DATA PRIVACY

PRIVACY POLICY OF ROBERT C. SPIES KG AND ASSOCIATED COMPANIES

You can find a list of the above mentioned associated companies here


Dear Visitors,

The protection of your privacy is important to us! So, with the information below we would like to inform you how we handle your data that collected during the use of our website.


A. Data Controller

1.     Name and Address of the Data Controller

 

The data controller within the meaning of the EU General Data Protection Regulation (GDPR) is 

 

Robert C. Spies KG

Domshof 21

28195 Bremen

 

Commercial Register: local court of Bremen HRA 14140 HB

General Partner: Dipl.-Kfm. Jens Lütjen

 

Managing Partner: Khaled Hadidi

Tel.: 0421 - 17393 - 0

Fax: 0421 - 17393 - 30

E-Mail: info(at)robertcspies.de

 

2.     Name and Address of the Data Protection Officer

 

The data protection officer of the data controller is: 

 

Amelie Mann

Domshof 21

28195 Bremen


Telefon: 0421 | 173 93-31


E-mail: datenschutz(at)robertcspies.de


B. General

1.    Scope of the Processing of Personal Data

 

We collect and use our users’ personal data strictly only where it is necessary to provide a functional website and our content and services. If this is not the case, the personal data is usually only used with the consent of the user. An exception applies in such cases where obtaining consent in advance is not possible for factual reasons and processing the data is permitted by statutory provisions. 

 

2.    Legal Bases for the Processing

 

Where we obtain the consent of the data subject for processing operations, Article 6 (1) (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

 

In the processing of personal data that is necessary for the performance of a contract to which the data subject is party, Article 6 (1) (b) GDPR forms the legal basis. This also applies to processing operations necessary prior to entering into a contract.

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

 

In the event that processing personal data is necessary in order to protect the vital interests of the data subject or of another natural person, Article 6 (1) (d) GDPR forms the legal basis. If processing is necessary for the purposes of the legitimate interests of our company or a third party, and such interests are not overridden by the interests or fundamental rights and freedoms of the data subject, Article 6 (1) (f) forms the legal basis for the processing. The legitimate interests of our company lie in the execution of our business activity.

 

3.    Routine Erasure and Blocking of Personal Data

 

We process and store the data subject’s personal data only for as long as is necessary to achieve the purpose of the storage. It may be stored for longer than that where this is laid down by the European or national legislator in EU regulations, laws or other provisions to which the data controller is subject. As soon as the purpose of storage no longer exists or a storage period laid down by the aforementioned regulations expires, the personal data will be routinely blocked or erased. 

 

4.    The Security of your Data

 

Within the website visit we use the widespread SSL procedure (Secure Socket Layer) in conjunction with the highest level of encryption supported by your browser. Usually this is 256-bit encryption. If your browser does not support 256-bit encryption, we fall revert instead to 128-bit v3 technology. You can identify whether individual pages of our website are transmitted encrypted by the representation of the key or padlock in the bottom status bar of your browser.

 

Apart from that, we use 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 constantly being improved in tune with technological development


C. Usage data

1.    Log files

 

Each time the website is visited we or the website provider use an automated system to collect data and information. These are stored in the server’s log files. 

 

The following data may be is collected:

 

·       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 access

·       Web pages from which the user’s system reaches our website (referrer)

·       Web pages accessed by the user’s system via our website.

 

The data is processed for delivering the content of our website, for ensuring the functionality of our technical IT systems and the optimisation of our website. The log file data is always stored separately from other personal data of the user. 

 

2.     Cookies

 

Our website uses so-called cookies. Cookies are small text files stored for the duration or your browser session in the temporary storage of your web browser (so-called session cookies) or for a specified period (so-called permanent cookies) on your hard disk. The cookies enable the web browser to be recognised again so that on future visits to our website more rapid and targeted content can be provided tailored to your needs and requirements. So we use cookies in order to be able to satisfy our legitimate interests in providing a website tailored to the visitors’ requirements The cookies do not store any personal data.

 

How can I prevent the storage of cookies?

 

You can set your browser to only store cookies if you consent. You can delete cookies still present. However, deactivating cookies may restrict the usability of our website. Further information on how cookies can be deactivated can be found at the following LINK (wikihow.com).

