personal data (hereinafter referred to as “data”) within our online offer and
the related websites, functions and content as well as external online presence, such as
eg our Social Media Profile. (collectively referred to as “online offer”). in the
Regard to the terms used, such as “personal data” or their
“Processing” we refer to the definitions in Article 4 of the General Data Protection Regulation
DELFER GROUP is a brand of
ASSISTENZWERK Danyel Elferink e.K.
Telephone +49 (0) 251 97206500
Types of processed data
Meta / data communication
Processing of special categories of data (Article 9 (1) GDPR)
No special categories of data are processed.
Categories of data subjects
Customers and prospects as well as visitors and users of the online offer.
Purpose of processing
Providing the online offer, its contents and functions.
Provision of contractual services, service and customer care.
Answering contact requests and communicating with users.
Marketing and advertisement.
As of May 2018
1. Relevant legal bases
In accordance with Art. 13 GDPR, we will inform you of the legal basis of our
The following applies: The legal basis for obtaining consent is Article 6 (1) lit.
a and Art. 7 GDPR, the legal basis for processing in order to fulfill our services
and execution of contractual measures and answering queries is Art. 6 para. 1 lit.
b GDPR, the legal basis for processing to fulfill our legal
Obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for the processing of
Safeguarding our legitimate interests is Art. 6 para. 1 lit. f GDPR. In case that
vital interests of the person concerned or another natural person one
Processing of personal data, Art. 6 (1) lit. d GDPR as
Data processing required. We will inform you as soon as through the changes
a participation act on your part (eg consent) or any other individual
Notification is required.
3. Security measures
3.1. We meet in accordance with Art. 32 GDPR, taking into account the state of the art
Technology, the implementation cost and the nature, scope, circumstances and purposes
processing and the different likelihood and severity of the risk
for the rights and freedoms of natural persons, appropriate technical and organizational
Measures to ensure a level of protection appropriate to the risk; To the
Measures include, in particular, the assurance of confidentiality, integrity and availability
data by controlling the physical access to the data, as well as that of them
Access, input, disclosure, securing availability and their separation. Of
Furthermore, we have set up procedures that allow for a perception of data subjects’ rights,
To ensure data erasure and data vulnerability. Further
We take into account the protection of personal data already during development, or
Selection of hardware, software and procedures, according to the principle of data protection
due to technology design and privacy – friendly default settings (Art. 25
3.2. The security measures include in particular the encrypted transmission of
Data between your browser and our server.
4. Cooperation with contract processors and third parties
4.1. Unless we provide information to other persons in the course of our processing and
Disclose to them (contract processors or third parties), convey them to them or them
otherwise grant access to the data, this is done only on the basis of a legal permit
(eg if a transmission of the data to third parties, such as to payment service providers, in accordance with Art. 6 para
lit. b GDPR is required to fulfill the contract), you have consented to a legal
Obligation or on the basis of our legitimate interests (eg in use
of agents, webhosters, etc.).
4.2. Provided that we third parties with the processing of data on the basis of a so-called.
Contract processing contract, this is done on the basis of Art. 28 GDPR.
5. Transfers to third countries
If we have data in a third country (ie outside the European Union (EU) or the
European Economic Area (EEA)) or within the framework of the mobilization
services of third parties or disclosure, or transmission of data to third parties happens
this only if it is to fulfill our (pre) contractual obligations, based on your
Consent, due to a legal obligation or based on our legitimate
Interests happens. Subject to legal or contractual permissions, process or
we leave the data in a third country only if the special conditions of the
Art. 44 et seq. GDPR. That is, the processing is based on, for example, special
Guarantees, such as the officially recognized statement of an EU equivalent
Data protection levels (eg for the USA by the “Privacy Shield”) or observance official
recognized special contractual obligations (so-called “standard contractual clauses”).
6. Rights of the persons concerned
6.1. You have the right to ask for confirmation of any relevant data be processed and on information about this data as well as further information and copy
the data according to Art. 15 GDPR.
6.2. You have accordingly. Art. 16 GDPR the right to complete the you
data or correction of incorrect data concerning you.
6.3. In accordance with Art. 17 GDPR, they have the right to demand that the person concerned
Data are deleted immediately, or alternatively in accordance with Art. 18 GDPR
To restrict the processing of the data.
6.4. You have the right to demand that the data concerning you be provided to us
have to receive according to Art. 20 GDPR and their transmission to others
Responsible ones to demand.
6.5. You have gem. Art. 77 GDPR the right to file a complaint with the competent
To submit to the supervisory authority.
7. Right of withdrawal
You have the right to grant consent in accordance with. Art. 7 (3) GDPR with effect for the future
8. Right of objection
You may, in accordance with Art. 21, consider the future processing of your data
GDPR contradict at any time. The opposition may in particular against the processing for
Purposes of direct mailing.
