PRIVACY POLICY

I. Responsible person in terms of data protection laws, in particular the EU General Data Protection Regulation (DSGVO), is:

Gentlemen Group GmbH
Starnberger Straße 8
14612 Falkensee

Contact:
Fon: +49 3322 432 35 00
Fax: +49 3322 432 35 01
E-Mail: info@gentlemengroup.de

Chief Executive Officer:
Christian Zander

Our Data Protection Officer:
Markus Timm (Rechtsanwalt)

Contact: datenschutz@gentlemengroup.de

II. Your data subject rights

You can exercise the following rights at any time using the contact details provided by our data protection officer:

  • Information about your data stored by us and its processing (Art. 15 DSGVO),
  • Correction of inaccurate personal data (Art. 16 DSGVO),
  • Deletion of your data stored with us (Art. 17 DSGVO),
  • ERestriction of data processing if we are not yet allowed to delete your data due to legal obligations (Art. 18 DSGVO),
  • Object to the processing of your data by us (Art. 21 DSGVO) und
  • Data portability, provided you have consented to the data processing or have concluded a contract with us (Art. 20 DSGVO).

If you have given us consent, you can revoke this at any time with effect for the future.

You can contact a supervisory authority at any time with a complaint, e.g. the competent supervisory authority in the federal state of your residence or the authority responsible for us as the responsible body.

A list of the supervisory authorities (for the non-public sector) with address can be found at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

Information about your right to object according to Art. 21 DSGVO

Right to object on a case-by-case basis

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6(1)(f) DSGVO (data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Art. 4 No. 4 DSGVO.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

III. Cookies

Like many other websites, we also use so-called “cookies”. Cookies are small text files that are stored on your end device (laptop, tablet, smartphone or similar) when you visit our website.

You can delete individual cookies or the entire cookie inventory. In addition, you will receive information and instructions on how to delete these cookies or block their storage in advance. Depending on the provider of your browser, you will find the necessary information under the following links:

Storage duration and cookies used:

Insofar as you allow us to use cookies through your browser settings or consent, the cookies listed in the Cookie Policy may be used on our websites.

Nature and purpose of the processing:

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change.

We also use statistical/analytical and marketing cookies: These are cookies that are used for online marketing purposes (in particular marketing of advertising space, targeted advertising) and analysis of user behaviour for the purpose of optimising the online offer. Such cookies are also used for profiling. Profiling is used to show users content that matches their potential interests. Insofar as we use cookies or tracking technologies, we will point this out to you separately in the data protection declaration or in the context of obtaining consent.

You can find out which cookies are required for which applications in the Cookie Policy.

Legal basis and legitimate interest:

If we ask you to give consent to or consent to the processing of your personal data using cookies and you consent, the legal basis for the data processing is your consent (Art Art. 6 (1) p. 1 lit. a DSGVO). Otherwise, the processing is carried out in accordance with Art. 6 para. 1 lit. f DSGVO on the basis of our legitimate interest in a user-friendly design of our website.

Recipient:

Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website. Otherwise, we describe recipients in our Cookie Policy.

BThe provision of such information is not mandatory or required:

The provision of the aforementioned personal data is neither legally nor contractually required. With regard to the technically necessary cookies, the following applies: Without this data, the service and functionality of our website cannot be guaranteed. In addition, individual services and services may not be available or may be restricted.

Objection/revocation of consent:

If the processing of your personal data by cookies is based on a legal permission, you can object to the processing at any time. You can initially declare your objection by means of your browser settings (for example by deactivating the use of cookies, see above). Please note that certain functions of our website (e.g. the preset language) will then no longer function. We draw your attention to further objection options in the context of the information on the service providers and cookies used.

If the processing of personal data through cookies is based on your consent, you can revoke your consent at any time. For this purpose, we use a cookie consent management tool (more information can also be found in our cookie policy). This tool provides you with information on the cookies we use (processing and provider). In addition, you can give and/or revoke your consent in this tool. The declaration of consent is stored by a cookie. This is done so that the query about the use of cookies does not have to be repeated and we can also prove consent in accordance with our legal obligation. The settings that you have made in the cookie tool are stored in the cookie.

Please also read the information about your right to object in accordance with Art. 21 DSGVO above or manage your consent setting via our Cookie Policy.

Storage period:

For more information on the storage period of cookies, please refer to our Cookie Policy.

IV. Comment function

Nature and purpose of the processing:

When users leave comments on our website, in addition to this information, the time of their creation and the user name previously selected by the website visitor are also stored. This serves our security, as we can be prosecuted for unlawful content on our website, even if it was created by users.

