Dear Visitors,

Protecting your privacy is important us! Therefore, we would like to inform you here about how we handle your data that is gathered when you use our online offer.

A. Data controller

1. NAME AND ADDRESS OF THE DATA CONTROLLER

The data controller in the definition of the EU General Data Protection Regulation (“GDPR”) is

Robert C. Spies KG
Domshof 21, 28195 Bremen

Commercial Register:
Local Court of Bremen; Commercial Register No. HRA 14140 HB

General Partners:
Dipl. Kfm. Jens Lütjen and Robert C. Spies Beteiligungs GmbH
Registered office and commercial register: Bremen, HRB 33919
(Local Court of Bremen)

Managing Directors:
Dipl.-Kfm. Jens Lütjen, Khaled Hadidi, Andreas Fuchs

Phone: +49 421 - 17393 - 0
Fax: +49 421 - 17393 - 30

Email: info@robertcspies.de

 

2. NAME AND ADDRESS OF THE DATA PROTECTION OFFICER

The Data Protection Officer of the Controller is:

HDT Hanseatic Data Trust GmbH
Osterbekstraße 90 C (Alster City)
22083 Hamburg

T  +49 (40) 23 85 69 - 0
F  +49 (40) 23 85 69 - 10
Email: info@hdt-hh.de

Website: www.hdt-hh.de

 

B. General information

1. SCOPE OF THE PROCESSING OF PERSONAL DATA

We gather and use the personal data of our users generally only to the extent that this is required for providing a functional website, and our contents and services. Should this not be the case, personal data will normally only be used with the user’s consent. An exception applies for practical reasons in cases where it is not possible to obtain prior consent and the processing of the data is permitted under legal regulations.

 

2. LEGAL BASES FOR THE PROCESSING

If we obtain a consent declaration from the data subject for the processing of personal data, Art. 6 (1) lit. a) EU General Data Protection Regulation (GDPR) applies as the legal basis.

For the processing of personal data that is required for the performance of a contract to which the data subject is a party, Art. 6 (1) lit. b) GDPR serves as the legal basis. This also applies to processing that is required to take steps prior to entering into a contract. Where processing of personal data serves the purpose of fulfilling a legal obligation incumbent our company, the legal basis is Art. 6 (1), lit. c) GDPR.

In the event that vital interests of the data subject or another natural person necessitate the processing of personal data, Art. 6 (1) lit. d) GDPR applies as the legal basis. If the processing serves the purpose of protecting a legitimate interest of our company or that of a third party, and provided that the interests, fundamental rights and freedoms of the data subject do not override the interest mentioned first, Art. 6 (1), lit. f) GDPR serves as the legal basis for the processing. It is our company’s legitimate interest to operate our business.

 

3. ROUTINE DELETION AND BLOCKING OF PERSONAL DATA

We process and store personal data of the data subject only for as long as this is required for the purpose for which it is stored. Data can also be stored beyond this point if this is stipulated by the European or national legislatures in directives, laws, and other regulations under EU law which apply to the Controller. As soon as the purpose of the storage ceases to apply or the storage period prescribed by the mentioned regulations ends, the personal data will be routinely blocked or deleted.

 

4. SECURITY OF YOUR DATA

We use the common SSL procedure (Secure Socket Layer) during the website visit, in combination with the respectively highest encryption level that your browser supports. This is commonly a 256-bit encryption. If your browser does not support a 256-bit encryption, we will use the 128-bit v3 technology instead. You can tell if an individual page of our online appearance is transmitted in encrypted form by whether the key or lock symbol shown in the lower status bar of your browser is closed.

We furthermore use suitable technical and organisational security measures to protect your data from accidental or deliberate manipulation, partial or complete loss, destruction or access by unauthorised persons. Our security measures are being improved continuously according to technological progress.

C. Usage data

1. LOG FILES

On every retrieval of the website, we or the page provider gather data and information by means of an automated system. This data and information is stored in the log files of the server.

