In accordance with the legal requirements of data protection law (in particular in accordance with BDSG n.F. and the European Data Protection Regulation ‘DS-GVO’), we inform you below about the nature, scope and purpose of the processing of personal data by our company. This privacy policy also applies to our websites and social media profiles. Regarding the definition of terms such as “personal data” or “processing”, we refer to Art. 4 GDPR.

Name and contact details of the person(s) responsible
Our responsible person (hereinafter “responsible person”) within the meaning of Art. 4 No. 7 DS-GVO is:

Werner Klein Financial Consulting
Bärendellstraße 31
66862 Kindsbach, Germany
Owner: Werner Klein
E-mail address: finanzberatung-klein@web.de

Types of data, purposes of processing and categories of data subjects

In the following, we inform you about the type, scope and purpose of the collection, processing and use of personal data.

1. types of data we process
Contact data (telephone number, e-mail, fax, etc.), payment data (bank details, account details, payment history, etc.), contract data (subject of the contract, term, etc.), communication data (IP address, etc.),

2. purposes of processing according to Art. 13 para. 1 c) GDPR
Processing of contracts, evidence purposes / preservation of evidence, fulfillment of contractual obligations, contact in the event of legal complaints by third parties, fulfillment of legal storage obligations, avoidance of SPAM and abuse, processing of an application process, customer service and customer care, handling contact requests, security measures,

3. categories of data subjects according to Art. 13 para. 1 e) GDPR
Visitors/users of the website, customers, interested parties, applicants,

The data subjects are collectively referred to as “Users”.

Legal basis for the processing of personal data

Below we inform you about the legal basis for the processing of personal data:

1. If we have obtained your consent for the processing of personal data, Art. 6 para. 1 p. 1 lit. a) DS-GVO Legal basis.
2. If the processing is necessary for the performance of a contract or for the implementation of pre-contractual measures taken at your request, Art. 6 para. 1 p. 1 lit. b) DS-GVO Legal basis.
3. If the processing is necessary for the fulfillment of a legal obligation to which we are subject (e.g. legal retention obligations), Art. 6 para. 1 p. 1 lit. c) DS-GVO Legal basis.
4. If the processing is necessary to protect the vital interests of the data subject or another natural person, Art. 6 para. 1 p. 1 lit. d) DS-GVO Legal basis.
5. If the processing is necessary to protect our legitimate interests or the legitimate interests of a third party and your interests or fundamental rights and freedoms are not overridden in this respect, Art. 6 para. 1 p. 1 lit. f) DS-GVO Legal basis.

Disclosure of personal data to third parties and processors

As a matter of principle, we do not pass on any data to third parties without your consent. If this should nevertheless be the case, then the transfer will take place on the basis of the legal grounds mentioned above, e.g. in the case of the transfer of data to online payment providers for the fulfillment of a contract or due to a court order or because of a legal obligation to hand over the data for the purpose of criminal prosecution, to avert danger or to enforce intellectual property rights.
We also use contract processors (external service providers, e.g. for web hosting of our websites and databases) to process your data. If data is disclosed to processors as part of a commissioned processing agreement, this is always done in accordance with Art. 28 DS-GVO. We select our processors carefully, monitor them regularly and have been granted the right to issue instructions regarding the data. In addition, the processors must have taken appropriate technical and organizational measures and comply with the data protection provisions pursuant to. Comply with BDSG n.F. and DS-GVO

Data transfer to third countries

The adoption of the European General Data Protection Regulation (GDPR) created a uniform basis for data protection in Europe. Your data will therefore be processed mainly by companies to which the GDPR applies. However, if the processing is carried out by services of third parties outside the European Union or the European Economic Area, these must meet the special requirements of Art. 44 et seq. GDPR. This means that processing takes place on the basis of special guarantees, such as the officially recognized determination by the EU Commission of a level of data protection corresponding to the EU or the observance of officially recognized special contractual obligations, the so-called “standard contractual clauses”.
Insofar as we, due to the ineffectiveness of the so-called “Privacy Shield”, pursuant to Art. 49 para. 1 p. 1 lit. a) GDPR, we point out the risk of secret access by US authorities and the use of the data for monitoring purposes, possibly without any legal remedy for EU citizens.

Deletion of data and storage period

Unless expressly stated in this privacy policy, your personal data will be deleted or blocked as soon as you revoke your consent to the processing or the purpose for the storage no longer applies or the data is no longer required for the purpose, unless their continued storage is necessary for evidentiary purposes or is contrary to statutory retention obligations. This includes, for example, commercial law obligations to retain business letters in accordance with Section 257 para. 1 HGB (6 years) as well as tax law retention obligations according to § 147 para. 1 AO of supporting documents (10 years). If the prescribed retention period expires, your data will be blocked or deleted, unless the storage is still necessary for the conclusion or fulfillment of a contract.