 

3.    Google Analytics

 

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics also uses cookies (see section 3). The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. On our website we use IP anonymisation, which means that your IP address will first be truncated by Google within the area of member states of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. Google has committed itself to compliance with the Privacy Shield agreement between the EU and the USA published by the US Department of Commerce on the collection, use and storage of personal data from the member states of the EU and provides a Privacy Shield certificate to this effect.

 

On our behalf, Google will use this information to analyse your use of the website in order to compile reports on website activities and to provide further services for the website operator associated with the use of the website and the internet. Usage profiles of the visitors to our website can be created from the data transmitted. The IP address transmitted by your browser in the context of Google Analytics will not be linked to other data retrieved by Google.

 

The evaluation of the user behaviour of the website is based on the legitimate interests of the provider. The anonymised use data will be evaluated to adapt and optimise to user behaviour. You can prevent cookies being stored by adjusting the appropriate settings in your browser software. You can also prevent Google recording and processing the data generated by the cookie and relevant to your use of the website (including your IP address), by using the following link to download and install the plug-in available for your browser

 

tools.google.com/dlpage/gaoptout

 

. You can also prevent Google Analytics from collecting and processing your data by clicking on the following link. An opt-out cookie will be placed preventing the future collection of your data on visits to this website:

 

<a href=“javascript:gaOptout()“>Deactivate Google Analytics for this website</a >.²

 

We shall not disclose information on the use of this website gained by the cookie to third parties.

 

You can find more details regarding the conditions of use and data privacy of Google Analytics at

 

www.google.com/analytics/terms/de.html

 

or at 

 

https://www.google.de/intl/de/policies/.

 

4.    Use of Google Maps

 

Our website has integrated the Google Maps service to illustrate and display our contact address and that of our partners. Google Maps is operated by von Google Inc.,1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. During use, Google collects and processes data on the use of the map function by the user. By using this website you declare your consent with the recording, processing and use of the data by automatically collected Google Inc., its representatives and third parties. You can find more detailed information on the data processing from the Google Privacy Policy. 


D. Your Personal Data (user data)

1.    What is “Personal Data”?

 

Personal data is information on your person, that allow conclusions about your identity or relate directly or indirectly to your person, e.g. your name, address or your phone number. Information that does not allow conclusions about a specific or identifiable person do not fall under this.

 

2.    Use of the Contact Form

 

On our website www.robertcspies.de there is a contact button available for you to use for online contact. If you click on the email button, the window of your email program (e.g. Outlook) will open with your email address already in the address line. If you send us an email, we obtain from you at least your email address and the other details that you have given us voluntarily e.g. on your person (surname, first name, address). The provision of the contact button serves our legitimate interests as in this way we have more options for getting in contact with you. Alternatively it is possible to make contact using the phone numbers provided. If the data subject makes contact with the data controller via one of these channels, the personal data sent by the data subject will be automatically stored. Storing the data is solely for the purpose of processing or contacting the data subject. The data will not be disclosed to third parties.

 

3.     Use of the Application Form

 

Via our website there is the option of applying for job vacancies or making speculative applications and also uploading attachments (files) and sending them to us. This gives you the opportunity to apply online for the current job vacancies at Robert C. Spies KG or at one of the associated companies. To use this form, enter your name and email address and attach your application documents. Providing this application form serves our legitimate interests of creating a further way to send applications and addressing a wider field of potential applicants. Alternatively you can also send your application to us in writing by post. Storing the data collected is solely for conducting the application process. The data will only be disclosed to third parties within the scope described under clause 5.

 

4.     Linking to Other Web Content

 

To increase our range of services, on our website you can find links to other websites for which the other providers are responsible. Please see their data privacy declarations to find out to what extent our advertising partners collect personal data. You can identify linking by the fact that a new browser window opens and a new address is displayed in the browser line.

 

5.    Disclosure of Data to Third Parties

 

In principle no data is disclosed to third party companies and at most in the scope described below:

 

Robert C. Spies KG makes an application form available that also enables application for jobs vacancies at companies in which Robert C. Spies KG has an interest or that are part of the Robert C. Spies group of companies. You can find a list of these partner companies here. If an applicant uses the application form, we collect the name, email address, if applicable the phone number as well as the data sent in addition in letters, CVs and other data (e.g.: school leaving and qualification certificates). As part of the application process, we disclose this data to the respective partner company offering the job and to which the application might be made.

