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Privacy Policy
This privacy policy explains the nature, scope, and purpose of the processing of personal data (hereinafter referred to as "dat") within our online offering and the associated websites, functions, and content as well as external online presences, such as our social media profiles (collectively referred to as "online offering"). With regard to the terminology used, such as "processing" or "controller," we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Controller
Licu Stefan-Cristian
Reinhardstrasse, 17
73614, Schorndorf
Germany
Email: stefan.licu@hfg.design
Types of Data Processed
- Inventory data (e.g., names, addresses).
- Contact data (e.g., email, phone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., visited websites, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of Data Subjects
Visitors and users of the online offering (hereinafter we refer to the data subjects collectively as "users").
Purpose of Processing
- Provision of the online offering, its functions, and content.
- Responding to contact requests and communicating with users.
- Security measures.
- Reach measurement/marketing.
Terminology Used
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "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 (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data.
"Pseudonymization" means 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 the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means 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.
"Controller" means 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.
"Processor" means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
Legal Bases for Processing
In accordance with Article 13 GDPR, we inform you about the legal bases of our data processing. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Article 6(1)(a) and Article 7 GDPR, the legal basis for processing for the performance of our services and carrying out contractual measures as well as responding to inquiries is Article 6(1)(b) GDPR, the legal basis for processing to fulfill our legal obligations is Article 6(1)(c) GDPR, and the legal basis for processing to protect our legitimate interests is Article 6(1)(f) GDPR. In the event that vital interests of the data subject or another natural person make the processing of personal data necessary, Article 6(1)(d) GDPR serves as the legal basis.
Security Measures
We take appropriate technical and organizational measures in accordance with Article 32 GDPR, considering the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as the access, input, transfer, ensuring availability, and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, deletion of data, and response to data vulnerability. We also consider the protection of personal data already during the development, or selection of hardware, software, and procedures, according to the principle of data protection through technology design and through data protection-friendly default settings (Article 25 GDPR).
Collaboration with Processors and Third Parties
If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit data to them, or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g., if a transmission of the data to third parties, such as payment service providers, is necessary for contract performance according to Article 6(1)(b) GDPR), you have consented, a legal obligation provides for this or based on our legitimate interests (e.g., when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called "processing agreement," this is done on the basis of Article 28 GDPR.
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 this happens in the context of the use of third-party services or disclosure, or transmission of data to third parties, this only occurs if it is to fulfill our (pre)contractual obligations, based on your consent, a legal obligation, or based on our legitimate interests. Subject to legal or contractual permissions, we process or allow the data to be processed in a third country only if the special requirements of Article 44 ff. GDPR are met. That is, the processing is carried out, for example, based on special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g., for the USA through the "Privacy Shield") or compliance with officially recognized specific contractual obligations (so-called "standard contractual clauses").
Rights of Data Subjects
You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data as well as to further information and a copy of the data in accordance with Article 15 GDPR.
You have the right in accordance with Article 16 GDPR to request the completion of data concerning you or the rectification of inaccurate data concerning you.
In accordance with Article 17 GDPR, you have the right to demand that relevant data be deleted immediately, or alternatively, in accordance with Article 18 GDPR, to demand a restriction of the processing of the data.
You have the right to request that the data concerning you that you have provided to us be received in accordance with Article 20 GDPR and to request its transmission to other controllers.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with Article 77 GDPR.
Right of Withdrawal
You have the right to revoke consent granted in accordance with Article 7(3) GDPR with effect for the future.
Right to Object
You can object to the future processing of data concerning you in accordance with Article 21 GDPR at any time. The objection can be made in particular against processing for direct marketing purposes.
Cookies and Right to Object to Direct Advertising
"Cookies" are small files that are stored on users' computers. Various information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, or "session cookies" or "transient cookies,v are cookies that are deleted after a user leaves an online offering and closes their browser. In such a cookie, for example, the content of a shopping cart in an online store or a login status can be stored. "Permanent" or "persistent" cookies are those that remain stored even after the browser is closed. For example, the login status can be saved if users visit the site after several days. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie. "Third-party cookies" are cookies offered by providers other than the controller who operates the online offering (otherwise, if it is only their cookies, they are called "first-party cookies").
We may use temporary and permanent cookies and explain this in our privacy policy.
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 offering.
A general objection to the use of cookies for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all functions of this online offering may be usable in this case.
