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We are very pleased that you are interested in our company. Data protection has a particularly high priority for the management of Santiago Berlin GmbH. Use of the Santiago Berlin GmbH website is generally possible without providing any personal data. If a data subject wishes to use our company's special services via our website, processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, for example the name, address, email address or telephone number of a data subject, always takes place in accordance with the General Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to Santiago Berlin GmbH. With this data protection declaration, our company would like to inform the public about the type, scope and purpose of the personal data we collect, use and process. Data subjects are also informed about their rights by means of this data protection declaration.
As the controller, Santiago Berlin GmbH has implemented numerous technical and organizational measures to ensure the most complete protection possible for the personal data processed via this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us in alternative ways, for example by telephone.
1. Definitions
The data protection declaration of Santiago Berlin GmbH is based on the terminology used by the European directors and regulators when the General Data Protection Regulation (GDPR) was issued. Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.
We use the following terms in this data protection declaration:
2. Name and address of the controller
Responsible within the meaning of the General Data Protection Regulation, other data protection laws applicable in the member states of the European Union and other provisions with data protection character is:
Santiago Berlin GmbH, Monika Smith
Liebigstrasse 9
82008 Unterhaching
Germany
Tel .: +491721338629
Email: monika@santiagoberlin.com
Website: www.monikasmith.com
3. Collection of general data and information
The website of Santiago Berlin GmbH collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server's log files. The following can be recorded: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites that use an accessing system on our website can be controlled, (5) the date and time of access to the 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 serves to avert risks in the event of attacks on our information technology systems.
When using this general data and information, Santiago Berlin GmbH does not draw any conclusions about the person concerned. Rather, this information is required to (1) deliver the content of our website correctly, (2) optimize the content of our website and the advertising for it, (3) to ensure the long-term functionality of our information technology systems and the technology of our website and ( 4) to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyber attack. This anonymously collected data and information is therefore statistically evaluated by Santiago Berlin GmbH on the one hand and also with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
4. Subscription to our newsletter
On the website of Santiago Berlin GmbH, users are given the opportunity to subscribe to our company's newsletter. Which personal data are transmitted to the person responsible for processing when you order the newsletter is determined from the input mask used for this purpose.
Santiago Berlin GmbH informs its customers and business partners at regular intervals by means of a newsletter about the company's offers. The newsletter of our company can only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter. For legal reasons, a confirmation email will be sent to the email address entered by the data subject for the first time for sending the newsletter in a double opt-in procedure. This confirmation email is used to check whether the owner of the email address as the person concerned has authorized the receipt of the newsletter.
When registering for the newsletter, we also save the IP address assigned by the Internet service provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to understand the (possible) misuse of the e-mail address of a data subject at a later point in time and therefore serves to provide legal protection for the controller.
The personal data collected when you register for the newsletter will only be used to send our newsletter. Furthermore, subscribers to the newsletter could be informed by email if this is necessary for the operation of the newsletter service or for a registration in this regard, as could be the case in the event of changes to the newsletter offer or changes in the technical circumstances. The personal data collected as part of the newsletter service is not passed on to third parties. The data subject can cancel the subscription to our newsletter at any time. The consent to the storage of personal data that the data subject has given us for sending the newsletter can be revoked at any time. For the purpose of withdrawing consent, there is a corresponding link in every newsletter. You can also unsubscribe from the newsletter at any time directly on the website of the controller or inform the controller in another way.
5. Newsletter tracking
The Santiago Berlin GmbH newsletters contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in emails that are sent in HTML format to enable log file recording and log file analysis. This enables a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Based on the embedded tracking pixel, Santiago Berlin GmbH can recognize whether and when an email was opened by a data subject and which links in the email were called up by the data subject.
Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the data controller in order to optimize the sending of the newsletter and to adapt the content of future newsletters even better to the interests of the person concerned. This personal data will not be passed on to third parties. Affected persons are entitled at any time to revoke the separate declaration of consent relating to this, which is made using the double opt-in procedure. After revocation, this personal data will be deleted by the controller. Unsubscribing from receiving the newsletter automatically interprets Santiago Berlin GmbH as a revocation.
6. Comment function in the blog on the website
Santiago Berlin GmbH offers users the opportunity to leave individual comments on individual blog posts on a blog located on the website of the controller. A blog is a portal that is usually listed on a website and can be viewed publicly, in which one or more people, called bloggers or web bloggers, can post articles or write down thoughts in so-called blog posts. The blog posts can usually be commented on by third parties.
