PRIVAVY POLICY
We are very delighted that you have shown interest in our enterprise. Data protection
is of a particularly high priority for the management of the Peer Lorenz. The use of
the Internet pages of the Peer Lorenz is possible without any indication of personal
data; however, if a data subject wants to use special enterprise services via our
website, processing of personal data could become necessary. If the processing of
personal data is necessary and there is no statutory basis for such processing, we
generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or
telephone number of a data subject shall always be in line with the General Data
Protection Regulation (GDPR), and in accordance with the country-specific data
protection regulations applicable to the Peer Lorenz. By means of this data
protection declaration, our enterprise would like to inform the general public of the
nature, scope, and purpose of the personal data we collect, use and process.
Furthermore, data subjects are informed, by means of this data protection
declaration, of the rights to which they are entitled.
As the controller, the Peer Lorenz has implemented numerous technical and
organizational measures to ensure the most complete protection of personal data
processed through this website. However, Internet-based data transmissions may in
principle have security gaps, so absolute protection may not be guaranteed. For this
reason, every data subject is free to transfer personal data to us via alternative
means, e.g. by telephone.
- Definitions
The data protection declaration of the Peer Lorenz is based on the terms used by the
European legislator for the adoption of the General Data Protection Regulation
(GDPR). Our data protection declaration should be legible and understandable for
the general public, as well as our customers and business partners. To ensure this,
we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
a) Personal data
Personal data means any information relating to an identified or identifiable
natural person (“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 or
to one or more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.
b) Data subject
Data subject is any identified or identifiable natural person, whose personal
data is processed by the controller responsible for the processing.
c) Processing
Processing is any operation or set of operations which is performed on
personal data or on sets of personal data, whether or not by automated
means, such as collection, recording, organisation, structuring, storage,
adaptation or alteration, retrieval, consultation, 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 means any form of automated processing of personal data consisting
of the use of personal data to evaluate certain personal aspects relating to a
natural person, in particular to analyse or predict aspects concerning that
natural person’s performance at work, economic situation, health, personal
preferences, interests, reliability, behaviour, location or movements.
f) Pseudonymisation
Pseudonymisation 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
the use of additional information, provided that such additional information is
kept separately and is subject to technical and organisational measures to
ensure that the personal data are not attributed to an identified or identifiable
natural person.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is 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; where the purposes and means of such processing are determined by
Union or Member State law, the controller or the specific criteria for its
nomination may be provided for by Union or Member State law.
h) Processor
Processor is a natural or legal person, public authority, agency or other body
which processes personal data on behalf of the controller.
i) Recipient
Recipient is a natural or legal person, public authority, agency or another
body, to which the personal data are disclosed, whether a third party or not.
However, public authorities which may receive personal data in the framework
of a particular inquiry in accordance with Union or Member State law shall not
be regarded as recipients; the processing of those data by those public
authorities shall be in compliance with the applicable data protection rules
according to the purposes of the processing.
j) Third party
Third party is a natural or legal person, public authority, agency or body other
than the data subject, controller, processor and persons who, under the direct
authority of the controller or processor, are authorised to process personal
data.
k) Consent
Consent of the data subject 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 a clear affirmative action, signifies agreement to the
processing of personal data relating to him or her. - Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other
data protection laws applicable in Member states of the European Union and other
provisions related to data protection is:
Peer Lorenz
VIA S.PAULO 16
39050 APPIANO SULLA STRADA DAL VINO (BZ)
Italien
Phone: +393923088383
Email: lorenz@peerig.com
Website: lorenzpeer.com - Collection of general data and information
The website of the Peer Lorenz collects a series of general data and information
when a data subject or automated system calls up the website. This general data
and information are stored in the server log files. Collected may be (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, (5) the date and time of access to the Internet site,
(6) an Internet protocol address (IP address), (7) the Internet service provider of the
accessing system, and (8) any other similar data and information that may be used
in the event of attacks on our information technology systems.
When using these general data and information, the Peer Lorenz does not draw any
conclusions about the data subject. Rather, this information is needed to (1) deliver
the content of our website correctly, (2) optimize the content of our website as well
as its advertisement, (3) ensure the long-term viability of our information technology
systems and website technology, and (4) provide law enforcement authorities with
the information necessary for criminal prosecution in case of a cyber-attack.
