Data Protection

Thank you very much for your interest in our company. Data protection is of particular importance to the management of Klüh Service Management GmbH.
Using the web pages of Klüh Service Management GmbH is basically possible without disclosing any personal data. However, if a data subject wishes to make use of special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (DSGVO) and in accordance with the country-specific data protection regulations applicable to Klüh Service Management GmbH. By means of this data privacy statement, our company would like to inform the public about the type, scope and purpose of the personal data collected, used and processed by us. Furthermore, data subjects will be informed of their rights by means of this data privacy statement.

As data controller, Klüh Service Management GmbH has implemented numerous technical and organisational measures to ensure the most complete protection possible for personal data processed via this website. Nevertheless, Internet-based data transmissions can still have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

The data privacy statement of Klüh Service Management GmbH is based on the terms used by the European regulator when the General Data Protection Regulation (DSGVO) was issued. Our data privacy statement is intended to be easy to read and understand both for the public and for our customers and business partners. To ensure this, we would like to explain the terms used in advance. We use the following terms, among others, in this data privacy statement:

a) personal data
Personal data is all information relating to an identified or identifiable natural person (hereinafter "data subject"). Identifiable is a natural person who can be identified directly or indirectly, in particular by assignment to an identifier such as a name, an identification number, location data, an online identifier or one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.

b) data subject
Data subject is any identified or identifiable natural person whose personal data are processed by the data controller.

c) processing
Processing means any operation or series of operations carried out with or without the aid of automated procedures in relation to personal data, such as the collection, capture, organisation, sorting, storage, adaptation or alteration, reading, retrieval, use, disclosure by transmission, dissemination or any other form of provision, reconciliation or linking, restriction, erasure or destruction.

d) restriction of processing
Restriction of processing is the marking of stored personal data with the aim of restricting their future processing.

e) profiling
Profiling is any form of automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, behaviour, location or relocation of that natural person.

f) pseudonymisation
Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not assigned to an identified or identifiable natural person.

g) Controller or data controller
Controller or data controller is the natural or legal person, public authority, institution or other body which alone or jointly with others decides on the purposes and means of processing of personal data. Where the purposes and means of such processing are laid down by Union law or by the law of the Member States, the controller or the specific criteria for his appointment may be laid down in accordance with Union law or the law of the Member States.

h) Data processor
Data processor is a natural or legal person, authority, institution or other body that processes personal data on behalf of the controller.

i) recipient
Recipient is a natural or legal person, authority, institution or other body to which personal data is disclosed, regardless of whether it is a third party or not. However, authorities which may receive personal data under Union law or the law of the Member States within the framework of a particular investigation mandate are not regarded as recipients.

j) third party
A third party is a natural or legal person, authority, institution or other body other than the data subject, the controller, the data processor and the persons authorised to process the personal data under the direct responsibility of the controller or the data processor.

k) consent
Consent means any informed and unequivocal statement of intent, made voluntarily by the data subject in the specific case, in the form of a statement or other clear affirmative act by which the data subject indicates his/her consent to the processing of personal data concerning him or her

The party responsible within the meaning of the General Data Protection Regulation, other data protection laws in force in the Member States of the European Union and other provisions of a data protection nature is:

Klüh Service Management GmbH
represented by its managing directors
Frank Theobald and Christian Frank
Am Wehrhahn 70
40211 Düsseldorf
Germany

The web pages of Klüh Service Management GmbH use cookies. Cookies are text files which are stored and saved on a computer system via an Internet browser.
Numerous websites 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 string of characters through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the visited Internet pages and servers to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A particular Internet browser can be recognised and identified by its unique cookie ID.
The use of cookies enables Klüh Service Management GmbH to provide users of this website with more user-friendly services that would not be possible without setting cookies.

By means of a cookie, the information and offers on our website can be optimised for the benefit of the user. Cookies enable us, as already mentioned, to recognise the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter his/her access data each time he/she visits the website because this is undertaken by the website and the cookie stored on the user's computer system. Another example is the cookie of a shopping basket in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping basket via a cookie.

