Skip to content
my accountmy account

Privacy Policy

We are very pleased about your interest in our company. Data protection is of particularly high importance to the management of ISS International Security School & Services GmbH®, Konstantinos Kanakaris. The use of the websites of ISS International Security School & Services GmbH®, Konstantinos Kanakaris is generally possible without providing any personal data. However, if a data subject wishes to make use of special services provided by our company via our website, the processing of personal data may become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to ISS International Security School & Services GmbH®, Konstantinos Kanakaris. By means of this Privacy Policy, our company 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 informs data subjects about the rights to which they are entitled.

As the controller responsible for processing, ISS International Security School & Services GmbH®, Konstantinos Kanakaris has implemented numerous technical and organisational measures to ensure the most complete protection possible of personal data processed through this website. Nevertheless, internet-based data transmissions may in principle have security vulnerabilities, meaning that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. Definitions

The Privacy Policy of ISS International Security School & Services GmbH®, Konstantinos Kanakaris is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our Privacy Policy is intended to be easy to read and understand both for the public and for our customers and business partners. To ensure this, we would first like to explain the terminology used.

In this Privacy Policy, we use the following terms, among others:

a) Personal Data

Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as the “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 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 responsible for processing.

c) Processing

Processing means any operation or set of operations performed on 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 such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that person’s work performance, 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 ensuring that the personal data is not attributed to an identified or identifiable natural person.

g) Controller or Controller Responsible for Processing

The controller or controller responsible for 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 processing personal data. Where the purposes and means of such processing are determined by Union law or the law of Member States, the controller or the specific criteria for its nomination may be provided for by Union law or Member State law.

h) Processor

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

i) Recipient

A recipient is a natural or legal person, public authority, agency or other body to which personal data is disclosed, whether or not it is a third party. However, public authorities which may receive personal data in the framework of a particular investigation in accordance with Union law or Member State law are not regarded as recipients.

j) Third Party

A third party is a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

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

2. Name and Address of the Controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in Member States of the European Union and other provisions relating to data protection is:

ISS International Security School & Services GmbH®
Konstantinos Kanakaris
Krombacher Str. 39
51491 Overath
56

Tel.: +49 (0) 2206 - 951944-0
Email: shops@issprotectiontrade.com
Website: https://www.issprotectiontrade.com

3. Cookies

The websites of ISS International Security School & Services GmbH®, Konstantinos Kanakaris use cookies. Cookies are text files that are stored on a computer system via an internet browser.

Numerous websites 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 sequence of characters through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This enables visited websites and servers to distinguish the individual browser of the data subject from other internet browsers containing different cookies. A specific internet browser can be recognised and identified using the unique cookie ID.

By using cookies, ISS International Security School & Services GmbH®, Konstantinos Kanakaris can provide users of this website with more user-friendly services that would not be possible without the setting of cookies.

Cookies allow the information and offers on our website to be optimised in the interests of the user. As already mentioned, cookies enable us to recognise users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, users of a website that uses cookies do not have to enter their access data again each time they visit the website because this is handled by the website and the cookie stored on the user’s computer system. Another example is the cookie used for a shopping cart in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart by means of a cookie.

The data subject may prevent the setting of cookies by our website at any time by selecting the appropriate setting in the internet browser used and may therefore permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject disables cookies in the internet browser used, not all functions of our website may be fully available.

4. Collection of General Data and Information

The website of ISS International Security School & Services GmbH®, Konstantinos Kanakaris collects a range 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 log files. The following may be collected: (1) 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 subpages accessed on our website by an accessing system, (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 used for security purposes in the event of attacks on our information technology systems.

When using this general data and information, ISS International Security School & Services GmbH®, Konstantinos Kanakaris does not draw any conclusions about the data subject. Rather, this information is required in order to (1) correctly deliver the content of our website, (2) optimise the content of our website and the advertising for it, (3) ensure the permanent functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. This anonymously collected data and information is therefore statistically evaluated by ISS International Security School & Services GmbH®, Konstantinos Kanakaris and also with the aim of increasing data protection and data security within our company in order to ensure an optimal level of protection for the personal data we process. Anonymous data from server log files is stored separately from all personal data provided by a data subject.

