Data protection declaration
This data protection declaration informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and content connected with it as well as external online presences, such as our social media profiles (hereinafter jointly referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
HD Vision Systems GmbH
Dr. Christoph S. Garbe
Link to the imprint: Imprint
Types of data processed:
- Inventory data (e.g., names, addresses)
- Contact data (e.g., email, phone numbers)
- Content data (e.g., text entries, photographs, videos)
- Usage data (e.g., web pages visited, interest in content, access times)
- Meta/communication data (e.g., device information, IP addresses)
Categories of persons concerned
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as “users”).
Purpose of the processing
- Providing the online offer, its functions and contents
- Responding to contact requests and communicating with users
- Security measures
- Reach measurement/marketing
“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.
“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 covers virtually any handling of data.
„Pseudonymisation” means the processing of personal data in such a way that personal data can no longer be related to a specific data subject without additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.
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.
“Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal basis
We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transfer, assurance of availability and separation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account in the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Art. 25 GDPR).
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (order processors or third parties), transmit it to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract pursuant to Art. 6 (1) lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties to process data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this is only done if it is done in order to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or allow the processing of data in a third country if the special requirements of Art. 44 ff. GDPR are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of the data subjects
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 Art. 15 of the GDPR.
You have the right according to. Article 16 of the GDPR to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
In accordance with Art. 17 of the GDPR, you have the right to demand that the data in question be deleted without delay, or alternatively, in accordance with Art. 18 of the GDPR, to demand restriction of the processing of the data.
You have the right to obtain the data concerning you that you have provided to us in accordance with Article 20 of the GDPR and to request that it be transferred to other data controller
You also have the right to lodge a complaint with the competent supervisory authority pursuant to Art. 77 GDPR.
Right of withdrawal
You have the right to revoke consent granted in accordance with Art. 7 (3) of the GDPR with effect for the future.
Right of objection
You may object to the future processing of data relating to you in accordance with Art. 21 GDPR at any time. The objection can be made in particular against processing for direct marketing purposes.
Cookies and right to object to direct advertising
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his or her browser. In such a cookie, for example, the contents of a shopping basket in an online shop or a login status can be stored. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of data
The data we process will be deleted or its processing restricted in accordance with Articles 17 and 18 of the GDPR. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. 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.
According to legal requirements in Germany, data is stored for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 nos. 2 and 3, para. 4 HGB (commercial letters).
According to legal requirements in Austria, storage is carried out in particular for 7 years pursuant to § 132 para. 1 BAO (accounting records, vouchers/invoices, accounts, receipts, business papers, statement of income and expenditure, etc.), for 22 years in connection with real property and for 10 years for records in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is claimed.
When contacting us (e.g. via contact form, email, telephone or social media), the user’s details will be used to process the contact request and handle it in accordance with Art. 6 Para. 1 lit. b. (in the context of contractual/pre-contractual relations), Art. 6 para. 1 lit. f. (other enquiries) GDPR. The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable enquiry organisation.
We delete the enquiries if they are no longer necessary. We review the necessity every two years; Furthermore, the legal archiving obligations apply.
With the following information, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or a legal permission. If the contents of the Newsletter are specifically described in the course of registration, they are decisive for the consent of the users. Apart from that, our newsletters contain information about our services and us.
Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other email addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.
Registration data: To register for the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name for the purpose of a personal address in the newsletter.
The newsletter is sent and its success is measured on the basis of the recipients’ consent pursuant to Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with Section 7 para. 2 no. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lt. f. GDPR. GDPR in conjunction with. § 7 para. 3 UWG.
The logging of the registration process takes place on the basis of our legitimate interests pursuant to Art. 6 para. 1 lt. f GDPR. We are interested in the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and also allows us to prove consent.
Cancellation/revocation – You can cancel receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent previously given. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
Newsletter – Mailchimp
The dispatch service provider may use the recipients’ data in pseudonymous form, i.e. without assigning it to a user, to optimise or improve its own services, e.g. to technically optimise the dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
Newsletter – Success measurement
The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval are initially collected.
This information is used for the technical improvement of the services on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled.
Google Tag Manager
Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus, for example, integrate Google Analytics and other Google marketing services into our online offer). The tag manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, please refer to the following information on Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.
Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous user profiles of the users can be created from the processed data.
We only use Google Analytics with IP anonymisation activated. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
The users’ personal data is deleted or anonymised after 14 months.
Google Universal Analytics
We use Google Analytics in the form of “Universal Analytics”. “Universal Analytics” refers to a Google Analytics procedure in which user analysis is carried out on the basis of a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from the use of different devices (so-called “cross-device tracking”).
Audience building with Google Analytics
We use Google Analytics to display the ads placed within Google’s advertising services and those of its partners only to users who have also shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Google (so-called “Remarketing Audiences” or “Google Analytics Audiences”). With the help of the Remarketing Audiences, we also want to ensure that our ads correspond to the potential interest of the users.
Online presence in social media
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services there.
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 it could, for example, make it more difficult to enforce the rights of the users. With regard to US providers certified under the Privacy Shield, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.
urthermore, user data is usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data may also be stored in the usage profiles irrespective of the devices used by the users (especially if the users are members of the respective
The processing of users’ personal data is based on our legitimate interests in effectively informing users and communicating with users pursuant to Art. 6 para. 1 lit. f. GDPR. If the users are asked by the respective providers for consent to the data processing (i.e. declare their consent e.g. by ticking a checkbox or confirming a button), the legal basis of the processing is Art. 6 para. 1 lit. a., Art. 7 GDPR.
For a detailed description of the respective processing and the opt-out options, please refer to the information of the providers linked below.
In the case of requests for information and the assertion of user 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 help, you can contact us.
- Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland) – Data Protection Declaration: https://www.facebook.com/about/privacy/, Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
- Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) –Data Protection Declaration: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) –Data Protection Declaration/ Opt-Out: http://instagram.com/about/legal/privacy/.
- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) -Data Protection Declaration: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
- LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Irland) – Data Protection Declaration https://www.linkedin.com/legal/privacy-policy , Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
Integration of third-party services and content
Within our online offer, we use content or service offers of third-party providers on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) content or service offers from third-party providers in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.
Typekit fonts from Adobe
We use external “Typekit” fonts from the provider Adobe Systems Software Ireland Limited, 6-6 Riverwalk Citywest Business Campus Dublin 24, Republic of Ireland, on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Art. 6 (1) lit. f. DSGVO). GDPR), we use external “Typekit” fonts from the provider Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland. Adobe is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TNo9AAG&status=Active).
Use of Facebook Social Plugins
We use social plugins (“plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook“) on basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f.
This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user calls up a function of this online offer that contains such a plugin, his or her device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer by the latter. In the process, user profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.
By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his or her Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from their device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and store his or her IP address. According to Facebook, only an anonymised IP address is stored in Germany.
If a user is a Facebook member and does not want Facebook to collect data about him/her via this online offer and link it to his/her membership data stored on Facebook, he/she must log out of Facebook and delete his/her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
Within our online offer, functions and contents of the service Twitter, offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, may be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Twitter.