The following data can be gathered in this process:

• Information on the browser type and the version used
• The user’s operating system
• The user’s internet service provider
• The user’s IP address
• Date and time of the access
• Webpages from which the user’s system has been directed to our website (referrer)
• Webpages that are accessed by the user's system via our website

The data is processed for the purpose of delivering the contents of our webpage, assuring the functionality of our IT systems, and optimising our webpage. The log file data meanwhile is always stored separately from other personal data of the users.

 

2. COOKIES

Our pages use so-called cookies. Cookies are small text files that are stored in your web browser’s cache (so-called session cookies) for the duration of your browser session or for a certain period on your hard drive (so-called permanent cookies). The cookies enable that your web browser is recognised again, so that you can access contents more quickly and systematically, and that contents can be provided customised to your needs and preferences when you visit our website again in the future. For the purpose of our legitimate interest in providing the website, we therefore use technically necessary cookies to be able to offer the website customised to the visitors’ preferences. The cookies do not store any personal data.

If, besides the technically necessary cookies, we also want to use marketing, tracking or analysis cookies, your prior explicit consent is required. We ask for your consent, as soon as you start using the website, in the cookie banner appearing on our website, which informs you about our cookie policy and gives you selectable options to refuse or give your consent to all or certain kinds of cookies.

If you give us your consent, the legal basis for the processing of personal data is Art. 6 (1) lit. a) GDPR.

You can change your cookie settings or revoke the granted consent via the cookie banner.

The data processed by essential cookies is required for the purposes of protecting our and third parties’ legitimate interests pursuant to Art. 6 (1) sent. 1, lit. f) GDPR.

In addition, cookies by Google Analytics and Google Maps will be set on our website if you have given your consent. Please read more about this in the corresponding sections.

 

3. HOW CAN I PREVENT COOKIES FROM BEING STORED?

You can set your browser so that the storing of cookies is accepted only if you consent to this. You can delete any cookies that are still present. If you deactivate cookies, however, the functionality of webpages might be limited. You can find useful tips on how cookies can be deactivated in this wikihow.com.

 

4. USE OF THE COOKIEBOT FROM USERCENTRICS

We use the "Cookiebot" programme from Usercentrics A/S (referred to as "Usercentrics"), Havnegade 39, 1058 Copenhagen, Denmark, on our website for the purpose of needs-based and legally compliant use of our website. The German branch has the following address: Usercentrics GmbH, Sendlinger Str. 7, 80331 Munich, Germany.

This service is used to obtain and manage the consents and authorisations given by visitors to our website. The processing is carried out to fulfil our legal obligations, as without consent the cookies in question may not be stored or the tools on our website may not be used (cf. Art. 7 para. 1 GDPR). The legal basis for the use of the cookiebot is therefore Art. 6 para. 1 sentence 1 lit. c GDPR.

The cookiebot collects the following data, which is transmitted to Usercentrics

• Cookie preferences (consent given or not?)
• Information about the browser type and version used
• Information about the visitor's end device
• The IP address of the visitor
• Date and time of access

The Usercentrics cookiebot also sets a cookie in order to be able to assign the consent given or its revocation to the visitor or their end device. You can find additional information about Usercentrics and how it handles the data it collects at: https://usercentrics.com/de/datenschutzerklaerung/

 

5. USE OF GOOGLE ANALYTICS

For the purpose of a design as appropriate to need and for the continuous optimisation of our webpages, we use Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, 4 Barrow Street, Dublin 4, Ireland.

The information generated by the cookie about the use of the website by you is usually transmitted to a server of Google in the USA and stored there. We use IP anonymisation on our website, which truncates your IP address beforehand, within the Member States of the European Union or in other signatory states of the Agreement on the European Economic Area. The complete IP address will only be transmitted in exceptional cases to a server of Google in the USA and truncated there.

Google uses this information to analyse your anonymised use of the website and to compile reports about website activities. The reports generated by Google Analytics are used to analyse the performance of our website and the success of our marketing campaigns.

We have no influence over this data transmission. This and the fact that the data is transmitted to the USA is problematic for reasons of data protection.

You can prevent the storing of cookies by means of corresponding settings in your browser software. In addition, you can prevent the data, which is generated by the cookie and which relates to your use of the website, from being gathered by and transmitted to Google, and from being processed by Google by downloading and installing the browser plug-in available at the following link:

We do not pass on the information that is gathered by the cookie about the use of this website to any third parties.

