Privacy policy
Privacy Policy
We are very pleased that you have shown interest in our company. Data protection has a particularly high priority for the management of UNI Srl. The use of the Internet pages of UNI Srl is possible without any indication of personal data; However, if a data subject wants to use special services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the Data Protection Regulations. by country regulations applicable to UNI Srl By means of this data protection declaration, our company would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As data controller, UNI Srl has implemented numerous technical and organizational measures to guarantee the most complete protection of personal data processed through this site. However, Internet-based data transmissions may, in principle, have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data via alternative means, e.g. by phone.
1. Definitions
The data protection declaration of UNI Srl is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public as well as our customers and business partners. To ensure this, we would first like to explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
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a) Personal data
Personal data: any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
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b) Object of the data
Data subject is an identified or identifiable natural person, whose personal data are processed by the controller for processing.
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c) Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission , dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction.
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d) Limitation of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
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e) Behavior monitoring
Behavior monitoring: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
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f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that personal data is not attributed to an identified or identifiable natural person.
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g) Supervisory authority or supervisory authority responsible for the processing of personal data
Controller responsible for the processing of personal data is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; if the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
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h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
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i) Recipient
Beneficiary is a natural or legal person, public authority, agency or other body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of such data by those public authorities must comply with the data protection rules applicable according to the purposes of the processing.
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j) Third part
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
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k) Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and address of the data controller of personal data
Controller of personal data for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions relating to data protection is:
UNI Srl
Via Bacchiglione 25
35030 Cervarese Santa Croce
PD
Phone: 049 7851771
Email: info@unisrl.eu
Website: https://www.unisrl.eu
3. Cookies
UNI Srl’s Internet pages use cookies. Cookies are text files that are stored in a computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the test subjects’ individual browser from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
Through the use of cookies, UNI Srl can provide users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as mentioned above, to recognize users of our site. The purpose of this recognition is to make it easier for users to use our website. The website user who uses cookies, e.g. it is not necessary to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online store. The online store stores the items that a customer has placed in the virtual shopping cart via a cookie.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
4. Collection of general data and information
The website of UNI Srl collects a series of general data and information when a data subject or automated system calls up the website. This general data and information is stored in server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and ( 8) any other similar data and information that can be used in the event of attacks on our IT systems.
When using these general data and information, UNI Srl does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertising, (3) ensure the long-term viability of our information technology systems and technology of the Website and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack. Therefore, UNI Srl statistically analyzes anonymously collected data and information, with the aim of increasing the data protection and data security of our company and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.
5. Registration on our website
The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data is transmitted to the controller is determined by the respective input mask used for registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) and used by the data subject – date and time of the registration are also stored. The storage of this data takes place in the background, which is the only way to prevent the misuse of our services and, if necessary, to make the investigation of committed crimes possible. Therefore, the storage of this data is necessary to protect the. This data is not passed on to third parties unless there is a legal obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter. Registered persons are free to change the personal data specified during registration at any time or to have them completely deleted from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. Furthermore, the data controller will correct or delete personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. All employees of the controller are available to data subjects in this regard as contact persons.
6. Subscription to our newsletters
On the UNI Srl website, users have the opportunity to subscribe to our newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
UNI Srl regularly informs its customers and business partners via a newsletter on commercial offers. The newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
Personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of changes to the newsletter offer, or in the case of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for the purpose of sending the newsletter, may be revoked at any time. For the purpose of revoking consent, a corresponding link can be found in each newsletter. It is also possible to subscribe to the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.
7. Newsletter Tracking
The UNI Srl newsletter contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows for a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, UNI Srl may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects have the right at any time to revoke the respective separate declaration of consent issued by means of the double opt-in procedure. After a revocation, these personal data will be deleted by the controller. UNI Srl automatically considers a withdrawal from receiving the newsletter as a revocation.
8. Possibility of contact via the website
The website of UNI Srl contains information that enables quick electronic contact to our company, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
9. Subscription to comments in the blog on the site
Comments made in the UNI Srl blog may be subscribed to by third parties. In particular, there is the possibility that a commenter subscribes to comments by following his comments on a particular blog post.
If a data subject decides to subscribe to the option, the controller will send an automatic confirmation e-mail to check the double opt-in procedure as to whether the owner of the specified e-mail address has decided in favor of this option. The comment subscription option can be stopped at any time.
10. Routine deletion and blocking of personal data
The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to of the treatment.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
11. Rights of the interested party
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a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her exist. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
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b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, European directives and regulations grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular recipients in third countries or international organisations;
- where possible, the expected period for which the personal data will be retained or, if not possible, the criteria used to determine this period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data relating to the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with the supervisory authority;
- if the personal data are not collected from the interested party, any available information on their origin;
- the existence of automated decision-making processes, including profiling, referred to in Article 22, paragraphs 1 and 4, of the GDPR and, at least in such cases, significant information on the logic in question, as well as on the significance and expected consequences of such processing for the interested party.