Therefore, the Peer Lorenz analyzes anonymously collected data and information
statistically, with the aim of increasing the data protection and data security of our
enterprise, and to ensure an optimal level of protection for the personal data we
process. The anonymous data of the server log files are stored separately from all
personal data provided by a data subject. - Contact possibility via the website
The website of the Peer Lorenz contains information that enables a quick electronic
contact to our enterprise, as well as direct communication with us, which also
includes a general address of the so-called electronic mail (e-mail address). If a data
subject contacts the controller by e-mail or via a contact form, the personal data
transmitted by the data subject are automatically stored. Such personal data
transmitted on a voluntary basis by a data subject to the data controller are stored for
the purpose of processing or contacting the data subject. There is no transfer of this
personal data to third parties. - Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only
for the period necessary to achieve the purpose of storage, or as far as this is
granted by the European legislator or other legislators in laws or regulations to which
the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the
European legislator or another competent legislator expires, the personal data are
routinely blocked or erased in accordance with legal requirements. - Rights of the data subject
a) Right of confirmation
Each data subject shall have the right granted by the European legislator to
obtain from the controller the confirmation as to whether or not personal data
concerning him or her are being processed. If a data subject wishes to avail
himself of this right of confirmation, he or she may, at any time, contact any
employee of the controller.
b) Right of access
Each data subject shall have the right granted by the European legislator to
obtain from the controller free information about his or her personal data
stored at any time and a copy of this information. Furthermore, the European
directives and regulations grant the data subject access to the following
information:
the purposes of the processing;
the categories of personal data concerned;
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 organisations;
where possible, the envisaged period for which the personal data will
be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or
erasure of personal data, or restriction of processing of personal data
concerning the data subject, or to object to such processing;
the existence of the right to lodge a complaint with a supervisory
authority;
where the personal data are not collected from the data subject, any
available information as to their source;
the existence of automated decision-making, including profiling,
referred to in 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 envisaged consequences of such processing for the
data subject.
Furthermore, the data subject shall have a right to obtain information as to
whether personal data are transferred to a third country or to an international
organisation. Where this is the case, the data subject shall have the right to
be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may,
at any time, contact any employee of the controller.
c) Right to rectification
Each data subject shall have the right granted by the European legislator to
obtain from the controller without undue delay the rectification of inaccurate
personal data concerning him or her. Taking into account the purposes of the
processing, the data subject shall have the right to have incomplete personal
data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at
any time, contact any employee of the controller.
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to
obtain from the controller the erasure of personal data concerning him or her
without undue delay, and the controller shall have the obligation to erase
personal data without undue delay where one of the following grounds
applies, as long as the processing is not necessary:
The personal data are no longer necessary in relation to the purposes
for which they were collected or otherwise processed.
The data subject withdraws consent to which the processing is based
according to point (a) of Article 6(1) of the GDPR, or point (a) of Article
9(2) of the GDPR, and where there is no other legal ground for the
processing.
The data subject objects to the processing pursuant to Article 21(1) of
the GDPR and there are no overriding legitimate grounds for the
processing, or the data subject objects to the processing pursuant to
Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal
obligation in Union or Member State law to which the controller is
subject.
The personal data have been collected in relation to the offer of
information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to
request the erasure of personal data stored by the Peer Lorenz, he or she
may, at any time, contact any employee of the controller. An employee of Peer
Lorenz shall promptly ensure that the erasure request is complied with
immediately.
Where the controller has made personal data public and is obliged pursuant
to Article 17(1) to erase the personal data, the controller, taking account of
available technology and the cost of implementation, shall take reasonable
steps, including technical measures, to inform other controllers processing the
personal data that the data subject has requested erasure by such controllers
of any links to, or copy or replication of, those personal data, as far as
processing is not required. An employees of the Peer Lorenz will arrange the
necessary measures in individual cases.
e) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to
obtain from the controller restriction of processing where one of the following
applies:
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 and the data subject opposes the erasure of
the personal data and requests instead 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 defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1)
of the GDPR pending the verification whether the legitimate grounds of
the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to
request the restriction of the processing of personal data stored by the Peer
Lorenz, he or she may at any time contact any employee of the controller. The
employee of the Peer Lorenz will arrange the restriction of the processing.
