Name and address of the responsible entity
- RMH MEDIA GmbH
- Address: Richmodstraße 31, 50667 Cologne/Germany
- Telephone: 0221 / 643031 0
- Telefax: 0221 / 643031 50
- Internet: www.rmh-media.com
- E-Mail: email@example.com
Data Protection Officer (see Article 37 GDPR)
- Manuel Schömburg
- E-Mail: firstname.lastname@example.org
1 General information on data processing
1.1 Scope of the processing of personal data
As a matter of principle, we process personal data of our users only insofar as this is necessary to provide a functional website as well as our content and services. The processing of personal data of our users is regularly carried out only with the consent of the user. An exception applies in those cases where obtaining prior consent is not possible for actual reasons and the processing of the data is permitted by legal regulations.
1.2 Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations involving personal data, Art. 6 (1) lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis. When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Art. 6 (1) lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures. Insofar as processing of personal data is necessary for the fulfillment of a legal obligation to which our company is subject, Art. 6 (1) lit. c GDPR serves as the legal basis. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d GDPR serves as the legal basis. If the processing is necessary to protect a legitimate interest of our company or a third party and the interests, fundamental rights and freedoms of the data subject do not override the former interest, Art. 6 (1) lit. f GDPR serves as the legal basis for the processing.
1.3 Data deletion and storage period
The personal data of the data subject will be deleted or blocked as soon as the purpose of storage ceases to apply. Storage may take place beyond this if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.
1.4 Duty to inform about data processing
Important note: For the sake of clarity, you will find the rights of data subjects listed once below (point 1.5), as they apply to every processing activity. Likewise, points 1.1 to 1.4 and 1.6 to 1.9 always also apply to all processing activities.
1.5 Rights of the data subject
1.5.1 Right of access (see Article 15 GDPR).
You may request confirmation from the controller as to whether personal data concerning you is being processed by us. If such processing is taking place, you may request information from the controller about the following:
- the purposes for which the personal data are processed;
- the categories of personal data which are processed;
- the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
- the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage period;
- the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
- the existence of a right of appeal to a supervisory authority;
- any available information on the origin of the data, if the personal data are not collected from the data subject;
- the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
- You have the right to request information about whether personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.
1.5.2 Right to rectification of inaccurate data (see Article 16 GDPR)
You have a right to rectification and/or completion towards the controller, if the processed personal data concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
1.5.3 Right to erasure (siehe Artikel 17 DSGVO)
a) Obligation to delete You may request the controller to delete the personal data concerning you without undue delay, and the controller is obliged to delete such data without undue delay, if one of the following reasons applies:
- The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
- You withdraw your consent on which the processing was based pursuant to Art. 6 (1) a or Art. 9 (2) a GDPR and there is no other legal basis for the processing.
- You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) GDPR.
- The personal data concerning you has been processed unlawfully.
- The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
- The personal data concerning you has been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.
b) Information to third parties
If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.
The right to erasure does not exist insofar as the processing is necessary
- for the exercise of the right to freedom of expression and information;
- for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
- for the assertion, exercise or defense of legal claims.
1.5.4 Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right against the controller to be informed about these recipients.
1.5.5 Right to restriction of processing (siehe Artikel 18 DSGVO)
Under the following conditions, you may request the restriction of the processing of personal data concerning you:
- you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
- the controller no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defense of legal claims; or
- if you have objected to the processing pursuant to Article 21 (1) GDPR and it is not yet clear whether the legitimate grounds of the controller outweigh your grounds.
Where the processing of personal data concerning you has been restricted, such data may be processed, with the exception of storage, only with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State. If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
1.5.6 Right to data portability (see Article 20 GDPR)
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. In addition, you have the right to transfer this data to another controller without hindrance by the controller to whom the personal data was provided, provided that
- the processing is based on consent pursuant to Art. 6 (1) a GDPR or Art. 9 (2) a GDPR or on a contract pursuant to Art. 6 (1) b GDPR and
- the processing is carried out with the help of automated procedures.
In exercising this right, you also have the right to have the personal data concerning you transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.
The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
1.5.7 Right to object (see Article 21 GDPR)
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to processing of the personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing. If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes. You have the possibility, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise your right to object by means of automated procedures using technical specifications.
1.5.8 Right to revoke declaration of consent under data protection law (see Article 21 of the GDPR)
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
1.5.9 Right to complain to a supervisory authority (see Article 77 of the GDPR)
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 residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 of the GDPR.
The contact details of the supervisory authority in NRW are:
1.6 Automated individual case decision / profiling (see Article 4. No. 4 GDPR).
Does not occur.
1.7 Data transfer to recipients in third countries (outside the EU) (see Article 44 GDPR).
Does not occur.
1.8 Multiple controllers in the sense of joint responsibility (see Article 26 GDPR).
There is only the one controller mentioned above.
1.9 Data collection by third parties
Does not occur.