5. Registration on Our Website

The data subject has the option of registering on the website of the controller by providing personal data. The personal data transmitted to the controller is determined by the respective input form used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for the controller’s own purposes. The controller may arrange for the data to be transferred to one or more processors, for example a parcel delivery service provider, which will also use the personal data exclusively for internal purposes attributable to the controller.

Registration on the controller’s website also results in the storage of the IP address assigned by the data subject’s internet service provider (ISP), as well as the date and time of registration. This data is stored because it is the only way to prevent misuse of our services and, if necessary, enables criminal offences to be investigated. In this respect, the storage of this data is necessary for the protection of the controller. This data is generally not disclosed to third parties unless there is a statutory obligation to disclose it or disclosure serves the purpose of criminal prosecution.

The voluntary registration of the data subject with personal data enables the controller to offer the data subject content or services which, by their nature, can only be offered to registered users. Registered persons are free to modify the personal data provided during registration at any time or to have it completely deleted from the controller’s database.

The controller shall, at any time and upon request, provide any data subject with information about which personal data relating to the data subject is stored. Furthermore, the controller shall correct or erase personal data at the request or instruction of the data subject, provided that there are no statutory retention obligations to the contrary. All employees of the controller are available to the data subject as contact persons in this context.

6. Subscription to Our Newsletter

On the website of ISS International Security School & Services GmbH®, Konstantinos Kanakaris, users are given the opportunity to subscribe to our company newsletter. The personal data transmitted to the controller when subscribing to the newsletter is determined by the input form used for this purpose.

ISS International Security School & Services GmbH®, Konstantinos Kanakaris regularly informs its customers and business partners about company offers by means of a newsletter. The company newsletter can generally only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter. For legal reasons, a confirmation email is sent using the double opt-in procedure to the email address entered by the data subject for the first time for newsletter delivery. This confirmation email is used to verify whether the owner of the email address, as the data subject, has authorised receipt of the newsletter.

When registering for the newsletter, we also store 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 trace the possible misuse of a data subject’s email address at a later date and therefore serves the legal protection of the controller.

The personal data collected as part of a newsletter subscription is used exclusively for sending our newsletter. Newsletter subscribers may also be informed by email if this is necessary for the operation of the newsletter service or a related registration, for example in the event of changes to the newsletter service or technical circumstances. Personal data collected as part of the newsletter service is not disclosed to third parties. The data subject may unsubscribe from our newsletter at any time. Consent to the storage of personal data given by the data subject for newsletter delivery may be withdrawn at any time. For the purpose of withdrawing consent, each newsletter contains an appropriate link. It is also possible to unsubscribe from the newsletter at any time directly via the controller’s website or to inform the controller by other means.

7. Newsletter Tracking

The newsletters of ISS International Security School & Services GmbH®, Konstantinos Kanakaris contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in emails sent in HTML format in order to enable log-file recording and log-file analysis. This allows statistical evaluation of the success or failure of online marketing campaigns. Using the embedded tracking pixel, ISS International Security School & Services GmbH®, Konstantinos Kanakaris can determine whether and when an email was opened by a data subject and which links contained in the email were accessed by the data subject.

Personal data collected via tracking pixels contained in newsletters is stored and evaluated by the controller in order to optimise newsletter delivery and to tailor the content of future newsletters even more closely to the interests of the data subject. This personal data is not disclosed to third parties. Data subjects are entitled at any time to withdraw the separate consent given via the double opt-in procedure in this regard. Following withdrawal, this personal data will be deleted by the controller. Unsubscribing from the newsletter is automatically interpreted by ISS International Security School & Services GmbH®, Konstantinos Kanakaris as withdrawal of consent.

8. Contact via the Website

The website of ISS International Security School & Services GmbH®, Konstantinos Kanakaris contains information required by law that enables rapid electronic contact with our company and direct communication with us, including a general electronic mail address (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data voluntarily transmitted by a data subject to the controller is stored for the purpose of processing the enquiry or contacting the data subject. This personal data is not disclosed to third parties.

9. Routine Erasure and Blocking of Personal Data

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

If the purpose of storage no longer applies or if a retention period prescribed by the European legislator or another competent legislator expires, the personal data will routinely be blocked or erased in accordance with statutory requirements.

