Privacy Policy

Published on Feb 3, 2012

This privacy policy informs you about the type, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and the associated websites, functions, and content as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”). With regard to the terminology used, such as “processing” or “controller,” we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Controller

Timo Montalto
Taunusstraße 32
65719 Hofheim am Taunus

hi@montalto.me

Imprint: Imprint Link

Types of processed data:

  • Inventory data (e.g., names, addresses).
  • Contact data (e.g., email, phone numbers).
  • Content data (e.g., text input, photographs, videos).
  • Usage data (e.g., visited websites, interest in content, access times).
  • Meta/communication data (e.g., device information, IP addresses).

Categories of data subjects

Visitors and users of the online offering (hereinafter we refer to the data subjects collectively as “users”).

Purpose of processing

  • Provision of the online offering, its functions, and content.
  • Responding to contact requests and communicating with users.
  • Security measures.
  • Reach measurement/marketing

Terminology used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data.

“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

“Controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

“Processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Article 13 GDPR, we inform you of the legal bases of our data processing. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Article 6(1)(a) and Article 7 GDPR, the legal basis for processing for the performance of our services and carrying out contractual measures as well as responding to inquiries is Article 6(1)(b) GDPR, the legal basis for processing to fulfill our legal obligations is Article 6(1)(c) GDPR, and the legal basis for processing to protect our legitimate interests is Article 6(1)(f) GDPR. In the event that vital interests of the data subject or another natural person make the processing of personal data necessary, Article 6(1)(d) GDPR serves as the legal basis.

Security measures

We take appropriate technical and organizational measures in accordance with Article 32 GDPR, taking into account the state of the art, the implementation costs, and the nature, scope, context, and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access, input, transfer, ensuring availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and response to data threats. Additionally, we consider the protection of personal data already during the development, or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default (Article 25 GDPR).

Collaboration with processors and third parties

If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them, or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g., if a transmission of the data to third parties, such as payment service providers, is necessary for the performance of the contract pursuant to Article 6(1)(b) GDPR), you have consented, a legal obligation provides for this, or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called “processing contract,” this is done on the basis of Article 28 GDPR.

Transfers to third countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure, or transmission of data to third parties, this will only be done if it is to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the data to be processed in a third country only if the special requirements of Articles 44 et seq. GDPR are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

Rights of data subjects

You have the right to request confirmation as to whether data concerning you is being processed and to information about this data as well as to further information and a copy of the data in accordance with Article 15 GDPR.

You have the right, in accordance with Article 16 GDPR, to request the completion of data concerning you or the correction of inaccurate data concerning you.

In accordance with Article 17 GDPR, you have the right to request that data concerning you be deleted without delay, or alternatively, in accordance with Article 18 GDPR, to request a restriction of the processing of the data.

You have the right to request that the data concerning you that you have provided to us be received in accordance with Article 20 GDPR and to request its transmission to other controllers.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with Article 77 GDPR.

Right of withdrawal

You have the right to withdraw consents granted in accordance with Article 7(3) GDPR with effect for the future.

Right to object

You can object to the future processing of data concerning you at any time in accordance with Article 21 GDPR. The objection can be made in particular against processing for direct marketing purposes.

Cookies and right to object to direct marketing

“Cookies” are small files that are stored on users’ computers. Various information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, or “session cookies” or “transient cookies,” are cookies that are deleted after a user leaves an online offering and closes their browser. In such a cookie, for example, the content of a shopping cart in an online store or a login status can be stored. “Permanent” or “persistent” cookies are cookies that remain stored even after the browser is closed. For example, the login status can be stored if users visit the site after several days. Likewise, the interests of users can be stored in such a cookie, which is used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online offering (otherwise, if it is only their cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies and provide information about this in our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offering.

A general objection to the use of cookies used for online marketing purposes can be declared for a variety of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by disabling them in the settings of the browser. Please note that not all functions of this online offering may be available if cookies are disabled.

Deletion of data

The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer necessary for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.

According to legal requirements in Germany, the retention is particularly for 10 years in accordance with §§ 147(1) AO, 257(1) Nos. 1 and 4, (4) HGB (books, records, management reports, accounting documents, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257(1) Nos. 2 and 3, (4) HGB (commercial letters).

According to legal requirements in Austria, the retention is particularly for 7 years in accordance with § 132(1) BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with properties, and for 10 years for documents related to electronically provided services, telecommunications, broadcasting, and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

Contacting us

When contacting us (e.g., via contact form, email, phone, or social media), the user’s details are processed to handle the contact request and its processing in accordance with Article 6(1)(b) GDPR. The user’s details may be stored in a Customer-Relationship-Management System (“CRM System”) or comparable inquiry organization.

We delete the inquiries if they are no longer necessary. We review the necessity every two years; furthermore, the statutory archiving obligations apply.

Hosting and email dispatch

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services, and technical maintenance services that we use for the purpose of operating this online offering.

In this context, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta, and communication data of customers, interested parties, and visitors to this online offering based on our legitimate interests in an efficient and secure provision of this online offering in accordance with Article 6(1)(f) GDPR in conjunction with Article 28 GDPR (conclusion of a processing contract).

Collection of access data and log files

We, or our hosting provider, collect data on the basis of our legitimate interests within the meaning of Article 6(1)(f) GDPR about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address, and the requesting provider.

Log file information is stored for security reasons (e.g., to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data that needs to be retained for evidence purposes is excluded from deletion until the respective incident is finally clarified.

Online presences in social media

We maintain online presences within social networks and platforms to communicate with the customers, interested parties, and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.

Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g., write posts on our online presences or send us messages.

Integration of third-party services and content

We use content or service offerings from third-party providers within our online offering based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of Article 6(1)(f) GDPR) to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).

This always requires that the third-party providers of this content perceive the IP address of the users, as they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We strive to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. Through the “pixel tags,” information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in cookies on the user’s device and may include, among other things, technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, as well as being linked to such information from other sources.

Vimeo

We may integrate the videos of the platform “Vimeo” of the provider Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. We point out that Vimeo may use Google Analytics and refer to the privacy policy (https://www.google.com/policies/privacy) as well as opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=en) or the settings of Google for data usage for marketing purposes (https://adssettings.google.com/.).

YouTube

We integrate the videos of the platform “YouTube” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Created with the privacy policy generator by RA Dr. Thomas Schwenke