We are delighted that you are interested in our company. Data protection is a particularly high priority for the management of Club of Communication GmbH. You can use the Club of Communication GmbH website without providing any personal data. However, if a data subject wishes to use specific services provided by our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the person concerned.

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to Club of Communication GmbH. Through this privacy policy, our company would like to inform the public about the type, scope, and purpose of the personal data we collect, use, and process. Furthermore, this privacy policy informs data subjects of their rights.

As the data controller, Club of Communication GmbH has implemented numerous technical and organizational measures to ensure that personal data processed via this website is protected as completely as possible. However, Internet-based data transmissions can generally have security gaps, so absolute protection cannot be guaranteed. For this reason, every person affected is free to transmit personal data to us via alternative means, such as by telephone.

1. Definitions

The privacy policy of Club of Communication GmbH is based on the terms used by the European legislators and regulators when enacting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

We use the following terms in this privacy policy, among others:

• a) Personal data

Personal data is any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

• b) Data subject

A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

• c) Processing

Processing is any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, reading, retrieval, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

• e) Profiling

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

• f) Pseudonymization

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without using additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

• g) Controller or data controller

The controller or controller responsible for processing is the natural or legal person, public authority, agency, or other body that alone or jointly with others determines the purposes and means of the processing of personal data. If the purposes and means of such processing are determined by Union law or the law of Member States, the controller or the specific criteria for its designation may be provided for by Union law or the law of Member States.

• h) Processor

A processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

• i) Recipient

A recipient is a natural or legal person, public authority, agency, or other body to whom personal data are disclosed, regardless of whether they are a third party or not. However, public authorities that may receive personal data in the course of a specific investigative task under Union law or the law of the Member States are not considered recipients.

• j) Third party

A third party is a natural or legal person, public authority, agency, or other body other than the data subject, the controller, the processor, and the persons who, under the direct authority of the controller or the processor, are authorized to process personal data.

• k) Consent

Consent is any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by action, signifies agreement to personal data relating to him or her being processed.

2. Name and address of the data controller

The responsible party in accordance with the General Data Protection Regulation, other data protection laws applicable in the member states of the European Union, and other provisions with data protection character is:

Club of Communication GmbH
Friedrich-Ebert-Str. 153
42117 Wuppertal
Deutschland

Tel.: 0202-6950-0
E-Mail: info@coc-team.de
Website: https://www.club-of-communication.de

3. Cookies

The websites of Club of Communication GmbH use cookies. Cookies are text files that are stored on a computer system via an Internet browser.

Numerous websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters that can be used to assign websites and servers to the specific Internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the person concerned from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID.

By using cookies, Club of Communication GmbH can provide users of this website with more user-friendly services that would not be possible without the use of cookies.

Cookies enable us to optimize the information and offers on our website for the benefit of the user. As already mentioned, cookies enable us to recognize users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, users of a website that uses cookies do not have to re-enter their access data each time they visit the website, as this is stored by the website and the cookie stored on the user's computer system. Another example is the cookie used in an online shopping cart. The online shop uses a cookie to remember the items that a customer has placed in their virtual shopping cart.

The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

We use the consent tool “Real Cookie Banner” to manage the cookies and similar technologies (tracking pixels, web beacons, etc.) used and the related consents. Details on how “Real Cookie Banner” works can be found at https://devowl.io/de/rcb/datenverarbeitung/. https://devowl.io/de/rcb/datenverarbeitung/.

The legal basis for the processing of personal data in this context is Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide personal data. If you do not provide the personal data, we cannot manage your consent.

 

4. Collection of general data and information

The Club of Communication GmbH website collects a range of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) other similar data and information that serve to protect against attacks on our information technology systems.

When using this general data and information, Club of Communication GmbH does not draw any conclusions about the data subject. This information is required in order to (1) deliver the content of our website correctly, (2) optimize the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by Club of Communication GmbH on the one hand statistically and on the other hand with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.

5. Routine deletion and blocking of personal data

The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or if this has been provided for by the European directive and regulation issuer or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies or if a storage period prescribed by European directive and regulation issuers or other competent legislators expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

6. Rights of the data subject

• a) Right to confirmation

Every data subject has the right granted by European directives and regulations to request confirmation from the controller as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they may contact an employee of the controller at any time.

• b) Right to information

Every person affected by the processing of personal data has the right granted by European directives and regulations to obtain, at any time, free of charge, from the controller, information about the personal data stored about them and a copy of this information. Furthermore, European directives and regulations grant the data subject the right to obtain the following information:

• the purposes of the processing
• the categories of personal data that are processed
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
• if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
• the existence of a right to request from the controller rectification or erasure of personal data concerning the data subject or restriction of processing or to object to such processing
• the existence of a right to lodge a complaint with a supervisory authority
• if the personal data are not collected from the data subject: all available information about the origin of the data
• the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has the right to obtain information on whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information on the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right to information, they may contact an employee of the controller at any time

• c) Right to rectification

Any person affected by the processing of personal data has the right granted by European directives and regulations to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary statement, taking into account the purposes of the processing.

If a data subject wishes to exercise this right to rectification, they may contact an employee of the controller at any time.

• d) Right to erasure (right to be forgotten)

Any person affected by the processing of personal data has the right granted by European directives and regulations to request that the controller delete personal data concerning them without delay if one of the following reasons applies and provided that the processing is not necessary:

o The personal data has been collected or otherwise processed for purposes for which it is no longer necessary.

o The data subject withdraws their consent on which the processing is based in accordance with Art. 6 para. 1 letter a GDPR or Art. 9 para. 2 letter a GDPR, and there is no other legal basis for the processing.

o The data subject objects to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.

o The personal data has been processed unlawfully.

o The personal data must be erased to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.

o The personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

If one of the above reasons applies and a data subject wishes to have personal data stored by Club of Communication GmbH deleted, they can contact an employee of the controller at any time. The employee of Club of Communication GmbH will ensure that the deletion request is complied with immediately.

