We are very pleased about your interest in our company. Data protection is of a particularly high priority for the management of Strategix CFT GmbH. The use of internet pages of Strategix CFT GmbH is possible without any indication of personal data. However, if a data subject wants to use special services of our enterprise via our website, processing of personal data could become necessary. If processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain the consent of a 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, and in accordance with the country-specific data protection regulations applicable to the Strategix CFT GmbH. By means of this data protection declaration, our company would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this data protection declaration.
As the controller, the Strategix CFT GmbH has implemented numerous technical and organizational measures to ensure complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can always be vulnerable to security risks, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.
The data protection declaration of Strategix CFT GmbH is based on the terms used by the European Directive and Ordinance Maker when issuing the General Data Protection Regulation (GDPR). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
We use the following terms, among others, in this data protection declaration:
a) personal data
Personal data is 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject means any identified or identifiable natural person whose personal data are processed by the controller.
Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
Profiling is any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
Pseudonymization is the processing of personal data in such a way 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 separate and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Controller or person responsible for processing.
The controller or person responsible for processing 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. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its designation may be provided for under Union or Member State law.
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
Recipient means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive Personal Data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.
j) Third Party
Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.
Consent shall mean any indication of intention given voluntarily by a data subject for the specific case in an informed and unambiguous manner, in the form of a declaration or other unanimous.
2. Name and address of the controller.
The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:
Strategix CFT GmbH
Garather Schlossallee 19
Tel.: +49 (0) 211 7584 7420
Data subjects can prevent the setting of cookies by our website at any time by means of an appropriate setting of the internet browser used and thus permanently object to 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 common internet browsers. If a data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.
4. Collection of general data and information
The website of the Strategix CFT GmbH collects a series of general data and information each time a data subject or automated system accesses the website. These general data and information are saved in server log files. The following data may be collected: (1) browser types and versions, (2) operating system used by the access system, (3) the website from which the access system accesses our website (“referrer”), (4) the webpage from which the access system accesses on our website, (5) the date and time the website was accessed, (6) the Internet Protocol address (IP address), (7) the access system’s Internet service provider, and (8) other similar data and information that serve to prevent imminent harm to our information technology systems.
When using these general data and information, Strategix CFT GmbH does not draw any conclusions on a data subject. Rather, the information is needed to (1) correctly deliver the content of our website, (2) optimize the content on and advertising of our website, (3) ensure the long-term functionality of our information systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Therefore, the Strategix CFT GmbH analyzes anonymously collected data and information on the one hand, and, on the other hand, for the purpose of increasing the data protection and data security of our enterprise, in order to ensure an optimal level of protection for the personal data we process. The anonymized data of server log files is stored separately from any personal data provided by data subjects.
5 Registration on our website
Data subjects have the possibility to register on the website of the controller by providing personal data. Which personal data is transmitted to the controller in the process results from the respective input mask used for the registration. The personal data entered by data subjects are collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be transferred to one or more processors, for example a parcel service provider, who will also use the personal data exclusively for an internal use attributable to the controller.
By registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) of data subjects, the date as well as the time of registration are also stored. The storage of this data takes place because only in this way can the misuse of our services be prevented and, if necessary, this data makes it possible to clarify committed crimes. In this respect, the storage of this data is necessary for the protection of the data controller. As a matter of principle, this data is not passed on to third parties unless there is a legal obligation to pass it on or the passing on serves the purpose of criminal prosecution.
The registration of data subjects by voluntarily providing personal data serves the purpose of the controller to offer data subjects content or services which, due to the nature of the matter, can only be offered to registered users. Registered persons are free to modify the personal data provided during registration at any time or to have it completely deleted from the data stock of the controller.
The controller shall provide any data subject at any time upon request with information about what personal data is stored in regard to the data subject. Furthermore, the controller shall correct or delete personal data at the request or indication of data subjects, provided that this does not conflict with any statutory retention obligations. The entire staff of the controller shall be available to data subjects as contact persons in this context.
6. Subscription to our newsletter
On the website of the Strategix CFT GmbH, users are given the opportunity to subscribe to our enterprise’s newsletter. The personal data transmitted to the controller when the newsletter is subscribed to is specified in the input mask used for this purpose.
The Strategix CFT GmbH informs its customers and business partners at regular intervals by means of a newsletter about enterprise offers. The newsletter of our enterprise can only be received by a data subject, if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter mailing. For legal reasons, a confirmation e-mail will be sent to the e-mail address entered by a data subject for the first time for newsletter dispatch using the double opt-in procedure. This confirmation e-mail serves to verify a data subject as owner of the address and willful recipient of the newsletter.
When registering for the newsletter, we also store the IP address of the computer system used by the data subject at the time of registration, as assigned by the Internet service provider (ISP), as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of e-mail addresses of data subjects at a later point in time and therefore serves the legal protection of the controller.
