the establishment, exercise or defence of legal claims; or
  4. if you have objected to processing under Article 21(1) GDPR and it has not yet been established whether the controller’s legitimate grounds override your grounds.

Where processing of your personal data has been restricted, that data may, apart from storage, be processed only with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another natural or legal person, or for reasons of important public interest of the Union or a Member State.

If processing has been restricted under the above conditions, the controller will inform you before the restriction is lifted.

4. Right to erasure

a)
You may ask the controller to erase your personal data without undue delay, and the controller must erase that data without undue delay, where one of the following grounds applies:

  1. Your personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
  2. You withdraw the consent on which processing was based under Article 6(1)(a) or Article 9(2)(a) GDPR, and there is no other legal basis for processing.
  3. You object to processing under Article 21(1) GDPR and there are no overriding legitimate grounds for processing, or you object to processing under Article 21(2) GDPR.
  4. Your personal data has been unlawfully processed.
  5. Your personal data must be erased to comply with a legal obligation under Union or Member State law to which the controller is subject.
  6. Your personal data was collected in relation to the offer of information society services under Article 8(1) GDPR.

Where the controller has made your personal data public and is obliged to erase it under Article 17(1) GDPR, the controller will take reasonable steps, including technical measures, taking account of available technology and implementation costs, to inform controllers processing that personal data that you, as the data subject, have requested the erasure of all links to, or copies or replications of, that personal data.

b)
The right to erasure does not apply to the extent that processing is necessary:

  1. to exercise the right to freedom of expression and information;
  2. to comply with a legal obligation requiring processing under Union or Member State law to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;
  3. for reasons of public interest in the area of public health under Article 9(2)(h) and (i) and Article 9(3) GDPR;
  4. for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes under Article 89(1) GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  5. for the establishment, exercise or defence of legal claims.

5. Right to notification

If you have exercised your right to rectification, erasure or restriction of processing against the controller, the controller must notify all recipients to whom your personal data has been disclosed of that rectification, erasure or restriction, unless this proves impossible or involves disproportionate effort.

You have the right to be informed by the controller about these recipients.

6. Right to data portability

You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. You also have the right to transmit that data to another controller without hindrance from the controller to whom it was provided, where:

  1. processing is based on consent under Article 6(1)(a) or Article 9(2)(a) GDPR, or on a contract under Article 6(1)(b) GDPR; and
  2. processing is carried out by automated means.

When exercising this right, you also have the right to have your personal data transmitted directly from one controller to another, where technically feasible. This must not adversely affect the rights and freedoms of others.

The right to data portability does not apply to processing personal data necessary to perform a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on those provisions.

The controller will no longer process your personal data unless it demonstrates compelling legitimate grounds for processing which override your interests, rights and freedoms, or processing serves the establishment, exercise or defence of legal claims.

Where your personal data is processed for direct marketing purposes, you have the right to object at any time to processing your personal data for such marketing. This includes profiling insofar as it is related to such direct marketing.

If you object to processing for direct marketing purposes, your personal data will no longer be processed for those purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means 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. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

9. Automated individual decision-making, 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 where the decision:

  1. is necessary for entering into or performing a contract between you and the controller;
  2. is authorised by Union or Member State law to which the controller is subject and which also provides suitable measures to safeguard your rights, freedoms and legitimate interests; or
  3. is based on your explicit consent.

However, these decisions must not be based on special categories of personal data under Article 9(1) GDPR, unless Article 9(2)(a) or (g) GDPR applies and suitable measures to safeguard your rights, freedoms and legitimate interests have been put in place.

In the cases referred to in (1) and (3), the controller will implement suitable measures to safeguard your rights, freedoms and legitimate interests, including at least the right to obtain human intervention on the controller’s part, to express your point of view and to contest 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 of your habitual residence, place of work or the place of the alleged infringement, if you consider that processing your personal data infringes the GDPR.

The supervisory authority with which the complaint has been lodged will inform the complainant of the progress and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.

You can find out which state data protection supervisory authority is responsible for our company at the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.