The data subject can prevent the setting of cookies by our website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our Internet site may be fully usable.

Please find our cookie policy here. 

Our website uses services from companies based outside the EU (e.g. USA), which, with your consent, transfer personal data to the servers of the respective companies, e.g. located in the USA. We would like to point out that, in the opinion of the European Commission, countries outside the EU may not offer an adequate level of data protection within the meaning of EU data protection law. US companies are obliged to disclose personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for surveillance purposes. We have no influence on these processing activities.

Google Analytics

If you have given your consent, this website will use Google Analytics, a web analysis service provided by Google LLC. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Scope of processing

Google Analytics uses cookies which permit analysis of your use of our website. As a rule, the information collected by the cookies about your use of this website are transferred to a Google server in the USA and stored there.

We use the “userID” function. This enables us to assign a unique and permanent ID to one or several sessions (and the activities during these sessions) and to analyse user behaviour across multiple devices.

We use Google Signals. This records additional information in Google Analytics about users who have activated personalised advertising (interests and demographic data). Ads can be delivered to these users in cross-device remarketing campaigns.

We use the “anonymizeIP” function (IP masking). By activating IP anonymisation on this website, your IP address will be truncated by Google in member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there. The IP address transmitted by your browser to Google Analytics will not be combined with other Google data.

During your visit to our website, the following data are recorded:

• The pages you access and your click path
• Achievement of website targets (conversions, e.g. newsletter registrations, downloads, purchases)
• Your user behaviour (e.g. clicks, session durations, bounce rates)
• Your approximate location (region)
• Your IP address (truncated)
• Technical information about your browser and the end devices you use (e.g. language setting, screen resolution)
• Your internet provider
• The referrer URL (the website/ad which directed you to this website)

Purposes of processing

On behalf of the website’s operator, Google uses this information to analyse your (pseudonymised) use of the website and to generate reports about website activities. The reports provided by Google Analytics serve to analyse the performance of our website and the success of our marketing campaigns.

Recipient

The recipient of the data is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, which is also the processor. To this end, we have concluded a processing agreement with Google. Google LLC, headquartered in California, USA, and possibly US authorities may access the data stored by Google.

Transfer to third countries

A transfer of data to the USA cannot be ruled out.

Duration of storage

The data sent by us and linked to cookies are automatically erased after 14 months. The erasure of data that have reached the end of their storage period takes place automatically once a month.
You can prevent Google recording and processing the data generated by the cookie in relation to your use of the website (incl. your IP address) by:

• a. Not giving your consent to the enabling of cookies or
• b. Downloading and installing the browser add-on to deactivate Google Analytics HERE.

You can block cookies via the settings in your browser software. However, if you configure your browser to reject all cookies, it may restrict the functions of this and other websites.

The legal basis and revocation option

for this data processing is your consent in accordance with Art.6 (1) (a) GDPR. You may revoke your consent at any time with effect for the future by changing your cookie settings.

You will find more information about Google Analytics and data protection at Google at: https://marketingplatform.google.com/about/analytics/terms/gb/ and https://policies.google.com/?hl=gb.

Google AdWords und Google Conversion-Tracking
This website uses Google AdWords. AdWords is an online advertising program of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).
In the context of Google AdWords we use the so-called conversion tracking. When you click on an ad placed by Google, a cookie is set for conversion tracking. Cookies are small text files that the Internet browser places on the user's computer. These cookies expire after 30 days and are not used to personally identify users. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognise that the user has clicked on the ad and has been redirected to this page.

Each Google AdWords customer receives a different cookie. Cookies cannot be tracked through the websites of AdWords customers. The information collected using the conversion cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. Customers see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they will not receive any information that personally identifies users. If you do not wish to participate in tracking, you can object to this use by easily deactivating the Google Conversion Tracking cookie via your Internet browser under User Settings. You will then not be included in the conversion tracking statistics.

