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Privacy Policy An overview of data protection 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 CHRITTO international AG. When visiting our website, statistical analyses may be made of your surfing behavior. This happens primarily using cookies and analytics. The analysis of your surfing behavior is usually anonymous, i.e. we will not be able to identify you from this data. You can object to this analysis or prevent it by not using certain tools. Detailed information can be found in the following privacy policy. You can object to this analysis. We will inform you below about how to exercise your options in this regard. Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed. This site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon is displayed in your browser’s address bar. If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties. Notice concerning the party responsible for this website The party responsible for processing data on this website is: CHRITTO international AG Industriestr. 51399 Burscheid Germany Email: This email address is being protected from spambots. You need JavaScript enabled to view it. III. Data protection officer We have appointed a data protection officer for our company. Dittmar Müller Industriestr. 51399 Burscheid Germany Email: This email address is being protected from spambots. You need JavaScript enabled to view it. Data collection on our website Cookies Some of our web pages use cookies. Cookies do not harm your computer and do not contain any viruses. Cookies help make our website more user-friendly, efficient, and secure. Cookies are small text files that are stored on your computer and saved by your browser. Most of the cookies we use are so-called “session cookies.” They are automatically deleted after your visit. Other cookies remain in your device’s memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site. You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of this website. Cookies which are necessary to allow electronic communications or to provide certain functions you wish to use (such as the shopping cart) are stored pursuant to Art. 6 paragraph 1, letter f of DSGVO. The website operator has a legitimate interest in the storage of cookies to ensure an optimized service provided free of technical errors. If other cookies (such as those used to analyze your surfing behavior) are also stored, they will be treated separately in this privacy policy. Server log files The website provider automatically collects and stores information that your browser automatically transmits to us in “server log files”. These are: – Browser type and browser version – Operating system used – Referrer URL – Host name of the accessing computer – Time of the server request – IP address These data will not be combined with data from other sources. The basis for data processing is Art. 6 (1) (f) DSGVO, which allows the processing of data to fulfill a contract or for measures preliminary to a contract. Google Analytics This website uses Google Analytics, a web analytics service. It is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Google Analytics cookies are stored based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in analyzing user behavior to optimize both its website and its advertising. We have activated the IP anonymization feature on this website. Your IP address will be shortened by Google within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity, and to provide other services regarding website activity and Internet usage for the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google. You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set to prevent your data from being collected on future visits to this site: Disable Google Analytics. For more information about how Google Analytics handles user data, see Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en. We have entered into an agreement with Google for the outsourcing of our data processing and fully implement the strict requirements of the German data protection authorities when using Google Analytics. Google Web Fonts For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly. For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO. If your browser does not support web fonts, a standard font is used by your computer. Further information about handling user data, can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/. Google reCAPTCHA We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). reCAPTCHA is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google. The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that such an analysis is taking place. Data processing is based on Art. 6 (1) (f) DSGVO. The website operator has a legitimate interest in protecting its site from abusive automated crawling and spam. For more information about Google reCAPTCHA and Google’s privacy policy, please visit the following links: https://www.google.com/intl/de/policies/privacy/ and https://www.google.com/recaptcha/intro/android.html. Chat In addition to your user name, your e-mail address will also be stored for the chat function on our site. We collect and process personal information that you provide to us for the purpose of using our service and which allows us to comply with our obligations in this regard. In particular, we will collect and process chat session information such as IP address, time and general chat facts as well as information about chat content and uploaded files to provide you with our service. All data will be deleted after expiry of the intended use. This data is stored on the basis of your consent, Art. 6 (1) (a) DSGVO. Contact form Should you send us questions via the contact form, we will collect the data entered on the form, including the contact details you provide, to answer your question and any follow-up questions. We do not share this information without your permission. We will, therefore, process any data you enter onto the contact form only with your consent per Art. 6 (1) (a) DSGVO. You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed. We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision. Legal basis for the processing - Art. 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. 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. 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. Rights of the data subject 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. 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. 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. 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 CHRITTO international AG, he or she may, at any time, contact any employee of the controller. An employee of CHRITTO international AG 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 CHRITTO international AG will arrange the necessary measures in individual cases. 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 CHRITTO international AG, he or she may at any time contact any employee of the controller. The employee of the CHRITTO international AG will arrange the restriction of the processing. 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 CHRITTO international AG. 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 CHRITTO international AG 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 CHRITTO international AG 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 CHRITTO international AG to the processing for direct marketing purposes, the CHRITTO international AG 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 CHRITTO international AG 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 CHRITTO international AG. 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. 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 CHRITTO international AG 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 CHRITTO international AG. 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 CHRITTO international AG. Right to file complaints with regulatory authorities If there has been a breach of data protection legislation, the person affected may file a complaint with the competent regulatory authorities. The competent regulatory authority for matters related to data protection legislation is the data protection officer of the German state in which our company is headquartered. A list of data protection officers and their contact details can be found at the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.
