Data protection

Data protection declaration according to the GDPR

I. Name and address of the controller

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is:

Cordillera Strategie
Christian Lukas
Herrenalberstrasse 34
D-76199 Karlsruhe

Phone: +49 176 2873 7810
E-mail: lukas@cordillera-strategie.com

II. Name and address of the data protection officer

The data protection officer of the controller is:

Cordillera Strategie
Christian Lukas
Herrenalberstrasse 34
D-76199 Karlsruhe

Phone: +49 176 2873 7810
E-mail: lukas@cordillera-strategie.com

III. General information on data processing

1. Scope of processing of personal data

In principle, we only collect and use personal data of our users to the extent necessary to provide a functional website as well as our content and services. The collection and use of personal data of our users takes place regularly only after the user’s consent. An exception applies in those cases in which it is not possible to obtain prior consent for factual reasons and the processing of the data is permitted by law.

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for processing operations of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.

In the processing of personal data required for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

Insofar as the processing of personal data is necessary to fulfill a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

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.

If processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for processing.

3. Data erasure and storage duration

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

IV. Provision of the website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.

The following data is collected:

  1. Information about the browser type and version used
  2. The user’s operating system
  3. The user’s Internet service provider
  4. The user’s IP address
  5. Date and time of access
  6. Websites from which the user’s system accesses our website
  7. Websites that are accessed by the user’s system via our website

2. Legal basis for data processing

The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.

3. Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user’s computer. For this purpose, the IP address of the user must remain stored for the duration of the session.

The storage in log files is done to ensure the functionality of the website. In addition, the data is used to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes also include our legitimate interest in data processing according to Art. 6 para. 1 lit. f GDPR.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.

In the case of storage of data in log files, this is the case after seven days at the latest. A storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.

5. Objection and removal option

The collection of data for the provision of the website and the storage of data in log files is mandatory for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

V. Use of cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the computer system of the user. When a user calls up a website, a cookie can be stored on the user’s operating system. This cookie contains a characteristic string that allows a unique identification of the browser when the website is called up again.

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 following data is stored and transmitted in the cookies:

  1. Language settings
  2. Browser
  3. Log-in information

We also use cookies on our website that enable an analysis of the surfing behavior of users.

The following data can be transmitted in this way:

  1. Entered search terms
  2. Frequency of page views
  3. Use of website functions

The data of the users collected in this way are pseudonymized by technical precautions. Therefore, an assignment of the data to the calling user is no longer possible. The data are not stored together with other personal data of the users.

When accessing our website, users are informed by an info banner about the use of cookies for analysis purposes and referred to this privacy policy. In this context, there is also a note on how the storage of cookies can be prevented in the browser settings.

When accessing our website, the user is informed about the use of cookies for analysis purposes.

2. Legal basis for data processing

The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.

3. Purpose of data processing

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 recognized even after a page change.

The user data collected by technically necessary cookies are not used to create user profiles.

The use of analysis cookies is for the purpose of improving the quality of our website and its content. Through the analysis cookies, we learn how the website is used and can thus continuously optimize our offer.

These purposes also include our legitimate interest in the processing of personal data pursuant to Art. 6 para. 1 lit. f GDPR.

4. Duration of storage, objection and removal option

Cookies are stored on the user’s computer and transmitted by it to our site. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transmission of cookies. Cookies already stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.

VI. Contact form and e-mail contact

1. Description and scope of data processing

Our website contains a contact form, which can be used for electronic contact. If a user takes advantage of this option, the data entered in the input mask will be transmitted to us and stored.

At the time of sending the message, the following data is also stored:

  1. The IP address of the user
  2. Date and time of registration

For the processing of the data, your consent is obtained during the sending process and reference is made to this privacy policy.

Alternatively, it is possible to contact us via the e-mail address provided. In this case, the personal data of the user transmitted with the e-mail will be stored.

There is no disclosure of data to third parties in this context. The data will be used exclusively for the processing of the conversation.

2. Legal basis for data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. a GDPR if the user has given his consent.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. If the e-mail contact aims at the conclusion of a contract, then additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.

3. Purpose of data processing

The processing of the personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this also includes the necessary legitimate interest in the processing of the data.

The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is terminated when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

The additional personal data collected during the sending process will be deleted at the latest after a period of seven days.

5. Objection and removal option

The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.

All personal data stored in the course of the contact will be deleted in this case.

VII. Integration of services and content of third parties

Within our online offer, we rely on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) content or service offerings from third-party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate 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 include, but is not limited to, technical information about the browser and operating system, referring websites, time of visit, and other information about the use of our online offer, as well as may be linked to such information from other sources.