Deletion of Data
The data processed by us will be deleted or restricted in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer necessary for their purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
According to legal requirements in Germany, the retention is particularly for 10 years in accordance with Sections 147(1) AO, 257(1) Nos. 1 and 4, Section 4 HGB (books, records, management reports, booking vouchers, commercial books, documents relevant to taxation, etc.) and 6 years according to Section 257(1) Nos. 2 and 3, Section 4 HGB (commercial letters).
According to legal requirements in Austria, the retention is particularly for 7 years in accordance with Section 132(1) BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with land and for 10 years for documents related to electronically provided services, telecommunications, broadcasting, and television services that are provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
Hosting and Emailing
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, emailing, security services, and technical maintenance services, which we use for the purpose of operating this online offering.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta, and communication data of customers, interested parties, and visitors of this online offering based on our legitimate interests in an efficient and secure provision of this online offering in accordance with Article 6(1)(f) GDPR in conjunction with Article 28 GDPR (conclusion of a processing agreement).
Google Analytics
Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering in the sense of Article 6(1)(f) GDPR), we use Google Analytics, a web analytics service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offering by users is usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering, and to provide us with further services related to the use of this online offering and the Internet. In this process, pseudonymous usage profiles of the users can be created from the processed data.
We use Google Analytics only with IP anonymization activated. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states 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 shortened there.
The IP address transmitted by the user's browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offering to Google as well as the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
Further information on data use by Google, setting options, and objections can be found in Google's privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
The personal data of users will be deleted or anonymized after 14 months.
Online Presence in Social Media
We maintain online presences within social networks and platforms to communicate with customers, interested parties, and users active there and to inform them about our services.
We would like to point out that data of users can be processed outside the European Union. This may result in risks for the users because, for example, the enforcement of the users' rights could be more difficult. With regard to US providers certified under the Privacy Shield, we point out that they thereby commit to comply with the data protection standards of the EU.
Furthermore, the data of users are usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and resulting interests of users. The usage profiles can in turn be used to display advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data can be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and logged in to them).
The processing of users' personal data is based on our legitimate interests in effective information of users and communication with users in accordance with Article 6(1)(f) GDPR. If users are asked by the respective providers for consent to data processing (i.e., they declare their consent, e.g., by ticking a checkbox or confirming a button), the legal basis for the processing is Article 6(1)(a) and Article 7 GDPR.
For a detailed description of the respective processing and the opt-out options, we refer to the following linked information of the providers.
Also, in the case of information requests and the assertion of user rights, we point out that these can be most effectively asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures directly and provide information. If you still need help, you can contact us.
- Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) - Privacy Policy: https://twitter.com/en/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
- LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) - Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
- Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) - Privacy Policy/ Opt-Out: https://soundcloud.com/pages/privacy.
Integration of Third-Party Services and Content
We use content or service offers from third-party providers within our online offering based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering in the sense of Article 6(1)(f) GDPR) to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content").
This always requires that the third-party providers of this content perceive the IP address of the users, as they could not send the content to their browser without the IP address. The IP address is thus necessary for the presentation of this content. We strive to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Through the "pixel tags," information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in cookies on the user's device and may include, among other things, technical information about the browser and operating system, referring websites, visit time, and other information on the use of our online offering, as well as being linked to such information from other sources.
Vimeo
We can embed videos from the "Vimeo" platform of the provider Vimeo Inc., Attention: Legal Department, 555 West 18th Street, New York, New York 10011, USA. Privacy Policy: https://vimeo.com/privacy. We point out that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) as well as opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=en) or the settings of Google for the use of data for marketing purposes (https://adssettings.google.com/authenticated).
Google Fonts
We embed the fonts ("Google Fonts") of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated.
Within our online offering, functions and contents of the Twitter service, offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated. This can include content such as images, videos, or texts and buttons with which users can share content of this online offering within Twitter.
If the users are members of the platform Twitter, Twitter can assign the call of the above content and functions to the profiles of the users there. Twitter is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy Policy: https://twitter.com/en/privacy, Opt-Out: https://twitter.com/personalization.
Within our online offering, functions and contents of the LinkedIn service, offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, can be integrated. This can include content such as images, videos, or texts and buttons with which users can share content of this online offering within LinkedIn.
If the users are members of the platform LinkedIn, LinkedIn can assign the call of the above content and functions to the profiles of the users there. LinkedIn is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active). Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
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