For free of charge non-binding consultation call +49 89 500778-14
Contact/Data protection officer: Ms Barbara Ostermeier Brunhamstrasse 21 (Building 202/2nd Floor) 82149 Munich Germany Tel.: (+49-89) 500778 0 E-mail:
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, 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.
b) Data subject A data subject is any identified or identifiable natural person whose personal data is processed by the controller.
c) Processing Processing means 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, organisation, 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 means the marking of stored personal data with the aim of limiting its 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 analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
f) Pseudonymisation Pseudonymisation 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 organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Controller 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.
h) Processor Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient Recipient means a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether it is 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 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 authorised 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 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.
2. Name and address of the controller
The controller 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 for this website is:
4. Collection of general data and information
Every time the website is visited by a data subject or an automated system, the website of HighTech communications GmbH collects a range of general data and information. This general data and information is stored in the log files of the server. The following may be collected: (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 sub-websites which are accessed via an accessing system on our website, (5) the date and the time of access to the website, (6) the Internet Protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information which serve for hazard prevention in the event of attacks on our IT systems. When using this general data and information, HighTech communications GmbH does not draw any conclusions on the data subject, but rather, this information is necessary in order to (1) deliver the contents of our website correctly, (2) optimise the contents of our website and any advertising for it, (3) guarantee the permanent functionality of our IT systems and the technology of our website and (4) provide the information necessary for prosecution to prosecution authorities in the event of a cyber attack. This anonymously collected data and information is thus analysed by HighTech communications GmbH both statistically and with the goal of increasing the data protection and data security in our company in order to ultimately ensure an optimum level of protection for the personal data processed by us. The anonymous data of the server log files is stored separately from any and all personal data given by a data subject.
7. Contact via the website
Due to legal regulations, the HighTech communications GmbH website contains information that enables quick electronic contact with our company and direct communication with us, including via an e-mail address. If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject will be stored automatically. Such personal data transmitted by a data subject to the controller on a voluntary basis will be stored for the purpose of processing or contacting the data subject. This personal data is not passed on to third parties.
8. Routine deletion and blocking of personal data
The controller processes and stores the data subject’s personal data only for the period of time necessary to achieve the intended storage purpose or insofar as this has been provided for by the European legislator or another legislator in laws or regulations to which the controller is subject. If the storage purpose no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or deleted in accordance with the statutory provisions.
9. Rights of the data subject
a) Right of confirmation Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her is being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact our data protection officer or any other employee of the controller.
b) Right of access Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored and a copy of this information at any time. Furthermore, the European legislator grants 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 has been or will be disclosed, in particular recipients in third countries or international organisations
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 from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
the right to lodge a complaint with a supervisory authority
where the personal data is not collected from the data subject, any available information as to its 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 shall have a right to obtain information as to whether personal data is transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to exercise this right of access, he or she may, at any time, contact our data protection officer or any other employee of the controller.
c) Right to rectification Each data subject shall have the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall also have the right to have incomplete personal data completed, including by means of a supplementary statement. If a data subject wishes to exercise this right of rectification, he or she may, at any time, contact our data protection officer or any other employee of the controller.
d) Right to erasure (Right to be forgotten) Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, where one of the following grounds applies, as long as the processing is not necessary:
The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) GDPR, or point (a) of Article 9(2) GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
The personal data has been unlawfully processed.
The personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by HighTech communications GmbH, he or she may, at any time, contact our data protection officer. The data protection officer of HighTech communications GmbH or another employee shall promptly ensure that the erasure request is complied with immediately.
If the personal data has been made public by HighTech communications GmbH and our company is obliged as a controller pursuant to Article 17(1) GDPR to erase the personal data, HighTech communications GmbH, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers which are processing the published personal data that the data subject has requested the erasure by such other controllers of any links to, or copy or replication of, that personal data, provided that processing is not required. The data protection officer of HighTech communications GmbH or another employee will take the necessary steps on a case-by-case basis.
d) Right to restriction of processing Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following conditions is met:
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 and the data subject opposes the erasure of the personal data and requests the restriction of its use instead.
The controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of processing of personal data stored by HighTech communications GmbH, he or she may, at any time, contact our data protection officer. The data protection officer of HighTech communications GmbH or another employee will arrange the restriction of processing.
f) Right to data portability Each data subject shall have the right granted by the European legislator to receive the personal data concerning him or her, which the data subject provided to a controller, in a structured, commonly used and machine-readable format. He or she shall also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR, or on a contract pursuant to point (b) of Article 6(1) 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 his or her right to data portability pursuant to Article 20(1) GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact the data protection officer appointed by HighTech communications GmbH.
g) Right to object Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. In the event of an objection, HighTech communications GmbH shall no longer process the personal data 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 defence of legal claims. Where HighTech communications GmbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject makes an objection to HighTech communications GmbH with regard to processing for direct marketing purposes, HighTech communications GmbH will no longer process the personal data for these purposes. In addition, where personal data is processed by HighTech communications GmbH for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the data subject may contact the HighTech communications GmbH data protection officer directly. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling Each data subject shall have 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 him or her, or similarly significantly affects him or her, unless the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is authorised by Union or Member State law to which the controller is subject and which also lays 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 a data controller, or (2) it is based on the data subject’s explicit consent, HighTech communications GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision. If the data subject wishes to exercise the rights with regard to automated decision-making, he or she may, at any time, contact our data protection officer.
i) Right to withdraw data protection consent Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise his or her right to withdraw consent, he or she may, at any time, contact our data protection officer.
10. Data protection provisions on the application and use of Google Analytics (with anonymisation function)
12. Legal basis for processing
Article 6(1)(a) GDPR serves as the legal basis for our company’s 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 party, as is the case, for example, when processing operations are necessary for the supply of goods or the provision of any other service, the processing is based on Article 6(1)(b) GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of enquiries concerning our products or services. If our company is subject to a legal obligation which necessitates the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Article 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 of another natural person. This would be the case, for example, if a visitor to our business were injured and his or her name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. The processing would then be based on Article 6(1)(d) GDPR. Finally, processing operations could be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal bases, if processing is necessary to safeguard the legitimate interests pursued by our company or by 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 permissible in particular because they have been specifically mentioned by the European legislator, which takes 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 in processing 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 carry out our business in favour of the well-being of all our employees and our shareholders.
14. Period for which the personal data will be stored
The criteria 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, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.
15. Statutory or contractual regulations on the provision of 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 inform you that the provision of personal data is partly required by law (such as tax regulations) or can also result from contractual provisions (such as information on the contractual partner). It may sometimes be necessary for the conclusion of a contract that the data subject provides us with personal data, which must subsequently be processed by us. For example, the data subject is obligated to provide us with personal data when our company signs a contract with him or her. The non-provision of personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our data protection officer. Our data protection officer will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide personal data and the consequences of non-provision of personal data.
16. Existence of automated decision-making
As a responsible company, HighTech communications GmbH does not use automatic decision-making or profiling.