Data protection policy
We appreciate your visit to our website svenja-thoes.de and your interest in our company.
It is extremely important to us that we protect your personal data, e.g. date of birth, name, telephone number, address etc.
The purpose of this data protection policy is to inform you about the processing of your personal data that we collect when you visit the website. Our data privacy practices are consistent with the statutory provisions of the EU General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (BDSG). The following data protection policy is used to fulfil the information obligations arising from the GDPR. You can find these in Articles 13 and 14 et seq. of the GDPR.
The responsible entity as defined in Art. 4 No. 7 GDPR is the entity that solely or jointly with others decides on the purposes and means of processing personal data.
With regard to our website the responsible entity is:
Svenja Thoes Triathlete
Provision of website and creation of log files
Whenever our website is called up, our system automatically records data and information about the device (e.g. computer, mobile phone, tablet etc.) involved in the call-up.
Which personal data is collected and to what extent is this processed?
(1) Information on the browser type and version used;
(2) The operating system of the device used for the call up;
(3) Host name of the accessing computer;
(4) The IP address of the call up device;
(5) Date and time of the access;
(6) Websites and resources (images, files, other page content) that were called up in our website;
(7) Websites from where the user’s system reached our website (referrer tracking);
(8) Notification of whether the call-up was successful;
(9) Data volume transferred
This data is stored in our system’s log files. This data is not stored alongside personal data of a specific user so individual page visitors are not identified.
Legal basis for processing personal data
Art. 6 Para. 1 lit. f GDPR (justified interest). Our justified interest is in achieving the purpose described below.
Purpose of data processing
The temporary (automated) storage of data is necessary for the website visit in order to enable the website to be provided. The storage and processing of personal data also take place to maintain the compatibility of our website for as many visitors as possible, to combat abuse and resolve defects. This requires logging the technical data of the computer calling up the site in order to respond as quickly as possible to depiction errors, attacks on our IT systems and/or functional errors on our website. The data is used on the one hand to optimise the website and to generally ensure the security of our IT systems.
The stated technical data is deleted as soon as it is no longer required in order to ensure the compatibility of the website for all visitors, at the latest however 3 months after calling up our website.
Objection and deletion option
Pursuant to Art. 21 GDPR you can object to and pursuant to Art. 17 GDPR request the deletion of data at any time. You will find the rights to which you are entitled and how to assert them in the lower part of this data protection policy.
Special functions of our website
Our website offers you various different functions during which personal data will be collected, processed and saved. Below we describe what happens to this data:
- Which personal data is collected and to what extent is this processed? The data that you enter in the entry mask of our contact forms.
- Legal basis for processing personal data Art. 6 Para. 1 lit. a GDPR (consent through a clear confirming action or behaviour)
- Purpose of data processing The data collected via our contact form or forms is used by us only for the purpose of specific contact requests arising from the contact form. Please note that we may also send emails to the stated address to fulfil your contact request. This has the purpose of you receiving a confirmation from us that your query was correctly forwarded to us. We are however not obligated to send this confirmation email and this is only done to provide notification to you.
- Storage period Provided that there is no legal retention period, any data collected will be immediately deleted after your request has been processed.
- Objection and deletion option The objection and resolution options depend on the general provisions shown below on the data protection law objection and deletion rights in this data protection policy.
- Need to state personal data The use of the contact forms is voluntary and not required by contract or law. You are not obligated to make contact with us via the form but rather can also use the other contact options stated on our page. If you want to use our contact form you must complete all of the fields that are marked compulsory. If you do not complete the information required on the contact form you either cannot send the request or we can unfortunately not process your request.
Integration of external web services and processing data outside the EU
On our website we use active content from external suppliers, so-called web services. When our internet site is accessed, these external providers may receive personal information regarding your visit to our website. It is possible that this data will be processed outside of the EU. You can prevent this by installing a corresponding browser plug-in or deactivate the execution of scripts in your browser. This may inhibit some of the functions on the internet sites which you visit.
We use the following external web services:
- Social plug-in – “Instagram”
- Which personal data is collected and to what extent is this processed? We have integrated a social plug-in on our website for the “Instagram” social network which is operated by Facebook Ireland Limited, 4 Grand Canal Square, 2 Dublin, Ireland, E-Mail: firstname.lastname@example.org, Website: http://facebook.com/ (“Instagram”). If you call up a page that contains such a plug-in, your browser automatically creates a background connection to the Instagram servers. The content of the Instagram plug-in is transmitted directly to your browser and is only incorporated in our page. Through this integration, Instagram receives information that your browser has loaded a specific page on our website. This also applies if you have no Instagram profile or are not currently logged into Instagram. This information (including your IP address) is transferred by your browser directly to an Instagram server in Ireland and stored there. If you are logged into Instagram, Instagram can assign the visit to our website to your Instagram profile. If you interact with the plug-in, e.g. press the “Like” button or make a comment, the relevant information is also transferred directly to an Instagram server and is saved there. The information is also published on your Instagram profile and displayed to your Instagram contacts that you have released for this.