Your explicit consent is required for the use of Google (Universal) Analytics. You receive the option to refuse or give your consent via the cookie banner in the beginning of your use process and to inform yourself about our company’s data protection rules.

If you give us your consent, the legal basis for the processing of personal data is Art. 6 (1) lit. a) GDPR. You can revoke consents once given at any time and without a statement of reasons. To do so, you can change your cookie settings via the cookie banner and revoke the granted consent.

 

6. USE OF GOOGLE MAPS

We use the offer of Google Maps on this website. It lets us display interactive maps directly on the website and allow you to use the convenient map feature. The provider is Google Ireland Limited (“Google”), Gordon House, 4 Barrow Street, Dublin 4, Ireland.

By visiting the website, Google receives the information that you have accessed the relevant subpage of our website. The data named under Section 4 of this Data Privacy Policy is transmitted in addition. This is done regardless of whether Google provides a user account where you are logged in or if you do not have a user account at all. If you are logged in with Google, your data will be attributed directly to your account. If you do not want the attribution to your profile at Google, you need to log out before activating the button. Google stores your data as a usage profile and uses it for the purpose of marketing, market research, and/or design as appropriate to need of its website. Such an analysis is done in particular (even of users who are not logged in) in order to provide personalised advertising and inform other users of the social network about your activities on our website. You have a right to object to the creation of these usage profiles, but you need to exercise it in relation to Google.

We have no influence over this data transmission. This and the fact that the data is transmitted to the USA is problematic for reasons of data protection. You have the option to easily deactivate the Google Maps service and thereby prevent the data transfer to Google: For this, deactivate JavaScript in your browser. We point out, however, that you might then not be able to use the map display.

Your explicit consent is required for the use of Google Maps. You receive the option to refuse or give your consent via the cookie banner in the beginning of your use process and to inform yourself about our company’s data protection rules.

If you give us your consent, the legal basis for the processing of personal data is Art. 6 (1) lit. a) GDPR.

You can revoke consents once given at any time and without a statement of reasons. To do so, you can change your cookie settings via the cookie banner and revoke the granted consent.

You can find more information about the handling of user data in Google’s data privacy policy at: https://policies.google.com/privacy?hl=de.

 

7. USE OF FACEBOOK INSIGHTS

Facebook uses its service “Facebook Insights” on our Facebook pages. If you grant your consent to the tracking on our website by opt-in, your data will be gathered for our Facebook fan page. You can claim your rights as a data subject against Facebook Ireland and Robert C. Spies KG. In accordance with the GDPR, Facebook has the primary responsibility for the processing of the Insights data. Facebook fulfils all duties under the GDPR relating to the processing of Insights data and makes the essential content of the Page Insights add-on available to the data subjects. Robert C. Spies KG does not make any decisions regarding the processing of Insights data and the further information according to Art. 13 GDPR, including the legal basis, identity of the controller, and storage period for cookies on user end devices. You can find more information about the Page Insights add-ons with regard to the people responsible at Facebook via this link:

You can revoke consents once given at any time and without a statement of reasons. To do so, you can change your cookie settings via the cookie banner and revoke the granted consent.

 

8. SOCIAL PLUG-INS OF SOCIAL NETWORKS

We use social plug-ins on our website to make our company more popular via social media. The promotional purpose behind this is regarded as consistent with the GDPR and it is therefore based on Art. 6 (1) lit. f) GDPR. If a corresponding consent has been requested, the processing takes place exclusively on the basis of Art. 6 (1) lit. a) GDPR); the consent can be revoked at any time.

You can recognise the linking by the relevant logo. If you click on it, you will be forwarded to our appearance on the relevant network.

To protect your data in the best possible way, the buttons are embedded in our page so that they will be activated only when clicking on the respective network’s logo button. Only upon activation by clicking the logo button will a connection with the servers of the relevant network be established. Therefore, no data will be transmitted yet solely by accessing and visiting the page.