"Conversion cookies" are stored on the basis of Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in analysing user behaviour in order to optimise both his website and his advertising.

For more information about Google AdWords and Google Conversion Tracking, please see Google's privacy policy: https://www.google.de/policies/privacy/ .
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or generally and activate the automatic deletion of cookies when closing the browser. When cookies are deactivated, the functionality of this website may be limited.

Google Marketing Platform (formerly DoubleClick by Google)

This website uses the online marketing tool Campaign Manager from Google. Campaign Manager uses cookies to display ads that are relevant to users, to improve campaign performance reports or to prevent a user from seeing the same ads more than once. Google uses a cookie ID to record which ads are displayed in which browser and can thus prevent them from being displayed more than once. In addition, Campaign Manager can use cookie IDs to record so-called conversions that are related to ad requests. This is the case, for example, when a user sees a Campaign Manager ad and later visits the advertiser's website with the same browser and makes a purchase there. According to Google, Campaign Manager cookies do not contain any personal information.

Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our level of knowledge: Through the integration of Campaign Manager, Google receives the information that you have accessed the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible that the provider will find out your IP address and store it.

In addition, the Campaign Manager (DoubleClick Floodlight) cookies used enable us to understand whether you perform certain actions on our website after you have accessed or clicked on one of our display/video ads on Google or on another platform via Campaign Manager (conversion tracking). Campaign Manager uses this cookie to understand the content you have interacted with on our websites in order to be able to send you targeted advertising later.

You can prevent participation in this tracking process in various ways: 

a) by setting your browser software accordingly; in particular, suppressing third-party cookies means that you will not receive any ads from third-party providers; 

b) by deactivating cookies for conversion tracking by setting your browser to block cookies from the domain googleadservices.com, www.google.de/settings/ads, whereby these settings are deleted when you delete your cookies; 

c) by deactivating the interest-based ads of the providers that are part of the “About Ads” self-regulation campaign via the link www.aboutads.info/choices, whereby this setting is deleted when you delete your cookies;

d) by permanent deactivation in your browsers Firefox, Internet Explorer or Google Chrome under the link www.google.com/settings/ads/plugin, 

e) by means of the corresponding cookie setting → forwarding to section X of the customer's data protection declaration. We would like to point out that in this case you may not be able to use all functions of this website to their full extent.

In addition, you can prevent Google from collecting the data generated by the cookies about your use of the websites and the processing of this data by Google by downloading and installing the browser plug-in available at support.google.com/adsense/answer/142293 under “Display settings”, “Campaign Manager deactivation extension”. 

Further information on the Google Marketing Platform can be found at marketingplatform.google.com/about/ and on data protection at Google in general: www.google.de/intl/de/policies/privacy . Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at www.networkadvertising.org. Google has submitted to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework.

Legal basis: Art. 6 (1) a GDPR

Google Tag Manager
We use Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Tag Manager is a tool that enables us to integrate tracking or statistics tools and other technologies on our website. Google Tag Manager itself does not generate user profiles, save cookies or perform analyses. It serves only to manage and deploy the tools it is used to integrate. However, Google Tag Manager does record your IP address and may transfer this to Google’s parent company in the United States of America.

Google Tag Manager is used on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the rapid and uncomplicated integration and management of various tools on its website. If consent is requested, processing shall be solely on the basis of Art. 6 (1) (a) GDPR and section 25 (1) of Germany’s Act to Regulate Data Protection and Privacy in Telecommunications and Telemedia (TTDSG) to the extent that such consent covers the enabling of cookies or access to information on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. This consent may be revoked at any time.

Use of the SalesViewer® technology:
This website uses SalesViewer® technology from SalesViewer® GmbH to collect and store data for marketing, market research and optimisation purposes on the basis of the website operator's legitimate interests (Art. 6(1)(f) GDPR).

For this purpose, a javascript-based code is used to collect company-related data and the corresponding use. The data collected using this technology is encrypted using a non-reversible one-way function (known as hashing). The data is immediately pseudonymised and is not used to personally identify the visitor to this website. The data stored by Salesviewer is deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations.

