Privacy Policy of oh22systems GmbH

We are very delighted that you have shown interest in our enterprise. Data
protection is of a particularly high priority for the management of
oh22systems GmbH (OH22). The use of the Internet pages of OH22 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 OH22. 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, OH22 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 in principle may 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.

A. Definitions

The data protection declaration of OH22 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:

1. 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.

2. Data subject

Data subject is any identified or identifiable natural person, whose
personal data is processed by the controller responsible for the
processing.

3. 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, organization, structuring, storage,
adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction.

4. Restriction of processing

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

5. 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 analyze or predict aspects
concerning that natural person’s performance at work, economic situation,
health, personal preferences, interests, reliability, behavior, location or
movements.

6. 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
organizational measures to ensure that the personal data are not attributed
to an identified or identifiable natural person.

7. 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. 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.

8. Processor

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

9. 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.

10. 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 authorized to
process personal data.

11. 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.

B. 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:

oh22systems GmbH

Otto-Hahn-Strasse 22

65520 Bad Camberg

Germany

Phone: +49-6434-2091-0

Email: systems[at]oh22systems[dot]net

Website: www.oh22systems.net

C. Name and Address of the Data Protection Officer

The Data Protection Officer of the controller is:

Nadja Stotz

oh22systems GmbH

Otto-Hahn-Strasse 22

65520 Bad Camberg

Germany

Phone: +49-6434-2091-0

E-Mail: dataprotection[at]oh22systems[dot]net

Website: www.oh22systems.net

Any data subject may, at any time, contact our Data Protection Officer
directly with all questions and suggestions concerning data protection.

D. Cookies

The Internet pages of OH22 use cookies. Cookies are text files that are
stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a
so-called cookie ID. A cookie ID is a unique identifier of the cookie. It
consists of a character string through which Internet pages and servers can
be assigned to the specific Internet browser in which the cookie was
stored. This allows visited Internet sites and servers to differentiate the
individual browser of the data subject from other Internet browsers that
contain other cookies. A specific Internet browser can be recognized and
identified using the unique cookie ID.

By using cookies, OH22 can provide the users of this website with more
user-friendly services that would not be possible without the cookie
setting.

By means of a cookie, the information and offers on our website can be
optimized with the user in mind. Cookies allow us, as previously mentioned,
to recognize our website users. The purpose of this recognition is to make
it easier for users to utilize our website. The website user that uses
cookies e.g. does not have to enter access data each time the website is
accessed, because this is taken over by the website, and the cookie is thus
stored on the user’s computer system. Another example is the cookie of a
shopping cart in an online shop. The online store remembers the articles
that a customer has placed in the virtual shopping cart via a cookie.

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

E. Collection of general data and information

The website of OH22 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

(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, OH22 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

(4) provide law enforcement authorities with the information necessary for
criminal prosecution in case of a cyber-attack.

Therefore, OH22 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.

F. Contact possibility via the website

The website of OH22 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.

G. 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.

H. Rights of the data subject

 

1. 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.

2. 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:

o the purposes of the processing;

o the categories of personal data concerned;

o the recipients or categories of recipients to whom the personal data have
been or will be disclosed, in particular recipients in third countries or
international organizations;

o where possible, the envisaged period for which the personal data will be
stored, or, if not possible, the criteria used to determine that period;

o 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;

o the existence of the right to lodge a complaint with a supervisory
authority;

o where the personal data are not collected from the data subject, any
available information as to their source;

o 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 organization. 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.

3. 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.

4. 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:

o The personal data are no longer necessary in relation to the purposes for
which they were collected or otherwise processed.

o 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.

o 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.

o The personal data have been unlawfully processed.

o The personal data must be erased for compliance with a legal obligation
in Union or Member State law to which the controller is subject.

o 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 OH22, he or she may, at any
time, contact any employee of the controller. The data protection officer
of OH22 shall promptly ensure that the erasure request will be processed
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. The data protection officer of
OH22 will arrange the necessary measures in individual cases.

5. 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:

o The data subject contests the accuracy of the personal data, for a period
enabling the controller to verify the accuracy of the personal data.

o The processing is unlawful and the data subject opposes the erasure of
the personal data and requests instead the restriction of their use
instead.

o The controller no longer needs the personal data for the purposes of the
processing, but they are required by the data subject for the
establishment, exercise or defense of legal claims.

o 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
OH22, he or she may at any time contact any employee of the controller. The
data protection officer of OH22 will arrange the restriction of the
processing.

6. 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 OH22.

7. 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.

OH22 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 defense of legal claims.

If OH22 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 OH22 to the processing for direct marketing
purposes, OH22 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 OH22 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 OH22. 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.

8. 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 authorized 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) is based on the data subject’s explicit consent

OH22 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 the data
protection officer of OH22.

9. 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 the data protection officer of OH22 by
phone or E-Mail.

I. Data protection for applications and the application procedures

The data controller shall collect and process the personal data of
applicants for the purpose of the processing of the application procedure.
The processing may also be carried out electronically. This is the case, in
particular, if an applicant submits corresponding application documents by
e-mail or by means of a web form on the website to the controller. If the
data controller concludes an employment contract with an applicant, the
submitted data will be stored for the purpose of processing the employment
relationship in compliance with legal requirements. If no employment
contract is concluded with the applicant by the controller, the application
documents shall be automatically erased two months after notification of
the refusal decision, if no other legitimate interests of the controller
are opposed to the erasure. Other legitimate interest in this relation is,
e.g. a burden of proof in a procedure under the General Equal Treatment Act
(AGG).

J. 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 Inc.

1600 Amphitheatre Pkwy

Mountain View, CA 94043-1351

United States

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 anonymized 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. Google considers the installation of the browser add-ons.
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/.

K. 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 the European legislator has specifically mentioned
them. He considered that a legitimate interest could be assumed if the data
subject is a client of the controller (Recital 47 Sentence 2 GDPR).

L. 12. 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.

M. 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.

N. 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 obliged to
provide us with personal data when our company signs a contract with him or
her for example. 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.

O. Existence of automated decision-making

As a responsible company, we do not use automatic decision-making or
profiling.

This Privacy Policy has been generated by the Privacy Policy Generator of
the

DGD – Your External DPO

that was developed in cooperation with German Lawyers from WILDE BEUGER
SOLMECKE, Cologne.