Privacy Statement by Kohfahl Ballstrategien GmbH & Co. KG for www.frmclinics.co.uk
Some personal data is collected from you on the web pages of Kohfahl Ballstrategien GmbH & Co. KG (referred to hereinafter as “Kohfahl Ballstrategien”). Kohfahl Ballstrategien believes it is a self-evident obligation to collect, transfer, store and otherwise process this data exclusively for the performance of contracts and the pursuit of its legitimate business interests in accordance with the valid rules on the protection of personal data. The following information instructs you on how Kohfahl Ballstrategien processes this data:
1. Name and contact details of the controller and the Data Protection Officer
Kohfahl Ballstrategien GmbH & Co. KG
Tel.: +49 (0)40 / 380 440 40
2. Collection, storage and other processing of personal data, as well as the type and purpose of its use
(a) When visiting the website www.frmclinics.co.uk
The browser installed on your device automatically transmits information to us when you access our website. This information is stored in a ‘log management system’. The following information is collected and stored until its erasure:
- IP address of the accessing computer
- Date and time of access
- Name and URL of the accessed file
- Referrer URL (website from where access is made)
- Your browser and possibly your computer’s operating system
We process this data for the following purposes:
- To guarantee a smooth connection with the website
- To ensure our website’s ease-of-use
- To analyse system security and stability; and
- For other administrative purposes
The legal grounds for this data processing are set out in Article 6 paragraph 1 sentence 1 point (f) of the General Data Protection Regulation (GDPR). The purposes listed above constitute our legitimate interests. On no account will we use the collected data to draw conclusions about your identity.
(b) Online booking of camps
You are required to register with us to book camps online. Personal data is collected during registration, for instance your name, title, address, e-mail address, delivery address and payment method. Provision of this data is mandatory. It is used to identify our contracting partner and to perform the contract.
The legal grounds for data processing are set out in Article 6 paragraph 1 sentence 1 point (b) GDPR.
During registration, we request information about the participant’s state of health. We require this information to ensure that we are aware of any health issues or allergies that may apply to the participants and to be able to include these considerations in our preparations and organisation. Unfortunately, participation is not possible if you do not provide this information and consent. The legal grounds for data processing are set out in Article 6 paragraph 1 sentence 1 point (a) GDPR.
We request additional information in connection with payment for the provision of paid services (refer to Section 6).
(c) When subscribing to our newsletter online
If you have provided consent according to Article 6 paragraph 1 sentence 1 point (a) GDPR, we will use your e-mail address to send you our regular newsletter. You are required to provide an e-mail address to receive our newsletter. Our company’s newsletter can only be received by you if you have a valid e-mail address and have subscribed to the newsletter.
The personal data collected in connection with your newsletter subscription is used to send you the newsletter. Moreover, where it is necessary to operate the newsletter service or to organise the necessary registration, newsletter subscribers may receive e-mail alerts if there are changes to the newsletter service or technical circumstances.
You may cancel your subscription to our newsletter at any time without charge.
You are also entitled to withdraw your consent for the storage of personal data at any time.
Each newsletter contains a link that you can use to cancel the newsletter or withdraw your consent. There are other options to inform the controller of your decision, for instance by sending an e-mail to the address email@example.com.
(d) When making contact with us
We provide a contact form on our website www.frmclinics.co.uk that customers may use to make contact with us by e-mail or telephone.
The data processing will depend on the content of your enquiry.
Depending on the type of enquiry, the legal grounds for data processing are set out in Article 6 paragraph 1 sentence 1 point (b) GDPR or in Article 6 paragraph 1 sentence 1 point (f) GDPR. Our legitimate interests lie in responding to your enquiry.
(e) When using the comment function in our blog
You may post public comments to our blog, which publishes various articles on issues concerning our activities. Your comment will be published beneath the article together with the name you provide. We also store your IP address when you post a comment. We are required to store this information for the defence of liability claims in the event that unlawful content is posted. Your e-mail is necessary so that we can make contact with you if a third party claims that your comment is unlawful. The legal grounds are set out in Article 6 paragraph 1 points (b) + (f) GDPR. Comments are not checked before they are published. We reserve the right to delete comments that third parties have claimed to be unlawful.
(f) Data of business partners and their employees
We may store the contact details (surname, first name, telephone number, e-mail address, company affiliation) of our business partners and the primary contacts at our business partners for the preparation, establishment and performance of contractual relationships. The legal grounds for data processing are set out in Article 6 paragraph 1 point (f) GDPR. Our legitimate interests lie in the preparation, establishment and performance of contracts.
