We, SGV, thank you for visiting our website. As a service provider, the secure handling of your data is particularly important to us. We would therefore like to inform you in detail about the use of your data when you visit our website.

1. Definitions

SGV’s Privacy Policy is based on the terms used by the European legislator for directives and regulations when enacting the General Data Protection Regulation (GDPR). Our Privacy Policy is intended to be easily readable and understandable for both the public and our customers and business partners. To ensure this, we would like to explain the terms used in advance.

Among others, we use the following terms in this Privacy Policy:

– Personal Data: Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as ‘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.

– Data Subject: Data subject means any identified or identifiable natural person whose personal data are processed by the controller.

– Processing: 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, 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, erasure or destruction.

– Restriction of Processing: Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.

– Profiling: 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 analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

– Pseudonymisation: Pseudonymisation 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

– Controller or controller responsible for the processing: Controller or controller responsible for the processing 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. Where 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.

– Processor: Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

– Recipient: Recipient means a natural or legal person, public authority, agency or another 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.

– Third Party: Third party means 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 authorised to process personal data.

– Consent: Consent of the data subject means 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. Collection of Data

The SGV website collects a series of general data and information with each access to the website by a data subject or an automated system. These general data and information are stored in the server’s log files. The following may be collected:

a) browser types and versions used,

b) the operating system used by the accessing system,

c) the website from which an accessing system reaches our website (so-called referrer),

d) the sub-websites that are accessed on our website by an accessing system,

e) the date and time of an access to the website,

f) an Internet Protocol address (IP address),

g) the Internet service provider of the accessing system, and

h) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using these general data and information, SGV does not draw any conclusions about the data subject. Rather, this information is needed to

a) deliver the content of our website correctly,

b) optimize the content of our website and the advertising for it,

c) ensure the long-term functionality of our information technology systems and the technology of our website, and

d) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack.

These anonymously collected data and information are therefore evaluated by SGV statistically and furthermore with the aim of increasing data protection and data security in our company, ultimately 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 all personal data provided by a data subject.

3. Legal or contractual provisions for the provision of personal data; necessity for the conclusion of a contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We inform you that the provision of personal data is partly required by law (e.g., tax regulations) or may also result from contractual provisions (e.g., information on the contractual partner). Occasionally, for the conclusion of 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, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact our data protection officer. Our data protection officer will inform the data subject on a case-by-case basis whether the provision of 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 what consequences the non-provision of the personal data would have.

4. Data Use when Subscribing to the Email Newsletter

Users are given the opportunity to subscribe to our company’s newsletter on the SGV website. The personal data transmitted to the controller when ordering the newsletter is determined by the input mask used for this purpose.

SGV regularly informs its customers and business partners about company offers via a newsletter. Our company’s newsletter can generally only be received by the data subject if

a) the data subject has a valid email address, and

b) the data subject registers for newsletter delivery.

For legal reasons, a confirmation email is sent using the double opt-in procedure to the email address entered by a data subject for the first time for newsletter delivery. This confirmation email serves to verify whether the owner of the email address, as the data subject, has authorized the receipt of the newsletter.
When subscribing to the newsletter, we also store the IP address assigned by the Internet Service Provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary to be able to trace the (possible) misuse of a data subject’s email address at a later date and therefore serves to legally protect the controller.

The personal data collected during newsletter registration are used exclusively for sending our newsletter. Furthermore, newsletter subscribers may be informed by email if this is necessary for the operation of the newsletter service or a related registration, as might be the case with changes to the newsletter offering or changes in technical conditions. No personal data collected within the scope of the newsletter service is passed on to third parties. The data subject can cancel their subscription to our newsletter at any time. The consent to the storage of personal data that the data subject has given us for newsletter delivery can be revoked at any time. For the purpose of revoking consent, a corresponding link is found in every newsletter. Furthermore, it is possible to unsubscribe from newsletter delivery directly on the controller’s website at any time or to inform the controller in another way.

5. Newsletter Tracking

SGV newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in emails sent in HTML format to enable log file recording and analysis. This allows for a statistical evaluation of the success or failure of online marketing campaigns. Using the embedded tracking pixel, SGV can see whether and when an email was opened by a data subject and which links in the email were clicked by the data subject.

Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the controller to optimize newsletter delivery and to better adapt the content of future newsletters to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given via the double opt-in procedure. After revocation, this personal data will be deleted by the controller. SGV automatically interprets an unsubscribe from the newsletter as a revocation.

6. Contact Option via the Website

Due to legal regulations, the SGV website contains information that enables quick electronic contact with our company and direct communication with us, which also includes a general address for so-called electronic mail (email address). If a data subject contacts the controller via email or a contact form, the personal data transmitted by the data subject will be automatically stored. Such personal data voluntarily transmitted by a data subject to the controller are stored for the purpose of processing or contacting the data subject. This personal data is not passed on to third parties.

7. Use of Cookies

To make visiting our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e., after you close your browser (so-called session cookies). Other cookies remain on your device and allow us to recognize your browser on your next visit (persistent cookies). You can set your browser to inform you about the setting of cookies and to decide individually about their acceptance or to exclude the acceptance of cookies for certain cases or generally. If cookies are not accepted, the functionality of our website may be limited.

8. Notification of Changes

Changes in law or changes in our internal processes may necessitate an adjustment to this Privacy Policy.

In the event of such a change, we will inform you at least six weeks before it takes effect. You generally have a right of revocation (Section 6) regarding your given consents.

Please note that (unless you exercise your right of revocation) the current version of the Privacy Policy is the valid one.

9. Updating/Deletion of Your Personal Data
You have the option at any time to review, change, or delete the personal data provided to us by sending an email to the email address info@sgv-stuttgart.de. If you are a member with us, you can also opt out of receiving further information in the future.

Likewise, you have the right to revoke any consents given at any time with effect for the future.

The stored personal data will be deleted if you revoke your consent to storage.

The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or insofar as this has been provided for by the European legislator for directives and regulations or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage ceases to apply, or if a storage period prescribed by the European legislator for directives and regulations or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with legal provisions.

10. Cookie Management

We use the consent tool “Real Cookie Banner” to manage the cookies and similar technologies (tracking pixels, web beacons, etc.) used and the related consents. Details on how “Real Cookie Banner” works can be found at <a href=”https://devowl.io/de/rcb/datenverarbeitung/” rel=”noreferrer” target=”_blank”>https://devowl.io/de/rcb/datenverarbeitung/</a>.

The legal bases for the processing of personal data in this context are Art. 6 para. 1 lit. c GDPR and Art. 6 para. 1 lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

11. Rights of data subjects

Every data subject has the right granted by the European legislator for directives and regulations to obtain from the controller confirmation as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, they may, at any time, contact our data protection officer or another employee of the controller.

Every data subject affected by the processing of personal data has the right granted by the European legislator for directives and regulations to obtain free information from the controller at any time about the personal data stored concerning him or her and a copy of this information. Furthermore, the European legislator for directives and regulations has granted the data subject the right to information about the following:

– 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 disclosed, in particular recipients in third countries or international organisations

– where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period

– the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing concerning the data subject or to object to such processing

– the existence of the right to lodge a complaint with a supervisory authority

– if the personal data are not collected from the data subject: All available information about the origin of the data

– the existence of automated decision-making, including profiling, pursuant to Art. 22 (1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has the right to obtain information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.

Should a data subject wish to exercise this right to information, they may contact our Data Protection Officer or another employee of the controller at any time.

Every data subject affected by the processing of personal data has the right granted by the European legislator to demand the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right, taking into account the purposes of the processing, to demand the completion of incomplete personal data – including by means of a supplementary statement.

Should a data subject wish to exercise this right to rectification, they may contact our Data Protection Officer or another employee of the controller at any time.

Every data subject affected by the processing of personal data has the right granted by the European legislator to demand from the controller that personal data concerning them be erased without undue delay, provided that one of the following reasons applies and insofar as the processing is not necessary:

– The personal data were collected or otherwise processed for purposes for which they are no longer necessary.

– The data subject withdraws their consent on which the processing was based pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, and there is no other legal basis for the processing.

– The data subject objects to the processing pursuant to Art. 21 (1) GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.