2 Providing the website and creating log files
2.1 Description and scope of data processing
Each time our website is visited, our system automatically collects data and information from the computer system of the calling computer. The following data is collected in this process:
– Information about the browser type and the version used
– Date and time of access
– Websites from which the user’s system accesses our website
This data is also stored in the log files of our system. Not affected by this are the IP addresses of the user or other data that allow the data to be assigned to a user. This data is not stored together with other personal data of the user.
2.2 Legal basis for data processing
The legal basis for the temporary storage of data is Art. 6 para. 1 lit. f GDPR.
2.3 Purpose of data processing
The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user’s computer. For this purpose, the user’s IP address must remain stored for the duration of the session. These purposes are also our legitimate interest in data processing according to Art. 6 para. 1 lit. f GDPR.
2.4 Category of personal data
2.5 Category of data subjects
Visitors to the website
2.6 Category of recipients
2.7 Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
2.8 Possibility of objection and elimination
The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.
3.1 Description and scope of data processing
3.2 Legal basis for data processing
The legal basis for the processing of personal data using cookies is Art. 6 (1) lit. f GDPR.
3.3 Purpose of the data processing
The cookie is set exclusively to note in the browser that the cookie disclaimer has been accepted. Cookies are not used beyond this.
3.4 Category of personal data
3.5 Category of data subjects
Visitors to the website
3.6 Category of recipients
3.7 Duration of storage
The cookie is set with a duration of 30 days.
3.8 Possibility of objection and removal
4 Contact form and contact by e-mail
For each of the following processing operations, the information and rights listed under point 1. apply.
4.1 Description and scope of data processing
A contact form is available on our website, which can be used for electronic contact. If a user takes advantage of this option, the data entered in the input mask is transmitted to us (128 bit TLS encryption) and stored. These data are: Name, e-mail address, telephone number. At the time of sending the form, the date and time of sending is also stored. Alternatively, it is possible to contact us via the e-mail address provided. In this case, the user’s personal data transmitted with the e-mail will be stored. In this context, the data will not be passed on to third parties. The data is used exclusively for processing the conversation.
4.2 Legal basis for data processing
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 (1) lit. f GDPR.
If the e-mail contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b GDPR.
4.3 Purpose of the data processing
The processing of the personal data from the input mask serves us solely to process the contact. In the case of contact by e-mail, this also constitutes the necessary legitimate interest in processing the data. The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
4.4 Category of personal data
Contact/Application Data. Everything that the data subject sends in.
4.5 Category of data subjects
4.6 Category of recipients
Employee (back office)
4.7 Duration of storage
The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form and those sent by e-mail, this is the case when the respective conversation with the user has ended. The conversation is ended when it is clear from the circumstances that the matter in question has been conclusively clarified. The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
4.8 Possibilities of objection and removal
The user has the option to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail email@example.com, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued. All personal data stored in the course of contacting us will be deleted in this case.
5 Application management
For each of the following processing operations, the information and rights listed in point 1. apply.
5.1 Description and scope of data processing
We receive application documents that contain personal data.
5.2 Legal basis for data processing
The legal basis for the processing of the data mentioned under point 5.1 is Art. 6 (1) lit. f GDPR in conjunction with §26 BDSG.
5.3 Purpose of data processing
The processing of application documents.
5.4 Category of personal data
Application documents (cover letter, CV, certificates, proof of work and anything else the person sends in).
5.5 Category of data subjects
5.6 Category of recipients
5.7 Duration of storage
In principle, we delete the documents after the purpose has been fulfilled or they are transferred to the personnel file. With regard to legal aspects (AGG), we also retain the data for a further 6 months after the purpose has been fulfilled. Further storage for 1 year from collection can only take place if the person concerned gives us consent to do so.
5.8 Possibilities of objection and removal
The user has the option to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. With the revocation, the participation in the application process ends. The legality of the data processing carried out until the revocation remains unaffected by the revocation, as does any storage in accordance with legal requirements.
6 Customer management / CRM
The information and rights listed under point 1. apply to each of the following processing operations
6.1 Description and scope of data processing
Managing and maintaining customer and prospect data (“Customer Relationship Management (CRM)”).
6.2 Legal basis for data processing
The legal basis for the processing of the data mentioned under point 6.1 is Art. 6 (1) lit. f GDPR.
6.3 Purpose of data processing
Maintenance of customer relationships and relationships with interested parties
6.4 Category of personal data
First name, last name, title, company name, address (business), Internet address, e-mail address, telephone number, fax number, marital status, customer number, type of customer, contact data, contact history, appointment data, data on interests, data on purchased services/products, contract data, communication data, photos, information on profession.
6.5 Category of data subjects
Customers, interested parties, employees
6.6 Category of recipients
6.7 Duration of storage
In the case of personal data in the CRM system, a check is made after two years at the end of the respective calendar year to determine whether further storage is necessary. If there is no need, the data will be deleted. An exception to this is data that is to be classified as business letters within the meaning of the German Commercial Code (HGB) or as accounting-relevant data. Here, the respective statutory retention obligations apply.
6.8 Possibilities of objection and removal
If the interested party or customer contacts us by e-mail, he can object to the storage of his personal data at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation, as does storage in accordance with legal requirements.