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Data Protection Policy

Data Protection Policy

GENERAL DATA PROTECTION INFORMATION

Below we provide information about the processing of personal data in conjunction with use of our online services.

Controller

GLÜCK AUF Immobilien GmbH

Am Stadtbad 37

D-45219 Essen

Tel: + 49 (0) 20 54 / 969 51 70

Fax: +49 (0) 20 54 / 969 51 50

Mail: info@glueck-auf.de

Data Protection Officer

The Data Protection Officer

c/o GLÜCK AUF Immobilien GmbH

Am Stadtbad D-3745219 Essen

datenschutz@glueck-auf.de


Purposes and legal basis of processing

We process the personal data of various data subjects (e.g. website users, interested parties and customers) as part of our business activities. We are informing you about the purposes and legal bases as well as additional details of the respective processing, categorized according to the different processing situations, in the lower part of this Data Protection Policy.


Recipients

Depending on the respective processing situation, your personal data shall not only be processed by the controller, but also by third parties. Potential recipients include, in particular, processors (e.g. web hosting, software providers and other technical service providers) and third-party providers of online services and content. Please see the information about the respective processing for details. Recipients within the meaning of the GDPR are also the companies that are part of the GLÜCK AUF Group.

Third-country transfer

We only process your personal data within the EU. You shall be informed separately about possible third-country transfers, depending on the situation.

Retention period

Personal data is stored for as long as is required for the purpose. We are legally obliged to store it or other legal reasons justify further processing.

Data subjects’ rights

In accordance with Article 15, GDPR (General Data Protection Regulation), you have the right to obtain information about the personal data stored about you, including any recipients and the planned retention period. Insofar as the processed data is not (or is no longer) correct, you have the right to rectification (Article 16, GDPR). If the respective legal requirements are met, you can request the erasure (Article 17) or restriction (Article 18) of the processing and object to the processing (Article 21, GDPR). If you believe that the processing of your personal data violates data protection law, you have the right to lodge a complaint with a data protection supervisory authority of your choice (Article 77, GDPR).

RIGHT TO OBJECT

You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, which is based on Article 6(1), Point f, GDPR. We shall then no longer process your personal data unless there are compelling legitimate grounds that outweigh your interests or the processing serves the establishment, exercise or defense of legal claims. You can object to the processing of your data for the purposes of direct advertising or any associated profiling without stating reasons for your actions.

PROCESSING SITUATIONS

  Website use

Our website aims to provide information about our company and our services, conclude or initiate contractual relationships and communicate and interact with our customers and interested parties.

We also process personal data for these purposes. The scope and legal basis of data processing depend on the services requested by the user, the respective browser configuration and the scope of any granted consent.

Web technologies

To improve communication and interaction with our customers and optimize the user experience, we use various software solutions and web technologies, including tools provided by third-party providers for web analysis and marketing as well as services for integrating third-party content, such as fonts, maps or videos.

Analysis tools are used to record, measure and analyze data points such as visitor numbers, visitor sources, pages visited, dwell time on the website or scroll depth. Marketing tools enable the targeted control and evaluation of marketing measures (ad campaigns, affiliate advertising and multichannel analysis).

Use of such tools often requires the consent of the respective user for reasons of ePrivacy and data protection. We use a so-called consent management tool to obtain and manage the necessary consent in accordance with Section 25(1), TTDSG (German Telecommunications Digital Services Data Protection Act) and, if applicable, Article 6(1), Sentence 1, Point a., GDPR (see the following section).

Detailed information about the subject matter and scope of the corresponding consent and the data processing based on them shall be made available to you directly via the CMT.

Insofar as consent is not required, personal data is processed based on Article 6(1), Sentence 1, Point f), GDPR, for the purposes described, which also constitute the interests pursued by us or our partners. The collection of data for the provision of the website and the retention of log files are absolutely necessary to operate the website.

  1. Consent management tool

We use a consent management tool (CMT) for the purpose of consent management. When you visit our website, a CMT Cookie is set, which is used to store the consents granted for the individual services and control the corresponding activation or deactivation of the respective functionalities.

The CMT is used to obtain the necessary consent and document it in accordance with our obligation to furnish proof. The legal basis in this respect is Article 6(1), Point c, GDPR.

The CMT is provided by a service provider, which processes the data for us. The collected data is stored until you delete the Cookie. Details about data processing by the CMT can be found in the tool’s user interface.

Customer management, direct advertising

We use a so-called Customer Relationship Management System (CRMS) for the purpose of centralized management of business-related contact and marketing information within the GLÜCK AUF Group. The data managed in the CRMS entails both existing customer contacts and registered website users, including whitepaper subscribers, webinar participants, newsletter subscribers and other marketing contacts.

