Privacy Policy



1. An overview of data protection



General Information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit our website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.



Data recording on our website

Who is the responsible party for the recording of data on this website?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information Required by Law” on this website.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Our IT systems automatically record other data when you visit our website. This data comprises primarily technical information (e.g. web browser, operating system or time the site was accessed). This information is recorded automatically when you access our website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyse your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified, blocked or eradicated. Please do not hesitate to contact us at any time under the address disclosed in section “Information Required by Law” on this website if you have questions about this or any other data protection related issues. You also have the right to log a complaint with the competent supervising agency.

Moreover, under certain circumstances, you have the right to demand the restriction of the processing of your personal data. For details, please consult the Data Protection Declaration under section “Right to Restriction of Data Processing.”



2. Hosting



We host the content of our website with the following provider:



Strato


The provider is Strato AG, Otto-Ostrowski-Straße 7, 10249 Berlin (hereinafter referred to as “Strato”). When you visit our website, Strato collects various log files including your IP addresses

Further information can be found in Strato's privacy policy: https://www.strato.de/datenschutz/.

The use of Strato is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in displaying our website as reliably as possible. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.



3. General information and mandatory information



Data protection


The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e. through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third party access.



Information about the responsible party
(referred to as the “Controller” in the GDPR)


The data processing controller on this website is:

ABCircular GmbH
Sonnenallee 224a
12059 Berlin

Telefon: +49 (0) 30 673809 - 25
E-Mail: info@ab-circular.de



The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, e-mail addresses, etc.).



Duration of data storage


Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a justified 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); in the latter case, the deletion will take place after these reasons no longer apply.



General information on the legal basis for
data processing on this website


If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, insofar as special categories of data are processed in accordance with Art. 9 para. 1 GDPR. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or access to information in your end device (e.g. via device fingerprinting), the data processing is also carried out on the basis of § 25 para. 1 TTDSG. Consent can be revoked at any time. If your data is required for the fulfillment of the contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.



Revocation of your consent to the processing of data


A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. To do so, all you are required to do is sent us an informal notification via e-mail. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.



Right to object to the collection of data in special cases;
Right to object to direct advertising (Art. 21 GDPR)


In the event that data are processed on the basis of Art. 6 Sect. 1 lit. e or f GDPR, you have the right to at any time object to the processing of your personal data based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. To determine the legal basis, on which any processing of data is based, please consult this Data Protection Declaration. If you log an objection, we will no longer process your affected personal data, unless we are in a position to present compelling protection worthy grounds for the processing of your data, that outweigh your interests, rights and freedoms or if the purpose of the processing is the claiming, exercising or defence of legal entitlements (objection pursuant to Art. 21 Sect. 1 GDPR).

If your personal data is being processed in order to engage in direct advertising, you have the right to at any time object to the processing of your affected personal data for the purposes of such advertising. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes (objection pursuant to Art. 21 Sect. 2 GDPR).



Right to log a complaint with the competent supervisory agency


In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.



Right to data portability


You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.



Information about blockage, rectification and eradication of data


Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified, blocked or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time at the address provided in section “Information Required by Law.”



Right to demand processing restrictions


You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time at the address provided in section “Information Required by Law.” The right to demand restriction of processing applies in the following cases:

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.



SSL and/or TLS encryption


For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption programme. You can recognise an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.



Objection to advertising e-mails /h2>

We hereby object to the use of contact data published as part of our obligation to provide a legal notice for the purpose of sending unsolicited advertising and information material. The operators of this website expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.



4. Recording of data on our website



Cookies


In some instances, our website and its pages use so-called cookies. Cookies do not cause any damage to your computer and do not contain viruses. The purpose of cookies is to make our website more user friendly, effective and more secure. Cookies are small text files that are placed on your computer and stored by your browser. Most of the cookies we use are so-called “session cookies.” They are automatically deleted after your leave our site. Other cookies will remain archived on your device until you delete them. These cookies enable us to recognise your browser the next time you visit our website.

You can adjust the settings of your browser to make sure that you are notified every time cookies are placed and to enable you to accept cookies only in specific cases or to exclude the acceptance of cookies for specific situations or in general and to activate the automatic deletion of cookies when you close your browser. If you deactivate cookies, the functions of this website may be limited.

Cookies that are required for the performance of the electronic communications transaction or to provide certain functions you want to use (e.g. the shopping cart function), are stored on the basis of Art. 6 Sect. 1 lit. f GDPR. The website operator has a legitimate interest in storing cookies to ensure the technically error free and optimised provision of the operator’s services. If other cookies (e.g. cookies for the analysis of your browsing patterns) should be stored, they are addressed separately in this Data Protection Declaration.



Server-Log-Files




The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

This data is not merged with other data sources.
This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.



Request by e-mail or telephone


If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases, the processing is based on your consent (Article 6 (1) a GDPR) and/or on our legitimate interests (Article 6 (1) (f) GDPR), since we have a legitimate interest in the effective processing of requests addressed to us.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.