(g) Data protection for applications and in the applications procedure
We collect and process the personal data of individuals who apply for a position at Kohfahl Ballstrategien to manage the applications procedure. The legal grounds for data processing are set out in Article 88 GDPR in conjunction with Section 26 Federal Data Protection Act (BDSG). Processing may take place electronically. This is the case, in particular, if a candidate sends application documents to us by electronic means, for instance by e-mail or using the contact form on our website. Where we enter into a contractual relationship with the candidate, the data transmitted to us will be used for the performance of the contract with due adherence to the statutory requirements.
On the one hand, cookies are used to make our services more attractive. For instance, we use session cookies to detect whether you have already visited individual pages on our website. They are deleted automatically when you close our website.
Moreover, we use temporary cookies that are stored on your device for a defined period, also to optimise ease-of-use. This means that when you return to our website to use our services, we are able to detect automatically that you have already visited us and which information you provided and settings you made, so that you do not have to repeat the process.
The data processed by the cookies is required for the aforementioned purposes to protect our legitimate interests and the legitimate interests of third parties according to Art. 6 paragraph 1 sentence 1 point (f) GDPR.
4. Analytics/tracking tools
The analytics/tracking measures that we use and that are described in the following are carried out according to Art. 6 paragraph 1 sentence 1 point (f) GDPR. We use these analytics/tracking measures to ensure needs-based design and continuous optimisation of our website. We also use the analytics/tracking measures to compile statistics on the use of our website and to optimise our services. These interests are considered legitimate according to the regulation quoted above.
The purposes of data processing and the data categories are stated in connection with each analytics/tracking tool.
(a) Google Analytics
We use Google Analytics, a web analytics service by Google Inc. (https://www.google.co.uk/intl/en/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; in the following “Google”) for the needs-based design and continuous optimisation of our pages. Pseudonymised usage profiles and cookies (refer to Section 3) are used in this context. The information generated by the cookie about your use of this website, for instance
- Browser type/version
- Operating system used
- Referrer URL (the site you last visited)
- Host name of the accessing computer (IP address)
- Time of the server enquiry
is transferred to a Google server in the United States and stored there. The information is used to analyse usage of the website, to compile reports on website activities and to provide other services associated with website and Internet usage for the purposes of market research and to ensure needs-based design of this website. This information may also be transferred to third parties where it is required by law or these third parties process the data on our behalf. On no accounts will your IP address be associated by other Google data. The IP addresses are anonymised so that identification is not possible (IP masking). Google is certified according to the EU-U.S. Privacy Shield (www.privacyshield.gov), for which the EU Commission has issued an adequacy decision (refer to http://ec.europa.eu/newsroom/just/item-detail.cfm?item_id=605819) confirming that an adequate level of data protection is guaranteed.
You can object to the use of Google Analytics as follows: You can prevent the installation of cookies by making suitable adjustments to your browser settings; but please be aware that you may not be able to use all functions of our website in this case.
In addition, you can prevent collection of the data generated by the cookie about your use of the website (including your IP address) and the processing of this data by Google by downloading and installing a browser add-on (https://tools.google.com/dlpage/gaoptout?hl=en).
As an alternative to the browser add-on, especially for browsers on mobile devices, you can prevent the collection of data by Google Analytics by clicking on the following link https://tools.google.com/dlpage/gaoptout This places on opt-out cookie on your device that prevents the collection of your data when you visit this website. The opt-out cookie only applies to this browser and only for this website and is placed on your device. You must install the opt-out cookie again if you delete cookies in this browser.
For further information about data protection in connection with Google Analytics, visit the Google Analytics help page at (https://support.google.com/analytics/answer/6004245?hl=en).
(b) Facebook conversion pixel
This tag establishes a direct connection with the Facebook servers when you visit the website. Which Internet pages you visited is then transmitted to the Facebook server. It associates this information with your personal user account on Facebook.
You can place a cookie on your device that will prevent installation of the Facebook pixel by clicking on the following link: Facebook-Pixel Opt-Out
5. Youtube plug-in
Furthermore, our website uses YouTube plug-ins provided by YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA, a subsidiary of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.
Accessing a page on our website that includes a YouTube video will establish a direct connection between your browser and the YouTube server. YouTube and Google will therefore receive information about which subpages you visited with your IP address.
If you are signed into YouTube at the same time, YouTube will detect the subpage of our website that you visited whenever it contains a YouTube video. This information is collected by YouTube and Google and associated with your YouTube account.
YouTube and Google will always receive information from the YouTube plug-ins that you have visited our website when you are simultaneously signed into your YouTube account while visiting our site; this takes place regardless of whether you click on YouTube video or not. You can prevent the transfer of this information by signing out of your YouTube account before visiting our website.