f) Right to data portability
Each data subject shall have the right granted by the European legislator, to
receive the personal data concerning him or her, which was provided to a
controller, in a structured, commonly used and machine-readable format. He
or she shall have the right to transmit those data to another controller without
hindrance from the controller to which the personal data have been provided,
as long as the processing is based on consent pursuant to point (a) of Article
6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract
pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried
out by automated means, as long as the processing is not 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, in exercising his or her right to data portability pursuant to Article
20(1) of the GDPR, the data subject shall have the right to have personal data
transmitted directly from one controller to another, where technically feasible
and when doing so does not adversely affect the rights and freedoms of
others.
In order to assert the right to data portability, the data subject may at any time
contact any employee of the Peer Lorenz.
g) Right to object
Each data subject shall have the right granted by the European legislator to
object, on grounds relating to his or her particular situation, at any time, to
processing of personal data concerning him or her, which is based on point
(e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on
these provisions.
The Peer Lorenz shall no longer process the personal data in the event of the
objection, unless we can demonstrate compelling legitimate grounds for the
processing which override the interests, rights and freedoms of the data
subject, or for the establishment, exercise or defence of legal claims.
If the Peer Lorenz processes personal data for direct marketing purposes, the
data subject shall have the right to object at any time to processing of
personal data concerning him or her for such marketing. This applies to
profiling to the extent that it is related to such direct marketing. If the data
subject objects to the Peer Lorenz to the processing for direct marketing
purposes, the Peer Lorenz will no longer process the personal data for these
purposes.
In addition, the data subject has the right, on grounds relating to his or her
particular situation, to object to processing of personal data concerning him or
her by the Peer Lorenz for scientific or historical research purposes, or for
statistical purposes pursuant to Article 89(1) of the GDPR, unless the
processing is necessary for the performance of a task carried out for reasons
of public interest.
In order to exercise the right to object, the data subject may contact any
employee of the Peer Lorenz. In addition, the data subject is free in the
context of the use of information society services, and notwithstanding
Directive 2002/58/EC, to use his or her right to object by automated means
using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not
to be subject to a decision based solely on automated processing, including
profiling, which produces legal effects concerning him or her, or similarly
significantly affects him or her, as long as the decision (1) is not is necessary
for entering into, or the performance of, a contract between the data subject
and a data controller, or (2) is not authorised by Union or Member State law to
which the controller is subject and which also lays down suitable measures to
safeguard the data subject’s rights and freedoms and legitimate interests, or
(3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a
contract between the data subject and a data controller, or (2) it is based on
the data subject’s explicit consent, the Peer Lorenz shall implement suitable
measures to safeguard the data subject’s rights and freedoms and legitimate
interests, at least the right to obtain human intervention on the part of the
controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated
individual decision-making, he or she may, at any time, contact any employee
of the Peer Lorenz.
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to
withdraw his or her consent to processing of his or her personal data at any
time.
If the data subject wishes to exercise the right to withdraw the consent, he or
she may, at any time, contact any employee of the Peer Lorenz. - Data protection provisions about the application and use of Google Analytics (with
anonymization function)
On this website, the controller has integrated the component of Google Analytics
(with the anonymizer function). 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 analysis service collects, inter alia, data about the
website from which a person has come (the so-called referrer), which sub-pages
were visited, or how often and for what duration a sub-page was viewed. Web
analytics are mainly used for the optimization of a website and in order to carry out a
cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Ireland Limited, Gordon
House, Barrow Street, Dublin, D04 E5W5, Ireland.