You can object to the collection and storage of data at any time with effect for the future by clicking on this link https://www.salesviewer.com/opt-out to prevent the collection by SalesViewer® within this website in the future. An opt-out cookie for this website will be stored on your device. If you delete your cookies in this browser, you must click on this link again.

If you visit us via a social network, the operators of the social networks process personal data as the controller in accordance with their own privacy policy. We ask you to read the privacy policy carefully before you visit us via these social networks. There you will also find further information on exercising your rights as a data subject. 

Use of social media plugins
We have integrated various social media plugins on our website so that you can also access the interactive options provided by the social media networks you use when on our website. These plugins provide various functions, the purpose and scope of which are determined by the respective social media network operator. Please note that we are not the provider of the social media networks and have no influence on data processing by the respective service provider. The plugin provider stores the data about you as user profiles and uses these for the purposes of advertising, market research and/or customising the design of its website. This kind of analysis is performed in particular (also for users who are not logged in) to facilitate the delivery of customised advertising and to inform other social media users about your activities on our website. You have the right to object to the creation of these user profiles; to do so, please contact the respective plugin provider. We use plugins to enable you to interact with social media networks and other users so that we can improve our offering and make it more interesting for you as the user. The legal basis for the use of the plugins is Art. 6 (1) (f) GDPR. The data are transferred irrespective of whether you have an account with the plugin provider and are logged in there. If you are logged in to your account with the plugin provider, the data we store about you will be directly assigned to your respective user account. If, for example, you link the website, the plugin provider also stores this information in your user account and shares it publicly with your contacts. We recommend that you regularly log out from your social media account.

The following information provides more details about the individual plugins:

Meta
Our website incorporates plugins from the social media networks of Meta.You can identify the plugins from the Facebook or WhatsApp logo on our website. You will find an overview of the Meta plugins here: developers.facebook.com/docs/plugins/. The plugin establishes a direct link between your browser and the Facebook server. This informs Facebook that you have visited our website from your IP address. When you click on the Facebook “like” button while logged in to your Facebook account, you can reference content from our website in your Facebook profile. We would like to point out that, as the website provider, we are not informed of the content of the data transferred nor of the use of these data by Facebook and that we are not responsible for the processing of the data by Facebook. You can find further information in the Facebook privacy policy at: facebook.com/policy.php.

YouTube
Our website uses plug-ins from the Google-operated YouTube site. The web pages are operated by YouTube.
If you visit one of our pages equipped with a YouTube plug-in, a connection to the YouTube servers is established. In the process, the YouTube server is informed which of our pages you have visited. If you are logged into your YouTube account, you allow YouTube to associate your surfing behaviour directly with your personal profile. You can prevent this by logging out of your YouTube account. The use of YouTube is made in the interest of an appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f DSGVO. For more information on the handling of user data, please refer to YouTube's data privacy statement: https://www.google.de/intl/de/policies/privacy.

Social Media Advertising

Meta (Facebook, Instagram) and LinkedIn ads 

We work with Meta Platforms Ireland Ltd. and LinkedIn Ireland Unlimited Company to report on the effectiveness of our Facebook/Instagram and LinkedIn advertising campaigns and other online content, to analyze the use of our offers and to show you targeted advertising.

When you access our offers, cookies are set and tracking pixels from Meta Platforms and LinkedIn are used to carry out measurements and ad targeting (i.e. ad targeting and control). You can object to the collection and use of information for ad targeting and measurements by preventing the setting of cookies. You can also change your settings for online advertising and tracking via the URL http://www.youronlinechoices.com/de/. 

The legal basis for this is Art. 6 para. 1 lit. f. GDPR. 

You can find an overview of the cookies used in our cookie policy.

Google Maps

This website uses the map service Google Maps via an API. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

To use the functions of Google Maps, it is necessary to save your IP address. This information is usually transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.