Existence of automated decision making

We do not use automated decision making or profiling.

Provision of our website and creation of log files

1. If you only use our website for informational purposes (i.e. no registration and no other transmission of information), we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data:
   • IP-Adress
   • Internet service provider of the user;
   • Date and time of retrieval;
   • Browser type;
   • Language and browser version;
   • Content of the retrieval;
   • Time zone;
   • Access Status/HTTP Status Code;
   • Amount of data;
   • Websites from which the request is coming;
   • Operating system.
   A storage of this data together with other personal data of yours does not take place.
2. This data serves the purpose of user-friendly, functional and secure delivery of our website to you with functions and content as well as its optimization and statistical evaluation.
3. The legal basis for this is our legitimate interest in data processing, which also lies in the above purposes, in accordance with Art. 6 Para. 1 S.1 lit. f) GDPR.
4. For security reasons, we store this data in server log files for a storage period of 70 days. After this period, they are automatically deleted, unless we need to keep them for evidence purposes in the event of attacks on the server infrastructure or other legal violations.

Cookies

1. We use so-called cookies when you visit our website. Cookies are small text files that your Internet browser places and stores on your computer. When you visit our website again, these cookies provide information to automatically recognize you. Cookies also include the so-called “user IDs”, where user details are stored by means of pseudonymized profiles. When you access our website, we will inform you by means of a reference to our data protection declaration about the use of cookies for the aforementioned purposes and how you can object to this or prevent their storage (“opt-out”).A distinction is made between the following types of cookies: • Necessary, essential cookies: Essential cookies are cookies that are absolutely necessary for the operation of the website in order to save certain functions of the website such as logins, shopping cart or user entries, e.g. regarding the language of the website.- Session cookies: Session cookies are required to recognize multiple use of an offer by the same user (e.g. when you have logged in to determine your login status). When you return to our site, these cookies provide information to automatically recognize you. The information obtained in this way is used to optimize our offers and to provide you with easier access to our site. If you close the browser or log out, the session cookies will be deleted.• Persistente Cookies: These cookies remain stored even after the browser is closed. They are used for login storage, reach measurement and marketing purposes. These are automatically deleted after a specified duration, which may differ depending on the cookie. You can delete the cookies at any time in the security settings of your browser.– Cookies from third-party providers (third-party cookies, esp. from advertisers): According to your preferences, you can configure your browser settings and, for example, refuse to accept third-party cookies or all cookies. However, we would like to point out at this point that you may then not be able to use all the functions of this website. Read more about these cookies in the respective privacy statements of the third-party providers.
2. Data categories: User data, cookie, user ID (inb. the pages visited, device information, access times and IP addresses).
3. Purposes of processing: The information thus obtained is used for the purpose of technically and economically optimizing our web offerings and providing you with easier and more secure access to our website.
4. Legal basis: If we process your personal data using cookies based on your consent (“opt-in”), then Art. 6 para. 1 p. 1 lit. a) DSGVO the legal basis. Otherwise, we have a legitimate interest in the effective functionality, improvement and economic operation of the website, so that in that case Art. 6 para. 1 p. 1 lit. f) DS-GVO Legal basis. The legal basis is also Art. 6 para. 1 p. 1 lit. b) DS-GVO, if the cookies are set to initiate a contract, e.g. for orders.
5. Storage period/deletion: The data is deleted as soon as it is no longer required to achieve the purpose for which it was 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. Otherwise, cookies are stored on your computer and transmitted to our site by it. Therefore, as a user, you also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transfer of cookies. Cookies that have already been saved can be deleted at any time. This can also be automated. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website to their full extent. Here you can find information on how to delete cookies by browser:Chrome: https://support.google.com/chrome/answer/95647Safari: https://support.apple.com/de-at/guide/safari/sfri11471/macFirefox: https://support.mozilla.org/de/kb/cookies-und-website-daten-in-firefox-loschen

   Internet Explorer: https://support.microsoft.com/de-at/help/17442/windows-internet-explorer-delete-manage-cookies

   Microsoft Edge: https://support.microsoft.com/de-at/help/4027947/windows-delete-cookies

6. Objection and “Opt-Out”: You can generally prevent the storage of cookies on your hard drive, regardless of consent or legal permission, by selecting “do not accept cookies” in your browser settings. However, this may result in a functional restriction of our offers. You can object to the use of third-party cookies for advertising purposes via a so-called “opt-out” via this American website (https://optout.aboutads.info) or this European website (http://www.youronlinechoices.com/de/praferenzmanagement/).