 

Disclosing this data to partner companies other than the one offering the job in question and storing beyond the specific purpose for up to 24 months is only carried out where you have given us your consent to do so. You can select this opt-in by ticking the box before sending the application form. I can withdraw this consent at any time by email to datenschutz@robertcspies.de, by using the contact button provided, by post to Robert C. Spies KG, Domshof 21, 28195 Bremen or by fax to 0421-17393 – 30. 

 

I consent to Robert C. Spies KG disclosing my personal data and application documents to one of its partner companies if the latter is offering a comparable job to the one I am applying for. At the same time I consent to my applicant data being stored for a period of up to 24 months by Robert C. Spies KG and to Robert C. Spies KG contacting me in the event of a suitable job vacancy. I am aware that this consent is voluntary and will not give me any advantage over other applicants but simply offers the opportunity to use my application for comparable jobs. I can withdraw this consent at any time by email to datenschutz@robertcspies.de, by using the contact button provided, by post to Robert C. Spies KG, Domshof 21, 28195 Bremen or by fax to 0421-17393 – 30.

 

Beyond that, we only disclose your personal data to third parties if:

 

·       you have given your express consent in accordance with Art. 6 (1) (1) (a) GDPR,

·       disclosure under Art. 6 (1) (1) (f) GDPR is necessary within the partner companies of Robert C Spies KG for legitimate interests, particularly for information purposes and for organisational reasons and there is no reason to assume that you have an overriding legitimate interest in non-disclosure of your data,

·       in the event that there is a statutory obligation to disclosure under Art. 6 (1) (1) (c) GDPR and

·       this is legally allowed and under Art. 6 (1) (1) (b) GDPR is necessary for the processing of contracts with you.

 

6.    Your Rights as a Data Subject

 

If Robert c. Spies KG processes your personal data, you are the data subject within the meaning of the General Data Protection Regulation and the data controller must grant you to the following rights:

 

a) Right to Information

 

You can require confirmation from the data controller whether personal data relating to you is being processed by us. 

If such processing is present, you can require the data controller to provide you with information on the following matters:

 

a.             the purposes for which the personal data is being processed;

b.             the categories of personal data that are being processed;

c.             the recipients or the categories of recipients to whom the personal data relating to you has been or is still being disclosed;

d.             the planned storage period of the personal data relating to you or, if no specific details on this are possible, criteria for the determination of the storage period;

e.             the existence of a right to rectification or erasure of the personal data relating to you, a right to restriction to the processing by the data controller or a right to object to the processing; 

f.             the existence of a right to complain to the supervisory authorities;

g.             all available information on the origin of the data if the personal data has not been collected from the data subject;

h.             the existence of automated individual decision making including profiling in accordance with Article 22 (1) and (4) GDPR and, at least in these cases, meaningful information on the logic involved as well as the scope of the desired effects of such processing for the data subject.

 

You have the right to require information about whether the personal data relating to you is transferred to a third country or to an international organisation. In this connection you can require that you are informed about the appropriate safeguards under Article 46 GDPR in connection with the transfer.

 

b) Right to Rectification 

 

You have the right to rectification and/or completion by the data controller if the processed personal data relating to you is incorrect or incomplete. We must carry out the rectification without delay.

 

c) Right to Restriction of Processing

 

Under the following conditions you can require the restriction of the processing of the personal data relating to you:

 

a.             if you contest the accuracy of the personal data relating to you for a period enabling the data controller to check the accuracy of the personal data;

b.             the processing is unlawful and you object to the erasure of the personal data and instead require the restriction of the use of the personal data;

c.             Robert C. Spies KG 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

d.             if you have objected to processing in accordance with Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override your grounds.

 

If the processing of the personal data relating to you has been restricted, this data may, apart from storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a member state. If the restriction of processing under the above conditions has been restricted, you will be informed by the controller before the restriction is lifted.

