CPA ReDev GmbH takes the protection of personal data very seriously. We want you to know when we store data, which types of data are stored and how it is used. We have taken technical and organizational measures to ensure our compliance and the compliance of external service providers with the data protection regulation.
The controller in the meaning of the General Data Protection Regulation, other national data protection laws in the Member States and related data protection regulations is:
CPA ReDev GmbH
Auf dem Seidenberg 3a
Telephone: +49 2241 2594-0
1. Personal data
Personal data refers to 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 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
A data subject is any identified or identifiable natural person whose personal data is processed by the controller.
Processing is any operation or set of operations 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, deletion or destruction.
4. Restriction of processing
Restriction of processing means the marking of stored personal data with the aim of limiting its processing in the future.
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 analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymization means 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 data processing controller
Controller or data processing controller means 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; where 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.
Processor means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Recipient means 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 that 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.
10. Third party
Third party means 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.
Consent of the data subject means 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.
1. Scope of processing of personal data
We process personal data concerning our users exclusively to the extent required to provide a functioning website, as well as our content and services. Ordinarily, we will only process the personal data of our users after obtaining their consent. An exception to this rule is where obtaining prior consent is factually impossible and the processing of the data is permitted by law.
2. Legal grounds for the processing of personal data
Where we obtain consent from the data subject for the processing of personal data, the legal grounds are set out in Art. 6, paragraph 1, part (a) of the EU General Data Protection Regulation (GDPR).
Where personal data is processed for the performance of a contract in which the data subject is a contractual partner, the legal grounds are set out in Art. 6, paragraph 1, part (b) of the GDPR. This also applies to processing that is necessary for pre-contractual measures.
Where personal data is processed for compliance with a legal obligation to which our company is subject, the legal grounds are set out in Art. 6, paragraph 1, part (c) of the GDPR.
Where processing of personal data is necessary for the protection of vital interests of the data subject or another natural person, the legal grounds are set out in Art. 6, paragraph 1, part (d) of the GDPR.
Where processing is necessary for the legitimate interests of our company or a third party, and where the fundamental rights and freedoms of the data subject do not override the first interests, the legal grounds are set out in Art. 6, paragraph 1, part (f) of the GDPR.
3. Data deletion and duration of data storage
The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. In addition, storage takes place if authorized by Union or Member State directives, laws or other regulations to which the controller is subject. Blocking or deletion of the data shall also take place when a storage period stipulated by one of the above standards comes to an end, except where it is necessary to continue storing the data to enter into or perform a contract.
a) Description and scope of data processing
Our system automatically collects data and information from the accessing computer system each time our website is visited.
The following data is collected in this context:
The data is also stored in log files kept on our system. This data is not stored together with other personal data concerning the user.
b) Legal grounds for data processing
The legal grounds for temporary storage of the data and log files are set out in Art. 6, paragraph 1, part (f) of the EU General Data Protection Regulation (GDPR).
c) Purpose of data processing
Temporary storage of the IP address by our system is necessary to deliver the website to the computer of the user. For this purpose, the user’s IP address must be stored for the duration of the session.
Storage in log files takes place to ensure functionality of the website. In addition, the data is used to optimize the website and to ensure security of our Information Technology systems. Data analysis for marketing purposes does not take place in this context.
The CPA ReDev GmbH website collects a variety of general data and information each time it is accessed by a data subject or an automated system. This general data and information is stored in server log files. The data and information collected include the (1) browser types and versions; (2) the operating system used by the accessing system; (3) the website from which the accessing system arrives on our website (the referrer); (4) the sub-pages visited by the accessing system; (5) the date and time of accessing our website; (6) an Internet Protocol address (IP address); (7) the Internet service provider of the accessing system and (8) other similar data and information that is used to protect against risks in the case of attacks on our Information Technology systems.
CPA ReDev GmbH does not draw any conclusions about the identity of the data subject during use of this general data and information. Instead, this information is necessary to (1) deliver the contents of our website in their correct form; to (2) optimize the contents of our website and promote it; to (3) guarantee the permanent functionality of our information technology systems and equipment used for our website; and to (4) provide the information necessary for law enforcement organizations to investigate cyber-attacks. This anonymous data and information is analyzed by CPA ReDev GmbH, firstly for statistical purposes, and secondly with the objective of increasing data protection and data security at our company, and hence to achieve an optimum level of protection for the personal data processed by us.
The anonymous data contained in the server log files is stored separately from all other personal data concerning the data subject.
These purposes justify our legitimate interests in data processing according to Art. 6, paragraph 1, part (f) of the GDPR.
d) Duration of storage
The data is deleted as soon as it is no longer needed for the purpose for which it was collected. In the case of data collection for the provision of this website, this applies at the end of each session.