Legal basis:

The processing of the data entered as comments is based on a legitimate interest (Art. 6 para. 1 lit. f DSGVO).

By providing the comment function, we would like to enable you to interact in an uncomplicated manner. The information you provide will be stored for the purpose of processing your enquiry and for possible follow-up questions.

Recipient:

Recipients of the data are, if applicable, order processors.

Storage period:

The data is deleted as soon as it is no longer required for the purpose for which it was collected. This is generally the case when the communication with the user has been concluded and the company can infer from the circumstances that the matter in question has been conclusively clarified. We reserve the right to delete data without giving reasons and without prior or subsequent information.

You can also have your comment deleted by us at any time. To do so, please write an e-mail to the data protection officer listed below or to the person responsible for data protection and send the link to your comment as well as the e-mail address used when creating the comment for identification purposes.

Provision prescribed or required:

The provision of your personal data is voluntary. Without the provision of your personal data, we cannot grant you access to our comment function.

V. Newsletter

Description and scope of data processing:

You have the possibility to subscribe to our free newsletter. In it, we will inform you about [describe possible contents in abstract terms, e.g. events] that might be of interest to you. The following data will be processed by us.

  • E-mail address
  • First and last name

In addition, the following data will be collected during registration:

  • Date/Time

For the processing of the data, your consent is obtained during the registration process via the so-called double opt-in and reference is made to this data protection declaration. We also save the registration process so that we can prove that it has taken place correctly.

Legal basis:

The legal basis for the processing of newsletter subscription data is your consent pursuant to Art. 6 para. 1 sentence 1 lit. a DSGVO as well as § 7 para. 2 no. 3 UWG or our legitimate interest in being able to prove that the registration process has been carried out properly (Art. 6 para. 1 sentence 1 lit. f DSGVO).

Purpose of data processing:

The collection of your name, title and e-mail address serves to deliver the newsletter and to address you correctly.

The collection of other personal data as part of the registration process serves to prevent misuse of the services or the e-mail address used and to be able to prove that the registration process has been carried out correctly.

Duration of storage:

The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. Accordingly, the above-mentioned data will be stored as long as the subscription to the newsletter is active. Thereafter, we may store the unsubscribed e-mail address for up to three years on the basis of our legitimate interest in order to be able to prove consent previously given. The purpose of the processing for this period until deletion is limited to the defence against claims.

Possibility of objection and removal:

You can cancel your subscription to the newsletter at any time. For this purpose, you will find a corresponding “Unsubscribe” link in each newsletter. This also enables you to revoke your consent to the storage of the personal data collected during the registration process.

Shipping service provider for the newsletter/recipient:

We use the company rapidmail GmbH, Wentzingerstraße 21, 79106 Freiburg im Breisgau, Germany, to send our newsletters (please find the privacy policy of rapidmail GmbH here: https://www.rapidmail.de/datenschutz). We have concluded an order processing agreement (Art. 28 DSGVO) with rapidmail (hereinafter also referred to as newsletter service provider). The data is used exclusively for sending the newsletter.

VI. Newsletter tracking

Description and scope of data processing:

We also use the dispatch service provider rapidmail GmbH, Wentzingerstraße, 21, 79106 Freiburg, Germany to analyse the dispatch of our newsletters. The data you enter for the purpose of receiving the newsletter is stored on rapidmail’s servers in Germany. For the purpose of analysis, the e-mails sent with rapidmail contain a so-called tracking pixel, which connects to the servers of rapidmail when the e-mail is opened. In this way, it can be determined whether a newsletter message has been opened. Furthermore, with the help of rapidmail we can determine whether and which links are clicked on in the newsletter message. All links in the email are so-called tracking links, with which your clicks can be counted.

Legal basis for data processing:

The legal basis for the newsletter tracking (measurement of the opening and click rates, as well as the storage of the measurement result) is your consent, which you gave when subscribing to the newsletter with reference to this data protection declaration (Art. 6 para. 1 lit. a DSGVO).

Purpose of data collection:

The information obtained within the scope of newsletter tracking is used for the technical improvement of the newsletter dispatch based on technical data or the recipient groups and their reading behaviour as well as the access times. Information is also obtained as to whether the newsletter has been opened, when this occurs and which links are clicked on in it (please also see the notes under “Description and scope of data processing” in this section). It is true that this information can be assigned to the individual newsletter recipients. However, we do not want to monitor the recipients of our newsletter. The information obtained enables us to tailor our newsletter service even better to the interests of the recipients, e.g. by adapting different content to the interests of the recipients and learning about the reading habits of the recipients.