For the web analytics through Google Analytics the controller uses the application
„_gat. _anonymizeIp“. By means of this application the IP address of the Internet
connection of the data subject is abridged by Google and anonymised when
accessing our websites from a Member State of the European Union or another
Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our
website. Google uses the collected data and information, inter alia, to evaluate the
use of our website and to provide online reports, which show the activities on our
websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data
subject. The definition of cookies is explained above. With the setting of the cookie,
Google is enabled to analyze the use of our website. With each call-up to one of the
individual pages of this Internet site, which is operated by the controller and into
which a Google Analytics component was integrated, the Internet browser on the
information technology system of the data subject will automatically submit data
through the Google Analytics component for the purpose of online advertising and
the settlement of commissions to Google. During the course of this technical
procedure, the enterprise Google gains knowledge of personal information, such as
the IP address of the data subject, which serves Google, inter alia, to understand the
origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the
location from which the access was made, and the frequency of visits of our website
by the data subject. With each visit to our Internet site, such personal data, including
the IP address of the Internet access used by the data subject, will be transmitted to
Google in the United States of America. These personal data are stored by Google
in the United States of America. Google may pass these personal data collected
through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our
website at any time by means of a corresponding adjustment of the web browser
used and thus permanently deny the setting of cookies. Such an adjustment to the
Internet browser used would also prevent Google Analytics from setting a cookie on
the information technology system of the data subject. In addition, cookies already in
use by Google Analytics may be deleted at any time via a web browser or other
software programs.
In addition, the data subject has the possibility of objecting to a collection of data that
are generated by Google Analytics, which is related to the use of this website, as
well as the processing of this data by Google and the chance to preclude any such.
For this purpose, the data subject must download a browser add-on under the link
https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells
Google Analytics through a JavaScript, that any data and information about the visits
of Internet pages may not be transmitted to Google Analytics. The installation of the
browser add-ons is considered an objection by Google. If the information technology
system of the data subject is later deleted, formatted, or newly installed, then the
data subject must reinstall the browser add-ons to disable Google Analytics. If the
browser add-on was uninstalled by the data subject or any other person who is
attributable to their sphere of competence, or is disabled, it is possible to execute the
reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be
retrieved under https://www.google.com/intl/en/policies/privacy/ and under
http://www.google.com/analytics/terms/us.html. Google Analytics is further explained
under the following Link https://www.google.com/analytics/. - Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for 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, when processing operations are necessary for the supply of
goods or to provide any other service, the processing is based on Article 6(1) lit. b
GDPR. The same applies to such processing operations which are necessary for
carrying out pre-contractual measures, for example in the case of inquiries
concerning our products or services. Is our company subject to a legal obligation by
which processing of personal data is required, such as for the fulfillment of tax
obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the
processing of personal data may be necessary to protect the vital interests of the
data subject or of another natural person. This would be the case, for example, if a
visitor were injured in our company and his name, age, health insurance data or
other vital information would have to be passed on to a doctor, hospital or other third
party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally,
processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is
used for processing operations which are not covered by any of the abovementioned
legal grounds, if processing is necessary for the purposes of the legitimate interests
pursued by our company or by a third party, except where such interests are
overridden by the interests or fundamental rights and freedoms of the data subject
which require protection of personal data. Such processing operations are
particularly permissible because they have been specifically mentioned by the
European legislator. He considered that a legitimate interest could be assumed if the
data subject is a client of the controller (Recital 47 Sentence 2 GDPR). - The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our
legitimate interest is to carry out our business in favor of the well-being of all our
employees and the shareholders. - Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the
respective statutory retention period. After expiration of that period, the
corresponding data is routinely deleted, as long as it is no longer necessary for the
fulfillment of the contract or the initiation of a contract. - Provision of personal data as statutory or contractual requirement; Requirement
necessary to enter into a contract; Obligation of the data subject to provide the personal
data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax
regulations) or can also result from contractual provisions (e.g. information on the
contractual partner). Sometimes it may be necessary to conclude a contract that the
data subject provides us with personal data, which must subsequently be processed
by us. The data subject is, for example, obliged to provide us with personal data
when our company signs a contract with him or her. The non-provision of the
personal data would have the consequence that the contract with the data subject
could not be concluded. Before personal data is provided by the data subject, the
data subject must contact any employee. The employee clarifies to the data subject
whether the provision of the 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 the consequences of non-provision of the personal data. - Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
Developed by the specialists for LegalTech at Willing & Able that also developed the
system for data protection courses. The legal texts contained in our privacy policy
generator have been provided and published by Prof. Dr. h.c. Heiko Jonny Maniero
from the German Association for Data Protection and Christian Solmecke from WBS
law.