If a data subject leaves a comment on the blog published on this website, in addition to the comments left by the data subject, information on the time the comment was entered and the user name (pseudonym) chosen by the data subject are saved and published. Furthermore, the IP address assigned by the data subject's Internet service provider (ISP) is also logged. This IP address is saved for security reasons and in the event that the data subject violates the rights of third parties by posting a comment or posts illegal content. The storage of this personal data is therefore in the own interest of the person responsible for the processing, so that the latter could possibly exculpate himself in the event of an infringement. The personal data collected will not be passed on to third parties unless such transfer is required by law or serves to defend the rights of the controller.
7. Routine deletion and blocking of personal data
The data controller processes and stores personal data of the data subject only for the period necessary to achieve the storage purpose or if this is done by the European directive and regulation giver or another legislator in laws or regulations, which of the data controller subject, was provided.
If the storage purpose no longer applies or if a storage period prescribed by the European directive and ordinance provider or another responsible legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
8. Rights of the data subject
9. Data protection regulations for the application and use of Facebook
The controller has integrated components of the Facebook company on this website. Facebook is a social network.
A social network is a social meeting point operated on the Internet, an online community that usually enables users to communicate with each other and to interact in virtual space. A social network can serve as a platform for exchanging opinions and experiences or enables the internet community to provide personal or company-related information. Facebook enables the users of the social network, among other things, to create private profiles, upload photos and network via friend requests.
Facebook is operated by Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If an affected person lives outside the USA or Canada, the person responsible for processing personal data is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland.
Each time one of the individual pages of this website is accessed, which is operated by the controller and on which a Facebook component (Facebook plug-in) has been integrated, the Internet browser on the information technology system of the person concerned is automatically activated by the respective Facebook Component causes a representation of the corresponding Facebook component to be downloaded from Facebook. A complete overview of all Facebook plug-ins can be found at https://developers.facebook.com/docs/plugins/?locale=de_DE. As part of this technical process, Facebook receives knowledge of which specific subpage of our website is visited by the data subject.
If the data subject is logged into Facebook at the same time, Facebook recognizes each time our website is accessed by the data subject and for the entire duration of their stay on our website, which specific subpage of our website the data subject visits. This information is collected by the Facebook component and assigned to the respective Facebook account of the person concerned by Facebook. If the person concerned presses one of the Facebook buttons integrated on our website, for example the "Like" button, or if the person concerned makes a comment, Facebook assigns this information to the person's personal Facebook user account and stores this personal data .
Facebook always receives information via the Facebook component that the data subject has visited our website if the data subject is logged in to Facebook at the same time as accessing our website; this takes place regardless of whether the person concerned clicks on the Facebook component or not. If the data subject does not want this information to be transmitted to Facebook, he can prevent the transmission by logging out of his Facebook account before visiting our website.
The data policy published by Facebook, which is available at https://de-de.facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. It also explains which setting options Facebook offers to protect the privacy of the data subject. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by the data subject to suppress data transmission to Facebook.
10. Data protection regulations for the application and use of Google AdSense
The controller has integrated Google AdSense on this website. Google AdSense is an online service that enables the placement of advertising on third-party sites. Google AdSense is based on an algorithm that selects the advertisements displayed on third-party sites to match the content of the respective third-party site. Google AdSense allows interest-based targeting of the Internet user, which is implemented by generating individual user profiles.
The Google AdSense component is operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of the Google AdSense component is to integrate advertisements on our website. Google AdSense places a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Alphabet Inc. is able to analyze the use of our website. Every time one of the individual pages of this website is accessed, which is operated by the controller and on which a Google AdSense component has been integrated, the Internet browser on the information technology system of the data subject is automatically triggered by the respective Google AdSense component To transmit data to Alphabet Inc. for online advertising and commission billing purposes. As part of this technical process, Alphabet Inc. receives knowledge of personal data, such as the IP address of the data subject, which Alphabet Inc. uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission statements.
The person concerned can prevent the setting of cookies by our website, as already described above, at any time by means of a corresponding setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Alphabet Inc. from setting a cookie on the information technology system of the person concerned. In addition, a cookie already set by Alphabet Inc. can be deleted at any time via the internet browser or other software programs.
Google AdSense also uses so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in Internet pages to enable log file recording and log file analysis, which enables statistical analysis to be carried out. Alphabet Inc. can use the embedded tracking pixel to recognize whether and when a website was opened by a data subject and which links were clicked by the data subject. Tracking pixels are used, among other things, to evaluate the flow of visitors to a website.
Via Google AdSense, personal data and information, which also includes the IP address and is necessary for the recording and billing of the advertisements displayed, are transferred to Alphabet Inc. in the United States of America. This personal data is stored and processed in the United States of America. Alphabet Inc. may share this personal information collected through the technical process with third parties.
