Privacy Policy

Your privacy is important to us. We solely process your information based on the legal requirements of DSGVO and the Act on Telemedia (Germany). This privacy policy discloses how we collect, protect, use and share personal information gathered from you on the website.By accessing and using the website, you consent to the terms of this privacy policy and agree to be bound by it and the terms of use.

The use of our website is possible without disclosing private data. If voluntarily-entered personal information is gathered (e.g. your name, address, email, phone number or the like), it will exclusively be processed by us and will not be transferred to third parties without prior agreement.

We need to inform that all data transmitted over the internet (e.g. email communication) can besubject to interception and inappropriate use. Completely securing data to omit third party access is not possible.

1 Data deletion and data retention

Your personal data will be deleted immediately once it has served the purpose for which it was collected. If data cannot be deleted for legal reasons (HGB, etc.), the data will be kept. However, the data will not be disclosed to any third parties.

1.1 Criteria for period prior to data deletion:

When data reaches the end of the retention period, it is deleted automatically. If you wish to delete all your personal data – we will do so immediately unless it cannot be deleted for legal reasons.

2 Cookies

Our website uses cookies. Cookies are small pieces of data sent from a website and stored on a website user’s web browser while a user is browsing a website. When the user browses the same website in the future, the data stored in the cookie can be retrieved by the website for marketing and advertising purposes. Cookies do not harm your computer in any way. You can disable the use of cookies by our websites by turning off the cookie function on your browser. Deactivation could affect the browsers performance on our website.

3 Server-Log-Files

The provider of this website automatically stores information in so-called server log files, which your browser automatically transmits to us. These server log files contain the following information:

• Browsertype and version
• Operating system
• Referrer URL
• Host name of accessing device
• Time of server request

This data cannot be associated with individual persons, and they are not correlated with data

from any other sources. We reserve the right to check the data retroactively in case of concrete

indications of unlawful use. We use the information to assure an unimpeded web presence.

4 Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

Further information about Google’s privacy policy may be obtained from: https://support.google.com/analytics/answer/6004245?hl=de

4.1 IP Anonymization

We use Google‘s service “AnonymizeIP“ on this website. In this case Google will anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of the website provider, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google.

4.2 Browser plugin

You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Your IP address will be obtained and stored, but instantly pseudonymized by deleting the last 8-bit. This will only only allow approximate tracking. The relationship to the web analysis provider is based on an adequacy decision of the European Commission (Privacy Shield).

5 Legal basis

The legal basis for the processing of your personal data is your consent and only permitted under the EU data protection law. At least one of the following must apply whenever your data is processed:

• Consent
• Contract
• Legal obligation
• Protection of interests on the basis of Art. 6 Abs. 1 DSGVO (GDPR)

6 Newsletter data

If you would like to receive our newsletter, we require a valid email address as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive this newsletter. No additional data is collected or is only collected on a voluntary basis. We only use this data to send the requested information and do not pass it on to third parties.

6.1 Information we obtain

• Registered names of companies
• E-Mail address
• Interests

The collected data is used exclusively for the purpose of sending the requested information and will not be passed on to third parties. After subscribing to our newsletter we will send you a confirmation email with a verification link. You may at any time withdraw your consent to the storing of these data and your e-mail address, as well as to its use for sending the newsletter, for example by using the “Unsubscribe” link in the newsletter or by writing an email directly to : info@jas-consultants.com.

7 Contact form

If you reach out to us using the contact form available on our website, the data you provide in the

form, including your contact data, are stored for the purpose of processing your current request

and possible associated future requests. The data will not be passed on without your consent.

Once the processing of your request is done, all collected data will be deleted (see Data deletion and data retention). You have the right to withdraw consent at any time by sending an email to info@jas-consultants.com

8 Comment section on our website

Our website offers a blog element where users can leave comments. If you use the comment section, we will also collect information about the specific time when the comment was written, your e-mail address and your user name, if you are signed in.