The legal grounds are set out in Art. 6 paragraph 1 sentence 1 point (f) GDPR. Our justified interest lies in making our Internet site interesting for marketing purposes.
6. Payment methods
We offer a variety of payment options that involve the processing of personal data. The legal grounds for data processing are set out in Article 6 paragraph 1 sentence 1 points (a), (b) and (f) GDPR, respectively.
We have integrated components of PayPal on our website. The European operator of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg. PayPal fulfils the function of the online payment services provider. Data is transmitted automatically to PayPal when you select PayPal as your payment method. By selecting this payment option, you consent to your personal data being transmitted to the extent required to fulfil the payment transaction. In general, the personal data transmitted to PayPal will be your first name, surname, address, e-mail address, IP address, telephone number, mobile telephone number and other data that is necessary to complete payment.
The data is transmitted for fulfilment of the payment transaction and fraud prevention. In particular, we will only transmit personal data to PayPal where there is a legitimate interest to do so.
PayPal may transmit the personal data exchanged between us and PayPal to a credit agency. This information is transmitted to check your identity and credit rating.
PayPal may also transfer the personal data to affiliated companies, service providers or subcontractors where this is necessary to perform contractual obligations, or the data is processed on behalf of PayPal.
You have the right at any time to withdraw your consent for your data to be handled by PayPal. Withdrawing your consent does not affect personal data that must be processed, used or transmitted for the (contractual) performance of the payment transaction.
(b) Payment by credit card, debit card and Sofort
If credit card, debit card or Sofort are selected as payment methods, the payment services provider for the fulfilment of payment is Heidelberger Payment GmbH, Vangerowstraße 18, 69115 Heidelberg (referred to in the following as “Heidelpay”), to which we transfer the data provided during the order process exclusively for performance of the payment transaction in accordance with Art. 6 paragraph 1 point (b) GDPR. The data is only transmitted if it is actually necessary for the performance of payment. When necessary, Heidelpay transmits the data for the performance of payment to HUELLEMANN & STRAUSS ONLINESERVICES S.A., 1, Place du Marché, 6755 Grevenmacher, Luxembourg in accordance with Art. 6 paragraph 1 point (b) GDPR.
You may withdraw your consent at any time for your data to be processed by sending a message to the controller or to Heidelpay. Nevertheless, Heidelpay will remain entitled to process your personal data if it is necessary for the performance of contractual payment transactions.
7. Transfer of data
Service providers commissioned by us with certain data processing tasks may receive to comply with their contractual and legal obligations. This is predicated on their adherence to our instructions concerning data protection.
In regard to the transfer of data to recipients outside of our company, it is important to note that we are only entitled to pass on personal data when required to do so by law, when you have provided consent and/or when the contract processors guarantee equivalent compliance with the requirements of GDPR/Federal Data Protection Act (BDSG). Under these conditions, the recipients of personal data may include, for example, contract processors to which we transfer personal data. Specifically, support/maintenance of EDP/IT applications; archiving; controlling; data destruction; website management; newsletter mailings etc.
Other recipients may include parties for which you have provided consent to the transfer of data.
We process and store your personal data for as long as is necessary to comply with contractual or legal obligations. It is important to note that our contractual relationship is designed as a long-term arrangement. If the data is no longer needed for compliance with contractual or legal obligations, the data will ordinarily be erased, except where its – temporary – processing is necessary for the following purposes:
- Compliance with retention periods under commercial or fiscal law: The Commercial Code (HGB) and the Fiscal Code (AO) should be mentioned as examples in this context. The mandatory periods for storage, i.e. documentation, set out in these codes are two to ten years.
- Preservation of evidence within the framework of statutory limitation periods. Pursuant to Section 195 et seq. German Civil Code (BGB), these limitation periods may be up to 30 years, with the regular limitation period being three years.
Data from candidates who have applied for a position with us is erased three months after the end of the application process if a contract is not concluded with the candidate, unless erasure contradicts our other legitimate interests. Other legitimate interests in this regard include the obligation to furnish evidence in proceedings under the General Act on Equal Treatment (AGG).
9. Rights of the data subject
You have the right to obtain information according to Article 15 GDPR; the right to rectification according to Article 16 GDPR; the right to erasure according to Article 17 GDPR; the right to restriction of processing according to Article 18 GDPR; the right to object according to Article 21 GDPR; and the right to data portability according to Article 20 GDPR. You also have the right to lodge a complaint with a supervisory authority (Article 77 GDPR in conjunction with Section 19 BDSG). Furthermore, you are entitled to withdraw the consent you have given us for the processing of personal data at any time. Please take note that the withdrawal of consent applies only to the future. Processing that took place before consent was withdrawn remains unaffected.