Furthermore, the data subject shall have the right to obtain information as to whether personal data is transferred to a third country or an international organisation. In this case, the data subject has the right to be informed of the appropriate guarantees relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
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c) Right of rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
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d) Right to erasure (right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies , provided that the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The interested party withdraws the consent on which the processing is based in accordance with Article 6, paragraph 1, letter a), of the GDPR, or Article 9, paragraph 2, letter a), of the GDPR, and where there is no other legal basis for processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data has been processed unlawfully.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data were collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by UNI Srl, he or she may, at any time, contact any employee of the controller. An employee of UNI Srl must promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking into account available technology and the costs of implementation, shall take reasonable measures, including technical measures, to inform other controllers processing personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of UNI Srl will organize the necessary measures in individual cases.
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e) Right to restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
- The data subject has contested the processing pursuant to Article 21(1) of the GDPR pending verification whether the legitimate reasons of the controller prevail over those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by UNI Srl, he or she may at any time contact any employee of the controller. The UNI Srl employee will arrange the restriction of processing.
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f) Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He has the right to transmit such data to another controller without impediments to the controller to whom the personal data were provided, provided that the processing is based on the consent referred to in Article 6(1)(a) , of the GDPR or point (a) of Article 9 (2) of the GDPR, or a contract pursuant to Article 6 (1) (b) of the GDPR, and the processing is carried out by automated means, to provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of public powers vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and in doing so do not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may at any time contact any employee of UNI Srl
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g) Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her which is based on point (e) or (f) ) of Article 6, paragraph 1, of the GDPR. This also applies to profiling based on these provisions.
UNI Srl shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the establishment, operation or the defense of legal claims.
If UNI Srl processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to UNI Srl to the processing for direct marketing purposes, UNI Srl will no longer process the personal data for these purposes.
Furthermore, the interested party has the right, for reasons relating to his particular situation, to object to the processing of personal data concerning him by UNI Srl for scientific or historical research purposes or for statistical purposes pursuant to Article 89 ( 1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the data subject may contact any employee of UNI Srl. Furthermore, the data subject is free in the context of the use of information society services and, notwithstanding Directive 2002/58/EC, to make use of of your right to object using automated tools using technical specifications.
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h) automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects about him or her, or significantly affects him or her, provided that that the decision (1) is not necessary for entering into or the performance of a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the data controller is subject to processing and which also establishes appropriate measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary to enter into, or perform a contract between the interested party and a data controller, or (2) is based on the explicit consent of the interested party, UNI Srl implements appropriate measures to safeguard the rights and the data subject’s freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights relating to automated individual decision-making, he or she may, at any time, contact any employee of the UNI Srl
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i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of UNI Srl
12. Data protection provisions about the application and use of LinkedIn
The controller has integrated components of LinkedIn Corporation on this website. LinkedIn is a web-based social network that allows users with existing business contacts to connect and to create new business contacts. Over 400 million registered people in over 200 countries use LinkedIn. Therefore, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.
The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, UNITED STATES. For US privacy matters, LinkedIn Ireland, Privacy Policy Officer, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the downloading a visualization of the corresponding LinkedIn component of LinkedIn. For more information about the LinkedIn Plugin, please visit https://developer.linkedin.com/plugins. During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject.
If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was accessed. visited by the interested party. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.
LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call to our website. This occurs regardless of whether the person clicks the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our website is made.
LinkedIn provides https://www.linkedin.com/psettings/guest-controls the ability to unsubscribe from e-mail messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua and Lotame. The setting of such cookies can be denied under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn can be found at https://www.linkedin.com/legal/privacy-policy. LinkedIn’s Cookie Policy is available at https://www.linkedin.com/legal/cookie-policy.
13. Legal basis for processing
Art. 6 (1) on. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, such as when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on the Article 6, paragraph 1, letter lit. b GDPR. The same applies to processing operations that are necessary for carrying out pre-contractual measures, for example in the case of inquiries relating to our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6 (1) on. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor was injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party . Therefore the processing would be based on the art. 6 (1) on. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the interested party which require the protection of personal data. Such processing operations are particularly permissible as they have been expressly mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (recital 47, sentence 2, GDPR).
14. The legitimate interests pursued by the controller or by a third party
If the processing of personal data is based on Article 6 (1) lit. Under GDPR our legitimate interest is to carry out our business for the well-being of all our employees and shareholders.
15. Period of retention of personal data
The criteria used to determine the retention period of personal data are the respective retention periods required by law. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
16. Provision of personal data as a legal or contractual requirement; Necessary requirement to enter into a contract; Obligation of the interested party to provide personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. Failure to provide the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
17. Existence of automated decision-making processes
As a responsible company, we do not use automatic decision-making or profiling.
Developed by the specialists for LegalTech at Willing & Able that also developed the system for timesheet tracker . The legal texts contained in our privacy policy generator have been provided and published by Prof. Dr. hc Heiko Jonny Maniero from the German Association for Data Protection and Christian Solmecke from WBS law.