The use of Google Maps is in the interest of an appealing presentation of our online offers and to make it easy to find the locations we have indicated on the website. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR.

You can find more information on the handling of user data in Google's privacy policy: policies.google.com/privacy.

Information obligations when collecting personal data, especially during the application process (Art. 13, 14 GDPR)

E-Recruiting via Softgarden

Klüh Service Management uses the online application tool Softgarden to carry out the online application process. When using this function, you leave the website of Klüh Service Management GmbH and switch to the website of Softgarden e-recruiting GmbH. This company is based at Tauentzienstraße 14, 10789 Berlin.

Softgarden e-recruiting GmbH processes the data on behalf of Klüh Service Management GmbH and provides a platform for processing your application data. The data uploaded by you is analyzed within the IT structure of Softgarden in order to extract relevant data. The data is not transferred to third parties.

As part of this process, you will be given the opportunity to create an account in the Softgarden career portal where you can view and manage your application. You will receive an automatically generated email to create an account. Creating an account is only optional and is not a prerequisite for applying to Klüh Service Management GmbH.

Further information about data processing at Softgarden can be found at https://softgarden.com/en/privacy-policy/

Purpose of data processing

We store all information provided to us by persons who apply for a job in our company. This applies both to applications in response to specific job advertisements and to unsolicited applications. The maximum storage period is six months. During this time, the application is reviewed and the information is available until the storage period expires, also in order to be able to respond to subsequent inquiries (e.g. requests for documents, rejections, etc.) in a qualified manner. No data is collected from third parties as part of the application process unless the data subject has given their consent. No data is transferred to third parties, especially not to another country.

If the application leads to the establishment of a training or employment relationship, the data will be stored for ten years, unless other regulations stipulate longer retention periods. Applicants are then obliged to complete data to establish an employment relationship, e.g. social security data. Subsequently, data is transferred to social security institutions and the tax office.

The legal basis for data collection is Art. 6 Para. 1 No. f GDPR and Section 26 Para. 1 BDSG-new as well as other legal requirements from which storage obligations arise in the event of the establishment of employment relationships, e.g. Section 147 AO, Section 257 HGB, Section 35 Para. 1 SRVwV etc.

Rights of the data subjects

On the basis of Art. 13, 14 GDPR, applicants have the right to request information about the personal data concerning themselves at any time and subsequently, if applicable, the further right to rectification or deletion or to restriction of processing. In particular, you have the right to delete stored data at any time. A deletion request leads to a termination of the application procedure and no further information on the course of the procedure can subsequently be provided.

Once an employment relationship has been established, the right to data deletion or restriction of processing is reduced. Legal and/or contractual regulations on documentation and archiving take precedence over deletion requests. To exercise their rights, data subjects can contact the above-mentioned persons responsible in the company, the company data protection officer or the supervisory authority.

The website of Klüh Service Management GmbH collects a series of general data and information every time a person or an automated system accesses the website. This general data and information is stored in the log files of the server. We may record (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 referrer), (4) the subwebsites which are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol (IP) address, (7) the Internet service provider of the accessing system, and (8) other similar data and information used to avert dangers in the event of attacks on our information technology systems.

When using this general data and information, Klüh Service Management GmbH does not draw any conclusions about the data subject. Rather, this information is required to (1) correctly deliver the contents of our website, (2) optimise the contents of our website and the advertising for it, (3) ensure the permanent functionality of our information technology systems and the technology of our website and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack. These anonymously collected data and information are therefore on the one hand statistically evaluated by Klüh Service Management GmbH and on the other hand evaluated with the aim of increasing data protection and data security in our company in order ultimately to ensure an optimum level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

Due to legal regulations, the website of Klüh Service Management GmbH contains information that enables rapid electronic contact with our company and direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If a data subject contacts the data controller via e-mail or a contact form, the personal data transmitted by the data subject will be stored automatically. Such personal data voluntarily provided by a data subject to the data controller will be stored for the purpose of data processing or contacting the data subject. This personal data will not be passed on to third parties.