Google AdSense is explained in more detail under this link https://www.google.de/intl/de/adsense/start/.
11. Data protection provisions on the application and use of Google Analytics (with anonymization function)
The controller has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analytics service. Web analysis is the collection, collection and evaluation of data about the behavior of visitors to websites. A web analysis service collects data, among other things, from which website a data subject came to a website (so-called referrer), which subpages of the website were accessed or how often and for how long a subpage was viewed. A web analysis is mainly used to optimize a website and for the cost-benefit analysis of internet advertising.
The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The person responsible for processing uses the addition "_gat._anonymizeIp" for web analysis via Google Analytics. With this addition, the IP address of the data subject's Internet connection is shortened and anonymized by Google if access to our website is from a member state of the European Union or from another contracting state to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze visitor flows on our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us that show the activities on our website, 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 able to analyze the use of our website. Each time one of the individual pages of this website is accessed, which is operated by the controller and on which a Google Analytics component has been integrated, the Internet browser on the information technology system of the data subject is automatically triggered by the respective Google Analytics component To transmit data to Google for the purpose of online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission statements.
The cookie is used to store personal information, such as the access time, the location from which access was made and the frequency of visits to our website by the person concerned. Each time you visit our website, this personal data, including the IP address of the internet connection used by the data subject, is transferred to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data collected through the technical process with third parties.
The person concerned can prevent the setting of cookies by our website, as already described above, at any time by means of a corresponding setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from placing a cookie on the information technology system of the person concerned. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.
Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google. To do this, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout. This browser add-on tells Google Analytics via JavaScript that no data and information about visits to websites may be transmitted to Google Analytics. Google considers the installation of the browser add-on to be an objection. If the information technology system of the data subject is later deleted, formatted or reinstalled, the data subject must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the person concerned or another person who is within their sphere of influence, there is the option of reinstalling or reactivating the browser add-on.
Further information and the applicable data protection regulations of Google can be found at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail under this link https://www.google.com/intl/de_de/analytics/.
12. Data protection regulations for the application and use of Google AdWords
The controller has integrated Google AdWords on this website. Google AdWords is an internet advertising service that allows advertisers to place advertisements in both the Google search engine results and the Google advertising network. Google AdWords enables an advertiser to define certain keywords in advance, by means of which an advertisement is only displayed in Google's search engine results when the user uses the search engine to retrieve a keyword-relevant search result. In the Google advertising network, the ads are distributed on topic-related websites using an automatic algorithm and taking the previously defined keywords into account.
The operator of the services of Google AdWords is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google AdWords is to advertise our website by displaying interest-related advertising on the websites of third-party companies and in the search engine results of the Google search engine and by displaying third-party advertising on our website.
If a data subject reaches our website via a Google ad, a so-called conversion cookie is placed on the data subject's information technology system by Google. What cookies are has already been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the person concerned. If the cookie has not yet expired, the conversion cookie is used to determine whether certain sub-pages, such as the shopping cart from an online shop system, have been accessed on our website. The conversion cookie enables both us and Google to understand whether a data subject who came to our website via an AdWords ad generated sales, i.e. completed or canceled a purchase of goods.
The data and information collected through the use of the conversion cookie is used by Google to generate visit statistics for our website. These visit statistics are in turn used by us to determine the total number of users who were referred to us via AdWords ads, i.e. to determine the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future . Neither our company nor any other Google AdWords advertisers receive information from Google that could be used to identify the data subject.
The conversion cookie is used to store personal information, such as the websites visited by the data subject. Every time you visit our website, personal data, including the IP address of the internet connection used by the data subject, is transferred to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data collected through the technical process with third parties.
The person concerned can prevent the setting of cookies by our website, as already described above, at any time by means of a corresponding setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a conversion cookie on the information technology system of the person concerned. In addition, a cookie already set by Google AdWords can be deleted at any time via the internet browser or other software programs.
Furthermore, the data subject has the option to object to Google's interest-based advertising. To do this, the data subject must access the link www.google.de/settings/ads from each of the Internet browsers they use and make the desired settings there.
Further information and the applicable data protection provisions of Google can be found at https://www.google.de/intl/de/policies/privacy/.
13. Data protection regulations for the application and use of Instagram
The controller has integrated components of the Instagram service on this website. Instagram is a service that qualifies as an audiovisual platform and enables users to share photos and videos and also to disseminate such data on other social networks.
Instagram is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2 Ireland.