The personal data collected in the context of a registration for the newsletter are used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter may be informed by e-mail if this is necessary for the operation of the newsletter service or a related registration, as could be the case in the event of changes to the newsletter offer or changes in the technical circumstances. No personal data collected as part of the newsletter service will be passed on to third parties. The subscription to our newsletter can be cancelled by data subjects at any time. The consent to the storage of personal data that the data subject has given us for the newsletter mailing can be revoked at any time. For the purpose of revoking consent, a corresponding link can be found in each newsletter. Furthermore, it is also possible to unsubscribe from the newsletter mailing directly on the website of the controller at any time or to notify the controller of this in another way.
7. Newsletter tracking
The newsletters of Strategix CFT GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in such e-mails that are sent in HTML format to enable log file recording and log file analysis. This enables a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the Strategix CFT GmbH 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 the data subject.
Such personal data collected via tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the newsletter dispatch and to optimise the content of future newsletters to the interests of data subjects. This personal data will not be disclosed to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via the double opt-in procedure. After a revocation, this personal data will be deleted by the controller. The Strategix CFT GmbH automatically regards a withdrawal from the receipt of the newsletter as a revocation.
8. Contact possibility via the website
Based on statutory provisions, the website of Strategix CFT GmbH contains information that enables a quick electronic contact to our enterprise, 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 by using a contact form, personal data transmitted by data subjects will be stored automatically. Such personal data transmitted on a voluntary basis by data subjects to the controller will be stored for the purposes of processing or contacting them. No disclosure of this personal data to third parties will take place.
9. Routine erasure and blocking of personal data.
The controller processes and stores personal data of data subjects only for the period necessary to achieve the purpose of storage set by the European Directives and Regulations, other legislators or regulations to which the controller is subject.
If the storage purpose ceases to apply or if a storage period prescribed by the European Directive and Regulation Maker or another competent legislator expires, personal data will be routinely blocked or deleted in accordance with the statutory provisions.
10. Rights of data subjects
a) Right to confirmation
Every data subject has the right granted by the European Directive and Regulation to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, s/he may, at any time, contact any employee of the controller.
b) Right of access
Any person concerned by the processing of personal data has the right granted by the European Directive and Regulation to obtain from the controller at any time, free of charge, information about personal data stored about them and a copy of that information. In addition, the European Directive and Regulation Legislator has granted data subjects access to the following information:
o the purposes of processing
o the categories of personal data processed
o the recipients or categories of recipients to whom personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations
o if possible, the planned duration for which personal data will be stored or, if this is not possible, the criteria for determining this duration
o the existence of a right to obtain rectification or erasure of personal data concerning them, or to obtain the restriction of processing by the controller, or a right to object to such processing
o the existence of a right of appeal to a supervisory authority
o if the personal data are not collected from the data subject: Any available information on the origin of the data
o the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved, the scope and intended effects of such processing for data subjects.
Furthermore, data subjects shall have the right to obtain information as to whether personal data have been transferred to a third country or to an international organization. If this is the case, data subjects also have the right to obtain information about the appropriate safeguards in connection with the transfer.
If a data subject wishes to exercise this right of access, s/he may, at any time, contact an employee of the controller.
c) Right of rectification
Every data subject affected by the processing of personal data has the right granted by the European Directive and Regulation to request the immediate rectification of inaccurate personal data concerning them. Furthermore, data subjects have the right to request the completion of incomplete personal data – also by means of a supplementary declaration – taking into account the purposes of the processing.
If a data subject wishes to exercise this right to rectify, s/he may, at any time, contact any employee of the controller.
d) Right to erasure (right to be forgotten)
Any person concerned by the processing of personal data has the right granted by the European Directive and Regulation to obtain from the controller the erasure without delay of personal data concerning him or her, where one of the following grounds applies and insofar as the processing is no longer necessary:
o The personal data were collected or otherwise processed for such purposes for which they are no longer necessary.
o A data subject revokes the consent on which the processing was based pursuant to Art. 6(1)(a) DS-GVO or Art. 9(2)(a) DS-GVO and there is no other legal basis for the processing.
o A data subject objects to the processing pursuant to Art. 21(1) DS-GVO and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) DS-GVO.
o Personal data have been processed unlawfully.
o The erasure of personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
o Personal data has been collected in relation to information society services offered pursuant to Article 8(1) DS-GVO.
If one of the aforementioned reasons applies, and a data subject wishes to arrange for the erasure of personal data stored by Strategix CFT GmbH, he or she may, at any time, contact any employee of the controller. The employee of the Strategix CFT GmbH will arrange for the erasure request to be complied with immediately.
If personal data have been made public by Strategix CFT GmbH and our enterprise as the controller is obliged to delete personal data pursuant to Article 17 (1) of the Data Protection Regulation, Strategix CFT GmbH shall implement reasonable measures, including technical measures, to ensure that other data controllers process the published personal data and that the data subject has requested from those other data controllers the deletion of all links to personal data, copies or replications of personal data, unless the processing is necessary. Strategix CFT GmbH’ employee in charge will arrange a solution in individual cases.
e) Right to restriction of processing
Each data subject concerned by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain from the controller restriction of processing if one of the following conditions is met:
o The accuracy of personal data is contested by a data subject for a period enabling the controller to verify the accuracy of the personal data.
o The processing is unlawful, a data subject objects to the erasure of personal data and requests instead the restriction of the use of the personal data.