If the personal data has been made public by Club of Communication GmbH and our company is obliged to delete the personal data in accordance with Art. 17 (1) GDPR, Club of Communication GmbH shall take appropriate measures, including technical measures, taking into account the available technology and implementation costs, to inform other data controllers who process the published personal data that the data subject has requested the other controllers to delete all links to this personal data or copies or replications of this personal data, unless the processing is necessary. The employee of Club of Communication GmbH will take the necessary steps in each individual case.

• e) Right to restriction of processing

Any person affected by the processing of personal data has the right granted by European directives and regulations to request that the controller restrict processing if one of the following conditions is met:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful, the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims.
• The data subject has objected to the processing pursuant to Art. 21 (1) GDPR and it is not yet clear whether the legitimate reasons of the controller outweigh those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Club of Communication GmbH, they may contact an employee of the controller at any time. The employee of Club of Communication GmbH will arrange for the processing to be restricted.

• f) Right to data portability

Any person affected by the processing of personal data has the right granted by the European Directive and Regulation to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent pursuant to Art. 6 (1) letter a GDPR or Art. 9 (2) letter a GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, when exercising their right to data portability pursuant to Art. 20 (1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

To exercise the right to data portability, the data subject may contact an employee of Club of Communication GmbH at any time.

• g) Right to object

Any person affected by the processing of personal data has the right granted by European directives and regulations to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them on the basis of Art. 6 para. 1 lit. e or f GDPR. This also applies to profiling based on these provisions.

Club of Communication GmbH will no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or the processing serves to assert, exercise, or defend legal claims.

If Club of Communication GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing purposes. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to Club of Communication GmbH processing their data for direct marketing purposes, Club of Communication GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them by Club of Communication GmbH for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 (1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.

To exercise the right to object, the data subject may contact any employee of Club of Communication GmbH or another employee directly. The data subject is also free to exercise their right to object in relation to the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.

• h) Automated individual decision-making, including profiling

Any person affected by the processing of personal data has the right granted by European directives and regulations not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and that law provides for appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is based on the data subject's explicit consent.

If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller or (2) is made with the express consent of the data subject, Club of Communication GmbH shall take appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, including at least the right to obtain human intervention on the part of the controller, to express their own point of view and to contest the decision.

If the data subject wishes to assert rights relating to automated decisions, they may contact an employee of the controller responsible for processing at any time.

• i) Right to withdraw consent under data protection law

Any person affected by the processing of personal data has the right granted by European directives and regulations to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise their right to withdraw consent, they may contact an employee of the controller responsible for processing at any time.

7. Data protection provisions regarding the use of Google Analytics (with anonymization function)

The controller has integrated the Google Analytics component (with anonymization function) into this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analytics service collects, among other things, data about which website a data subject came from (so-called referrers), which subpages of the website were accessed, how often and for how long a subpage was viewed. Web analytics is mainly used to optimize a website and to analyze the cost-benefit ratio of Internet advertising.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. This addition shortens and anonymizes the IP address of the Internet connection of the person concerned by Google if access to our Internet pages is made from a member state of the European Union or from another contracting state of the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze visitor traffic on our website. Google uses the data and information obtained to evaluate the use of our website, to compile online reports for us showing the activities on our website, and to provide other services related to the use of our website.

Google Analytics places a cookie on the information technology system of the data subject. What cookies are has already been explained above. By placing the cookie, Google is enabled to analyze the use of our website. Each time one of the individual pages of this website operated by the controller and on which a Google Analytics component has been integrated is accessed, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently enable commission settlements.

The cookie stores personal information, such as the time of access, the location from which access originated, and the frequency of visits to our website by the data subject. Each time you visit our website, this personal data, including the IP address of the Internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected through the technical process to third parties.

The data subject can prevent the setting of cookies by our website at any time, as described above, by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the data subject's information technology system. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google. To do this, the data subject must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information relating to visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection. If the information technology system of the data subject is deleted, formatted or reinstalled at a later point in time, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their sphere of influence, it is possible to reinstall or reactivate the browser add-on.

Further information and Google's applicable privacy policy can be found at https://www.google.de/intl/de/policies/privacy/ and http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at this link: https://www.google.com/intl/de_de/analytics/.

8. Legal basis for processing

Art. 6 I lit. a GDPR serves as the legal basis for our company for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and their name, age, health insurance details or other vital information had to be passed on to a doctor, hospital or other third party. In this case, the processing would be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the above legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator.In this regard, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, sentence 2 GDPR).

9. Legitimate interests in processing pursued by the controller or a third party

If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the performance of our business activities for the benefit of all our employees and our shareholders.

10. Duration for which the personal data will be stored

The criterion for the duration of the storage of personal data is the respective statutory retention period.After expiry of this period, the corresponding data will be routinely deleted unless it is no longer required for the fulfillment of the contract or for the initiation of a contract.

11. Legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We hereby inform you that the provision of personal data is partly required by law (e.g., tax regulations) or may also result from contractual provisions (e.g., information about the contractual partner). In some cases, it may be necessary for a data subject to provide us with personal data in order to conclude a contract, which we will then have to process. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded.Before providing personal data, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what consequences the non-provision of personal data would have.

12. Existence of automated decision-making

As a responsible company, we refrain from automatic decision-making or profiling.

This privacy policy was created by the privacy policy generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as an external data protection officer in Dortmund, in cooperation with the Cologne-based data protection lawyer Christian Solmecke.