Data protection

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in our online offer and all associated websites, functions and content as well as in external online presences, such as our social media profile (hereinafter collectively referred to as “online offer”). With regard to the terms that are used, such as “processing” and “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Controller
CTR Marina Dresden GmbH
Ostra-Allee 13
D-01067 Dresden

Email: sales@ctrgroup.de

Types of data processed:
– Inventory data (e.g. names, addresses).
– Contact data (e.g. email, telephone numbers).
– Content data (e.g. text entries, photographs, videos).
– Usage data (e.g. websites visited, interest in content, access times).
– Meta/communication data (e.g. device information, IP addresses).

Categories of data subjects
Visitors and users of the online offer (hereinafter we shall also refer to the data subjects collectively as “users”).

Purpose of processing the data
– Provision of the online offering, its functions and content.
– Answering contact enquiries and communicating with users.
– Safety measures.
– Reach measurement/marketing

Terminology
“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. a cookie) or 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, whether or not by automated means. The term is far-reaching 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 that consists of the use of such personal data to evaluate certain personal aspects relating to a natural person; in particular, to analyze or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

The “controller” 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.

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

Relevant legal bases
We inform you in accordance with Art. 13 GDPR of the legal basis 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 Art. 6 Para. 1 lit. a, Art. 7 GDPR and Art. 9 Para. 2 GDPR, the legal basis for the processing in order to fulfil our services and implement contractual measures as well as answer enquiries is Art. 6 Para. 1 lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 Para. 1 lit. c GDPR, and the legal basis for processing in order to protect our legitimate interests is Art. 6, Para. 1, lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 Para. 1 lit. d GDPR serves as the legal basis.

Security measures
We take appropriate technical and organizational measures in accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well its access, input, transfer, safeguarding of availability and its separation. In addition, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted and we respond to data threats. Furthermore, we take the protection of personal data into account as early as the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and privacy-friendly default settings (Art. 25 GDPR).

Cooperation with processors and third parties
If we disclose data to other persons and companies (processors or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary for the fulfilment of the contract in accordance with Art. 6 Para. 1 lit. b GDPR), you have given your consent, a legal obligation provides for this or on the basis of 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 “order processing contract”, this is done on the basis of Art. 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 if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual authorizations, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

We would like to point out that no level of data protection comparable to that in the EU can be guaranteed in these countries. For example, US companies are obligated to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for surveillance purposes. We have no influence on these processing activities.

Storage period
Unless a more specific storage period has been specified in this Privacy Policy, your personal data will remain with us until the purposes for which it is processed no longer apply. If you make a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law). However, this data will also be deleted as soon as these reasons no longer apply.

Rights of the data subjects
You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.

In accordance with Art. 16 GDPR, you have the right to request the rectification of data concerning you or the correction of incorrect data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with Art. 18 GDPR.

You have the right to demand to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request its transfer to other controllers.

You have the right to receive information about the purpose, origin and recipient of your stored personal data, free of charge.

Furthermore, pursuant to Art. 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement. The right to appeal exists without prejudice to other administrative or judicial remedies.

Right of revocation
You have the right to revoke your consent in accordance with Art. 7 Para. 3 GDPR. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object
You may object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection can be made in particular against processing for direct marketing purposes in accordance with Art. 21 Para. 2 GDPR.

Cookies and the right to object to direct advertising
Cookies are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies” are cookies that are deleted after a user leaves an online service and closes their browser. For example, the content of a shopping cart in an online store or a login status can be stored in such a cookie. Permanent” or “persistent” cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. Third-party cookies are cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only the controller’s cookies, they are referred to as first-party cookies).

Cookies that are required to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 Para. 1 lit. f GDPR, unless another legal basis is specified.

The website operator has a legitimate interest in the storage of necessary cookies in order to provide optimized and technically error-free services. If consent to the storage of cookies and comparable recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6 Para. 1 lit. a GDPR and Section 25 (1) TTDSG [German Telecommunications Telemedia Data Protection Act]; consent can be revoked at any time.