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S obzirom na društvo brzog tehnološkog razvoja, opseg prikupljanja i razmjene osobnih podataka značajno se povećava. Kako bi pojedinci imali mogućnost što kvalitetnijeg nadzora nad vlastitim osobnim podacima, Opća uredba o zaštiti podataka u svom trećem poglavlju detaljno određuje prava ispitanka u cilju ostvarenja djelotvorne zaštite vlastitih osobnih podataka. Pravo na informiranje U člancima 12. do 14. Uredbe određeno je da ispitanik ima pravo saznati sve informacije od voditelja obrade u vezi prikupljanja njegovih osobnih podataka. To znači da voditelji obrade osobnih podataka informacije o navedenom pravu mogu pružiti ispitanicima putem javnih dokumenata o zaštiti privatnosti u kojima su im dužni dostaviti sve podatke iz članka 13. stavka 1. Uredbe, a koji se odnose na prava ispitanika i načine na koje ih mogu ostvarivati. (recital 58 Uredbe) Pravo na pristup Prema članku 15. Uredbe, ispitanik ima pravo dobiti od voditelja obrade potvrdu obrađuju li se osobni podaci koji se odnose na njega te ako se takvi osobni podaci obrađuju, ima pravo na pristup osobnim podacima i informacije, među ostalim, o obrađenim osobnim podacima, o svrsi obrade, roku pohrane, iznošenju u treće zemlje itd. Pravo na ispravak U članku 16., Uredba ispitaniku pruža pravo zahtijevati ispravak netočnih osobnih podataka koji se na njega odnose. Uzimajući u obzir svrhe obrade, ispitanik ima pravo dopuniti nepotpune osobne podatke, uz ostale načine, i davanjem dodatne izjave. Pravo na zaborav Ispitanik ima pravo od voditelja obrade zahtjevati brisanje osobnih podataka koji se na njega odnose te voditelj obrade ima obvezu obrisati osobne podatke bez nepotrebnog odgađanja ako osobni podaci više nisu nužni u odnosu na svrhu obrade, ispitanik je povukao privolu za obradu, osobni podaci su nezakonito obrađeni itd. (članak 17. Uredbe) Pravo na ograničavanje obrade U pojedinim situacijama ispitanik ima pravo od voditelja obrade zahtijevati da se obrada njegovih osobnih podataka ograniči, i to kada su ispunjeni Uredbom propisani uvjeti (članak 18. Uredbe) Pravo na prijenos Ispitanik ima pravo zaprimiti svoje osobne podatke koje je prethodno pružio voditelju obrade, u strukturiranom obliku te u uobičajeno upotrebljavanom i strojno čitljivom formatu. Također ima pravo prenijeti te podatke drugom voditelju obrade bez ometanja od strane voditelja obrade kojem su osobni podaci pruženi, ako se obrada provodi automatiziranim putem i temelji na privoli ili ugovoru (članak 20. Uredbe) Pravo na prigovor Ispitanik ima pravo na temelju svoje posebne situacije uložiti prigovor na obradu osobnih podataka ako je ona nužna za izvršavanje zadaće od javnog interesa, za izvršavanje službenih ovlasti voditelja obrade ili za potrebe legitimnih interesa voditelja obrade (uključujući i profiliranje). Tada voditelj obrade ne smije više obrađivati osobne podatke ispitanika (osim ako dokaže da njegovi legitimni razlozi za obradu nadilaze interese ispitanika) te radi zaštite pravnih zahtjeva. Također, ako se ispitanik protivi obradi za potrebe izravnog marketinga, osobni podaci više se ne smiju obrađivati (članak 21 Uredbe). Zahtjev za zaštitu prava Početkom primjene GDPR-a, a sukladno članku 34. Zakona o provedbi Opće uredbe o zaštiti podataka (NN 42/18), svatko tko smatra da mu je povrijeđeno neko pravo zajamčeno tim Zakonom i Općom uredbom o zaštiti podataka može nadzornom tijelu (Agenciji za zaštitu osobnih podataka) podnijeti zahtjev za utvrđivanje povrede navedenih prava. Zahtjev za zaštitu prava ispitanik može podnijeti osobno ili pisanim putem te je u njemu dužan navesti osobne podatke potrebne radi provođenja postupka i objašnjenje u čemu se sastoji povreda prava ispitanika. Agencija će o zahtjevu odlučiti rješenjem koje je upravni akt i protiv kojega žalba nije dopuštena, ali se može pokrenuti upravni spor pred nadležnim upravnim sudom. Ana Paštrović, mag.iur.