Privacy Policy

This privacy policy informs you about the nature, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and the associated websites, functions and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”). With regard to the terminology used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Controller

Assistant Directors Union – ADU e.V.
Heinrich-Roller-Str. 23
10405 Berlin
Legal Notice: https://www.ad-union.org/impressum

Types of Data Processed:

• Inventory data (e.g., names, addresses)
• Contact data (e.g., email addresses, 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 offering (hereinafter collectively also referred to as “users”).

Purpose of Processing

• Provision of the online offering, its functions and content
• Responding to contact inquiries and communicating with users
• Security measures
• Reach measurement/marketing

Terminology Used

“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., cookie) or to 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 broad 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 is not attributed to an identified or identifiable natural person.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

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

Applicable Legal Bases

In accordance with Article 13 GDPR, we inform you of the legal bases of our data processing. Unless the legal basis is specifically stated in this privacy policy, the following applies: the legal basis for obtaining consent is Article 6(1)(a) and Article 7 GDPR; the legal basis for processing for the performance of our services and implementation of contractual measures as well as responding to inquiries is Article 6(1)(b) GDPR; the legal basis for processing to fulfill our legal obligations is Article 6(1)(c) GDPR; and the legal basis for processing to safeguard our legitimate interests is Article 6(1)(f) GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.

Security Measures

In accordance with Article 32 GDPR, taking into account the state of the art, implementation costs, and the nature, scope, circumstances and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access concerning them, input, disclosure, safeguarding availability and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, deletion of data, and response to data threats. In addition, we take the protection of personal data into account already during the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default settings (Article 25 GDPR).

Cooperation with Processors and Third Parties

If, as part of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this is done only on the basis of legal permission (e.g., if a transfer of data to third parties, such as payment service providers, is necessary for contract performance pursuant to Article 6(1)(b) GDPR), if you have consented, if 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 to process data on the basis of a so-called “data processing agreement”, this is done on the basis of Article 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 is done only if it is necessary for the fulfillment of our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only where the special requirements of Articles 44 et seq. GDPR are met. This means, for example, that the processing is carried out on the basis of special safeguards, such as an officially recognized determination of a level of data protection corresponding to that of the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognized specific contractual obligations (so-called “Standard Contractual Clauses”).

Rights of Data Subjects

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

In accordance with Article 16 GDPR, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.

In accordance with Article 17 GDPR, you have the right to request that the data concerned be deleted without delay, or alternatively, in accordance with Article 18 GDPR, to request a restriction of the processing of the data.

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

Furthermore, pursuant to Article 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority.

Right of Withdrawal

You have the right to withdraw consents granted pursuant to Article 7(3) GDPR with effect for the future.

Right to Object

You may object at any time to the future processing of data concerning you in accordance with Article 21 GDPR. In particular, the objection may be made against processing for direct marketing purposes.

Cookies and Right to Object to Direct Advertising

“Cookies” are small files that are stored on users’ computers. Different types of information can be stored within cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or even after their visit within an online offering. Temporary cookies, also known as “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offering and closes their browser. Such a cookie may, for example, store the contents of a shopping cart in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be stored when users visit again after several days. Likewise, such a cookie may store users’ interests, which are used for reach measurement or marketing purposes. “Third-party cookies” are cookies offered by providers other than the controller operating the online offering (otherwise, if they are only the controller’s cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies and provide information about this within the framework of 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. Stored cookies can be deleted in the browser’s system settings. Excluding cookies may lead to functional restrictions of this online offering.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by disabling them in the browser settings. Please note that in this case, not all functions of this online offering may be available.

Deletion of Data

The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 GDPR. Unless expressly stated otherwise within this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and no statutory retention obligations prevent deletion. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

According to legal requirements in Germany, retention takes place in particular for 10 years pursuant to Sections 147(1) AO, 257(1) Nos. 1 and 4, (4) HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years pursuant to Section 257(1) Nos. 2 and 3, (4) HGB (commercial correspondence).

According to legal requirements in Austria, retention takes place in particular for 7 years pursuant to Section 132(1) BAO (accounting documents, receipts/invoices, accounts, vouchers, business papers, statements of income and expenses, etc.), for 22 years in connection with real estate, and for 10 years for documents related to electronically supplied services, telecommunications, radio and television services provided to non-taxable persons in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

Registration Function

Users may create a user account. As part of the registration, the required mandatory information is communicated to users and processed on the basis of Article 6(1)(b) GDPR for the purpose of providing the user account. The processed data includes, in particular, the login information (name, password and an email address). The data entered during registration is used for the purposes of using the user account and its purpose.

Users may be informed by email about information relevant to their user account, such as technical changes. If users have terminated their user account, their data relating to the user account will be deleted, subject to any statutory retention obligation. It is the responsibility of users to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all data stored during the term of the contract.

As part of the use of our registration and login functions and the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as the users’ interest in protection against misuse and other unauthorized use. As a rule, this data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so pursuant to Article 6(1)(c) GDPR. The IP addresses are anonymized or deleted after no later than 7 days.

Newsletter

With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures, and your rights to object. By subscribing to our newsletter, you agree to receive it and to the procedures described.

Newsletter content: We send newsletters, emails and other electronic notifications containing promotional information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the content of the newsletter is specifically described when registering for the newsletter, this description is decisive for the users’ consent. Otherwise, our newsletters contain information about our services and us.

Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with someone else’s email address. Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation, as well as the IP address. Likewise, changes to your data stored by the mailing service provider are logged.

Registration data: To register for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name for the purpose of addressing you personally in the newsletter.

The dispatch of the newsletter and the associated performance measurement are based on the consent of the recipients pursuant to Article 6(1)(a), Article 7 GDPR in conjunction with Section 7(2) No. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Article 6(1)(f) GDPR in conjunction with Section 7(3) UWG.

The logging of the registration procedure is based on our legitimate interests pursuant to Article 6(1)(f) GDPR. Our interest is directed toward the use of a user-friendly and secure newsletter system that serves both our business interests and the expectations of users, and also allows us to prove consents.

Termination/Withdrawal – You may unsubscribe from our newsletter at any time, i.e. revoke your consent. You will find a link to unsubscribe from the newsletter at the end of each newsletter. We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time.

Created with Datenschutz-Generator.de by attorney Dr. Thomas Schwenke