The IP address will never be linked with other data relating to the user. The IP addresses are anonymised so that an attribution is not possible (IP masking).

a) Facebook

Plug-ins of the social network Facebook of the provider Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, are integrated on our pages. The Facebook plug-ins can be interactive elements or contents (e.g., videos, graphics or text contributions) and you can recognise them by the Facebook logos (white “f” on blue tile, the words “like”, “I like” or a “thumbs-up” symbol) or they are marked by the additional text “Facebook social plug-in.” The list and appearance of the Facebook social plug-ins can be viewed here: https://developers.facebook.com/docs/plugins/.  

By activating a button on our website, the plug-in establishes a direct connection between your browser and the Facebook server. Facebook thereby receives the information that you have visited our page from your IP address. When you click the Facebook “like” button or leave a comment while you are logged into your Facebook account, you can link the contents of our pages to you Facebook profile.

This way, Facebook can attribute the visit on our website to your user account. At the same time, the processed data can be used to create usage profiles of the users. If a user is a Facebook member and does not want that Facebook to gather data about him or her via this online offer and does not want Facebook to link the data to his or her member data stored at Facebook, the user must log out of Facebook and delete his or her cookies before using our online offer.

If you do not want Facebook to be able to attribute the visit to this website to your Facebook user account, please log out of your Facebook user account.

We point out that we, as the operator of this website, do not obtain knowledge of the content of transmitted data nor of its use by Facebook. This and the fact that the data is regularly transmitted to the USA is problematic for reasons of data protection.

You can find details on the purpose and scope of the data gathering, the further processing, and use of the data by Facebook, as well as the rights in this regard and optional settings for the protection of privacy in Facebook’s data privacy policies at https://www.facebook.com/about/privacy/.  

b) Instagram

Our website also uses so-called social plug-ins (“Plug-ins”) of Instagram, which is operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Instagram”). The Plug-ins are marked by an Instagram logo, for example, in the form of an “Instagram camera.”

When you call up a page of our internet appearance that contains such a Plug-in and click on the logo, your browser will establish a direct connection with the servers of Instagram. The content of the Plug-in is transmitted by Instagram directly to your browser where it integrates it on the page. By this integration, Instagram receives the information that your browser has accessed a corresponding page of our internet appearance, even if you do not have an Instagram profile or if you are presently not logged into Instagram. This information (including your IP address) will be transmitted directly by your browser to a server of Instagram in the USA where it will be stored. If you are logged in on Instagram, Instagram can directly attribute the visit to our website to your Instagram account. The information will furthermore be published on your Instagram account and displayed there to your contacts. If you do not want Instagram to be able to attribute the data gathered via our internet appearance directly to your Instagram account, you have to log out of Instagram before your visit to our website.

We point out that we, as the provider of the pages, do not obtain knowledge of the content of transmitted data nor of its use by Instagram. This and the fact that the data is regularly transmitted to the USA is problematic for reasons of data protection.

You can find more information about this in Instagram’s data privacy policy (https://help.instagram.com/155833707900388).

 

9. meta pixel

Within our online offering, we use the so-called "Facebook pixel"/"meta pixel" of the social network Facebook, which is operated by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook").

 

With the help of the meta pixel, Facebook is able to determine the visitors to our online offering as a target group for the display of adverts (so-called "Facebook ads"). Accordingly, we use the meta pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called "custom audiences"). With the help of the meta pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and are not annoying. With the help of the meta pixel, we can also track the effectiveness of Facebook adverts for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advert (so-called "conversion").

 

The data collected is anonymous to us as the operator of this website; we cannot draw any conclusions about the identity of the user. However, the company Meta stores and processes this data and can use it for its own advertising purposes. If you do not want Meta to be able to associate your visit to this website with your Facebook user account, please log out of your Facebook user account and delete the cookies. Otherwise, Meta can assign the data received via Meta pixels to your user account.

 

Further information on how meta pixels work can be found at the following link: https://de-de.facebook.com/business/help/742478679120153?id=1205376682832142

 

This use of data by Meta/Facebook cannot be influenced by us as the operator of this website.