Cookie consent solutions

Borlabs Cookie

1. We have integrated the Borlabs Cookie Consent Plugin for WordPress (service provider: Borlabs – Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg) as a consent management service on our website.
2. Categories of data and description of data processing: cookies, date and time of visit, device information, browser information, anonymized IP address, opt-in and opt-out data. This service enables us to obtain and document your consent to the storage of cookies. In addition, a cookie is stored in your browser in order to be able to assign your consent or its revocation. Below you will find further information in Borlabs’ data protection declaration here: https://de.borlabs.io/kb/which-data-stores-borlabs-cookie/.
3. Purposes of data processing: compliance with legal obligations, consent storage.
4. Legal basis: The legal basis for the processing of personal data is our legitimate interest in the above purposes in accordance with Art. 6 para. 1 p. 1 lit. f) GDPR and the fulfillment of legal obligations according to Art. 6 Para. 1 p. 1 lit. c) GDPR.
5. Duration of storage: Storage of the data until you delete the Borlabs cookie in your browser yourself or the purpose for storing the data no longer applies. The revocation receipt of a previously given consent will be kept for a period of three years. The storage is based on our accountability according to Art. 5 para. 2 GDPR and the standard statute of limitations.
6. Data transmission/recipient category: the data will not be passed on to Borlabs.

Settlement of contracts

1. We process inventory data (e.g. company, title/academic degree, names and addresses as well as contact data of users, e-mail), contract data (e.g. services used, names of contact persons) and payment data (e.g. bank details, payment history) for the purpose of fulfilling our contractual obligations (knowledge of who is a contracting party; justification, content and execution of the contract; checking the plausibility of the data) and services (e.g. contacting customer service) in accordance with the German Data Protection Act. Art. 6 par. 1 p. 1 lit b) DS-GVO. The entries marked as mandatory in online forms are required for the conclusion of the contract.
2. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims (e.g. transfer to a lawyer for debt collection) or for the fulfillment of the contract (e.g. transfer of data to a payment provider) or if there is a legal obligation to do so in accordance with the German Data Protection Act. Art. 6 par. 1 p. 1 lit. c) GDPR.
3. We may also process the data you provide to inform you about other interesting products from our portfolio or to send you e-mails with technical information.
4. The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. This is the case for inventory and contract data when the data is no longer required for the performance of the contract and claims can no longer be asserted under the contract because they are time-barred (warranty: two years / standard limitation period: three years). We are obliged by commercial and tax law to store your address, payment and order data for a period of ten years. However, we will restrict processing after three years if the contract is terminated, i.e. your data will only be used to comply with legal obligations. Information in the user account remains until it is deleted.

Contact us via contact form / e-mail / fax / mail

1. When contacting us via contact form, fax, mail or e-mail, your information will be processed for the purpose of handling the contact request.
2. The legal basis for the processing of the data is, if you have given your consent, Art. 6 para. 1 p. 1 lit. a) GDPR. The legal basis for the processing of data transmitted in the course of a contact request or e-mail, letter or fax is Art. 6 para. 1 p. 1 lit. f) GDPR. The responsible party has a legitimate interest in processing and storing the data in order to be able to answer user inquiries, to preserve evidence for liability reasons and, if necessary, to be able to comply with its statutory retention obligations for business letters. If the contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 p. 1 lit. b) GDPR.
3. We may store your information and contact request in our customer relationship management system (“CRM System”) or similar system.
4. The data is deleted as soon as it is no longer required to achieve the purpose for which it was 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 you has ended. The conversation is ended when the circumstances indicate that the matter in question has been conclusively clarified. We store requests from users who have an account or contract with us until two years after termination of the contract. In the case of legal archiving obligations, deletion takes place after their expiry: end of commercial law (6 years) and tax law (10 years) retention obligation.
5. You have the possibility at any time to withdraw your consent according to Art. 6 para. 1 p. 1 lit. a) DS-GVO to the processing of personal data. If you contact us by e-mail, you can object to the storage of personal data at any time.

Contact by phone

1. When contacting us by phone, your phone number will be processed and temporarily stored or displayed in the RAM / cache of the phone device / display for processing the contact request and its handling. The storage is done for liability and security reasons, in order to be able to lead the proof of the call as well as for economic reasons, in order to enable a callback. In the event of unauthorized advertising calls, we block the numbers.
2. The legal basis for the processing of the telephone number is Art. 6 para. 1 p. 1 lit. f) GDPR. If the contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b) GDPR.
3. The device cache stores the calls for 366 days and successively overwrites or deletes old data. When the device is disposed of, all data is deleted and the memory may be destroyed. Blocked phone numbers are reviewed annually to determine the need for blocking.
4. You can prevent the phone number from being displayed by calling with the phone number suppressed.

