Data protection is of particularly high priority for us. In principle, the use of our website is possible without providing any personal data. However, if a data subject wishes to use special services offered on our website, it may become necessary to process personal data. If the processing of personal data is required and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, for example, the name, address, email address or telephone number of a data subject, is always carried out in compliance with the General Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to our company. By means of this Privacy Policy, we would like to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, this Privacy Policy explains to data subjects the rights to which they are entitled.

As the controller responsible for processing, we have implemented numerous technical and organizational measures to ensure the most complete protection of the personal data processed through this website. Nevertheless, internet-based data transmissions can generally have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, for example by telephone.

1. Definitions of terms

Our Privacy Policy is based on the terms used by the European legislator when issuing the General Data Protection Regulation (GDPR). Our Privacy Policy should be easy to read and understand, both for the public and our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

We use, among others, the following terms in this Privacy Policy:

a) Personal data
Personal data means any information relating to an identified or identifiable natural person (“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, online identifiers, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

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

c) Processing
Processing is any operation or set of operations which is 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, erasure, or destruction.

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

e) Profiling
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 analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

f) Pseudonymization
Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, as long as such additional information is kept separately and is subject to technical and organizational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. 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.

h) Processor
Processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

i) Recipient
Recipient is a natural or legal person, public authority, agency, or other body to which personal data are disclosed, whether a third party or not. However, public authorities which 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.

j) Third party
Third party is 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.

k) Consent
Consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them for a specific purpose.

2. Name and address of the controller

Controller for the purposes of the General Data Protection Regulation, other data protection laws applicable in Member States of the European Union, and other provisions related to data protection is:

WMP EUROCOM AG
Schlüterstraße 42
10707 Berlin
Germany

Phone: +49 (0)30 / 20 61 14 – 0
Email: privacy@wmp-ag.de
Website: https://wmp-ag.de/

3. Cookies

Our website uses cookies. Cookies are text files that are stored and saved via an internet browser on a computer system.

Many internet sites 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 web pages and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified by its unique cookie ID.

By using cookies, we can provide users of this website with more user-friendly services that would not be possible without the cookie setting.

Through a cookie, the information and offers on our website can be optimized with the user in mind. As mentioned, cookies enable us to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. For example, a user of a website that uses cookies does not have to re-enter access data each time they visit the site, because this is handled by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online store. The online store remembers the articles that a customer placed in the virtual shopping cart via a cookie.

The data subject can, at any time, prevent the setting of cookies by our website by means of an appropriate setting of the internet browser used and thus may permanently deny the setting of cookies. Furthermore, cookies already set may be deleted at any time via an internet browser or other software programs. This is possible in all popular internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, it may not be possible to use all functions of our website in full.

4. Collection of general data and information

Each time the website is accessed by a data subject or by an automated system, a series of general data and information is collected. This general data and information are stored in the server’s log files. The data collected may include (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 referrers), (4) the subpages that are accessed on our website, (5) the date and time of access to the internet site, (6) an Internet Protocol address (IP address), (7) the Internet Service Provider of the accessing system, and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using this general data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as the advertising for it, (3) ensure the long-term 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 cyberattack. Therefore, these anonymously collected data and information are evaluated statistically and also with the aim of increasing the data protection and data security of our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files are stored separately from all personal data provided by a data subject.

5. Contact possibility via the website

Due to legal requirements, our website contains information that enables a quick electronic contact to our company as well as direct communication with us, which also includes a general address of so-called electronic mail (email address). If a data subject contacts the controller via email or a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

6. Routine erasure and blocking of personal data

The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage or to the extent provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the storage purpose ceases to apply or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or erased in accordance with legal requirements.

7. Rights of the data subject

a) Right of confirmation
Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning them are being processed. If a data subject wishes to exercise this right of confirmation, they may, at any time, contact any employee of the controller.

b) Right of access
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain at any time from the controller, free of charge, information about their stored personal data and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:

• the purposes of the processing
• the categories of personal data concerned
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
• the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
• the existence of a right to lodge a complaint with a supervisory authority
• where the personal data are not collected from the data subject, any available information as to their source
• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject

Furthermore, the data subject has a right to be informed whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, they may, at any time, contact any employee of the controller.

c) Right to rectification
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject also has the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, they may, at any time, contact any employee of the controller.

d) Right to erasure (Right to be forgotten)
Every data subject affected by the processing of personal data has the right granted by the European legislator to demand from the controller the erasure of personal data concerning them without undue delay, where one of the following grounds applies and processing is not necessary:

• The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
• The data subject withdraws consent on which the processing is based according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Art. 21(1) GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
• The personal data have been unlawfully processed.
• The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
• The personal data have been collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.