In the case of data stored in log files, this occurs after no longer than seven days. Further storage is possible; in these cases, the users’ IP addresses are deleted or pseudonymized to prevent any association with the accessing client.
e) Right to objection and removal
The collection of data for the provision of our website and the storage of data in log files is crucial to operation of the website. Hence, users are not granted a right to object.
a) Description and scope of data processing
Where personal data concerning you is processed, you are the data subject as defined in the EU General Data Protection Regulation (GDPR) and you have the following rights with respect to the controller:
a) Right to information
You have the right to obtain from the controller confirmation of whether personal data concerning you is processed by us.
Where such processing takes place, you have the right to obtain the following information from the controller:
The controller will provide a copy of the personal data that is subject to processing. Where you request additional copies, the controller is entitled to charge an appropriate fee based on administrative costs. If you place the application by electronic means, the information will be made available in a standard electronic format, except where otherwise specified by you. The right to receive a copy in accordance with paragraph 3 of this section must not adversely affect the rights and freedoms of other persons.
b) Right to correction
As a data subject, you have the right to request from the controller the correction of inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
c) Right to limit processing
You have the right to request from the controller restriction of processing of personal data concerning you under the following conditions:
Where processing of the personal data concerning you has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
Where you have obtained restriction of processing under the conditions set out above, you will be informed by the controller before the restriction of processing is lifted.
d) Right to deletion
Obligation to delete
You have the right to request the controller to delete personal data concerning you without undue delay, and the controller will be obliged to delete personal data immediately where one of the following grounds applies:
Information to third parties
Where the controller has made the personal data concerning you public and is obliged pursuant to Art. 17, paragraph 1 of the GDPR to delete the personal data, the controller, taking account of available technology and the cost of implementation, is required to take reasonable steps, including technical measures, to inform controllers who are processing the personal data that you have requested to be deleted by such controllers, as well as any links to, copies or replications of such personal data.
The right to deletion does not apply to the extent that processing is necessary:
e) Right to notification
Where you have exercised the right to correction, deletion or restriction of processing with the data controller, the data controller shall be obliged to notify all recipients to whom the personal data concerning you was disclosed of this correction or deletion of data or of the restriction of processing, except where compliance proves to be impossible or is associated with a disproportionate effort.
In addition, you are entitled to require that the data controller inform you about these recipients.
f) Right to data portability
You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format and have the right to transfer that data to another controller without hindrance from the controller to which the personal data have been provided, where:
The processing is based on consent pursuant to part (a) of Article 6, paragraph 1 or part (a) of Article 9, paragraph 2 of the GDPR or in a contract pursuant to part (b) of Art. 6, paragraph 1 of the GDPR; and the processing is carried out by automated means.In exercising your right to data portability, you have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. This must not adversely affect the rights and freedoms of other persons.
You have the right to object, at any time, on grounds relating to your particular situation, to the processing of personal data concerning you, which is based on parts (e) or (f) of Art. 6, paragraph 1 of the GDPR; this includes profiling based on those provisions.
The controller shall no longer process the personal data concerning you, unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
Where personal data concerning you is processed for direct marketing purposes, you have the right to object, at any time, to the processing of personal data concerning you for the purpose of such marketing. This applies also to profiling to the extent that it is related to such direct marketing.
Where you object to processing for direct marketing purposes, the personal data will no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding directive 2002/58/EC, you may exercise your right to object by automated means that use technical specifications.
Where personal data is processed for scientific or historical research purposes or for statistical purposes pursuant to Art. 89, paragraph 1 of the GDPR, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you, except where the processing is necessary for the performance of a task carried out for reasons of public interest.
Should you wish to exercise your right to withdraw consent or to object, please send an email to firstname.lastname@example.org.
h) Right to withdraw consent pursuant to Art. 7, paragraph 3 of the GDPR
You have the right to withdraw your consent to the processing of data at any time, with future effect. In the event that you withdraw consent, we will delete the data concerned immediately, except where processing can be based on legal grounds that do not require consent. The withdrawal of consent will not affect the lawfulness of processing carried out prior to withdrawal of consent.
i) Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects for you or similarly significantly affects you.
This does not apply if the decision:
However, these decisions must not be based on special categories of personal data referred to in Art 9, paragraph 1 of the GDPR, unless parts (a) or (g) of Art. 9, paragraph 2 of the GDPR applies and suitable measures to safeguard your rights, freedoms and legitimate interests are in place.
In the cases referred to in parts (1) and (3), the data controller is required to implement suitable measures to safeguard your rights, freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express your own point of view and to contest the decision.
j) Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your normal residence, you place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.