 

The use of Meta Pixel is based on Art. 6 para. 1 lit. f GDPR. As the website operator, we have a legitimate interest in effective advertising measures, including social media. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

 

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found at:

https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.

 

You can find further information on protecting your privacy in Facebook's data protection information: https://de-de.facebook.com/about/privacy/.

 

You can also use the remarketing function "Custom Audiences" in the settings for adverts under

Deactivate https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. You must be logged in to Facebook to do this.

 

If you do not have a Facebook account, you can deactivate usage-based advertising from Facebook on the website of the European Interactive Digital Advertising Alliance at: http://www.youronlinechoices.com/de/praferenzmanagement/.

 

Details on the storage period can be found under the following link: https://de-de.facebook.com/privacy/policy/?section_id=8-HowLongDoWe

 

10. LinkedIn Insight Tag

We use the LinkedIn Insight tag on our website. The provider of this service is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland ("LinkedIn").

 

We use this service to obtain various information about visitors to our website. This includes the IP address, referrer URL, device and browser characteristics, timestamp and page views. If the visitor is logged in to LinkedIn, additional data (industry, job title, country, location, etc.) can also be analysed.

 

This enables us to further customise the presentation of our website. It also enables us to determine the success of our advertising measures and campaigns. We are also able to track "conversions", i.e. we can measure whether the visitor to our website has made a purchase or taken any other action.

 

The data collected is anonymous for us as the operator of this website; we cannot draw any conclusions about the identity of the users. However, LinkedIn stores and processes this data and can use it for its own advertising purposes. This use of the data by LinkedIn cannot be influenced by us as the operator of this website.

 

If you do not want LinkedIn to be able to associate your visit to this website with your LinkedIn user account, please log out of your LinkedIn account and delete the cookies. LinkedIn members can also authorise or restrict the use of their personal data for advertising purposes in their account settings: https://www.linkedin.com/psettings/advertising/actions-that-showed-interest

 

Details on data collection (purpose, scope, further processing, use) as well as your rights and setting options can be found in LinkedIn's privacy policy. This information can be found at the following link https://www.linkedin.com/legal/privacy-policy.

 

The Insight Tag is used on the basis of Art. 6 para. 1 lit. f GDPR. As the website operator, we have a legitimate interest in effective advertising measures, including social media. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

 

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found at: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.

 

If you do not have a LinkedIn account, you can deactivate usage-based advertising from LinkedIn on the website of the European Interactive Digital Advertising Alliance at: http://www.youronlinechoices.com/de/praferenzmanagement/.

 

For more details on how LinkedIn handles your data and how long it is stored, please follow the link below: https://www.linkedin.com/legal/privacy/eu?src=li-other&veh=www.linkedin.com

 

D. Your personal data (master data)

1. WHAT IS “PERSONAL DATA"?

Personal data is information about your person that permits identifying you personally or data that relates directly or indirectly to you personally, e.g., your name, address or phone number. Information that cannot be traced back to any particular or identifiable person is not personal data.

 

2. USE OF THE CONTACT FORM

Our webpage www.robertcspies.de features a contact button that you can use to contact us electronically. When you click the mail button, the window of your email program (e.g., Outlook) will open with our email address already entered in the address line. If you send us an email, we will receive from you at least your email address and further personal details you have provided voluntarily (e.g., last name, first name, address). We make the contact button available for the purpose of our legitimate interest, as this gives us more options to get in touch with you. Alternatively, it is possible to contact us at the provided phone numbers. If the data subject contacts the controllers who are responsible for the processing via one of these channels, the personal data transmitted by the data subject will be stored automatically. The storage solely serves the purpose of processing or establishing contact with the data subject. No data will be transferred to third parties.

 

3. USE OF THE JOB APPLICATION FORM

Our website offers the opportunity to apply for job openings or also submit an unsolicited application, and upload and transmit attachments (files) to us for this purpose. This provides you with the opportunity to apply online to currently published job openings of Robert C. Spies KG or one of its affiliates. To use this form, please enter your name and email address and attach your job application documents. Making this application form available serves the purpose in our legitimate interest of creating an additional method for transmitting job applications and addressing a broader field of potential applicants. In the alternative, you can also send us your job application in writing by post. The storage of the gathered data exclusively serves for implementing the application process. The data is only transmitted to third parties within the limits described under Section 5.