- Legal basis for processing personal data Art. 6 Para. 1 lit. a GDPR (if you have registered for “Instagram”) and Art. 6 Para. 1 lit. f GDPR (if you have not registered for Instagram). If the processing takes place as per Art. 6 Para. 1 S. 1 lit. f GDPR, the justified interest of the page operator is to enable interaction by the users with the contents of the page operator on Instagram.
- Purpose of data processing The primary purpose of data collection is in offering a networked option for social interaction with Instagram and thus designing our website to be interactive. The scope of the data collection, the ongoing processing and use of the data by Instagram as well as your rights and setting options related to this to protect your private sphere are shown in the Instagram data protection information: https://www.facebook.com/about/privacy
- Storage period Instagram will store the data required to provide the web services for as long as it is necessary. If the data is subject to statutory storage obligations, it is deleted after the end of the storage obligation.
- Objection and deletion option If you do not want the Instagram social plug-in to be implemented, you can block the execution by installing an appropriate add-on or script blocker. If you do not wish Instagram to assign the data on our website to your Instagram profile, you must log out of Instagram before visiting our website. The other objection and resolution options also depend on the general provisions shown below in this data protection policy relating to the data protection law objection right and deletion claim.
Information on using cookies
Scope of processing personal data
Legal basis for processing personal data
Art. 6 Para. 1 lit. f GDPR (justified interest) or Art. 6 Para. 1 lit. a or Art. 9 Para. 2 lit. a GDPR (consent).
The relevant legal basis is shown in the cookie table below.
In general it is the case that for cookies used due to justified interest, our justified interest is in the functionality of our website and ensuring the integrated services (technically necessary cookies). It may also be the case that the cookies increase the user-friendliness and enable more individual addressing. Here we have ensured a balance between our and your interest.
With the aid of cookie technology we can only identify, analyse and track individual website visitors if they consent to the use of the cookie under Art. 6 Para. 1 lit. a GDPR.
Purpose of data processing
The cookies are set by our website or the external web services in order to maintain the full functionality of our website, improve user-friendliness or track the purpose stated for your consent. The cookie technology also enables us to recognise individual visitors using pseudonyms, e.g. an individual or random ID, so that we can offer individual services. The details are described in the following table.
The cookies listed below are stored in your browser until they are deleted or, in the event of a cookie session until the session has ended. The details are listed in the following table:
|Cookie name||Server||Supplier||Purpose||Legal basis||Storage term||Type|
|borlabs-cookie||test.svenja-thoes.fbo.de||Website operator||This cookie enables us to store individual comfort settings that you have selected for your current and future visits to the website.||Declaration of consent||approx. 12 months||Configuration|
Objection option, revocation of consent and deletion
You can set your browser as you wish such that it generally prevents cookies from being set. You can decide on accepting cookies on a case by case basis or accept all cookies. Cookies may be used for different purposes, e.g. to detect that your access device already had a connection to our website (permanent cookies) or to save the most recently viewed offers (session cookies). If you have explicitly given your consent to process your personal data, you can revoke this consent at any time. Please note that the legality of the processing undertaken based on consent until revocation is not affected by this.
Data security & protection, email communication
Your personal data is protected using technical and organisational measures so that the collection, storage and processing is not accessible to third parties. Where unencrypted communication is made via email, we cannot guarantee complete data security on the transmission route to our IT systems. We therefore recommend that all information with a high confidentiality requirement is sent by encrypted communication.
Automatic email archiving
- Scope of processing personal data We explicitly inform you that our mail system has an automated archiving process. All incoming and outgoing emails are stored here digitally to ensure proper auditing.
- Legal basis for processing personal data Art. 6 Para. 1 lit. c GDPR (legal obligation). The legal obligation is in complying with tax and commercial law regulations (e.g. Sections 146, 147 of the German Tax Code – AO; Sections 238, 257 of the German Commercial Code – HGB).
- Purpose of data processing The purpose of archiving is to comply with tax law (e.g. Sections 146, 147 AO – obligation to store emails relevant for tax law) and commercial law (e.g. Sections 238, 257 HGB – obligation to archive business correspondence).