8.1 Subscribing to comments

As a signed in user of this website, you can subscribe to comments. You will receive a confirmation email for verification of your identity. The subscription can be cancelled by you at anytime.

9 Privacy Policy for the use Google AdSense

This website uses Google AdSense, a web advertising service provided by Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA.

Google AdSense uses ‘cookies’, which are text files placed on your computer, to help the website analyse site usage. Google AdSense also uses Web beacons (invisible images). Web beacons allow information such as visitor traffic to be analysed on this site.

The information generated by the cookies and Web beacons about your use of this website (including your IP address) and the distribution of advertising formats will be transmitted to and stored by Google on a server in the United States. This information may be transmitted by Google to its contractual partners.

However, your IP address will not be associated with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings in your browser; however, please note that if you do this, you may not be able to use the full functionality of this website.

Use the following link and go to the DoubleClick-Deactivation extension section. It is required to be signed in to account to make changes. Alternatively, you can disable the DoubleClick-Cookies on the Network Advertising Initiative website by following this link.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

10 Privacy Policy for the use of YouTube

Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit our website, which features a YouTube plugin, a connection to the YouTube servers is established. The YouTube server will be informed about which of our pages you have visited. If you are logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account.

YouTube is used to help make our website appealing. This constitutes a justified interest persuant to Art. 6 (1) (f) DSGVO (GDPR). Further information about handlung user data, can be found in the data protection declaration of YouTube under https://www.google.de/intl/de/policies/privacy.

11 Facebook-Plugins (Like-Button)

Our website includes plugins fort he social network Facebook, Facebook Inc., 1601 South California Avenue, Palo Alto, CA 94304, USA.

The Facebook plugin can be recognized by the Facebook logo on our website. For an overview of Facebook plugins, see http://developers.facebook.com/docs/plugins/

When you visit our site, a direct connection between your browser and the Facebook server is established via the plugin. This enables Facebook to receive information that you have visited our site from your IP address. If you click on the Facebook “Share button” while you are logged into your Facebook account, you can link the content of our site to your Facebook profile. This allows Facebook to associate visits to our site with your user account. Please note that, as the operator of this site, we have no knowledge of the content of the data transmitted to Facebook or of how Facebook uses these data. For more information, please see Facebook’s privacy policy at https://de-de.facebook.com/policy.php.

If you do not want Facebook to associate your visit to our site with your Facebook account, please log out of your Facebook account.

12 Sharing content on other social media platforms

The contents displayed on our website can be shared on other social media platforms, such as Facebook, Twitter, or Xing. A direct connection to other platforms or networks will only be established, if the user actively gives permission by clicking on the platform’s buttons.

There will be no automatic transmission of the user data to the any of the platforms. If the user is logged in to any of the networks while browsing our website, the Social-Buttons of Facebook, Google+ and Twitter can be used prior to publishing a comment.

Our users can share information of our website on other social media platforms without disclosing the entire user profile and browsing behavior.

13 Privacy Policy for the use of Remarketing

Our website uses the service of Google Analytics Remarketing to advertise on third party websites (including Google) to previous visitors on our site. The provider is: Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA.

We use Google Analytics’ 3rd-party audience data such as age, gender, and interests to better understanding the behavior of our customers and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. For example, you may see certain ads on this website or other websites because we contract with Google and other similar companies to target our ads based on information we or they have collected, including information that was collected through automated means.

If you have agreed to remarketing through Google Analytics, Google will connect you browser history to your Google account. Each device you use, that is logged in to your Google account will receive personalized advertising.

In order to support the service, Google Analytics collects google-authentificated user ID’s, that will temporarly be connected to our Google-Analytics Data to create more personalized ads.

You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by disabling it in your Google account: https://www.google.com/settings/ads/onweb/.