If one of the above reasons applies and a data subject wishes to request the erasure of personal data stored by us, they may, at any time, contact any employee of the controller. The employee shall promptly ensure that the erasure request is complied with immediately.

Where we have made the personal data public and our company, as controller, is obliged pursuant to Art. 17(1) GDPR to erase the personal data, we shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested erasure by such controllers of any links to or copies or replications of this personal data, insofar as processing is not required. The employee will arrange the necessary measures in individual cases.

e) Right to restriction of processing
Every data subject affected by the processing of personal data has the right granted by the European legislator to demand from the controller the restriction of processing where one of the following conditions applies:

• The accuracy of the personal data is contested by the data subject for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful, the data subject opposes the erasure of the personal data, and requests instead the restriction of their use.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims.
• The data subject has objected to processing pursuant to Art. 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met, and a data subject wishes to request the restriction of personal data stored by us, they may, at any time, contact any employee of the controller. The employee will arrange the restriction of processing.

f) Right to data portability
Every data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which was provided by the data subject to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to whom the personal data were provided, as long as the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising their right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have personal data transmitted directly from one controller to another, where technically feasible and if doing so does not adversely affect the rights and freedoms of others.

The data subject may contact any employee to assert the right to data portability at any time.

g) Right to object
Every data subject affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to their particular situation, at any time, to processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.

We shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims.

If we process personal data for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning them for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to our processing for direct marketing purposes, we will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them which is carried out by us for scientific or historical research purposes, or for statistical purposes pursuant to Art. 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may directly contact any of our employees. Furthermore, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject is free to exercise their right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling
Every data subject affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning them or similarly significantly affects them, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a controller, or (2) is authorized by Union or Member State law to which the controller is subject, and these laws lay down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) it is based on the data subject’s explicit consent, we shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, which shall include at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, they may, at any time, contact any employee of the controller.

i) Right to withdraw data protection consent
Every data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, they may, at any time, contact any employee of the controller.

8. Data protection provisions about the use of Google Analytics (with anonymization function)

The controller has integrated the Google Analytics component (with the anonymization function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and evaluation of data on the behavior of visitors to websites. A web analytics service collects, among other things, data on which website a data subject has come from (the so-called referrer), which subpages were visited, or how often and for what duration a subpage was viewed. Web analytics is mainly used to optimize a website and to conduct a cost-benefit analysis of internet advertising.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The controller uses the “_gat._anonymizeIp” add-on for web analytics through Google Analytics. By means of this add-on, Google truncates and anonymizes the IP address of the data subject’s internet connection when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the flow of visitors on our website. Google uses the collected data and information to, among other things, evaluate the use of our website in order to compile online reports for us showing the activities on our websites, and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject’s information technology system. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyze the usage of our website. By each call-up of one of the pages of this website, which is operated by the controller and into which a Google Analytics component has been integrated, the internet browser on the data subject’s IT system is automatically prompted by the Google Analytics component to submit data to Google for online analysis. During this technical procedure, Google gains knowledge of personal data, such as the IP address of the data subject, which serves, among other things, to track the origin of visitors and clicks and subsequently to enable commission settlements.

The cookie stores personal information, e.g., the access time, the location from which access was made, and the frequency of visits to our website by the data subject. Each time you visit our website, these personal data, including the IP address of the internet connection used by the data subject, are transferred to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure on to third parties.

The data subject can, at any time, prevent the setting of cookies by our website, as stated above, by means of an appropriate adjustment of the internet browser used and thus permanently deny the setting of cookies. Such an adjustment to the internet browser used would also prevent Google Analytics from setting a cookie on the data subject’s IT system. Additionally, a cookie already set by Google Analytics may be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the possibility to object to the collection of data generated by Google Analytics related to the use of this website, as well as the processing of this data by Google, and to prevent any such processing. To do so, the data subject must download and install a browser add-on under the link: https://tools.google.com/dlpage/gaoptout. This browser add-on uses JavaScript to inform Google Analytics that no data or information regarding visits to internet pages may be transmitted to Google Analytics. Google considers the installation of the browser add-on to be an objection. If the data subject’s IT system is later deleted, formatted, or newly installed, the data subject must reinstall the browser add-on to disable Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their sphere of control, the browser add-on can be reinstalled or reactivated.

