data privacy

This data protection declaration explains to you the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the associated websites, functions and contents as well as external online presences, e.g. our social media profile. (hereinafter jointly referred to as "online offer"). With regard to the terms used, such as "personal data" or their "processing", we refer to the definitions in Art. 4 of the Basic Data Protection Ordinance (DSGVO).


Responsible person:

DER KREIS UK LLP
c/o Watson Buckle LLP
York House
Cotingley Business Park
Bradford
BD16 1PE


LLP number OC382169
Operating as a limited liability partnership incorporated and registered in England and Wales with partnership number OC382169, having its registered office at c/o Watson Buckle LLP, York House, Cotingley Business Park, Bradford, BD16 1PE.


Types of data processed:
☒ Inventory data (e.g., names, addresses)
☒ contact details (e.g., e-mail)
☒ Content data (e.g., text input, photographs)
☒ usage data (e.g., visited websites, interest in content, access times)
☒ Meta/communication data (e.g., device information, IP addresses)

 
Purpose of the processing:
☒ Provision of the online offer, its contents and functions
☒ Response to contact requests and communication with users
☒ Marketing, Advertising and Market Research
☒ Security measures

1. authoritative legal bases
In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the performance of our services and performance of contractual measures as well as for answering inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c DSGVO, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f DSGVO. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) DSGVO serves as the legal basis.

2 Changes and Updates to the Privacy Policy
We ask you to inform yourself regularly about the contents of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

3. security measures

3.1 We shall take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in accordance with Art. 32 DSGVO. Such measures shall in particular include ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, entry, disclosure, security of availability and its separation. Furthermore, we have established procedures to ensure the exercise of rights of data subjects, deletion of data and reaction to endangerment of data. Furthermore, we already take into account the protection of personal data during the development or selection of hardware, software and procedures in which, in accordance with the principle of data protection, technical design and data protection-friendly presettings are taken into account (Art. 25 DSGVO).

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 If, in the course of our processing, we disclose data to other persons and companies (contract processors or third parties), transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transfer of the data to third parties, such as to payment service providers, is required for contract fulfilment pursuant to Art. 6 para. 1 lit. b DSGVO), if you have consented, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

4.2 If we commission third parties with the processing of data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 DSGVO.

5. 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 transfer of data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the special requirements of Art. 44 ff. Process DSGVO. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the USA by the "Privacy Shield") or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").

6. rights of data subjects
6.1 You have the right to request confirmation as to whether the data concerned are being processed and to request information about these data as well as further information and a copy of the data in accordance with Art. 15 DSGVO.

6.2 You have accordingly. In accordance with Article 16 of the DSBER, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.

6.3 In accordance with Art. 17 DSGVO, you have the right to demand that relevant data be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with Art. 18 DSGVO.

6.4 You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 DSGVO and to request that it be forwarded to other persons responsible.

6.5 In accordance with Art. 77 DSGVO, you also have the right to file a complaint with the competent supervisory authority.
 
7. right of revocation
You have the right to revoke consents granted pursuant to Art. 7 para. 3 DSGVO with effect for the future.

8. right of objection
You can object to the future processing of the data concerning you in accordance with Art. 21 DSGVO at any time. The objection may be lodged in particular against processing for direct marketing purposes.

9 Cookies and right of objection in direct advertising
We use temporary and permanent cookies, i.e. small files that are stored on the user's devices. In part, cookies are used for security purposes or are required for the operation of our online offer (e.g. for the presentation of the website) or to save the user's decision when confirming the cookie banner. In addition, we or our technology partners use cookies to measure reach and for marketing purposes, about which the users will be informed in the course of the data protection declaration.

A general objection to the use of cookies for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site www.aboutads.info/choices/ or the EU site www.youronlinechoices.com. Furthermore, the storage of cookies can be prevented by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

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

10.2 In accordance with statutory requirements, the records shall be kept in particular for 6 years in accordance with § 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with § 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant for taxation, etc.).

 
11. contact / inquiries
11.1 When contacting us (via contact form or e-mail), the user's details will be processed for processing the contact request and its handling in accordance with Art. 6 Para. 1 lit. b) DSGVO.

11.2 User information may be stored in our Customer Relationship Management System ("CRM System").

11.3 We delete the requests if they are no longer necessary. We review the necessity every two years. In the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation).

12. collection of access data and log files
12.1 On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data on each access to the server on which this service is located (so-called server log files). The access data includes the name of the called website, file, date and time of the call, transferred data volume, notification of successful call, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

12.2 Log file information is stored for a certain period of time for security reasons (e.g. to detect misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.

13. online presence in social media
13.1 We maintain on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO 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 the data processing guidelines of their respective operators apply.

13.2 Unless otherwise stated in our data protection declaration, we process the data of users as long as they communicate with us within the social networks and platforms, e.g. write articles on our websites or send us messages.

14. cookies & range measurement
14.1 Cookies are information that is transferred from our web server or third party web servers to the user's web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.

 
14.2 We use "session cookies", which are only stored on our website for the duration of your current visit (e.g. to enable the storage of your login status and thus the use of our website). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and log out or close your browser, for example.

14.3 Users will be informed about the use of cookies within the scope of pseudonymous range measurement within the scope of this data protection declaration.

14.4 If users do not want cookies to be stored on their computer, they are asked to deactivate 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 offer.

14.5 You may opt-out of the use of cookies for range measurement and promotional purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

15. range analysis with Matomo (formerly PIWIK)
15.1 Within the scope of Matomo's range analysis, on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) processes the following data: the browser type and version you use, the operating system you use, your country of origin, date and time of the server request, the number of visits, your time spent on the website and the external links you click. The IP address of the users is anonymized before it is stored.

15.2 Matomo uses cookies which are stored on the user's computer and which enable an analysis of the use of our online offer by the user. Pseudonymous user profiles can be created from the processed data. The cookies are stored for one week. The information generated by the cookie about your use of this website is only stored on our server and not passed on to third parties.

15.3 Users can object to the anonymized data collection by the Matomo program at any time with effect for the future. In this case, a so-called opt-out cookie is stored in your browser, which means that Matomo no longer collects any session data. If users delete their cookies, however, this means that the opt-out cookie is also deleted and must therefore be activated again by the users. If you do not want Matomo to track your visit to this website, uncheck the box below.

16. integration of third-party services and content
16.1 We set within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) content or service offerings of third parties to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content"). This always presupposes that the third party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents.

Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as may be linked to such information from other sources.

16.2 The following presentation provides an overview of third-party providers and their contents, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, possibilities of objection (so-called opt-out):
Maps of the "Google Maps" service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: www.google.com/policies/privacy/, Opt-Out: www.google.com/settings/ads/.
Videos from the YouTube platform of third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.

17. application
17.1 When submitting an application by e-mail, please provide us with your data (e.g. name, address, telephone number, e-mail address) and, if applicable, further data and information (e.g. on your CV or qualifications) and application documents (e.g. certificates).

17.2 All personal data, information and documents are collected, stored and used exclusively for purposes in connection with the collection and processing of the application including, if applicable, the preparation of an employment.

17.3 In the case of an application, your data, information and documents will be deleted 6 months after receipt of the application. If your application is successful, the data you submit will continue to be used within the framework of the employment relationship in accordance with the statutory provisions. If the applicant agrees, we will keep the applicant data for up to 2 years.

17.4 If you have any further questions or would like further information on the subject, please send an e-mail to: info@derkreis.nl

Booth: 25.05.2018