The data controller processes and stores the personal data of the data subject only for the time necessary to achieve the purpose of the data storage or insofar as this has been provided for by the European regulator or another legislator in laws or regulations which the data controller is subject to.
If the storage purpose ceases to apply or if a storage period prescribed by the European regulator or other competent legislator expires, the personal data is routinely blocked or deleted in accordance with the statutory provisions.

a) Right to confirmation
Every data subject has the right granted by the European regulator to request the data controller to confirm whether personal data concerning him/her are being processed. If a data subject wishes to exercise this right to confirmation, he/she may contact an employee of the data controller at any time.

b) Right to information
Any person affected by the processing of personal data has the right granted by the European regulator to obtain, at any time and free of charge, information from the data controller concerning his/her personal data stored and a copy of that information. Furthermore, the European regulator has granted the data subject the right to obtain the following information:

• the processing purposes
• the categories of personal data that are being processed
• the recipients or categories of recipients to whom the personal data have been or are still to be disclosed, in particular recipients in third countries or at international organisations
• if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
• the existence of a right of correction or deletion of personal data concerning him/her or of a restriction on processing by the controller or of a right of objection to such processing
• the existence of a right to lodge a complaint with a supervisory authority
• if the personal data is not collected from the data subject: all available information about the origin of the data
• the existence of automated decision-making, including profiling in accordance with Art. 22 para. 1 and 4 DSGVO and - at least in these cases - meaningful information on the logic involved and the scope and intended effects of such processing for the data subject
• Furthermore, the data subject has a right of access to information as to whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to obtain information on the appropriate guarantees in connection with the transmission.

If a data subject wishes to exercise this right to information, he/she may contact an employee of the data controller at any time.

c) Right to correction
Any person affected by the processing of personal data has the right granted by the European regulator to request the immediate correction of inaccurate personal data concerning him/her. Furthermore, taking into account the purposes of the processing, the data subject has the right to request the completion of incomplete personal data, also by means of a supplementary declaration.
If a data subject wishes to exercise this right to correction, he/she may contact an employee of the data controller at any time.

d) Right to deletion (right to be forgotten)
Any person affected by the processing of personal data has the right granted by the European regulator to request the controller to delete personal data concerning him/her immediately, provided that one of the following reasons applies and insofar as processing is not necessary:

• The personal data have been collected or otherwise processed for such purposes for which they are no longer necessary.
• The data subject withdraws his/her consent on which the processing was based pursuant to Art. 6 para. 1 letter a DSGVO or Art. 9 para. 2 letter a DSGVO and no other legal basis for the processing is established.
• The data subject objects to processing pursuant to Art. 21 para. 1 DSGVO and there are no overriding legitimate grounds for processing or the data subject objects to processing pursuant to Art. 21 para. 2 DSGVO.
• The personal data have been processed unlawfully.
• The deletion of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.
• The personal data was collected in relation to services offered by the information society in accordance with Art. 8 para. 1 DSGVO.

If one of the above-mentioned reasons applies and a data subject wishes to have personal data stored at Klüh Service Management GmbH deleted, he/she may contact an employee of the data controller at any time. The employee of Klüh Service Management GmbH will arrange for the request for deletion to be complied with immediately.
If the personal data has been made public by Klüh Service Management GmbH and our company as the controller in accordance with Art. 17 para. 1 DSGVO is obliged to delete the personal data, Klüh Service Management GmbH will take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data controllers who process the published personal data, that the data subject has requested the deletion of all links to this personal data or of copies or replications of this personal data from these other data controllers, insofar as processing is not necessary. The employee of Klüh Service Management GmbH will arrange for the necessary in each individual case.

e) Right to restriction of processing
Any person affected by the processing of personal data has the right granted by the European regulator to request the controller to restrict the processing if one of the following conditions is met:

• The accuracy of the personal data is disputed by the data subject for a period that enables the controller to verify the accuracy of the personal data.
• The processing is unlawful; the data subject refuses the deletion of the personal data and instead requests the restriction of the use of the personal data.
• The controller no longer requires the personal data for the purposes of processing, but the data subject needs them to assert, exercise or defend legal claims.
• The data subject has filed an objection to the processing pursuant to Art. 21 para. 1 DSGVO and it has not yet been determined whether the legitimate reasons of the controller outweigh those of the data subject.