You can change your browser settings so that it only accepts the retention of cookies after your agreement. You may also only block third party cookies by using the EDAA deactivation website: http://www.youronlinechoices.com/de/praferenzmanagement/

Additional information about the privacy policy can be found in Google’s privacy policy: http://www.google.com/policies/technologies/ads/

14 Privacy Policy for the use of Google Tag Manager

This website uses Google Tag Manager. Google Tag Manager is a solution that allows marketed website tags to be managed using an interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not register personal data. The tool causes other tags to be activated which may, for their part, register data under certain circumstances. Google Tag Manager does not access this information. If recording has been deactivated on domain or cookie level, this setting will remain in place for all tracking tags implemented with Google Tag Manager.
For further information see: https://www.google.com/intl/de/tagmanager/faq.html.

15 Privacy Policy for the use of Google Fonts

The Google Fonts API is designed to limit the collection, storage, and use of end-user data to what is needed to serve fonts efficiently.

Use of Google Fonts is unauthenticated. No cookies are sent by website visitors to the Google Fonts API. Requests to the Google Fonts API are made to resource-specific domains, such as fonts.googleapis.com or fonts.gstatic.com, so that your requests for fonts are separate from and do not contain any credentials you send to google.com while using other Google services that are authenticated, such as Gmail.

In order to serve fonts quickly and efficiently with the fewest requests, responses are cached by the browser to minimize round-trips to our servers.

Requests for CSS assets are cached for 1 day. This allows us to update a stylesheet to point to a new version of a font file when it’s updated, and ensures that all websites using fonts hosted by the Google Fonts API will be using the most updated version of each font within 24 hours of each release.

The font files themselves are cached for one year, which cumulatively has the effect of making the entire web faster: When millions of websites all link to the same fonts, they are cached after visiting the first website and appear instantly on all other subsequently visited sites. We do sometimes update font files to reduce their file size, increase coverage of languages, and improve the quality of their design. The result is that website visitors send very few requests to Google: We only see 1 CSS request per font family, per day, per browser.

Google Fonts logs records of the CSS and the font file requests, and access to this data is kept secure. Aggregate usage numbers track how popular font families are, and are published on our analytics page. We use data from Google’s web crawler to detect which websites use Google fonts. This data is published and accessible in the Google Fonts BigQuery database. To learn more about the information Google collects and how it is used and secured, see Google’s Privacy Policy.

16 Rights of the data subject

16.1 Right of access by the data subject

The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information

(1) The purposes of the processing;

(2) The categories of personal data concerned;

(3) recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

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

(5) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

(6) the right to lodge a complaint with a supervisory authority;

(7) where the personal data are not collected from the data subject, any available information as to their source;

16.2 Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

16.3 Right to restriction of processing

The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

(1) 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;

(2) The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

(3) The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

(4) The data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informaed by the controller before the restriction of processing is lifted.

16.4 Right to erasure

The data subject have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

1. The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
2. The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
3. The data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
4. The personal data have been unlawfully processed;
5. The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
6. The personal data has been collected in relation to the offer of information society services referred to in Article 8(1).

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

1. For exercising the right of freedom of expression and information;
2. For compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of 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 area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
4. For archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
5. For the establishment, exercise or defence of legal claims.

16.5 Notification obligation regarding rectification or erasure of personal data or restriction of processing

The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.

16.6 Right to object

The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) (GDPR), including profiling based on those provisions.

16.7 Right to withdraw a consent

The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Prior to giving consent, the data subject shall be informed thereof. It shall be as easy to withdraw as to give consent.

16.8 Right to data portability

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

1) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and

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

In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to
Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

16.9 Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

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 Article 78.

17 Contact Information:

18 Data Protection Officer (DPO)

Stefan Voshage

+49 40-30 38 73 855

E-Mail: info@jas-consultants.com

19 Supervisory Authority:

Freie und Hansestadt Hamburg

Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit

Domain: datenschutz-hamburg.de

E-Mail: mailbox@datenschutz.hamburg.de

20 Sources:

• e-recht24.de
• https://dejure.org/gesetze/DSGVO
• https://dsgvo-gesetz.de
• https://www.datenschutz-hamburg.de/