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Privacy Policy

In the following, we inform you about the type, scope and purpose of the processing of personal data by our company in accordance with the legal requirements of data protection law (in particular according to BDSG nF and the European data protection basic regulation 'DS-GVO'). This privacy policy also applies to our websites and social media profiles. With regard to the definition of terms such as "personal data" or "processing", we refer to Art. 4 DS-GVO.

Name and contact details of the person responsible
Our responsible person (hereinafter "responsible person") within the meaning of Art. 4 no. 7 GDPR is:

comtif UG
Tiefenbroicher Weg 42
40472, Dusseldorf, Germany
Managing Director: Tim Felgner
Commercial Register No.: 62954
Registration court: District Court of Düsseldorf
Fax: 0211 65 55 7599
Email address: info@comtif.de

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

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

1. Types of data we process
Usage data (access times, websites visited, etc.),

2. Purposes of processing according to Art. 13 Para. 1 c) GDPR
Optimization and statistical evaluation of our services, making the website user-friendly, marketing/sales/advertising, creating statistics,

3. Categories of data subjects according to Art. 13 Para. 1 e) GDPR
Visitors/users of the website, interested parties,

 

The persons concerned are referred to collectively as "users".


Legal bases for the processing of personal data

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

  1. If we have obtained your consent to the processing of personal data, Article 6 Paragraph 1 Clause 1 Letter a) GDPR is the legal basis.

  2. If the processing is necessary to fulfill a contract or to carry out pre-contractual measures that are carried out at your request, Article 6 Paragraph 1 Sentence 1 lit. b) GDPR is the legal basis.

  3. If the processing is necessary to fulfill a legal obligation to which we are subject (e.g. statutory storage obligations), Article 6 Paragraph 1 Sentence 1 lit. c) GDPR is the legal basis.

  4. If processing is necessary to protect the vital interests of the data subject or another natural person, Article 6 Paragraph 1 Sentence 1 lit. d) GDPR is the legal basis.

  5. If the processing is necessary to protect our interests or those of a third party and your interests or fundamental rights and freedoms do not prevail in this regard, Article 6 Paragraph 1 Clause 1 Letter f) GDPR is the legal basis.


Disclosure of personal data to third parties and processors

In principle, we do not pass on any data to third parties without your consent. If this is the case, then the transfer takes place on the basis of the aforementioned legal bases, e.g. when transferring data to online payment providers to fulfill a contract or due to a court order or due to a legal obligation to release 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 passed on to the processors as part of an agreement on order processing, this is always done in accordance with Art. 28 DS-GVO. We carefully select our processors, check 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 regulations in accordance with BDSG nF 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 primarily by companies for which the GDPR applies. Should the processing take place by third-party services outside the European Union or the European Economic Area, they must meet the special requirements of Art. 44 et seq. GDPR. This means that the processing takes place on the basis of special guarantees, such as the determination of a level of data protection officially recognized by the EU Commission or compliance with officially recognized special contractual obligations, the so-called "standard contractual clauses".
Insofar as we obtain your express consent to the transfer of data to the USA due to the ineffectiveness of the so-called "Privacy Shield" pursuant to Article 49 Paragraph 1 Clause 1 Letter a) GDPR, we point out the risk of secret access in this respect by US authorities and the use of the data for surveillance purposes, possibly without legal remedies for EU citizens.


Deletion of data and storage period

Unless expressly stated in this data protection declaration, your personal data will be deleted or blocked as soon as you revoke your consent to processing or the purpose for storage no longer applies or the data are no longer required for the purpose, unless their further Storage is required for evidence purposes or there are legal storage obligations. This includes, for example, commercial law retention requirements for business letters in accordance with Section 257 (1) HGB (6 years) and tax retention requirements for receipts in accordance with Section 147 (1) AO (10 years). If the prescribed retention period expires, your data will be blocked or deleted, unless storage is still required 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 want to view our website, we collect the following data:
    • IP address;
    • User's internet service provider;
    • date and time of retrieval;
    • browser type;
    • language and browser version;
    • content of the call;
    • time zone;
    • Access Status/HTTP Status Code;
    • amount of data;
    • websites from which the request comes;
    • 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 providing you with functions and content of our website in a user-friendly, functional and secure manner, as well as optimizing and statistically evaluating them.
     

  3. The legal basis for this is our legitimate interest in data processing in accordance with Article 6 Paragraph 1 Clause 1 Letter f) GDPR, which also lies in the above purposes.
     

  4. For security reasons, we store this data in server log files for a storage period of 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 violations of the law.