 

4. REDIRECTION TO OTHER ONLINE OFFERS

To expand our service range, you can find links on our webpage to other websites for which other providers are responsible. Please see our advertising partners’ privacy policies regarding the extent to which they gather personal data. You can tell that you are redirected when a new browser window opens and shows a new address in the address bar.

 

5. TRANSFER OF DATA TO THIRD PARTIES

Data is generally not transferred to third-party companies and if at all, this is done only within the scope described below:

Robert C. Spies KG makes a job application form available, which also permits applying to jobs offered by companies in which Robert C. Spies KG is a stakeholder or by companies affiliated within the Robert C. Spies group of companies. You can find a list of these companies here. If a job applicant uses the application form, we gather the name, email address, and phone number if applicable, as well as the data transmitted additionally in the cover letter, CV and further data (e.g.: school completion and qualification certificates). As part of the application process, we pass on this data to the responsible partner company, which offers the position and where the applicant could be hired.

This data will only be transferred to further partner companies – other than the one offering the position in question – and stored beyond the concrete purpose for up to 24 months if you have consented to this. You can give this consent by setting the opt-in check-mark before sending the application form. The consent can be revoked at any time by sending an email to datenschutz@robertcspies.de, by using the provided contact button, by post to Robert C. Spies KG, Domshof 21, 28195 Bremen, or by fax to 0421-17393 – 30.

I consent that Robert C. Spies KG transfers my personal data and job application documents to one of its partner companies if this company offers an equivalent position as the one for which I am applying. I simultaneously consent that my applicant data is stored by Robert C. Spies KG for a period of up to 24 months and that Robert C. Spies KG contacts me for a suitable job offer. I am aware that this consent is voluntary and does not result in an advantage over other applicants, but that it solely offers the possibility to use my application for comparable positions. The consent can be revoked at any time by sending an email to datenschutz@robertcspies.de, by using the provided contact button, by post to Robert C. Spies KG, Domshof 21, 28195 Bremen, or by fax to +49 421-17393 – 30

Apart from this, we will transfer your data to third parties only if:

You have expressly consented to this pursuant to Art. 6 (1) sent. 1, lit. a) GDPR;
The transfer pursuant to Art. 6 (1) sent. 1, lit. f) GDPR within the partner companies of Robert C. Spies KG is required for legitimate interests, in particular for the purposes of information and for organisational reasons, and there is no reason to assume that you have an overriding interest in the data not being transferred;
In case there is a legal obligation to transfer the data pursuant to Art. 6 (1) sent. 1, lit. c) GDPR; and
This is legally permissible and required pursuant to Art. 6 (1) sent. 1, lit. b) GDPR for the processing of the contractual relationship with you.

 

6. YOUR RIGHTS AS A DATA SUBJECT

If Robert C. Spies KG processes your personal data, you are a data subject in the definition of the General Data Protection Regulation and have the following rights in relation to us as the data controller:

a) Right to obtain confirmation

You can request a confirmation from the controller as to whether personal data relating to you is being processed by us.
If such a processing takes place, you can request the following information from the controller:

The purposes for which the personal data is processed;
The categories of from personal data that is processed;
The recipients or categories of recipients to whom personal data relating to you has been disclosed or is to be disclosed in the future;
The length of time for which it is planned to store your personal data or, if no concrete information can be given about this, the criteria for determining the storage duration;
Applicability of a right of rectification or deletion of your personal data, the right to the restriction of the processing by the controller or a right to object to this processing;
Applicability of a right to lodge complaint with a supervisory authority;
All available information about the source of the data if the personal data is not collected from the data subject;
Existence of automated decision-making, including profiling as referred to in Art. 22 (1) and (4) GDPR and, at least in those cases – meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
You have the right to receive information on whether the personal data relating to you is transmitted to a third country or an international organisation. You can demand in this context to be informed of the suitable transmission-related safeguards according to Art. 46 GDPR.