o The controller no longer needs personal data for purposes of processing, but the data subject needs it for the assertion, exercise or defense of legal claims.
o A data subject has objected to the processing pursuant to Article 21 (1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of personal data stored by Strategix CFT GmbH, s/he may, at any time, contact any employee of the controller. The employee of Strategix CFT GmbH will arrange the restriction of the processing.
f) Right to data portability
Each data subject concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain personal data concerning them, which has been provided by a data subject to a controller, in a structured, commonly used and machine-readable format. S/he also has the right to transmit such data to another controller without hindrance from the controller to whom personal data have been provided, provided that processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, when exercising the right to data portability pursuant to Article 20(1) of the GDPR, data subjects shall have the right to obtain that personal data be transferred directly from one controller to another controller where technically feasible; provided that this does not adversely affect the rights and freedoms of other individuals.
In order to assert the right to data portability, the data subject may at any time contact any employee of Strategix CFT GmbH.
g) Right to object
Any person affected by processing of personal data has the right granted by the European Directive and Regulation to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them which is carried out on the basis of Article 6(1)(e) or (f) of the DS-GVO. This also applies to profiling based on these provisions.
Strategix CFT GmbH shall no longer process personal data in the event of objection, unless we can demonstrate compelling legitimate grounds for processing which override interests, rights and freedoms of data subjects, or for assertion, exercise or defence of legal claims.
If Strategix CFT GmbH processes personal data for direct marketing purposes, data subjects shall have the right to object at any time to processing of personal data processed for such marketing. This also applies to profiling, insofar as it is related to such direct marketing. If data subjects object to Strategix CFT GmbH’s processing for direct marketing purposes, Strategix CFT GmbH will no longer process the personal data for these purposes.
In addition, data subjects have the right, on grounds relating to their particular situation, to object to processing of personal data concerning them which is carried out by Strategix CFT GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the Data Protection Regulation (DS-GVO), unless such processing is necessary for the performance of a task carried out in the public interest.
In order to exercise the right to object, a data subject may directly contact any employee of the Strategix CFT GmbH. data subjects are also free to exercise their right to object by means of automated procedures using technical specifications in connection with the use of information society services, notwithstanding Directive 2002/58/EC.
h) Automated decisions in individual cases, including profiling.
Any person concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects them, unless the decision (1) is necessary for entering into, or the performance of, a contract between data subject and controller, or (2) is permitted by Union or Member State law to which the controller is subject and that law contains suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is made with the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between data subject and data controller, or (2) it is made with a data subject’s explicit consent, Strategix CFT GmbH shall implement suitable measures to safeguard a data subject’s rights and freedoms and legitimate interests, which include at least the right to obtain a data subject’s involvement on the part of the controller, to express their point of view and contest the decision.
If data subjects wish to exercise rights concerning automated decisions, they may, at any time, contact any employee of the controller.
i) Right to withdraw consent under data protection law.
Any data subject concerned by the processing of personal data has the right, granted by the European Directive and Regulation-maker, to withdraw consent to the processing of personal data at any time.
If a data subject wishes to exercise the right to withdraw consent, s/he may, at any time, contact any employee of the controller.
11. Data protection during applications and the application process
The controller collects and processes personal data of applicants for the purpose of handling the application procedure. The processing may also take place electronically. This is particularly the case if an applicant submits relevant application documents to the controller by electronic means, for example by e-mail or via web form located on the website. If the controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller conflict with such deletion. Other legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).
12. Legal basis of processing
Art. 6 I lit. a DS-GVO serves as legal basis for our company for processing operations in 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 a data subject is a party, as is the case, for example, with processing operations that are necessary for a delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 I lit. b DS-GVO. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation by which processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c DS-GVO. In rare cases, the processing of personal data might become necessary to protect vital interests of a data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result their name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d DS-GVO. Finally, processing operations could be based on Art. 6 I lit. f DS-GVO. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47 sentence 2 DS-GVO).
13. Legitimate interests in the processing pursued by the controller or a third party.
If processing of personal data is based on Article 6 I lit. f DS-GVO, our legitimate interest is the performance of our business activities for the benefit of the well-being of all our employees and our shareholders.
14. Duration for which personal data are stored.
Criterion for the duration of storing personal data is the respective statutory retention period. After expiry of the period, corresponding data will be routinely deleted, provided that they are no longer required for the fulfillment or initiation of the contract.
15. Legal or contractual requirements for the provision of personal data; necessity for the conclusion of the contract; obligation of data subjects to provide personal data; possible consequences of non-provision.
We inform you that providing personal data is sometimes required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Sometimes, in order to conclude a contract, it may be necessary for a data subject to provide us with personal data that must subsequently be processed by us. For example, data subjects are obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide personal data would mean that the contract with a data subject could not be concluded. Before providing personal data by a data subject, the data subject must contact one of our employees. Our employee will explain to the data subject on a case-by-case basis whether the provision of personal data is required by law or by contract or is necessary for the conclusion of the contract, whether there is an obligation to provide personal data, and what the consequences of not providing personal data would be.
16. Existence of automated decision making