Cookies

  1. We use so-called cookies when you visit our website. Cookies are small text files that your Internet browser stores and saves on your computer. When you visit our website again, these cookies provide information to automatically recognize you. The cookies also include the so-called "user IDs", where user information is stored using pseudonymised profiles. When you visit our website, we inform you about the use of cookies for the aforementioned purposes and how you can object to them or prevent their storage ("opt-out") by means of a reference to our data protection declaration.

    The following types of cookies are distinguished:

    •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 repeated use of an offer by the same user (e.g. if you have logged in to determine your login status). When you visit our site again, these cookies provide information to automatically recognize you. The information obtained in this way is used to optimize our offers and to enable you to access our site more easily. If you close the browser or log out, the session cookies will be deleted.

    •Persistent cookies:These cookies remain stored even after the browser is closed. They are used to store the login, to measure the reach and for marketing purposes. These are automatically deleted after a specified period of time, which can vary depending on the cookie. You can delete cookies at any time in the security settings of your browser.

    •Third-party cookies (third-party cookies, in particular from advertisers):You can configure your browser settings according to your wishes and e.g. B. Decline to accept third-party cookies or all cookies. However, we would like to point out that you may then not be able to use all the functions of this website. Read more about these cookies in the respective data protection declarations of the third-party providers.

     

  2. Data categories:User data, cookie, user ID (including the pages visited, device information, access times and IP addresses).
     

  3. Purposes of processing:The information obtained in this way serves the purpose of technically and economically optimizing our website and enabling you to access our website more easily and securely.
     

  4. Legal bases:If we process your personal data with the help of cookies based on your consent (“opt-in”), then Article 6 Paragraph 1 Sentence 1 lit. a) GDPR is the legal basis. Otherwise, we have a legitimate interest in the effective functionality, improvement and economic operation of the website, so that in this case Article 6 (1) sentence 1 lit. f) GDPR is the legal basis. The legal basis is also Article 6 Paragraph 1 Sentence 1 Letter b) GDPR if the cookies are set to initiate a contract, e.g. for orders.
     

  5. Storage duration/ deletion:The data will be deleted as soon as they are no longer required to achieve the purpose for which they were 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.

    Cookies are otherwise stored on your computer and transmitted to our site. Therefore, as a user, you also have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been saved can be deleted at any time. This can also be done automatically. 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/95647

    safari:https://support.apple.com/de-at/guide/safari/sfri11471/mac

    Firefox: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 cookies from being saved on your hard drive, regardless of your consent or legal permission, by selecting “do not accept cookies” in your browser settings. However, this can result in a functional restriction of our offers. You can opt out of the use of third-party cookies for advertising purposes via this American website (https://optout.aboutads.info) or this European website (http://www.youronlinechoices.com/de /preference management/) object.
     


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

  1. When you contact us via the contact form, fax, post or e-mail, your details will be processed for the purpose of processing the contact request.
     

  2. If you have given your consent, the legal basis for processing the data is Article 6 (1) sentence 1 lit. a) GDPR. The legal basis for the processing of data transmitted in the course of a contact request or email, letter or fax is Article 6 Paragraph 1 Sentence 1 Letter f) GDPR. The person responsible has a legitimate interest in the processing and storage of the data in order to be able to answer user inquiries, to preserve evidence for reasons of liability and, if necessary, to be able to comply with his statutory storage obligations for business letters. If the contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) sentence 1 lit. b) GDPR.
     

  3. We can store your details and contact request in our customer relationship management system ("CRM system") or a comparable system.
     

  4. The data will be deleted as soon as they are no longer required to achieve the purpose for which they were 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 over when it can be inferred from the circumstances that the facts in question have been finally clarified. We store inquiries from users who have an account or contract with us for a period of two years after the end of the contract. In the case of legal archiving obligations, the deletion takes place after their expiry: end of commercial law (6 years) and tax law (10 years) storage obligation.
     

  5. You have the option at any time to revoke your consent to the processing of personal data in accordance with Article 6 Paragraph 1 Clause 1 Letter a) GDPR. If you contact us by email, you can object to the storage of your personal data at any time.
     


Contact by phone

  1. When you contact us by telephone, your telephone number will be processed and temporarily stored or displayed in the RAM / cache of the telephone device / display to process the contact request and its processing. It is stored for liability and security reasons, to be able to provide evidence of the call, and for economic reasons, to enable a callback. In the case of unauthorized advertising calls, we block the phone numbers.
     

  2. The legal basis for processing the telephone number is Article 6 Paragraph 1 Clause 1 Letter f) GDPR. If the contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) (b) GDPR.
     

  3. The device cache stores the calls for 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 telephone numbers are checked annually to determine whether blocking is necessary.
     