Each time one of the individual pages of this website is accessed, which is operated by the controller and on which an Instagram component (Insta button) has been integrated, the Internet browser on the information technology system of the person concerned is automatically activated by the respective Instagram component prompted to download a representation of the corresponding component from Instagram. As part of this technical process, Instagram receives knowledge of which specific subpage of our website is visited by the data subject.
If the data subject is logged in to Instagram at the same time, Instagram recognizes each time our website is accessed by the data subject and for the entire duration of their stay on our website, which specific subpage the data subject visits. This information is collected by the Instagram component and assigned to the respective Instagram account of the data subject by Instagram. If the data subject clicks one of the Instagram buttons integrated on our website, the data and information transmitted with it are assigned to the personal Instagram user account of the data subject and saved and processed by Instagram.
Instagram always receives information via the Instagram component that the data subject has visited our website if the data subject is logged in to Instagram at the same time as accessing our website; this takes place regardless of whether the person concerned clicks on the Instagram component or not. If the data subject does not want this information to be transmitted to Instagram, they can prevent the transmission by logging out of their Instagram account before accessing our website.
Further information and the applicable data protection regulations of Instagram can be found at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.
14. Data protection regulations for the application and 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 distribute so-called tweets, i.e. short messages that are limited to 280 characters. These short messages are available to everyone, including anyone who is not logged in to Twitter. The tweets are also displayed to the so-called followers of the respective user. Followers are other Twitter users who follow a user's tweets. Twitter also enables a wide audience to be addressed via hashtags, links or retweets.
Operating company of Twitter International Company, One Cumberland Place, Fenian Street Dublin 2, D02 AX07, Ireland.
Each time one of the individual pages of this website is accessed, which is operated by the controller and on which a Twitter component (Twitter button) has been integrated, the Internet browser on the information technology system of the person concerned is automatically activated by the respective Twitter component prompted to download a representation of the corresponding Twitter component from Twitter. Further information on the Twitter buttons can be found at https://about.twitter.com/de/resources/buttons. As part of this technical process, Twitter receives knowledge of which specific subpage of our website is visited by the data subject. The purpose of integrating the Twitter component is to enable our users to redistribute the content of this website, to make this website known in the digital world and to increase our visitor numbers.
If the data subject is logged in to Twitter at the same time, Twitter recognizes each time our website is accessed by the data subject and for the entire duration of their stay on our website, which specific subpage of our website the data subject visits. This information is collected by the Twitter component and assigned to the respective Twitter account of the data subject by Twitter. If the data subject clicks one of the Twitter buttons integrated on our website, the data and information transmitted with it are assigned to the personal Twitter user account of the data subject and saved and processed by Twitter.
Twitter always receives information via the Twitter component that the data subject has visited our website if the data subject is logged in to Twitter at the same time as accessing our website; this takes place regardless of whether the person concerned clicks on the Twitter component or not. If the data subject does not want this information to be transmitted to Twitter, he or she can prevent the transmission by logging out of their Twitter account before accessing our website.
The applicable data protection regulations of Twitter are available at https://twitter.com/privacy?lang=de.
15. Legal basis for processing
Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as to fulfill tax obligations, the processing is based on Art. 6 I lit. 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 to our company were injured and his 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 I lit. d GDPR are based. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not outweigh them. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, he took the view that a legitimate interest could be assumed if the data subject is a customer of the person responsible (recital 47 sentence 2 GDPR).
16. Legitimate interests in the processing that are pursued by the person responsible or a third party
Is the processing of personal data based on Article 6 I lit. f GDPR is our legitimate interest in carrying out our business for the benefit of all our employees and our shareholders.
17. Duration for which the personal data are stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After the deadline has expired, the corresponding data will be routinely deleted, provided that it is no longer required to fulfill or initiate a contract.
18. Legal or contractual provisions for the provision of personal data; Necessity for the conclusion of the contract; Obligation of the data subject to provide the personal data; possible consequences of not providing
We will inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information about the contract partner). Sometimes it may be necessary to conclude a contract that a data subject provides us with personal data that we subsequently have to process. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide personal data would result in the contract not being concluded with the person concerned. Before the data subject provides personal data, the data subject must contact one of our employees. Our employee clarifies the person concerned on a case-by-case basis whether the provision of the personal data is required by law or contract or is required for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of not providing the personal data.
19. Existence of automated decision making
As a responsible company, we do not use automatic decision-making or profiling.
This data protection declaration was created by the data protection declaration generator of the DGD German Society for Data Protection GmbH, which as External data protection officer Munich works in cooperation with the Lawyer for data protection law Christian Solmecke created.