9. Cookies and Right to Oppose Direct Mail
We use temporary and persistent cookies, ie small files stored on the devices
Users will be saved (Explanation of the term and the function, see last section
our online offer is required (eg, for the presentation of the website) or the
Save user decision when confirming the cookie banner. We are setting that aside
in a variety of services, especially in the case of tracking, via the US side
http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ explains
become. Furthermore, the storage of cookies by means of their shutdown in the
Settings of the browser can be achieved. Please note that then may not be
all functions of this online offer can be used.
10. Deletion of data
The data processed by us are deleted in accordance with Articles 17 and 18 GDPR or
expressly stated, the data stored with us are deleted, as soon as they are for their
Purpose are no longer required and the deletion no legal
Dispose of storage obligations. Unless the data is deleted because it is for
other and legally permissible purposes are required, their processing is restricted.
This means that the data is blocked and not processed for other purposes. This applies, for example, to data
which must be kept for commercial or tax reasons.
According to legal requirements, the storage takes place in particular for 6 years in accordance with § 257 Abs.
1 HGB (trading books, inventories, opening balance sheets, annual accounts, trade letters,
Accounting documents, etc.) as well as for 10 years according to § 147 Abs. 1 AO (books, records,
Management reports, accounting documents, commercial and business letters, relevant for taxation
11. Provision of contractual services
11.1. We process stock data (eg, names and addresses as well as contact details of
Users), contract data (eg, services used, names of contact persons,
Payment information) for the purpose of fulfilling our contractual obligations and Services acc. Art. 6 para. 1 lit b. GDPR. The in online forms as mandatory
marked entries are required for the conclusion of the contract.
11.2. As part of the use of our online services, we store the IP address and
the time of the respective user action. The storage is based on our
legitimate interests, as well as the user’s protection against abuse and other unauthorized
Use. A transfer of this data to third parties is not, unless it is to
Pursuit of our claims required or there is a statutory
Commitment acc. Art. 6 para. 1 lit. c GDPR.
12. Contact and processing of orders
12.1. When contacting us (via contact form, e-mail or registration for a
Workshop or webinar) will be the information of the user to process the contact request
and their settlement gem. Art. 6 para. 1 lit. b) GDPR processed.
12.2. The information provided by users can be found in our Customer Relationship Management System
(“CRM system”) or comparable request organization.
12.3. We set the CRM system “pipedrive” of the supplier Pipedrive OÜ, Paldiski mnt 80, Tallinn
10617, Estonia, a. This is done on the basis of the fulfillment of the contract and by authorized persons
Interests (efficient and fast processing of inquiries and orders). For this we have with
Pipedrive entered into a contract with so-called standard contract clauses in which Pipedrive
to process the user data only in accordance with our instructions and to comply with the
Committed to EU data protection levels. Pipedrive is also under the Privacy Shield Agreement
certified and thus offers an additional guarantee, the European data protection law
12.4. For the processing of orders, we use the online project management tool
“Agantty” (Agantty GmbH, Lange Str. 40, 27404 Zeven, Germany) and the time recording at
Orders are processed using the “ABRA primaERP” platform (ABRA Software as
Jeremiasova 1422 / 7b, 155 00, Prague Czech Republic). This happens on the basis of
Fulfillment of the contract and legitimate interests (efficient and rapid processing of the
Inquiries and orders). For this we have a contract with the aforementioned providers
so-called standard contractual clauses concluded in which the providers for processing the
User data only in accordance with our instructions and compliance with the EU
Commit privacy levels.
13. Collection of access data and logfiles
13.1. Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f.
GDPR Data on every access to the server on which this service is located (so-called
Server log files). The access data includes name of the retrieved web page, file, date and
Time of retrieval, amount of data transferred, message about successful retrieval, browser type together with
Version, user’s operating system, referrer URL (previously visited page), IP address
and the requesting provider.
13.2. Logfile information is used for security reasons (eg to investigate abuse
or fraud) for a maximum of seven days and after that
deleted. Data whose further retention is required for evidence purposes is up to
final clarification of the respective incident from the deletion1.
14. Online presence in social media
14.1. We maintain online presence within social networks and platforms to interact with
there active customers, prospects and users communicate and there over our
Services to inform. When calling the respective networks and platforms apply
the terms and conditions and the data processing guidelines of their respective operators.
The data of the users provided this with us within the social networks and platforms
communicate, eg write posts on our online presence or us messages
15. Cookies & reach measurement
15.1. Cookies are information provided by our web server or third party web servers to the
Web browser of users and stored there for later retrieval. at
Cookies can be small files or other types of information storage.
15.3. If users do not want cookies stored on their machine,
You will be asked to select the corresponding option in the system settings of your browser
deactivate. Saved cookies can be deleted in the system settings of the browser
become. The exclusion of cookies can lead to functional restrictions of this online offer
serve through the deactivation page of the Network Advertising Initiative (http: //
optout.networkadvertising.org/) and additionally the US-American website (http: //
www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/
16. Google Analytics
Google Analytics is not used by us.