Customer/user profiles

The CRMS enables us to combine marketing information from various sources and evaluate it for the purpose of optimizing our marketing strategy and targeting direct advertising. This may also entail the creation and analysis of customer or user profiles to establish which offers and services are particularly popular and design individualized marketing campaigns in line with the respective interests.

In addition to the operational existing customer data, the data generated via our online offers (e.g. landing pages and contact forms) is also processed via the CRMS. Data from email and social media marketing (e.g. opening rates and referral paths etc.) may also be processed.

 We are interested in the efficient and targeted organization of the sales efforts and marketing activities of the various business divisions within the GLÜCK AUF Group, and coordinating them across divisions. To that end, we process the relevant CRM data (including with the help of service providers) in accordance with Article 6(1), Point f, GDPR, based on the balancing of interests.

Consent-based advertising

Consent management is an additional component of our CRMS. In accordance with Section 7(2), Nos. 1 and 2, UWG, certain direct advertising measures, such as email advertising or telephone advertising to consumers in particular, are only permitted based on prior express consent.

If and insofar as you grant us your consent in the context of our internet offers, we document and retain (also with the help of service providers) the information required to honor our obligations to furnish proof (Article 7(1), GDPR, and, if applicable, Section 7a, UWG) based on Article 6(1), Point c, GDPR.

In the event of withdrawal of consent, we shall retain the evidence for documentation purposes based on Article 6(1), Point f, GDPR, until expiry of the statutory limitation periods. This is aimed at safeguarding our interest in a legal defense that may be required. The same applies to documenting advertising objections, which we also retain in a blocking list for sending emails to ensure that no advertising is sent to recipients who expressly do not wish to receive it.

Personalized direct advertising

If consent has been granted, data is processed for the purposes covered by the consent based on Article 6(1), Point a, GDPR. Irrespective of any requirement for consent, we process personal data from our CRMS and, where applicable, from other sources (including service providers) for the purpose of target group-oriented and, where applicable, personalized delivery and design of direct advertising. The legal basis for processing to pursue our advertising interests is Article 6(1),Point f, GDPR.

Please note that consent is not required for advertising to existing customers in accordance with the conditions of Section 7(3), UWG (German Unfair Competition Act). Data can thus be processed based on legitimate interests in conjunction with email marketing including if you have not granted your advertising consent or have withdrawn any consent granted to us.

Contact inquiries

If you contact us via our contact forms or by email, we regularly process your personal data (including with the help of service providers) to answer your inquiry or process your request based on Article 6(1), Point f, GDPR, and safeguard fundamental interests of business activities, in particular corporate communications.

Contract-related communication that is required to honor a contractual relationship concluded with you or as part of pre-contractual measures based on your inquiry is also implemented based on Article 6(1), Point b, GDPR.

Prize competitions/competitions

We organize prize puzzles or other competitions from time to time. For the purpose of organizing such competitions, we process the personal data of the participants based on Article 6(1), Point b, GDPR, and, if applicable, based on Article 6(1), Point f, GDPR, including for marketing purposes (marketing interest – e.g. publication of the winners by name).
Where not provided for to the contrary in individual cases, the following conditions apply to participation in our competitions. The overall organizer of the competition is GLÜCK AUF Immobilien GmbH. Persons aged 18 and over who are resident in Germany are eligible to participate. Employees and family members living in the same household as employees of the GLÜCK AUF Group and any other companies involved in organizing the competition are not eligible to participate. Multiple entries and entries via third-parties (so-called “straw men”) or commercial competition (entry) services are not permitted. The entry period, entry procedure and prizes awarded are set out in the respective announcement. The winners shall be determined by drawing lots (computer-supported if necessary). Payment of the prize value in cash is not possible. The prize claim is not transferable. We reserve the right to amend the conditions of participation at any time (including during the participation period) and/or cancel or prematurely terminate a competition for objective reasons (e.g. attempted manipulation). Legal recourse is excluded.

Applicant management

As part of applicant management, we process applicant data for the purpose of initiating a possible employment relationship based on Article 6(1), Sentence 1, Point b, GDPR, in conjunction with Section 26(1), BDSG. If an employment relationship is not established, we shall delete all application data at the latest six months following completion of the application process. With your consent, which is also the legal basis (Article 6(1), Sentence 1, Point a, GDPR) for further data processing, we may retain your application documents in our applicant pool for future job advertisements for one additional year.


Suppliers, service providers

We process contact and communication data and other business-relevant information of our cooperation partners, suppliers and service providers or the contact persons working on their behalf. Data are processed based on Article 6(1), Point f, GDPR, in the interest of initiating, implementing and maintaining our business relationships and on the basis of Article 6(1), Point b, if the data subject is a contracting party as an individual entrepreneur.