Further information and the applicable data protection provisions of Google can be retrieved under https://www.google.de/intl/de/policies/privacy/ and under http://www.google.com/analytics/terms/de.html. Google Analytics is further explained under https://www.google.com/intl/de_de/analytics/.

9. Data protection provisions about the use of Google Fonts

This site uses so-called web fonts provided by Google (https://fonts.google.com/) to ensure a uniform and visually enhanced presentation of text. When you visit our site, your browser loads the required web fonts into its browser cache. This is necessary for your browser to display our texts in an improved way. If your browser does not support this function, a standard font from your computer is used. Among the data processed can be in particular IP addresses and location data of the users, which, however, will not be collected without their consent (usually performed in the settings of their mobile devices). The data may be processed in the USA.

The operating company of the Google Fonts component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Further information and the applicable data protection provisions of Google can be found at https://www.google.de/intl/de/policies/privacy/.

10. Data protection provisions about the use of Google Maps

We integrate the maps of the “Google Maps” service provided by Google LLC. Among the data processed can be in particular IP addresses and location data of users, which, however, will not be collected without their consent (generally through the settings of their mobile devices). The data may be processed in the USA.

The operating company of the Google Maps component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Further information and the applicable data protection provisions of Google can be found at https://www.google.de/intl/de/policies/privacy/.

11. Data protection provisions about the use of Twitter

The controller has integrated Twitter components on this website. Twitter is a multilingual publicly accessible microblogging service on which users can publish and disseminate so-called tweets, i.e., short messages limited to 280 characters. These short messages can be accessed by anyone, including individuals not logged into Twitter. The tweets are also displayed to the followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows you to address a broad audience via hashtags, links, or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

By accessing any of the individual pages of this website, which is operated by the controller and on which a Twitter component (Twitter button) is integrated, the internet browser on the data subject’s IT system is automatically prompted by the respective Twitter component to download a display of the corresponding Twitter component from Twitter. Further information about the Twitter buttons is available at https://about.twitter.com/de/resources/buttons. As part of this technical process, Twitter is informed about which specific subpage of our website is visited by the data subject. The purpose of integrating the Twitter component is to allow our users to redistribute the content of this website, make this website known in the digital world, and increase our visitor numbers.

If the data subject is logged in on Twitter at the same time, Twitter recognizes which specific subpage of our website the data subject visits with each call-up of our website by the data subject, and for the entire duration of their stay on our website. This information is collected by the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, the data and information transferred will be assigned to the data subject’s personal Twitter user account and stored and processed by Twitter.

Twitter is always informed via the Twitter component that the data subject has visited our website if the data subject is logged in on Twitter at the time of accessing our website; this occurs regardless of whether the data subject clicks on the Twitter component or not. If such a transmission of information to Twitter is not desired by the data subject, they can prevent this by logging out of their Twitter account before calling our website.

The applicable data protection provisions of Twitter are available at https://twitter.com/privacy?lang=de.

12. Legal basis for processing

Art. 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. Where the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as for example in the case of processing operations necessary for the supply of goods or to provide any other service, the processing is based on Art. 6(1)(b) GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in cases of inquiries about our products or services. Where our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may be 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 in our company and their name, age, health insurance data, or other vital information had to be passed on to a doctor, hospital, or other third party. Then the processing would be based on Art. 6(1)(d) GDPR. Finally, processing operations could be based on Art. 6(1)(f) GDPR. This legal basis is used for processing operations not covered by any of the aforementioned legal grounds, if processing is necessary for the purposes of legitimate interests pursued by our company or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. Such processing operations are particularly permitted because they have been specifically mentioned by the European legislator. In this regard, it took the view that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 sentence 2 GDPR).

13. Legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is to conduct our business in favor of the well-being of all our employees and our shareholders.

14. Period for which the personal data will be stored

The criterion used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted if it is no longer necessary for the fulfillment or initiation of a contract.

15. Statutory or contractual requirements to provide personal data; necessity for entering into a contract; obligation of the data subject to provide personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contracting party). Sometimes, in order to conclude a contract, it may be necessary for a data subject to provide us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company enters into a contract with them. The non-provision of personal data would result in the contract with the data subject not being concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will clarify to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of a contract, whether there is an obligation to provide the personal data, and the consequences of not providing the personal data.