If one of the above conditions is fulfilled and a data subject wishes to request the restriction of personal data stored by Klüh Service Management GmbH, he/she may contact an employee of the data controller at any time. The employee of Klüh Service Management GmbH will arrange for the restriction of processing.

f) Right to data transferability
Any person affected by the processing of personal data has the right granted by the European regulator to receive the personal data concerning him/her, which have been provided by the data subject to a controller in a structured, current and machine-readable format. He/she also has the right to transmit such data to another controller without obstruction by the controller to whom the personal data have been made available, provided that the processing is based on the consent provided for in Art. 6 para. 1 letter a DSGVO or Art. 9 para. 2 letter a DSGVO or on a contract pursuant to Art. 6 para. 1 letter b DSGVO and that the processing is carried out using automated procedures, provided that the processing is not necessary for the performance of a task in the public interest or in the exercise of public authority conferred on the controller.
Furthermore, in exercising his/her right to data transferability pursuant to Art. 20 para. 1 DSGVO, the data subject has the right to effect that the personal data are transferred directly by a controller to another controller, insofar as this is technically feasible and provided that the rights and freedoms of other persons are not affected by this.
To assert the right to data transferability, the data subject may contact an employee of Klüh Service Management GmbH at any time.

g) Right to object
Any person affected by the processing of personal data has the right granted by the European regulator to object at any time, for reasons arising from his/her particular situation, to the processing of personal data concerning him or her on the basis of Art. 6 para. 1 letter e or f DSGVO. This also applies to profiling based on these provisions.
In the event of an objection, Klüh Service Management GmbH will no longer process the personal data unless we can prove compelling legitimate grounds for the processing which outweigh the interests, rights and freedoms of the data subject or the processing serves to assert, exercise or defend legal claims.
If Klüh Service Management GmbH processes personal data in order to carry out direct advertising, the data subject has the right to object at any time to the processing of the personal data for the purpose of such advertising. This also applies to profiling insofar as it is connected with such direct advertising. If the data subject objects to processing by Klüh Service Management GmbH for direct advertising purposes, Klüh Service Management GmbH will no longer process the personal data for these purposes.
Furthermore, the data subject has the right to object, for reasons arising from his/her particular situation, to the processing of personal data concerning him/her that is carried out at Klüh Service Management GmbH for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 DSGVO, unless such processing is necessary to fulfil a task in the public interest.
To exercise the right of objection, the data subject may directly contact any employee of Klüh Service Management GmbH or any other employee. The data subject is also free to exercise his/her right of objection in connection with the use of services of the information society by means of automated procedures using technical specifications, notwithstanding Directive 2002/58/EC.

h) Automated decisions in individual cases including profiling
Any person affected by the processing of personal data has the right granted by the European regulator not to be subject to a decision based exclusively on automated processing, including profiling, which has a legal effect against him or significantly affects him in a similar manner, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is admissible under Union or Member State law to which the controller is subject and that such law contains appropriate measures to safeguard the rights, freedoms and legitimate interests of the data subject, or (3) with the express consent of the data subject.
If the decision (1) is necessary for the conclusion or fulfilment of a contract between the data subject and the controller or (2) is taken with the express consent of the data subject, Klüh Service Management GmbH takes appropriate measures to protect the rights and freedoms as well as the legitimate interests of the data subject, including at least the right to obtain the intervention of an individual on the part of the controller, to state his/her own position and to challenge the decision.
If the data subject wishes to assert rights relating to automated decisions, he/she may contact an employee of the data controller at any time.

i) Right to withdraw consent under data protection law
Any person affected by the processing of personal data has the right granted by the European regulator to withdraw consent to the processing of personal data at any time.
If the data subject wishes to assert his/her right to withdraw his/her consent, he/she may contact an employee of the data controller at any time.