Google Maps

1. We have integrated maps from “Google Maps”(provider: Google Ireland Limited, Reg. No.: 368047, Gordon House, Barrow Street, Dublin 4, Ireland).
2. Data category and description of data processing: Usage data (e.g. IP, location, page viewed). Google Maps allows us to display the location of addresses and directions directly on our website in interactive maps and allows you to use this tool. When you visit our website where Google Maps is integrated, a connection is established to Google’s servers in the USA. In doing so, your IP and location may be transmitted to Google. In addition, Google receives the information that you have accessed the corresponding page. This is done even without a user account with Google. If you are logged into your Google account, Google can assign the above data to your account. If you do not wish to do this, you must log out of your Google account. Google creates user profiles from such data and uses this data for the purpose of advertising, market research or optimizing its websites.
3. Purpose of processing: providing a user-friendly, economical and optimized website.
4. Legal basis: If you have given your consent (“opt-in”) for processing of your personal data by means of “Google Maps” from the third-party provider, then Art. 6 para. 1 p. 1 lit. a) DS-GVO the legal basis. In addition, the legal basis is our legitimate interest in data processing in accordance with Art. 6 Para. 1 S.1 lit. f) GDPR.
5. Data transfer/recipient category: third-party providers in the USA.
6. Storage period: cookies up to 6 months or until you delete them. Otherwise, as soon as they are no longer needed for the processing purposes.
7. Possibility of objection and removal: You have the right to object to the creation of user profiles vis-à-vis Google. Therefore, please contact Google directly via the privacy policy mentioned below. You can make an opt-out objection regarding advertising cookies here in your Google account:
   https://adssettings.google.com/authenticated.
8. In the terms of use of Google Maps at https://www.google.com/intl/de_de/help/terms_maps.html and in the privacy policy for advertising of Google at https://policies.google.com/technologies/ads you can find more information about the use of Google cookies and their advertising technologies, storage period, anonymization, location data, functionality and your rights. Google’s General Privacy Policy: https://policies.google.com/privacy.

Font Awesome

We use Font Awesome from the American company Fonticons (307 S. Main St., Suite 202, Bentonville, AR 72712, USA) on our website. When you visit one of our websites, the Font Awesome web font (specifically icons) is loaded via the Font Awesome Content Delivery Network (CDN). The texts or fonts and icons are displayed appropriately on every device. In this data protection declaration we go into more detail about the data storage and data processing by this service.

OpenStreetMap

We use the OpenStreetMap (OSM) map service.
We embed the map material from OpenStreetMap on the server of the OpenStreetMap Foundation, St John’s Innovation Centre, Cowley Road, Cambridge, CB4 0WS, Great Britain. Great Britain is regarded as a safe third country under data protection law. This means that Great Britain has a data protection level that corresponds to the data protection level in the European Union. When using the 9/11 OpenStreetMap maps, a connection to the servers of the OpenStreetMap Foundation is established.
Among other things, Your IP address and other information about your behavior on this website will be forwarded to the OSMF. For this purpose, OpenStreetMap may store cookies in your browser or use comparable recognition technologies.
OpenStreetMap is used in the interest of an attractive presentation of our online offers and to make it easy to find the places we have indicated on the website. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If a corresponding consent was requested, the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR and §25 para. 1 TTDSG, insofar as consent is given to the storage of cookies or access to information on the user’s end device.

Google Web fonts

This site uses so-called web fonts, which are provided by Google, for the uniform display of fonts. When you access a page, your browser loads the required web fonts into your 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 was accessed via your IP address. The use of Google Web Fonts is in the interest of a uniform and attractive presentation of our online offerings. This represents a legitimate interest within the meaning of Article 6 Paragraph 1 Letter f GDPR.

If your browser does not support web fonts, your computer will use a standard font.

For more information about Google Web Fonts, see
https://developers.google.com/fonts/faq

and in Google’s privacy policy: https://www.google.com/policies/privacy/.