Duration of storage:

The data stored by us within the scope of your consent for the purpose of the newsletter will be stored by us until you unsubscribe from the newsletter and deleted from our servers as well as from the servers of rapidmail after you unsubscribe from the newsletter. Thereafter, we may store the unsubscribed email address for up to three years on the basis of our legitimate interest in order to be able to prove consent previously given. The purpose of the processing for this period until deletion is limited to the defence against claims.

Possibility of objection and removal:

You can object to newsletter tracking at any time for the future. To do so, simply cancel your subscription to the newsletter. For this purpose, you will find a corresponding link (“Unsubscribe”) in every newsletter. This will end your subscription to the newsletter and the newsletter tracking.

Shipping service provider for the newsletter/recipient:

For newsletter tracking, we use the company rapidmail GmbH, Wentzingerstraße 21, 79106 Freiburg im Breisgau (please find the privacy policy of rapidmail GmbH here: https://www.rapidmail.de/datenschutz. We have concluded an order processing agreement (Art. 28 DSGVO) with rapidmail (hereinafter also referred to as newsletter service provider). The data is used exclusively for sending the newsletter.

Further data protection information:

For more details, please refer to the data security information of rapidmail at: https://www.rapidmail.de/datensicherheit. For more information on the analysis functions of rapidmail, please see the following link: https://www.rapidmail.de/wissen-und-hilfe

VII. Webinars, online meetings, telephone conferences (henceforth online meeting).

To conduct online meetings, we use “Microsoft Teams” by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA (“Microsoft”). More information about how Microsoft processes personal data can be found here: https://privacy.microsoft.com/de-de/privacystatement.

When you participate in the Online Meeting, various types of data are processed.

The following personal data is subject to processing:

  • User details: first name, last name, email address, profile picture (optional).
  • Meeting metadata: Participant IP address; subject, device/hardware information.
  • For recordings (optional): Online meeting chat text files, video, audio and presentation recordings in appropriate file format.
  • Text, audio and video data: should you be given the opportunity to use the chat, question or poll functions in an online meeting, the text entries you make will be processed in order to display and, if necessary, record them in the online meeting. The processing of data from your microphone as well as from any video camera is done to enable the display of video and the playback of audio during the online meeting. You can mute your microphone as well as your video camera at any time using the “Microsoft Teams” features.

In order to participate in an online meeting or to enter the virtual meeting room, you must at least provide information about your name.

Data is processed to the following extent:

Should we wish to record online meetings, we will inform you of this in advance in a comprehensible manner and ask for consent should this be necessary.

We will also log chat content should this be necessary for the purposes of logging the results of an online meeting. However, this will usually not be the case.

Legal basis

The legal basis for conducting online meetings using “Microsoft Teams” is Art. 6 (1) lit. b DSGVO, insofar as the online meetings are conducted in the context of contractual relationships. If there is no contractual relationship, the legal basis for data processing is Art. 6 (1) lit. f DSGVO, whereby our interest in these cases is in the effective implementation of online meetings.

Recipients/disclosure of data:

If personal data is not specifically intended for disclosure to third parties, such data processed in connection with participation in online meetings will generally not be disclosed to third parties.

Other recipients: Microsoft necessarily receives knowledge of the above data to the extent provided for in our order processing agreement with Microsoft.

Data processing outside the European Union:

Microsoft is a service provided by a provider from the USA. Personal data may therefore also be processed in a third country. An appropriate level of data protection is guaranteed by the conclusion of so-called EU standard contractual clauses.

We have concluded an order processing contract with Microsoft. in accordance with Art. 28 DSGVO.

In addition, we use the service of [Abtis GmbH, Wilhelm-Becker-Strasse 11 B, 75179 Pforzheim], whereby “Microsoft Teams” is hosted on servers in the EU. We have also concluded an order processing agreement with [Abtis GmbH, Wilhelm-Becker-Strasse 11 B, 75179 Pforzheim].

VIII. SSL encryption

To protect the security of your data during transmission, we use state-of-the-art encryption methods (e.g. SSL) via HTTPS.

IX. Change to our privacy policy

We reserve the right to adapt this data protection declaration so that it always complies with the current legal requirements or in order to implement changes to our services in the data protection declaration, e.g. when introducing new services. The new data protection statement will then apply to your next visit.

X. Questions to the Data Protection Officer

If you have any questions about data protection, please write us an e-mail or contact our data protection officer directly at:

datenschutz@gentlemengroup.de

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