Privacy & Cookie Policy
Privacy Policy
With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").
The terms used are not gender-specific.
Status: September 28, 2022
Responsible
Delfín Management
Model & Talent Management
Germany
Northrine Westfalia
41363 Jüchen
Mobile: +45 (0) 71 / 810097
E-Mail: info@delfinmanagement.com
Types of data processed
-
Inventory data.
-
Contact data.
-
Content data.
-
Usage data.
-
Meta/communication data.
Categories of data subjects
-
Communication partners.
-
Users.
Purposes of processing
-
Provision of contractual services and customer service.
-
Contact requests and communication.
-
Security measures.
-
Management and response to requests.
-
Feedback.
Relevant legal bases
The following is an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.
-
Contract performance and pre-contractual inquiries (Art. 6 (1) p. 1 lit. b) DSGVO) - Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures which are carried out at the request of the data subject.
-
Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) - Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
Security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
TLS encryption (https): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Transmission of personal data
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
Data processing in third countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, entities or companies, this will only be done in accordance with legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not necessary for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.
Our data protection notices may also contain further details on the retention and deletion of data, which take priority for the respective processing operations.
Cookie Policy
Cookies are small text files or other memory tags that store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or functions used of an online offer. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows.
Consent notices: We use cookies in accordance with the law. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service (i.e., our online offering) expressly requested by the user. The revocable consent is clearly communicated to the users and contains the information about the respective cookie use.
Notes on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process the cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage duration: With regard to the storage duration, the following types of cookies are distinguished:
-
Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile application).
-
Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
Further notes on processing processes, procedures and services:
-
Processing of cookie data based on consent: We use a cookie consent management procedure, in the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers) as well as the browser, system and end device used.
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need assistance, you can contact us.
-
Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
-
Data subjects: Users (e.g., website visitors, users of online services).
-
Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
-
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
Further notes on processing operations, procedures and services:
-
Instagram: social network; service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
Change and update of the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Insofar as we provide addresses and contact information of companies and organizations in this data protection declaration, we ask you to note that the addresses may change over time and ask you to check the information before contacting us.
Rights of the data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
-
Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
-
Right to withdraw consent: You have the right to revoke any consent given at any time.
-
Right to information: you have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
-
Right to rectification: you have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
-
Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data.
-
Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand its transfer to another responsible party.
-
Complaint to supervisory authority: without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.
Definitions
This section provides you with an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.
-
Personal data: "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.
-
Controller: "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.
-
Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data, whether collecting, evaluating, storing, transmitting or deleting.