- Storage period Our mail communication is stored until the end of the tax and commercial law storage obligations. The storage duration may be up to 10 years.
- Objection and deletion option Pursuant to Art. 21 GDPR you can object to and pursuant to Art. 17 GDPR request the deletion of data at any time. You will find the rights to which you are entitled and how to assert them in the lower part of this data protection policy.
- Handling job application documents We also inform you that we only handle job application documents in the PDF file format. Zipped files (WinZip, WinRAR, 7Zip, etc.) are filtered out by our security systems and not delivered. Applications in Word and other formats are neither considered nor delivered. Please note that application documents transmitted by email without encryption may be opened by third parties before they arrive at our IT systems. We assume that we may answer application emails received without encryption in the same manner. If you do not wish this, please state this in your application email.
Right to information and correction requests – deletion & restriction of data – revocation of consent – objection right
Right to information
You have the right to request confirmation from us on whether we process your personal data. If this is the case, you have the right to receive notification of the information stated in Section 15 Para. 1 GDPR if this does not affect the rights and freedoms of other people (see Art. 15 Para. 4 GDPR). We are happy to provide you with a copy of the data.
Right to correction
Under Art. 16 GDPR you have the right to correct any incorrectly stored personal data (such as address or name) at any time. You can also request that the data we have stored is supplemented. Any modification takes place without delay.
Right to deletion
Under Art. 17 Para. 1 GDPR you have the right to delete the personal data we have collected if
- Either the data is no longer needed;
- The legal basis for processing has lapsed without replacement as a result of you revoking your consent;
- You have objected to the processing and there are no justified reasons for the processing;
- Your data was processed illegally;
- A legal obligation requires this or collection has taken place under Art. 8 Para. 1 GDPR.
The right under Art. 17 Para. 3 GDPR does not exist if
- the processing is required to exercise the right of one’s freedom to express an opinion and to provide information;
- Your data was collected based on a legal obligation;
- The processing is required for reasons in the public interest;
- The data is required to assert, execute or defend legal claims.
Right to restriction on processing
You have the right to request a restriction on the processing of your personal data under Art. 18 Para. 1 GDPR.
This is the case if
- You dispute the correctness of the personal data;
- The processing is illegal and you do not agree to deletion;
- The data is no longer required for the processing purpose but the collected data is used to assert, execute or defend legal claims;
- An objection has been raised against the processing under Art. 21 Para. 1 GDPR and it is not clear which interests have priority.
If you have given your explicit consent to processing your personal data (Art. 6 Para. 1 lit. a GDPR or Art. 9 Para. 2 lit. a GDPR) you can revoke this at any time. Please note that the legality of the processing based on consent is not affected by this until revocation of the processing.
Right to objection
Under Art. 21 GDPR you have the right to object at any time to the processing of your personal data that was collected due to Art. 6 Para. 1 lit. f (justified interest). You only have the right if there are special circumstances that oppose storage and processing.
How do you assert your rights?
You can assert your rights at any time by contacting us using the data shown below:
Svenja Thoes Triathlete
Right to data transfer
Under Art. 20 GDPR you have a right to transfer your personal data. We will provide the data in structured, common and machine-readable format. We can send the data either to yourself or a responsible party that you have stated to us.
On request we will provide the following data to you under Art. 20 Para. 1 GDPR:
- Data that was collected due to explicit consent under Art. 6 Para. 1 lit. a GDPR or Art. 9 Para. 2 lit. a GDPR;
- Data that we have received as part of contracts that exist with you under Art. 6 Para. 1 lit. b GDPR;
- Data that we have processed as part of an automated process.
We will undertake the transfer of personal data directly to a responsible party that you have requested if this is technically feasible. Please note that cannot transfer data that affects the rights and freedoms of other people under Art. 20 Para. 4 GDPR.
Right to complain to a supervisory authority under Art. 77 Para. 1 GDPR
If you suspect that we have processed your data illegally on our website, you can of course at any time arrange clarification of the issue in the courts. You are also entitled to use any other legal remedy. Notwithstanding, you have the option under Art. 77 Para. 1 GDPR to contact a supervisory authority. The complaint right under Art. 77 GDPR is available to you in the EU member state of your place of residence, work and/or the place of apparent infringement, i.e. you can select the supervisory authority to contact at the places stated above. The supervisory authority to whom a complaint was submitted will inform you about the status and results of your entry, including the option of court-based legal assistance under Art. 78 GDPR.
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