b) Right of rectification

You have the right of rectification and/or completion in relation to the controller if the processed personal data relating to you is incorrect or incomplete. In that case, we have to rectify the data without delay.

c) Right to restrict the processing

You can demand that the processing of your personal data be restricted on the following conditions:

If you deny the correctness of the personal data relating to you for a period that permits the controller to review the correctness of the personal data;
The processing is illegitimate and you reject the erasure of the personal data and instead request the restriction of the use of the personal data;
Robert C. Spies KG no longer requires your personal data for the purposes of the processing, but you require the data for the enforcement, exercise or defence of legal claims; or
If you have raised an objection against the processing according to Art. 21 (1) GDPR and if it is not certain yet if the justified interests of the data controller outweigh your reasons.
If the processing of your personal data has been restricted, this data – apart from its storage – may be processed only with your consent or for the enforcement, exercise or defence of legal claims, or for the protection of rights of another natural person or legal entity, or for reasons of a compelling public interest of the EU or a Member State of the EU.

If the processing has been restricted according to the aforementioned requirements, you will be informed by the controller before the restriction is lifted.

d) Right to erasure

You can demand from us that your personal data be deleted without delay and we are obligated to delete this data immediately, provided that one of the following reasons applies:

The personal data relating to you is no longer needed for the purposes for which it has been gathered or otherwise processed;
You revoke your consent that served as the basis for the processing according to Art. 6 (1) lit. a) GDPR or Art. 9 (2) lit. a) GDPR and there is no other legal basis for the processing;
You raise an objection according to Art. 21 (1) GDPR against the processing and there are no overriding justified reasons for the processing, or you object to the processing according to Art. 21 (2) GDPR;
Your personal data has been processed unlawfully;
The erasure of the personal data relating to you is required to fulfil a legal obligation according to EU law or the laws of the Member States that apply the controller;
Your personal data has been gathered with regard to offered services of the information society according to Art. 8 (1) GDPR.
If Robert C. Spies KG has made your personal data publicly accessible and if it is obligated to delete this data pursuant to Art. 17 (1) GDPR, it will take appropriate measures, including technical measures, in consideration of the available technology and the implementation costs, in order to inform the controllers, who process the personal data, that you as the data subject have requested the deletion of all links to this personal data or all copies or replications of this personal data.

The right of erasure does not apply, insofar as the processing is required for:

Exercising the right to free speech and information;
Fulfilment of a legal obligation that applies to the processing pursuant to EU law or the laws of the Member States or that applies to the controller, or in order to fulfil a task in the public interest or the processing takes place in exercise of an official authority that is vested in the controller;
Reasons of public interest in the area of public health pursuant to Art. 9 (2) lit. h) and i) as well as Art. 9 (3) GDPR;
Archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to Art. 89 (1) GDPR, insofar as the right referred to in (1) is expected to render the realisation of the processing purposes impossible or obstruct it to significant extent; or
Enforcement, exercise or defence of legal claims;.

e) Right to information

If you have asserted the right to the correction, erasure or restriction of the processing against the controller, it will be obligated to inform all recipients to whom personal data relating to you has been disclosed of this correction or erasure of this data, or the restriction of the processing, unless this proves impossible or involves disproportionate effort or expense.

You have the right against the controller to be informed of these recipients.

f) Right of data portability

You have the right to receive the personal data relating to you, which you have made available to Robert C. Spies KG, in a structured, common, and machine-readable format. In addition, you have the right to this data being transmitted to another controller without obstruction by the current controller to whom the personal data has been provided, insofar as

The processing is based on a consent according to Art. 6 (1) lit. a) GDPR. or Art. 9 (2) lit. a) GDPR, or according to Art. 6 (1) lit. b) GDPR; and
The processing takes place in automated procedures.
When exercising this right, you furthermore have the right to the personal data relating to you being transmitted directly from one controller to another controller, insofar as this is technically feasible. The rights and freedoms of others must not be impaired by this.

