Schöller SI GmbH in foundation
Obere Wässere 9
Managing Director: Willi Schöller
Contact of our Data Protection Officer:
Schöller SI GmbH i.G.
Data Protection Officer
Obere Wässere 9
Types of processed data:
– Inventory data (e.g. names, addresses).
– Contact information (e.g. e-mail, phone numbers).
– Content data (e.g. text input, photographs, videos).
– Usage data (e.g. websites visited, interest in content, access times).
– Meta / communication data (e.g. device information, IP addresses).
Categories of affected persons:
Visitors and users of our online offer (hereinafter we refer to the affected persons as “users”).
Purpose of processing:
– Provision of the online offer, its functions and contents.
– Answering contact requests and communicating with users.
– Safety measures.
– Measurement of range / Marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, if it can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, which express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term reaches far and includes virtually every handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, under the condition that such additional information is kept separate and is subject to technical and organizational measures to ensure that the personal data is not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to job performance, economic situation, health, personal preferences, reliability, behavior, whereabouts or relocation of that natural person.
“Responsible person / party” means the natural or legal person or party, public authority, agency or other institution which decides, alone or in concert with others, on the purposes and means of processing personal data.
“Processor” means a natural or legal person or party, public authority, agency or other institution which processes personal data on behalf of the responsible person / party.
Relevant legal bases:
In accordance with Art. 32 DSGVO (GDPR) we are taking into account the current state of technology, the implementation costs and the scope, circumstances and purposes of the processing of data as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and then take the appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the rights of affected parties, rights of data deletion and reactions to data vulnerability. Furthermore, we consider the protection of personal data already in the development or selection of hardware, software and procedures, according to the principle of data protection through the design of technology and privacy-friendly default settings (Article 25 DSGVO).
Collaboration with processors and third parties
If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit data to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) DSGVO (GDPR) is necessary to fulfill the contract), or you have consented, is based on a legal obligation or is based on our legitimate interests (e.g. the use of agents, webhosters, etc.).
If we commission third parties to process data on the basis of a so-called “processing contract”, this is done on the basis of Art. 28 DSGVO (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 in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done, if it is 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 in the presence of the special conditions of Art. 44 et seq. DSGVO. It means that the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection corresponding to EU standards (e.g. for the US the “Privacy Shield”) or in compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
Rights of data subjects
You have the right to ask for confirmation as to whether the data in question is being processed and ask for information about this data as well as for further information and a copy of the data in accordance with Art. 15 DSGVO (GDPR).
According to Art. 16 DSGVO you have the right to demand the completion of your data or the correction of the incorrect data about you.
In accordance with Art. 17 DSGVO (GDPR), you have the right to demand that the relevant data is being deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 DSGVO (GDPR).
You have the right to demand that the data related to you, which you have provided to us, be obtained in accordance with Art. 20 DSGVO (GDPR) and request their transmission to other responsible persons / parties.
Furthermore, you have the right according to Art. 77 to file a complaint with the competent supervisory authority.
Right of withdrawal
You have the right to withdraw granted consent with effect for the future in accordance with. Art. 7 (3) DSGVO.
Right to object
You can object to the future processing of your data in accordance with Art. 21 DSGVO (GDPR) at any time. The objection may in particular be made against processing for direct marketing purposes.
Cookies and right to object in direct mail
“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 the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie can be saved for example the contents of a shopping cart in an online shop or a login status. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit the online offer after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person or party who manages the online offer (otherwise, if it is only their cookies, these are called “first-party cookies”).
If users do not want cookies stored on their computer, they are asked to disable the option in their browser’s system settings. 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.
Deletion of data
According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 (1) AO, 257 (1) no. 1 and 4, para. 4 HGB (books, records, management reports, accounting documents, trading books, relevant documents for taxation, etc.) and 6 years in accordance with § 257 (1) no. 2 and 3, para. 4 HGB (commercial letters).
According to legal regulations in Austria the storage covers 7 years according to § 132 paragraph 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.), 22 years in connection with real estate and 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-commercial parties in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is used.
We process the data of our customers, clients and interested parties (uniformly referred to as “customers”) in accordance with Art. 6 para. 1 lit. b. DSGVO in order to provide them with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the underlying mandate. This includes in principle inventory and master data of the customer (name, address, etc.), as well as the contact data (e-mail address, telephone, etc.), the contract data (content and scope of the commission, fees, terms, information about the companies involved in the brokerage / insurers / services) and payment data (commissions, payment history, etc.). We may also process information about the characteristics and circumstances of persons or things belonging to them, if this is part of our commission. This can be e.g. information about personal circumstances, mobile or immovable property.