 

d) Right to Erasure

 

You can require from us that the personal data relating to you is erased without delay and we are required to erase this data without delay if one of the following reasons applies:

 

a.             The personal data relating to you is no longer necessary for the purposes for which it was collected or processed in any other way.

b.             You withdraw your consent on which the processing under Article 6 (1) (a) or Article 9 (2) (a) GDPR is based and there is no other legal basis for processing. 

c.             Under Article 21 (1) GDPR you object to the processing and there are no overriding legitimate grounds for the processing or you object to the processing under Article 21 (2) GDPR. 

d.             The personal data relating to you has been processed unlawfully. 

e.             The erasure of the personal data relating to you is necessary for fulfilling a statutory obligation under Union law or the law of the member states to which the data controller is subject. 

f.             The personal data relating to you has been collected relating to the offer of information society services under Article 8 (1) GDPR.

 

Where Robert C. Spies KG has made the personal data relating to you public and is required to erase it under Article 17 (1) GDPR, it must, taking into account the available technology and the implementation costs, take reasonable steps including technical measures, to inform controllers that are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, this personal data. 

 

There is no right to erasure where the processing is necessary

 

a.             for exercising the right to freedom of expression and information;

b.             for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

c.             on public interest grounds in the area of public health under Article 9 (2) (h) and (i) as well as Article 9 (3) GDPR;

d.             for archive purposes in the public interest, scientific or historical research purposes or for statistical purposes under Article 89 (1) GDPR where the right in (1) is likely to make impossible or seriously impair the achievement of the aims of this processing or

e.             for the establishment, exercise or defence of legal claims.

 

e) Right to Notification

 

If you have asserted the right to correction, erasure or restriction of the processing by the data controller, the latter is required to inform all recipients to which the personal data relating to you has been disclosed of this rectification or erasure of the data or restriction of processing, unless it proves impossible or associated with disproportionate expense.

You have the right to be notified about these recipients.

 

f) Right to Data Portability

 

You have the right to receive the personal data relating to you that you have provided to Robert C Spies KG in a structured, commonly used and machine-readable format. In addition you have the right to send this data to another data controller without hindrance from the controller to which the personal data has been provided if

a.             the processing is based on consent under Article 6 (1) (a) GDPR or Article 9 (2) (a) GDPR or on a contract under Article 6 (1) (b) GDPR and

b.             the processing is carried out with the aid of an automated procedure.

 

Furthermore, in the exercise of this right, you have the right to have the personal data relating to you transmitted directly from one data 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 the processing of personal data necessary for the performance of a task that is in the public interest or carried out in the exercise of official authority vested in the data controller.

 

g) Right to Object

 

You have the right on grounds relating to your particular situation to object at any time to the processing of the personal data relating to you carried out on the basis of Article 6 (1) (e) or (f) GDPR; this also applies to profiling based on those provisions. Robert C Spies KG may no longer process the personal data relating to you unless the it demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Where personal data relating to you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data relating to you for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where you object to processing for direct marketing purposes, the personal data must no longer be processed for such purposes. The objection may be sent to the contact details of the data controller or to the data protection officer 

 

Amelie Mann

Domshof 21

28195 Bremen


Telefon: 0421 | 173 93-31


E-mail: datenschutz(at)robertcspies.de

 

.

 

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.

 

h) Right to Withdraw the Data Protection Declaration of Consent

 

You have the right to withdraw your consent to the processing of your data at any time. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

 

i)    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 if the decision 

 

a.             is necessary for entering into, or performance of, a contract between you and Robert C Spies KG,

b.             is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests or

c.             is based on your explicit consent.

 

However these decisions must not be based on special categories of personal data referred to in Article 9 (1) GDPR, unless point (a) or (g) of Article 9 (2) applies and suitable measures to safeguard your rights and freedoms, and legitimate interests are in place. In the cases referred to in points (a) and (c), Robert C Spies KG must implement suitable measures to safeguard your rights and freedoms, and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

 

j)   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 place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. 

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

 

7.    Updating and Amending this Data Privacy Policy

 

This Privacy Policy is currently valid and was updated in May 2018.

Through the further development of our website and content on it or because of changes to the statutory regulations or official guidelines, it may be necessary to amend this Privacy Policy. You may view and print out the current Data Privacy Policy at any time on the website at www.robertcspies.de