The right to data portability does not apply if the processing of personal data 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.

g) Right to object

You have the right to object, at any time, for reasons arising from your particular situation, to the processing of your personal data taking place on the basis of Art. 6 (1) lit. e) or lit. f) GDPR; this also applies to profiling based on these provisions. Robert C. Spies KG will then cease the processing of your personal data, unless it can prove compelling reasons for the processing, which qualify for protection and override your interests, rights and freedoms, or if the processing serves the purpose of enforcing, exercising or defending legal claims. If personal data relating to you is processed to operate direct marketing, you have the right to object at any time to the processing of the personal data relating to you for the purpose of such advertising; this also applies to profiling if it is related to such direct marketing. If you object to the processing for the purposes of direct marketing, the personal data relating to you will no longer be processed for these purposes. The objection can be addressed the Data Protection Officer, using these contact details:

Amelie Mann
Domshof 21, 28195 Bremen

Phone: +49 421 - 173 93-31
Email: datenschutz@robertcspies.de

You additionally have the option – notwithstanding Directive 2002/58/EC – to exercise your right to object with regard to the use of the services of the information society by automated processes that use technical specifications.

h) Right to revoke a consent according to data protection regulations

You have the right to revoke your consent according to data protection regulations at any time. The legitimacy of the processing that has taken place up until your revocation will not be affected by the revocation of the consent.

i) Automated decision-making in the individual case including profiling

You have the right to prevent being subjected to decision-making based exclusively on automated processing – including profiling – which develops legal effects for you or which causes a similarly significant restriction for you. This does not apply if the decision-making

is required for the conclusion or the fulfilment of a contract concluded between you and Robert C. Spies KG;
is permissible based on the legal regulations of the EU or the Member States that apply to the controller and if these legal regulations contain appropriate measures to protect your rights and freedoms as well as your legitimate interests; or
takes place with your explicit consent.
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 (1) GDPR, unless Art. 9 (2) lit. a) or lit. g) GDPR applies and appropriate measures for the protection of rights and freedoms as well as your justified interests have been taken.

With regard to the cases named in lit. a) and c), Robert C. Spies KG will take appropriate measures to protect your rights and freedoms, as well as your legitimate interests, which includes at least the right to intervention by a person of the controller, the right to present own standpoints and to challenge the decision.

j) Right to lodge complaint with a supervisory authority

Without prejudice to any other legal remedy under administrative law or appeal to a court, you have the right to lodge complaint at any time with a supervisory authority, in particular in the Member State of your residence, your place of work or the place of the suspected violation if you believe that the processing of the personal data relating to you violates the GDPR.

The supervisory authority with which complaint has been filed will inform the applicant in the complaint of the status and the results of the complaint, including the possibility of appeal in court pursuant to Art. 78 GDPR.

 

7. AVAILABILITY OF THE STATE DATA PROTECTION COMMISSIONER

The State Data Protection Commissioner in Bremen within the meaning of Sec. 40 BDSG [German Data Protection Act] is:

Dr Imke Sommer
Arndtstr. 1, 27570 Bremerhaven

P.O. Box 10 03 80, 27503 Bremerhaven

Phone: +49 421 361 20 10
Fax: +49 421 496 18 495

Email: office@datenschutz.bremen.de

The State Data Protection Commissioner in Hamburg within the meaning of Sec. 40 BDSG is:

Prof. Dr Johannes Caspar
Kurt-Schumacher-Allee 4, 20097 Hamburg

Phone: +49 40/428 54-40 40
Fax: 040/428 54-40 00

Email: mailbox@datenschutz.hamburg.de

The State Data Protection Commissioner in Lower Saxony within the meaning of Sec. 40 BDSG is:

Barbara Thiel
Prinzenstraße 5, 30159 Hannover

Phone: +49 511-120 4500
Fax: +49 511-120 4599

Email: poststelle@lfd.niedersachsen.de

 

8. CURRENT STATUS AND CHANGE OF THIS DATA PRIVACY POLICY

This Data Privacy Policy is currently valid in the status of August 2020.

It may become necessary to modify this Data Privacy Policy in result of the further development of our website and the offers that are provided on it, or due to changed legal or administrative regulations. You can retrieve and print out the respectively current Data Privacy Policy at any time on the website at https://www.robertcspies.de.