We may use temporary and permanent cookies and provide information about 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 their browser’s system settings. Saved cookies can be deleted in the browser’s system settings. Excluding cookies can lead to restrictions of the functions of this online offer.

A general objection to the use of cookies that are used for online marketing purposes can be made with a large number of services, especially in the case of tracking, via the US websitehttp://www.aboutads.info/choices/ or the EU websitehttp://www.youronlinechoices.com/. Furthermore, you can also disable the storage of cookies in your browser settings. Please note that you may then not be able to use all the functions of this website.

Deletion of data
The data processed by us will be deleted or restricted in their processing in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this Privacy Policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other, legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for legal reasons under commercial or tax laws.

According to the legal requirements in Germany, the retention period is 10 years pursuant to Sections 147 Para. 1 AO [German Tax Code], 257 Para. 1 no. 1 and 4, Para. 4 HGB [German Commercial Code] (books, records, management reports, accounting records, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with Section 257 Para. 1 no. 2 and 3, Para. 4 HGB (commercial papers).

According to legal requirements in Austria, the retention period is 7 years in accordance with Section 132 Para. 1 BAO [Federal Fiscal Code] (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), 22 years in connection with real estate and 10 years for documents in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

External payment service providers
We use external payment service providers via whose platforms the users and we can carry out payment transactions (e.g. – each with a link to the Privacy Policy – Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html).

As part of the fulfillment of contracts, we use payment service providers on the basis of Art. 6 para. 1 lit. b. GDPR. We also use external payment service providers on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. b. GDPR in order to offer our users effective and secure payment options.

The data processed by the payment service providers includes inventory data (such as the name and address), bank data (such as account numbers or credit card numbers), passwords, TANs and checksums as well as the contract, totals and recipient-related details. This information is required to carry out the transactions. However, the data that is entered will be processed only by the payment service providers and stored with them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, payment service providers may transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. in this regard, we refer you to the general terms and conditions and data protection information of the payment service providers.

Payment transactions are subject to the terms and conditions and the data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications. In this regard, too, we refer you to these for further information and the assertion of rights of revocation and information, and other rights of data subjects.

Administration, financial accounting, office organization, contact management
We process data as part of administrative tasks and the organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process as part of the provision of our contractual services. The bases for processing are Art. 6 Para. 1 lit. c. GDPR and Art. 6 Para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose of and our interest in the processing lies in the administration, financial accounting, office organization and archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information specified in these processing activities.

We disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors, as well as other fee collection centers and payment service providers.

We also store information regarding suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We store this data, most of which is business-related, permanently.

Business analyses and market research
We analyze the data we have on business transactions, contracts, enquiries, etc. in order to operate our business economically and to identify market trends and the wishes of contractual partners and users. We process inventory data, communication data, contract data, payment data, usage data and metadata on the basis of Art. 6 Para. 1 lit. f. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with information, such as on the services they have used. The analyses help us to increase user-friendliness, optimize our offer and improve business efficiency. The analyses are intended for our use only and are not disclosed externally, unless they are anonymous analyses with summarized values.

If these analyses or profiles are personal, they will be deleted or anonymized when the user cancels the contract, or else after two years from the conclusion of the contract. Furthermore, the overall business analyses and determinations of general trends are prepared anonymously wherever possible.

Contacting us
When contacting us (e.g. by contact form, email, telephone or via social media), the user’s details are used to process the contact enquiry and its processing in accordance with Art. 6 Para. 1 lit. b) GDPR. User data may be stored in a customer relationship management (CRM) system or comparable enquiry system.

We delete the enquiries if they are no longer required. We review the legitimacy of the requirement every two years; in other respects, the statutory archiving obligations apply.

Hosting and email delivery
This website is hosted by an external service provider. The personal data collected on this website is stored on the host’s servers. The hosting services we use provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email dispatch, security services and technical maintenance services that we use for the purpose of operating this online service.