17.1. The following information will inform you about the content of our newsletter
as well as the registration, dispatch and statistical evaluation procedures as well as your
Right to object. By subscribing to our newsletter, you agree with the
Reception and the procedures described.
17.2. Content of the newsletter: We send newsletters, e-mails and other electronic
Notifications with promotional information (hereinafter “Newsletter”) only with the
Consent of the recipient or a legal permission. Unless under a
Registration for the newsletter whose contents are described concretely, they are for the
Consent of the users authoritative. Incidentally, our newsletter contains information about
our products, offers, promotions and our company.
17.3. Double opt-in and logging: The registration for our newsletter is done in one
so-called double-opt-in method. This means you will receive an email after logging in to order
the confirmation of your registration will be asked. This confirmation is necessary for yourself
nobody with foreign e-mail addresses can register. The registrations for the newsletter will be
Logged to prove the logon process according to the legal requirements
to be able to. This includes the storage of the registration and confirmation time, as well
the IP address. Likewise, the changes to your stored at the shipping service
17.4. Shipping service provider: The newsletter is sent by “MailChimp”, a
Newsletter shipping platform of US provider Rocket Science Group, LLC, 675 Ponce De Leon
you can see here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d /
b / a MailChimp is certified under the Privacy Shield Agreement, providing one Guarantee to comply with European data protection level (https://www.privacyshield.gov/
participant? id = a2zt0000000TO6hAAG & status = Active).
17.5. Furthermore, the shipping service provider may, according to its own information, enter this data in
pseudonymous form, ie without assignment to a user, for optimization or improvement
use the own services, eg for the technical optimization of the dispatch and the
Presentation of newsletters or for statistical purposes, to determine from which countries
the receivers come, use. The shipping service uses the data of our
Newsletter recipient, however, not to write this yourself or pass it on to third parties.
17.6. Credentials: To sign up for the newsletter, it is sufficient to sign up for your e-mail.
Specify email address. Optionally we ask you a name, for the purpose of personal address in the
17.7. Success measurement – The newsletters contain a so-called “web beacon”, ie a pixel-sized one
File that is retrieved from the shipping service provider’s server when the newsletter is opened.
This call will initially provide technical information, such as information on
Browser and your system, as well as your IP address and time of retrieval. These
Information is used to technically improve services based on specifications
or target groups and their reading habits on the basis of their call sites (which can be
Address can be determined) or the access times used. Belongs to the statistical surveys
also determining if the newsletters will be opened, when they will be opened and
which links are clicked. This information can be used for technical reasons
be assigned to individual newsletter recipients. However, it is neither our endeavor nor it
that of the shipping service provider to watch individual users. The evaluations serve us a lot
more to recognize the reading habits of our users and our content to them
to adapt or different content according to the interests of our users too
17.8. The dispatch of the newsletter and the measurement of success are based on a
Consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 (2) no. 3 UWG
or on the basis of the legal permission gem. § 7 Abs. 3 UWG.
17.9. The logging of the registration process is based on our authorized
Interests acc. Art. 6 para. 1 lit. f GDPR and serves as proof of consent in the
Receipt of the newsletter.
17.10. Termination / Revocation – You can cancel the receipt of our newsletter at any time,
ie revoke your consent. A link to cancel the newsletter can be found at the end
of each newsletter. If users are only subscribed to the newsletter and this
Have terminated their registration, their personal data will be deleted.
18. Integration of services and content of third parties
18.1. We rely on our legitimate online content
Interests (ie interest in the analysis, optimization and economic operation of our
Online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) content or service offers by
Third parties to include their content and services, such as videos or fonts
(hereinafter uniformly referred to as “content”). This always presupposes that the third party
this content, the IP address of the users perceive, as they without the IP address the content
could not send to their browser. The IP address is thus for the presentation of this content
required. We endeavor to use only those content whose respective providers use the IP
Use the address only to deliver the content. Third party providers may also call so-called
Pixel tags (invisible graphics, also known as “web beacons”) for statistical or
Use marketing purposes. Through the “pixel tags”, information such as the
Visitor traffic on the pages of this website will be evaluated. The pseudonyms
Information may also be stored in cookies on users’ devices and under other technical information about the browser and operating system, referring websites,
Visiting time and other information on the use of our online offer included, as well
such information can be linked from other sources.
18.2. The following presentation provides an overview of third-party providers and their contents,
Data and, in some cases already mentioned here, possible contradictions (so-called opt-out) include:
External fonts from Google, LLC., Https://www.google.com/fonts (“Google Fonts”). The
Integration of Google Fonts is done by a server call on Google (usually in the
Third-party platform YouTube videos from Google LLC, 1600 Amphitheater Parkway,
Maps of the third-party Google Maps service Google LLC, 1600 Amphitheater
policies / privacy / opt out: https://www.google.com/settings/ads/.
Presentations of the third-party Prezi platform Prezi Inc., Nagymező u. 54-56, Budapest