The data controller has integrated components of the company Meta (Facebook and Instagram) and LinkedIn on this website. Facebook, Instagram and LinkedIn are social networks.

A social network is an Internet-based social meeting place, an online community that usually enables users to communicate with each other and interact in virtual space. A social network can serve as a platform for the exchange of opinions and experiences or enables the Internet community to provide personal or company-related information. Facebook, Instagram and LinkedIn allow social network users to create private profiles, upload photos and create networks via friendship requests, among other things.

Each time one of the individual pages of this website is accessed, which is operated by the data controller and on which a Meta and LinkedIn component (Meta plug-in or pixel) has been integrated, the Internet browser on the data subject's information technology system is automatically prompted by the respective Meta or LinkedIn component to download a representation of the corresponding Facebook component of Facebook. An overview of all Facebook plug-ins can be found at developers.facebook.com/docs/plugins/. In the context of this technical procedure, Facebook is informed about which specific subpage of our website is visited by the data subject.

If the data subject is logged on to Facebook at the same time, Facebook recognises each time the data subject visits our website and for the entire duration of the respective stay on our website which specific subpage of our website the data subject visits. This information is collected by the Facebook component and assigned by Facebook to the respective Facebook account of the data subject. If the data subject clicks one of the Facebook buttons integrated on our website, for example the "Like" button, or if the data subject makes a comment, Facebook assigns this information to the personal Facebook user account of the data subject and stores this personal data.

Facebook receives information via the Facebook component that the data subject has visited our website whenever the data subject is logged on to Facebook at the same time as accessing our website; this happens regardless of whether the data subject clicks on the Facebook component or not. If the data subject does not want such information to be transmitted to Facebook, the data subject can prevent it from being transmitted by logging out of his/her Facebook account before he/she visits our website.

The data policy published by Facebook, which is available at de-de.facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. It also explains what setting options Facebook offers to protect the privacy of the data subject. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by the data subject to suppress data transmission to Facebook.

Art. 6 I lit. a GRDP serves our company as a 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 a party, as is the case for example with processing operations necessary for the delivery of goods or the provision of other services or consideration, such processing is based on Art. 6 I lit. b DSGVO. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, for example to fulfil tax obligations, such processing is based on Art. 6 I lit. c DSGVO. In rare cases, the processing of personal data may become necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and his name, age, health insurance data or other vital information had to be passed on to a doctor, a hospital or other third parties. Then processing would be based on Art. 6 I lit. d DSGVO. Ultimately, processing operations could be based on Art. 6 I lit. f DSGVO. Processing operations which are not covered by any of the aforementioned legal foundations are based on this legal foundation if processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and fundamental freedoms of the data subject do not prevail. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, the legislator took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47, sentence 2, DSGVO).

If the processing of personal data is based on Art. 6 I lit. f DSGVO, our legitimate interest is to conduct our business activities.

The criterion for the duration of the storage of personal data is the respective legal retention period. After expiry of this period, the corresponding data will be routinely deleted, provided that it is no longer required for the performance or initiation of a contract.

Legal or contractual regulations for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide the data

We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Occasionally it may be necessary for the conclusion of a contract that a data subject provides us with personal data which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company enters into a contract with him/her. Failure to provide personal data would mean that the contract with the data subject could not be concluded. Prior to the provision of personal data by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or required for the conclusion of the contract, whether there is an obligation to provide the personal data and what consequences the failure to provide the personal data would have.

As a responsible company, we do without automatic decision-making or profiling.

We have appointed a data protection officer for our company: :

Lawyer Thomas Hackl
Lawyer Steffi Konrad

Available at: datenschutz@klueh.de or: 0211 9068-235

You can reach our Compliance Officer lawyer Andreas Ludwig at: compliance@klueh.de

May 23rd 2024