5. Newsletter



If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.
The data entered in the newsletter registration form is processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You can revoke your consent to the storage of the data, the e-mail address and its use for sending the newsletter at any time, for example via the ‘unsubscribe’ link in the newsletter. The legality of the data processing operations that have already taken place remains unaffected by the cancellation.
The data you provide us with for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to exist. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR.
Data stored by us for other purposes remains unaffected by this.
After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist if this is necessary to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.



6. Plugins and Tools



Font Awesome

This website uses so-called Web Fonts provided by Font Awesome to ensure the uniform use of fonts on this site.Font Awesome is locally installed so that a connection to Font Awesome’s servers will not be established in conjunction with this application.

Further information can be found in Font Awesome's privacy policy: https://fontawesome.com/privacy



Google Web Fonts

This website uses so-called Web Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google’s servers will not be established in conjunction with this application.



7. Data protection provisions about the application
and use of LinkedIn

The controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world. The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, UNITED STATES. For privacy matters outside of the UNITED STATES LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a LinkedIn component (LinkedIn plug-in) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn. Further information about the LinkedIn plug-in may be accessed under https://developer.linkedin.com/plugins. During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject. If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-page of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data. LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our website is made. LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from e-mail messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn is available under https://www.linkedin.com/legal/privacy-policy. The LinkedIn Cookie Policy is available under https://www.linkedin.com/legal/cookie-policy.



8. Privacy policy for the use of Microsoft Forms



In the following, we would like to inform you about the processing of personal data in connection with the use of "Microsoft Forms". The global provision of the form is carried out by Microsoft Corporation.

Depending on the purpose of Microsoft Forms, we may use the personal data collected with Microsoft Forms for the following purposes:

Details of the person responsible

The controller within the meaning of data protection laws, in particular the EU General Data Protection Regulation (GDPR), is the company named at the beginning of the survey/form.

ABCircular GmbH
Sonnenallee 224a
12059 Berlin
Tel.: +49 (0) 30 673809 - 25
Mail: info@ab-circular.de


Your rights as a data subject

You can exercise the following rights at any time using the contact details provided:


If you have given us your consent, you can revoke it at any time with effect for the future. You can lodge a complaint with a supervisory authority at any time, e.g. with the competent supervisory authority in the federal state of your place of residence or with the authority responsible for us as the controller.

A list of supervisory authorities (for the non-public sector) with addresses can be found here: https://www.bfdi.bund.de/DE/Service/Anschriften/anschriften_table.html


Information about your right to object
in accordance with Art. 21 GDPR

Individual right of objection

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (f) of Article 6(1) GDPR (data processing on the basis of a balancing of interests); this also applies to profiling based on this provision within the meaning of Article 4(4) GDPR.
If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

Recipient of an objection

The objection can be sent informally with the subject "Objection", stating your name, address or other identifying features, to the contact information given above.


Microsoft Forms

Type and purpose of processing

When you use Microsoft Forms, personal data about you is processed. Please note that this privacy notice only informs you about the processing of your personal data by us if you use Microsoft Forms together with us. If you require information about the processing by Microsoft, we ask you to view the corresponding declaration under the following link:
https://privacy.microsoft.com/en-us/privacystatement

The following personal data may be subject to processing:

If you take part in an anonymous survey, your answer will not contain any personal data. Automated decision-making within the meaning of Art. 22 GDPR is not used.

Legal basis

Insofar as consent is given by participating in a survey, the legal basis is Art. 6 (1) lit. a) GDPR (consent of the data subject). Consent given can be revoked at any time with effect for the future. Withdrawal or non-granting of consent does not result in any disadvantages.
Insofar as personal data of employees of ABCircular GmbH or its affiliated companies are processed, Art. 6 para. 1 lit. b) GDPR is the legal basis for data processing. This legal basis for data processing also applies in the context of the establishment, execution or termination of a contractual relationship with customers.
If, in connection with the use of "Microsoft Forms", personal data is not required for the establishment, execution or termination of the contractual relationship, but is nevertheless an elementary component of the use of "Microsoft Forms", Art. 6 (1) f) GDPR is the legal basis for data processing. In these cases, our legitimate interest lies in effectively ensuring customer satisfaction and product improvement.
If survey responses contain special categories of data within the meaning of Art. 9 GDPR, e.g. data on food allergies, which are queried for the purpose of event planning, the legal basis is Art. 9 (2) lit. a) or Art. 6 (1) lit. a) GDPR (consent of the data subject).

Recipients

Recipients of the data are only the respective responsible survey creators and a limited number of employees. Other recipients of the data may be technical service providers who are involved in conducting the surveys, planning the event, sending out invitations or providing the IT infrastructure. "Microsoft Forms" is a service of the Microsoft Corporation. Information on data protection can be found here.

Third country transfer

Data processing outside the European Union (EU) does not generally take place, as we have restricted data storage locations to data centres in the European Union. However, we cannot rule out the possibility that data may be routed via internet servers located outside the EU. This may be the case if users are located in a third country. However, the data is encrypted during transport via the Internet and thus protected from access by third parties. from unauthorized access by third parties.