As part of our assignment, it may also be necessary for us to process special categories of data in accordance with Art. 9 para. 1 DSGVO, here in particular information on the health of a person. For this we obtain, if necessary, according to. Art. 6 (1) lit. a, Art. 7, Art. 9 (2) lit. a DSGVO an explicit consent of the customer.
To the extent necessary for the fulfillment of the contract or as required by law, we disclose or transmit the data of customers in the context of coverage requests as well as conclusion and settlement of contracts to providers of brokered services / objects, insurers, reinsurers, brokerage pools, technical service providers, other service providers, such as. cooperating associations, as well as financial service providers, credit institutions and capital investment companies as well as social security funds, tax authorities, tax consultants, legal advisers, auditors, insurance ombudsmen and the institution Federal Financial Supervisory Authority (BaFin). Furthermore, we can hire subcontractors, such as sub-brokers. We obtain the consent of the customer if this is required for the disclosure / transmission of the data (which can be the case, for example, in the case of special categories of data according to Art. 9 DSGVO (GDPR)).
The deletion of the data takes place after the expiration of legal warranty and comparable obligations, whereby the necessity of the storage of the data will be checked every three years; otherwise the statutory storage obligations apply.
In the case of legal archiving obligations, the deletion takes place after its expiration. In particular, according to German law for the insurance and finance industry, client consultation records must be kept for 5 years, broker notes for 7 years and broker contracts for 5 years and generally 6 years for documents relevant to commercial law and 10 years for tax-relevant documents.
We process the data of our contractual partners and interested parties as well as other contracting parties, customers, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. DSGVO in order to provide them with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g. services used, contents of the contract, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history).
In principle, we do not process special categories of personal data, unless they are part of a contracted or contractual processing.
We process data which is necessary for the establishment and fulfillment of the contractual services and point out the necessity of their indication, if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if required by a contract. When processing the data provided to us in relation to an order or commissioning, we act in accordance with the instructions of the client as well as the legal requirements.
As part of the use of our online services, we can save the IP address and the time of each user action. The storage is based on our legitimate interests, as well as the interests of the user in the protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is required to pursue our claims according to Art. 6 para. 1 lit. f. DSGVO or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c. DSGVO.
The data will be deleted if the data is no longer required for the fulfillment of contractual or statutory duties of care or for the handling of any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; otherwise the statutory and legal storage obligations apply.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks and organization of our business, financial accounting and compliance with legal obligations, such as archiving, for example. In doing so, we process the same data which we are processing in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. The processing affects customers, prospects, business partners and website visitors. The purpose and our interest in processing is based on the administration, financial accounting, office organization, data archiving, in general tasks which serve to maintain our business activities, perform our business obligations and provide our services. The deletion of the data related to contractual services and contractual communication corresponds to the information provided for these processing activities.
We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors, and other fee agencies / authorities and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. We generally store this mainly company-related data permanently.
When contacting us (for example, by contact form, e-mail, telephone or via social media) the information of the user to process the contact request and its handling is processed in accordance to Art. 6 para. 1 lit. b) DSGVO. User information can be stored in a Customer Relationship Management System (“CRM System”) or in comparable request organization system.
We delete the requests, if they are no longer required. We check the necessity every two years; furthermore, the legal archiving obligations apply.
Hosting and e-mailing,
The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security and technical maintenance services which we use to operate this online service.
Doing this, we or our hosting provider are processing inventory / master data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties, prospects and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer according to Art. 6 para. 1 lit. f DSGVO in combination with Art. 28 DSGVO (conclusion of a processing contract).
Collection of access data and log files
We, or our hosting provider, collect on the basis of our legitimate interests according to Art. 6 para. 1 lit. f. DSGVO data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, information about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes are exempted from the deletion until final clarification of the incident.
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation. (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the user’s use of our online offer, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. Doing this, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the users’s IP address will be shortened by Google within the member states of the European Union or other parties who are sharing the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
The IP address provided by the user’s browser will not be merged with other Google data. The users can prevent the storage of cookies by a corresponding setting of their browser software. In addition, the users can prevent the collection by Google of the data generated by the cookie and related to their use of the website as well as the processing of this data by Google if the users are downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
The personal data of users will be deleted or anonymized after 14 months.
Integration of services and contents of third parties
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer according to Art. 6 (1) lit. f DSGVO), we make use of content or services offered by third-party providers in order to provide and implement their content and services, such as videos or fonts (collectively referred to as “content” in the following).
This always presupposes that the third-party providers of this content perceive the IP address of the users, because without the IP address they could not send the content to the user’s browser. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third party providers may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate 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 may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer, as well as being linked to such information from other sources.
We embed the videos of the platform YouTube of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA.