Introduction

With the following privacy policy, we aim to inform you about the types of your personal data (hereinafter also referred to briefly as “data”) that we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the provision of our services and especially on our websites, mobile applications, and external online presences, such as our social media profiles (hereinafter collectively referred to as the “online offering”).

The terms used are not gender-specific.

Date: November 21, 2022

Table of Contents
IntroductionController
Overview of Processing
Change Privacy Settings
Relevant Legal Bases
Security Measures
Transmission of Personal Data
Data Processing in Third Countries
Data Deletion
Use of Cookies
Provision of the Online Offering and Web Hosting
Contact and Inquiry Management
Amendment and Update of the Privacy Policy
Rights of Data Subjects
Definition of Terms

Controller

SAH

Represented by Martin Görlitz

Bubenheimer Weg 23, 56072 Koblenz

Info at sah.de

IT and Data Processing Contact:

Marius Erdmann

marius.erdmann at isso.de

Overview of Processing

The following overview summarizes the types of processed data and the purposes of their processing, referring to the affected individuals.

Change Privacy Settings

Types of Processed Data

Contact details.

Content data.

Usage data.

Meta/communication data.

Categories of Data Subjects

Communication partners.

Users.

Purposes of Processing

Contact inquiries and communication.

Security measures.

Management and response to inquiries.

Feedback.

Provision of our online offering and user-friendliness.

Information technology infrastructure.

Relevant Legal Bases

Below is an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations may apply in your country of residence or establishment. If more specific legal bases are applicable in individual cases, we will inform you of these in the privacy policy.

Contractual performance and pre-contractual inquiries (Art. 6(1)(b) GDPR) – Processing is necessary for the performance of a contract with the data subject or for pre-contractual measures initiated at the data subject’s request.

Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary to protect the legitimate interests pursued by the controller or a third party, unless overridden by the interests or fundamental rights and freedoms of the data subject requiring personal data protection.

In addition to the GDPR, national data protection regulations in Germany may apply, particularly the Federal Data Protection Act (BDSG). The BDSG includes specific provisions regarding the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and the transmission and automated decision-making, including profiling, in individual cases. It also regulates data processing for employment purposes (§ 26 BDSG), especially concerning the initiation, implementation, or termination of employment relationships and employee consent. Additionally, data protection laws of individual federal states may be applicable.

Security Measures

In compliance with legal requirements and taking into account the state of the art, implementation costs, and the nature, scope, context, and purposes of processing, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include securing the confidentiality, integrity, and availability of data through control of physical and electronic access to the data and the corresponding access, input, disclosure, availability, and separation of the data. We have also established procedures to ensure the exercise of data subject rights, data deletion, and responses to data threats. Furthermore, we consider data protection when developing or selecting hardware, software, and procedures, following the principles of data protection, through technology design and privacy-friendly default settings.

TLS Encryption (https): To protect data transmitted via our online offering, we use TLS encryption. You can recognize encrypted connections by the prefix https:// in your browser’s address bar.

Transmission of Personal Data

In the course of processing personal data, it may be necessary to transmit the data to other entities, companies, legally independent organizational units, or individuals or disclose them to them. Recipients of this data may include, for example, IT service providers or providers of services and content embedded in a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to ensure their protection.

Data Processing in Third Countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if the processing occurs in the context of using third-party services or disclosing/transmitting data to other entities, bodies, or companies, this will only occur in compliance with legal requirements.

Subject to explicit consent or contractual or legal requirements for transmission, we will process or have your data processed in third countries with recognized data protection standards, contractual obligations through so-called standard contractual clauses of the EU Commission, in the presence of certifications, or binding corporate rules (Art. 44 to 49 GDPR, EU Commission’s information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Data Deletion

We will delete the data processed by us in accordance with legal requirements as soon as the consents for processing are revoked or other permissions expire (e.g., when the purpose of processing the data no longer exists or is not necessary for the purpose). If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.

Our privacy notices may also provide additional information about the retention and deletion of data that is primarily applicable to specific processing activities.

Use of Cookies

Cookies are small text files or other storage technologies that store information on end devices and retrieve information from them. For example, to store login status in a user account, shopping cart content in an e-shop, the accessed content, or functions used in an online offering. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as analyzing visitor flows.

Consent Information: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users unless it is not required by law. Consent is not necessary, in particular, if storing and retrieving information, including cookies, is absolutely necessary to provide users with a telemedia service expressly requested by them (i.e., our online offering). Revocable consent is clearly communicated to users and includes information about the specific use of cookies.

Information on Legal Bases for Data Processing: The legal basis on which we process users’ personal data using cookies depends on whether we ask users

for consent. If users consent, the legal basis for processing their data is the declared consent. Otherwise, if cookies are used within the scope of our legitimate interests (e.g., for the operational operation of our online offering and improving its usability) or if their use is necessary for fulfilling our contractual obligations, the legal basis is our legitimate interests or the necessity of using cookies to fulfill our contractual obligations. We will inform users of the purposes for which cookies are processed during this privacy policy or as part of our consent and processing processes.

Storage Duration: In terms of storage duration, the following types of cookies are distinguished:

Temporary Cookies (Session Cookies): Temporary cookies are deleted at the latest after a user leaves an online offering and closes their device (e.g., browser or mobile application).

Permanent Cookies: Permanent cookies remain stored even after closing the device. For example, login status can be stored or preferred content can be displayed directly when the user visits a website again. Also, data collected using cookies can be used for audience measurement. Unless we provide explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and can have a storage duration of up to two years.

General Information on Revocation and Objection (Opt-Out): Users can revoke any consent given and object to processing in accordance with the legal requirements of Art. 21 GDPR. Users can also declare their objection through their browser settings, such as by deactivating the use of cookies (which may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Additional Information on Processing Procedures, Processes, and Services:

Processing of Cookie Data Based on Consent: We use a cookie consent management process through which users’ consents to the use of cookies, as well as the processing and providers specified in the cookie consent management process, can be obtained, managed, and revoked by users. The consent declaration is stored to avoid repeated requests for consent and to be able to prove consent in accordance with legal obligations. Storage can be server-side and/or in a cookie (so-called opt-in cookie or similar technologies) to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The storage duration of the consent can be up to two years. A pseudonymous user identifier is created, and the time of consent, information about the scope of consent (e.g., which categories of cookies and/or service providers), and the browser, system, and device used are stored.

To manage the cookies and similar technologies (tracking pixels, web beacons, etc.) used and related consents, we use the “Real Cookie Banner” consent tool. Details on how “Real Cookie Banner” works can be found at https://devowl.io/en/rcb/data-processing/.

Legal bases for processing personal data in this context are Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and related consents.

Providing personal data is neither contractually required nor necessary to conclude a contract. You are not obliged to provide personal data. If you do not provide personal data, we cannot manage your consents.

Provision of the Online Offering and Web Hosting

We process user data to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or device.

Processed Data Types: Usage data (e.g., visited websites, interest in content, access times); Meta/communication data (e.g., device information, IP addresses).

Affected Individuals: Users (e.g., website v ** isitors, users of online services).

Purposes of Processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices such as computers, servers, etc.); Security measures.

Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR).

Additional Information on Processing Procedures, Processes, and Services:

Provision of Online Offering on Rented Storage Space:** To provide our online offering, we use storage space, computing capacity, and software rented or otherwise obtained from a server provider (also called “web hoster”); **Legal Bases:** Legitimate interests (Art. 6(1)(f) GDPR).

Collection of Access Data and Logfiles: Access to our online offering is logged in the form of “server logfiles.” Server logfiles may include the address and name of accessed websites and files, date and time of access, transmitted data volumes, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), and usually IP addresses and the requesting provider. Server logfiles may be used for security purposes, such as avoiding server overload (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure server utilization and stability; **Legal Bases:** Legitimate interests (Art. 6(1)(f) GDPR); **Data Deletion:** Logfile information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.

Contact and Inquiry Management

When contacting us (e.g., via contact form, email, phone, or social media) and within existing user and business relationships, the information provided by the inquiring individuals is processed to respond to contact inquiries and any requested measures.

Processed Data Types: Contact details (e.g., email, phone numbers); Content data (e.g., entries in online forms); Usage data (e.g., visited websites, interest in content, access times); Meta/communication data (e.g., device information, IP addresses).

Affected Individuals: Communication partners.

Purposes of Processing: Contact inquiries and communication; Management and response to inquiries; Feedback (e.g., collecting feedback via online form); Provision of our online offering and user-friendliness.

Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR); Contractual performance and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Additional Information on Processing Procedures, Processes, and Services:

Contact Form: When users contact us through our contact form, email, or other communication channels, we process the data communicated in this context to handle the stated request; **Legal Bases:** Contractual performance and pre-contractual inquiries (Art. 6(1)(b) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).

Amendment and Update of the Privacy Policy

We ask you to regularly check the content of our privacy policy. We adjust the privacy policy as soon as changes in the data processing we perform require it. We will inform you as soon as your cooperation (e.g., consent) or other individual notification is required due to these changes.

Rights of Data Subjects

As data subjects under the GDPR, you have various rights, particularly arising from Art. 15 to 21 GDPR:

– Right to Object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on Art. 6(1)(e) or (f) GDPR, including profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

– Right to Withdraw Consent: You have the right to withdraw consent at any time.

– Right to Information: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and additional information.

– Right to Rectification: You have the right to obtain the rectification of inaccurate personal data concerning you.

– Right to Erasure and Restriction of Processing: You have the right, under certain conditions, to request the erasure of your personal data or the restriction of its processing.

– Right to Data Portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format or to request its transmission to another controller.

– Complaint to Supervisory Authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Definition of Terms

In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The explanations below are intended to serve understanding. The terms are sorted alphabetically.

– Personal Data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “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 (e.g., cookie), or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

– Controller: The “controller” is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.

– Processing: “Processing” is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, including collection, evaluation, storage, transmission, or deletion.