Microsoft Corp. is based in the USA. Processing can therefore also take place outside the EU, namely in the USA. If there is a transfer to a third country, there are guarantees in the form of standard contractual clauses of the EU Commission.

Storage period

In principle, we delete personal data if there is no need for further storage. A requirement may exist in particular if the data is still required for the fulfilment of contractual services in order to check and grant or defend against warranty and guarantee claims. In the case of statutory retention obligations, deletion will only be considered after the respective obligation has expired. If your data is processed on the basis of your consent, we will delete your data after receiving a cancellation of your consent.

Provision required or necessary

Without the personal data, we are not able to carry out the consultation, registration or survey with you.

Objection

Please read the information on your right to object above.

9. Informationen zum Datenschutz zur Nutzung von
Microsoft Teams



Information on the processing of personal data

In this data protection declaration, we inform about the processing of your personal data in our online meetings using the video conference solution Microsoft Teams.

Accountability

Accountable pursuant to Article 4(7) of the EU Data Protection Regulation (GDPR) is:
ABCircular GmbH
Sonnenallee 224a
12059 Berlin
Tel.: +49 (0) 30 673809 - 25
Mail: info@ab-circular.de

Kinds of personal data we process

As part of our online meetings using Microsoft Teams, we process the following personal data:

Microsoft Teams Video Conference and Microsoft Office 365

The video conferencing function of Microsoft Teams allows you to participate in our online events via video / audio. We use the Team Meetings function of Microsoft Teams. In Team Meetings, audio input and video recordings are prevented by our Microsoft Teams settings. In general, events are not recorded.
In exceptional cases, a recording may take place under the following conditions:


We carry out the data processing in accordance with Article 6(1)(f) GDPR on the basis of a legitimate interest. Our legitimate interest in data processing is: organize online conferences to inform participants about relevant topics and our business activities.
Microsoft Teams is part of Microsoft Office 365. Microsoft Teams is a productivity, collaboration and exchange platform for individual users, as well as teams, communities and networks; it is used across our group of companies. This includes a video conferencing function.
Microsoft Office 365 is a software of

Microsoft Ireland Operations Limited
One Microsoft Place
South County Business Park
Leopardstown
Dublin 18
D18 P521
Ireland

Microsoft Teams is part of the Cloud application Office 365, for which a user account must be created.

The Office 365 data processing is performed on servers in data centers in the European Union, Ireland and the Netherlands. We have concluded a data protection agreement with Microsoft in accordance with Art. 28 GDPR. Accordingly, we have agreed on extensive technical and organizational measures for Office 365 with Microsoft, which correspond to the current state of the art in IT security, for example regarding access authorization and end-to-end encryption concepts for data lines, databases and servers.
We also implemented the "Customer Log Box" functionality in Office 365. This means that Microsoft has no access to the data in Office 365.
For remote maintenance purposes, Microsoft may request access. This access will then be checked by us on a case-by-case basis and granted upon approval. In this case, such access may also be granted for Microsoft affiliates outside the European Union. Only in this case of approved access from outside the European Union, we have concluded EU standard contractual clauses with Microsoft. In order to guarantee an adequate level of data protection in the transfer of personal data to a third country such as the USA in this particular case, we have implemented additional measures in the form of state-of-the art technical and organizational measures such as access authorization and encryption concepts for data lines, databases and servers, as described above.
Microsoft reserves the right to process customer data for its own legitimate business purposes. We have no influence on these data processing operations of Microsoft. To the extent that Microsoft Teams processes personal data in connection with legitimate business purposes, Microsoft is an independent controller for these data processing activities and as such is responsible for compliance with all applicable data protection regulations. If you need information about Microsoft processing, please consult the Microsoft privacy statement.

Transfer

As shown above, we use Microsoft for Office 365 as a processor acc. to Article 28 GDPR.

Data storage

The data is stored in the Microsoft Cloud and retrieved from there by the project team. Unless there is an operational necessity, legal obligation or a special operational interest in permanent storage, all data will be deleted within one year after the purpose no longer applies.


Your rights

You can ask for information about the personal data we store. If you have provided personal data on the basis of a contract or consent, you are entitled to receive such data in a standard, machine-readable format.
In justified cases, you may also request deletion, correction or limitation of the processing of your data. If your personal data is transferred to a country outside the EU that does not provide adequate protection, you can request a copy of the contract that provides for adequate protection of personal data. If you have given your consent for the use of your personal data, you can revoke your consent at any time with effect for the future.
If we use your personal data on the basis of a balance of interests, you may object to the use of your data. In this case, we will no longer use your data, unless our interests are outweighed.


Contact

f you have any questions about our use of personal data or this privacy statement, or wish to exercise your rights, you may contact us at any time:
ABCircular GmbH
Sonnenallee 224a
12059 Berlin
Tel.: +49 (0) 30 673809 - 25
Mail: info@ab-circular.de

Actuality of the privacy policy:

15.09.2024