Google reCaptcha

1. We have integrated the anti-spam function “reCAPTCHA” from “Google” (provider: Google Ireland Limited, registration number: 368047, Gordon House, Barrow Street, Dublin 4, Ireland) on our website.
2. Data category and description of data processing: Usage data (e.g. website accessed, IP). By using “reCAPTCHA” in our forms, we can determine whether the entry was made by a machine (robot) or a human. When you use the service, your IP address and any other data required for this may be transmitted to Google servers in the USA.
3. Purpose of processing: Prevention of spam and misuse as well as our economic interest in optimizing our website.
4. Legal basis: If you have given your consent to the processing of your personal data by the third party using “reCaptcha” (“opt-in”), then Art. 6 Paragraph 1 Sentence 1 Letter a) GDPR is the legal basis. The legal basis is also our legitimate interest in data processing for the above purposes in accordance with Article 6 Paragraph 1 Sentence 1 Letter f) GDPR.
5. Data transfer/recipient category: Third party providers in the USA.
6. Storage period: until you as the user delete the cookies.
7. Further information about Google ReCAPTCHA can be found at https://www.google.com/recaptcha/ and in Google’s privacy policy at: https://policies.google.com/privacy.

Data protection in applications and the application process

1. Applications sent electronically or by mail to the responsible person are processed electronically or manually for the purpose of handling the application process.
2. We expressly point out that application documents with “special categories of personal data” according to Art. 9 DS-GVO (e.g. a photo that gives conclusions about your ethnic origin, religion or marital status), with the exception of a possible severe disability, which you wish to disclose of your own free will, are undesirable. You should submit your application without this data. This will not affect your chances of applying.
3. Legal bases for the processing are Art. 6 para. 1 S.1 lit. b) DS-GVO as well as § 26 BDSG n.F.
4. If an employment relationship is entered into with the applicant after completion of the application process, the applicant data will be stored in compliance with the relevant data protection regulations. If you are not offered a position after completion of the application process, your submitted application letter including documents will be deleted 6 months after the rejection is sent in order to be able to satisfy any claims and obligations to provide evidence in accordance with the AGG.

Rights of the data subject

1. Objection or revocation against the processing of your data Insofar as the processing is based on your consent in accordance with Art. 6 para. 1 p. 1 lit. a), Art. 7 DS-GVO, you have the right to withdraw your consent at any time. This does not affect the legality of the processing carried out on the basis of the consent up to the point of revocation. Insofar as we base the processing of your personal data on the balancing of interests in accordance with Art. 6 Para. 1 p. 1 lit. f) DS-GVO, you may object to the processing. This is the case if the processing is not necessary, in particular, for the performance of a contract with you, which is shown by us in each case in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the situation and will either stop or adjust the data processing or show you our compelling legitimate reasons for continuing the processing. You can object to the processing of your personal data for advertising and data analysis purposes at any time. You can exercise the right of objection free of charge. You can inform us about your objection to advertising using the following contact details: Werner Klein Finanzberatung
   Bärendellstraße 31
   66862 Kindsbach, Germany
   Owner Werner Klein
   E-mail address: finanzberatung-klein@web.de
2. Right to information
   You have the right to request confirmation from us as to whether personal data relating to you are being processed. If this is the case, you have a right to information about your personal data stored by us in accordance with Art. 15 DS-GVO. This includes, in particular, information about the purposes of processing, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the origin of your data if it has not been collected directly from you.
3. Right to rectification
   You have the right to have incorrect data corrected or correct data completed in accordance with Art. 16 GDPR.
4. Right to deletion
   You have the right to have your data stored by us deleted in accordance with Art. 17 DS-GVO, unless legal or contractual retention periods or other legal obligations or rights to further storage conflict with this.
5. Right to restriction
   You have the right to demand a restriction in the processing of your personal data if one of the conditions in Art. 18 Para. 1 lit. a) to d) of the GDPR is fulfilled:
   • If you dispute the accuracy of the personal data concerning you for a period that enables the person responsible to check the accuracy of the personal data; • the processing is unlawful and you refuse the deletion of the personal data and instead the restriction of the use of the personal data request;• the person responsible no longer needs the personal data for the purposes of processing, but you need them to assert, exercise or defend legal claims, or• if you object to the processing in accordance with Art. 21 Para. 1 DS-GVO and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.
6. Right to data portability
   You have a right to data portability in accordance with Art. 20 GDPR, which means that you can receive the personal data we have stored about you in a structured, common and machine-readable format or you can request transmission to another person responsible.
7. Right to complain
   You have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority for this purpose, in particular in the member state of your place of residence, your place of work or the place of the alleged infringement.

Data security

In order to protect all personal data transmitted to us and to ensure that data protection regulations are complied with by us, as well as by our external service providers, we have taken appropriate technical and organizational security measures. Therefore, among other things, all data between your browser and our server is transmitted encrypted via a secure SSL connection.

Status: 05.2023