– The personal data have been unlawfully processed.

– The erasure of personal data is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the controller is subject.

– The personal data have been collected in relation to the offer of information society services pursuant to Art. 8 (1) GDPR.

If one of the aforementioned reasons applies and a data subject wishes to arrange for the erasure of personal data stored by SGV, they may contact our Data Protection Officer or another employee of the controller at any time. The SGV Data Protection Officer or another employee will ensure that the erasure request is complied with without undue delay.

If SGV has made the personal data public and our company, as controller pursuant to Art. 17 (1) GDPR, is obliged to erase the personal data, SGV shall, taking into account available technology and the costs of implementation, take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure by such other controllers of any links to, or copy or replication of, those personal data, insofar as processing is not required. The SGV Data Protection Officer or another employee will arrange for the necessary steps in individual cases.

Every data subject affected by the processing of personal data has the right granted by the European legislator to demand from the controller the restriction of processing if one of the following conditions is met:

– 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 the restriction of their use instead.

– The controller no longer needs the personal data for the purposes of processing, but the data subject requires them for the establishment, exercise or defense of legal claims.

– The data subject has objected to the processing pursuant to Art. 21 (1) GDPR, and it has not yet been determined 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 SGV, they may contact our Data Protection Officer or another employee of the controller at any time. The SGV Data Protection Officer or another employee will arrange for the restriction of processing.

Every data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, provided that the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) 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 their right to data portability pursuant to Art. 20 (1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may contact the Data Protection Officer appointed by SGV or another employee at any time.

Every data subject affected by the processing of personal data has the right granted by the European legislator to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them which is based on Art. 6 (1) (e) or (f) GDPR. This also applies to profiling based on these provisions.

In the event of an objection, SGV shall no longer process the personal data, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

If SGV processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for the purpose of such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to SGV processing for direct marketing purposes, SGV will no longer process the personal data for these purposes.

Furthermore, the data subject has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them which is carried out by SGV for scientific or historical research purposes or statistical purposes pursuant to Art. 89 (1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

To exercise the right to object, the data subject may contact the SGV Data Protection Officer or another employee directly. Furthermore, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject is free to exercise their right to object by automated means using technical specifications.

Every data subject affected by the processing of personal data has 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 concerning them or similarly significantly affects them, provided that the decision

a) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or

b) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or

c) is based on the data subject’s explicit consent.

If the decision

a) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or

b) is based on the data subject’s explicit consent, SGV shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.

Should the data subject wish to assert rights in relation to automated decisions, they may contact our Data Protection Officer or another employee of the controller at any time.

Every data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.

Should the data subject wish to assert their right to withdraw consent, they may contact our Data Protection Officer or another employee of the controller at any time.

12. Legal basis of the processing

Art. 6 (1) (a) GDPR serves as the legal basis for our company 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, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Art. 6 (1) (b) GDPR. The same applies to such processing operations that are necessary for carrying out 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 the processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6 (1) (c) GDPR. In rare cases, the processing of personal data might become necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our premises were injured and his name, age, health insurance data, or other vital information had to be passed on to a doctor, hospital, or other third parties. Then the processing would be based on Art. 6 (1) (d) GDPR. Finally, processing operations could be based on Art. 6 (1) (f) GDPR. Processing operations not covered by any of the aforementioned legal bases are based on this legal basis if the 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 data subject. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, the legislator was of the opinion that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

13. Legitimate interests in the processing pursued by the controller or a third party

If the processing of personal data is based on Art. 6 (1) (f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and shareholders.

14. The controller or your contact person

For questions regarding the collection, processing, or use of your personal data, for information, rectification, blocking, or erasure of data, as well as withdrawal of granted consents or objection to a specific data use, please contact:

Süddeutscher Gläubigerschutzverband
Erich-Herion-Str. 15
70736 Stuttgart
+49 711 55008 0
+49 711 5500811
info@sgv-stutgart.de

As of: 2020-07-28

Legal Validity:
This disclaimer is part of the internet offering of Südd. Gläubigerschutzverband GmbH. Should individual formulations or parts of this text no longer or not fully comply with the applicable legal situation, the remaining parts of this declaration shall remain unaffected.