Privacy policy

This privacy policy explains the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and the associated websites, functions and content as well as external online presences, such as our social media profile. (hereinafter jointly referred to as the “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).

Person responsible

SRC Commerce UG


69469 Weinheim
Owner: H.Montini-Wagner
E-Mail: contact@src-commerce.eu

Types of data processed:

– Inventory data (e.g., names, addresses).
– Contact details (e.g., e-mail, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).

Purpose of the processing

– Provision of the online offer, its functions and content.
– Answering contact requests and communicating with users.
– Safety measures.
– Reach measurement/marketing

Terminology used

“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 on personal data, whether or not by automated means. The term is far-reaching and covers practically any handling of data.

The “controller” 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.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not stated in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for the processing for the fulfillment of our services and the implementation of contractual measures as well as answering inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR as the legal basis.

Security measures

We take appropriate technical and organizational measures in accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk; 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, disclosure, safeguarding of availability and their separation. Furthermore, we have set up procedures to ensure that the rights of data subjects are exercised, data is deleted and we respond to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).

Cooperation with processors and third parties

If we disclose data to other persons and companies (processors or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is required to fulfill the contract in accordance with Art. 6 para. 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 with the processing of 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 occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

Rights of the data subjects

You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.

You have accordingly. In accordance with Art. 16 GDPR, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with Art. 18 GDPR.

You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request that it be transferred to other data controllers.

You also have acc. Art. 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority.

Right of withdrawal

You have the right to withdraw your consent in accordance with. Art. 7 para. 3 GDPR with effect for the future

Right of objection

You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection may 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 their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes their browser. For example, the content of a shopping cart in an online store or a login status can be stored in such a cookie. Permanent” or “persistent” cookies are cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only the controller’s cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies and provide information about this in our privacy policy.

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. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be disabled in the browser settings. Please note that you may then not be able to use all the functions of this website.

Deletion of data

The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, 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 are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

According to legal requirements in Germany, the storage is carried out in particular for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, trading books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).

According to legal requirements in Austria, storage is carried out in particular for 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services that are provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

Hosting

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating this online offering.

We, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit. f GDPR in conjunction with. Art. 28 GDPR (conclusion of order processing contract).

Collection of access data and log files

We, or our hosting provider, collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum of 7 days and then deleted. Data whose further retention is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

Provision of our statutory and business-related services

We process the data of our members, supporters, interested parties, customers or other persons in accordance with Art. 6 para. 1 lit. b. GDPR, insofar as we offer them contractual services or act within the framework of an existing business relationship, e.g. with members, or are ourselves recipients of services and benefits. Otherwise, we process the data of data subjects in accordance with. Art. 6 para. 1 lit. f. GDPR on the basis of our legitimate interests, e.g. in the case of administrative tasks or public relations work.

The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. This basically includes inventory and master data of the persons (e.g., name, address, etc.), as well as contact data (e.g., e-mail address, telephone, etc.), contract data (e.g., services used, content and information provided, names of contact persons) and, if we offer services or products subject to payment, payment data (e.g., bank details, payment history, etc.).

We delete data that is no longer required to fulfill our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. In the case of business processing, we retain the data for as long as it may be relevant for business transactions and with regard to any warranty or liability obligations. The necessity of retaining the data is reviewed every three years; otherwise the statutory retention obligations apply.

Administration, financial accounting, office organization, contact management

We process data as part of administrative tasks and the organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process as part of the provision of our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information specified in these processing activities.

We disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.

We also store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We store this data, most of which is company-related, permanently.

Contact us

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user’s details are used to process the contact request and its handling in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit. b) GDPR is processed. User data may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.

We delete the requests if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.

Integration of third-party services and content

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third-party providers within our online offer. GDPR), we use content or service offers from third-party providers to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).

This always presupposes that the third-party providers of this content are aware of the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content. We endeavor 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. Pixel tags can be used to analyze 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 contain, among other things, technical information about the browser and operating system, referring websites, visit time and other information about the use of our online offer, as well as being linked to such information from other sources.

Google Maps

We integrate the maps of the “Google Maps” service of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually in the context of the settings of their mobile devices). The data may be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.