  4. You can prevent the phone number from being displayed by calling with a suppressed phone number.
     


Google Analytics

  1. We have the website analysis tool "Google Analytics" (Service provider:Google Ireland Limited, Registration No.: 368047, Gordon House, Barrow Street, Dublin 4, Ireland) integrated on our website.
     

  2. Categories of data and description of data processing:User ID, IP address (anonymized). When you visit our website, Google places a cookie on your computer in order to be able to analyze your use of our website. We have activated the IP anonymization "anonymizeIP", which means that the IP addresses are only processed further in abbreviated form. On this website, your IP address will therefore be shortened beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website and internet use to the person responsible. We have also activated the cross-device analysis of website visitors, which is carried out using a so-called user ID. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You can find more information about the use of data by Google Analytics here: https://www.google.com/analytics/terms/de.html (Analytics Terms of Service), https://support.google.com/analytics/answer/6004245?hl=en  (Notes on data protection in Analytics) and Google's privacy policy https://policies.google.com/privacy.
     

  3. Purpose of processing:The use of Google Analytics serves the purpose of analyzing, optimizing and improving our website.
     

  4. Legal bases:If you have given your consent (“opt-in”) to the processing of your personal data by the third-party provider using “Google Analytics”, then Article 6 (1) sentence 1 lit. a) GDPR is the legal basis. The legal basis is also our legitimate interest in the above purposes (the analysis, optimization and improvement of our website) in data processing in accordance with Article 6 Paragraph 1 S.1 lit. f) GDPR. In the case of services provided in connection with a contract, user behavior is tracked and analyzed in accordance with Article 6 (1) sentence 1 lit. b) GDPR in order to use the information obtained in this way to provide optimized services to fulfill the to be able to offer for the purpose of the contract.
     

  5. Storage duration:The data sent by us and linked to cookies, user IDs (e.g. user ID) or advertising IDs are automatically deleted after months. Data that has reached the end of its retention period is automatically deleted once a month.
     

  6. Data transmission/recipient category:Google, Ireland and USA. We have also concluded an order processing agreement with Google in accordance with Art. 28 GDPR.
     

  7. Objection and elimination options ("opt-out"):
    • You can generally prevent cookies from being saved on your hard drive by selecting “do not accept cookies” in your browser settings. However, this can result in a functional restriction of our offers. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website and from processing this data by Google by downloading and installing the browser plug-in available under the following link:_cc781905-5cde -3194-bb3b-136bad5cf58d_http://tools.google.com/dlpage/gaoptout?hl=de

    •As an alternative to the above browser plugin, you can prevent Google Analytics from collecting data by clicking [__please__insert your website's analytics opt-out link]. The click sets an “opt-out” cookie that prevents your data from being collected when you visit this website in the future. This cookie only applies to our website and your current browser and only lasts until you delete your cookies. In this case you would have to set the cookie again.

    •You can deactivate the cross-device user analysis in your Google account under "My data > personal data".


     

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 Article 6 Paragraph 1 Sentence 1 Letter a), Article 7 GDPR, you have the right to revoke your consent at any time. This does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

    Insofar as we base the processing of your personal data on the balancing of interests in accordance with Article 6 (1) sentence 1 lit. f) GDPR, you can object to the processing. This is the case if the processing is not necessary in particular to fulfill a contract with you, which is shown by us in the following description of the functions. If you exercise such an objection, we ask that you 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 reasons worthy of protection on the basis of which we will continue the processing.

    You can object to the processing of your personal data for advertising and data analysis purposes at any time. You can exercise your right to object free of charge. You can inform us about your objection to advertising using the following contact details:

    Comtif USA LLC
    Tiefenbroicher Weg 42
    40472, Dusseldorf, Germany
    CEO Tim Felgner
    Commercial Register No.: 62954
    Registration court: District Court of Düsseldorf
    Fax: 0211 65 55 7599
    Email address: info@comtif.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 the 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 was or will be disclosed, the planned storage period, the origin of your data if it was not 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 Erasure
    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 requirements in Article 18 (1) lit. a) to d) GDPR is met:
    • If you dispute the accuracy of the personal data concerning you for a period of time that enables the controller to verify the accuracy of the personal data;

    • the processing is unlawful and you refuse to delete the personal data and instead request that the use of the personal data be restricted;

    • 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 have lodged an objection to the processing pursuant to Art. 21 Para. 1 DS-GVO and it is not yet certain whether the legitimate reasons of the person responsible 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 Complaint
    You have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority, in particular in the Member State where you live, where you work or where the alleged violation took place.

     


Data security

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



Status: 01 February 2023

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