In doing so, 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 to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer, in accordance with Art. 6 Para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract).

We use the following host:

CTR Development, s.r.o., Seifertova 2919/12 130 00 Prague 3

Collection of access data and log files
We or our hosting provider collect data about every access to the server on which this service is located (so-called server log files), on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. GDPR. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previous page visited), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data that is required to be retained further for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

Google Analytics
If you have given your consent in accordance with Art. 6 Para. 1 sentence 1 lit. a GDPR, we use Google Analytics – a web analytics service provided by Google Ireland Limited (“Google”). Google uses cookies. The information generated by the cookie about the user’s use of the online offer is usually transmitted to a Google server in Ireland and stored there.

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the user’s IP address is shortened by Google within member states of the European Union or in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in Ireland and shortened there.

The IP address transmitted by the user’s browser will not be merged with other Google data. 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 offer to Google, and the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information on the use of data by Google, options for settings 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).

Users’ personal data is deleted or anonymized after 14 months. As an alternative to the browser plugin, you can prevent Google Analytics from collecting data on this website the first time you visit our site. An opt-out cookie is stored on your end device. If you delete your cookies, you will be asked to give your consent again.

Google AdWords and conversion measurement
If you have given your consent in accordance with Art. 6 Para. 1 sentence 1 lit. a GDPR, we use the services of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, (“Google”).

We use the online marketing procedure Google “AdWords” to place ads in the Google advertising network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who are presumed to be interested in the ads. This allows us to display ads for and within our online offering in a more targeted manner, in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products that they were interested in on other online offers, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google advertising network is active are accessed, a Google code is executed directly by Google and so-called “cookies” are stored. (Re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which websites the user has visited, which content they are interested in and which offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, visiting time and other information on the use of the online offer.

We also receive an individual “conversion cookie”. The information collected with the help of this cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. We do not receive any information with which users can be personally identified.

User data is processed pseudonymously within the Google advertising network. This means that Google does not store and process the user’s name or email address, for example, but processes the relevant data in relation to cookies within pseudonymous user profiles. This means that, from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie owner, regardless of who this cookie owner is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in Ireland.
Further information on the use of data by Google, options for settings 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).

Online presence in social media
We maintain online presences within social networks and platforms in order to communicate with the customers, interested parties and users active there and to inform them of our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.

Unless otherwise stated in our Privacy Policy, we process users’ data if they communicate with us within social networks and platforms, such as writing posts on our online presences or sending us messages.

Integration of third-party services and content
Within our online offering, we use content or service offerings from third-party providers on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 Para. 1 lit. f. GDPR) in order to improve their content and integrate services, such as videos or fonts (hereinafter referred to as “content”).

This always presupposes that the third-party providers of this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as web beacons) for statistical or marketing purposes. Pixel tags can be used to analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offering, as well as being linked to such information from other sources.

YouTube
We integrate the videos of the platform “YouTube” of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit one of our websites on which YouTube is integrated, a connection to the YouTube servers is established. In the process, the YouTube server is informed which of our webpages you have visited.

YouTube may also store various cookies on your device or use comparable technologies for recognition (e.g. device fingerprinting). In this way, YouTube can obtain information about visitors to this website. This information is used, among other things, to record video statistics, improve user-friendliness and prevent attempts to commit fraud.

Google Fonts
We integrate the fonts (“Google Fonts”) of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Fonts are installed locally. There is no connection to Google servers established.

Google Maps
We integrate the maps of the “Google Maps” service of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually within the framework of the settings of their mobile devices). The data may be processed in Ireland. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated. Created with Datenschutz-Generator.de by Dr. Thomas Schwenke, lawyer

MailerLite
We integrate the email program “MailerLite” from the company MailerLite, Inc., 548 Market Street, PMB 98174, San Francisco, California 94104-5401 USA. Additional data processing information for the program can be found at https://www.mailerlite.com/legal/data-processing-agreement