The following overview provides an overview of third-party providers and their content, along with links to their privacy statements, which provide further information on the processing of data:

  • Maps of the service “Google Maps” of the third party Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.
  • This page uses so-called web fonts, which are provided by Google, for the uniform display of fonts. When you call up a page, your browser loads the required web fonts into its browser cache in order to display texts and fonts correctly. For this purpose, the browser you use must connect to Google’s servers. This gives Google knowledge that our website has been accessed via your IP address. The use of Google Web Fonts is in the interest of a uniform and appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If your browser does not support web fonts, a standard font will be used by your computer. Further information about Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://www.google.com/policies/privacy/.

VIII. Rights of the data subject

If personal data of you are processed, you are a data subject i.S.d. GDPR and you have the following rights against the controller:

1. Right to information

You can ask the controller to confirm whether personal data concerning you is processed by us.

If such processing is taking place, you can request the following information from the controller:

(1) the purposes for which the personal data are processed;

(2) the categories of personal data that are processed;

(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;

(4) the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage duration;

(5) the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;

(6) the existence of a right of appeal to a supervisory authority;

(7) all available information about the origin of the data if the personal data are not collected from the data subject;

(8) 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 scope and intended effects of such processing for the data subject.

You have the right to request information about whether the personal data concerning you are transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transfer.

2. Right to rectification

You have the right to rectification and/or completion vis-à-vis the controller, provided that the processed personal data concerning you are incorrect or incomplete. The controller must carry out the rectification without undue delay.

3. Right to restriction of processing

Under the following conditions, you may request the restriction of processing of personal data concerning you:

(1) if you dispute the accuracy of the personal data concerning you for a period that enables the controller to verify the accuracy of the personal data;

(2) the processing is unlawful and you object to the erasure of the personal data and instead request the restriction of the use of the personal data;

(3) the controller no longer needs the personal data for the purposes of the processing, but you need them for the assertion, exercise or defense of legal claims, or

(4) if you have objected to the processing pursuant to Art. 21 para. 1 GDPR and it has not yet been determined whether the legitimate grounds of the controller override your grounds.

If the processing of personal data concerning you has been restricted, such data may be processed – apart from being stored – only with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or on grounds of an important public interest of the Union or of a Member State.

If the restriction of processing has been restricted in accordance with the above-mentioned requirements, you will be informed by the controller before the restriction is lifted.

4. Right to erasure

a) Obligation to erase

You may request the controller to erase personal data concerning you without undue delay, and the controller is obliged to erase such data without undue delay where one of the following grounds applies:

(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.

(2) You withdraw your consent on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal basis for the processing.

(3) You object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 para. 2 GDPR.

(4) The personal data concerning you have been processed unlawfully.

(5) The erasure of the personal data concerning you is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.

(6) The personal data concerning you have been collected in relation to services offered by the information society pursuant to Art. 8 para. 1 GDPR.

b) Information to third parties

If the controller has made the personal data concerning you public and is obliged to erase them pursuant to Art. 17 para. 1 GDPR, it shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform data controllers who process the personal data that you, as the data subject, have requested them to erase all links to such personal data or copies or replications of such personal data.

c) Exceptions

The right to erasure does not apply to the extent that processing is necessary

(1) for exercising the right to freedom of expression and information;

(2) to fulfill a legal obligation which requires processing under the law of the Union or of the Member States to which the controller is subject, or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller;

(3) for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;

(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89 para. 1 GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of such processing, or

(5) for the assertion, exercise or defense of legal claims.

5. Right to information

If you have asserted the right to rectification, erasure or restriction of processing vis-à-vis the controller, the latter is obliged to notify all recipients to whom the personal data concerning you have been disclosed of such rectification or erasure of the data or restriction of processing, unless this proves impossible or involves disproportionate effort.

You have the right to be informed about these recipients vis-à-vis the controller.

6. Right to data portability

You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without hindrance from the controller to whom the personal data have been provided, provided that

(1) the processing is based on consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR, and

(2) the processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another, where technically feasible. The freedoms and rights of other persons must not be affected thereby.

The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7. Right to object

You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you which is based on Art. 6 para. 1 lit. e or f GDPR, including profiling based on those provisions.

The controller will no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise or defense of legal claims.

Where personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes.

You have the option, in connection with the use of services of the information society – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures using technical specifications.

8. Right to withdraw the declaration of consent under data protection law

You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

9. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

(1) is necessary for the conclusion or performance of a contract between you and the controller,

(2) is authorized by Union or Member State law to which the controller is subject and that law contains appropriate measures to safeguard your rights and freedoms and your legitimate interests, or

(3) is based on your explicit consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.

With regard to the cases mentioned in (1) and (3), the controller shall take reasonable measures to safeguard the rights and freedoms and your legitimate interests, including at least the right to obtain the intervention of a person on the part of the controller, to state his or her own position and to contest the decision.

10. Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Art. 78 GDPR.