10. Rights of the Data Subject

a) Right to Confirmation

Every data subject has the right granted by the European legislator to obtain confirmation from the controller as to whether personal data relating to them is being processed. If a data subject wishes to exercise this right to confirmation, they may contact an employee of the controller at any time.

b) Right of Access

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller, free of charge and at any time, information about the personal data stored concerning them and a copy of that 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 being processed;

  • 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 this is not possible, the criteria used to determine that period;

  • the existence of a right to request rectification or erasure of personal data concerning them or restriction of processing by the controller, or a right to object to such processing;

  • the existence of a 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 has the right to obtain information as to whether personal data has been transferred to a third country or an international organisation. 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 contact an employee of the controller at any time.

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. Furthermore, taking into account the purposes of the processing, the data subject 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 contact an employee of the controller at any time.

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 obtain from the controller the erasure of personal data concerning them without undue delay where one of the following grounds applies and insofar 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 pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and 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 must be erased in order to comply with a legal obligation under Union law 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.

Where one of the above-mentioned grounds applies and a data subject wishes to request the erasure of personal data stored by ISS International Security School & Services GmbH®, Konstantinos Kanakaris, they may contact an employee of the controller at any time. The employee of ISS International Security School & Services GmbH®, Konstantinos Kanakaris will arrange for the erasure request to be complied with without undue delay.

Where personal data has been made public by ISS International Security School & Services GmbH®, Konstantinos Kanakaris and our company, as controller, is obliged pursuant to Article 17(1) GDPR to erase the personal data, ISS International Security School & Services GmbH®, Konstantinos Kanakaris, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure by such controllers of any links to, or copies or replication of, that personal data, insofar as processing is not required. The employee of ISS International Security School & Services GmbH®, Konstantinos Kanakaris will arrange the necessary measures in each individual case.

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 obtain from the controller 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 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 processing, but the data subject requires it for the establishment, exercise or defence of legal claims.

  • The data subject has objected to processing pursuant to Article 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override those of the data subject.

Where one of the above conditions applies and a data subject wishes to request the restriction of personal data stored by ISS International Security School & Services GmbH®, Konstantinos Kanakaris, they may contact an employee of the controller at any time. The employee of ISS International Security School & Services GmbH®, Konstantinos Kanakaris 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 personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit this data to another controller without hindrance from the controller to which the personal data was provided, where the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR and the processing is carried out by automated means, provided that 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 Article 20(1) GDPR, the data subject has the right to have personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

To exercise the right to data portability, the data subject may contact an employee of ISS International Security School & Services GmbH®, Konstantinos Kanakaris 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 at any time, on grounds relating to their particular situation, to the processing of personal data concerning them based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.

In the event of an objection, ISS International Security School & Services GmbH®, Konstantinos Kanakaris 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 unless the processing serves the establishment, exercise or defence of legal claims.

Where ISS International Security School & Services GmbH®, Konstantinos Kanakaris processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to ISS International Security School & Services GmbH®, Konstantinos Kanakaris processing for direct marketing purposes, ISS International Security School & Services GmbH®, Konstantinos Kanakaris 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 the processing of personal data concerning them by ISS International Security School & Services GmbH®, Konstantinos Kanakaris for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, unless such 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 contact any employee of ISS International Security School & Services GmbH®, Konstantinos Kanakaris or another employee directly. The data subject is also free, in the context of the use of information society services and notwithstanding Directive 2002/58/EC, 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, unless the decision (1) is necessary for entering into or performing a contract between the data subject and the controller, (2) is authorised by Union or Member State law to which the controller is subject and which also lays down appropriate measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

Where the decision (1) is necessary for entering into or performing a contract between the data subject and the controller or (2) is based on the data subject’s explicit consent, ISS International Security School & Services GmbH®, Konstantinos Kanakaris shall implement appropriate measures to safeguard the data subject’s rights, freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express their own point of view and to contest the decision.

If the data subject wishes to exercise rights relating to automated decisions, they may contact an employee of the controller at any time.

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

11. Data Protection in Applications and the Recruitment Process

The controller collects and processes applicants’ personal data for the purpose of managing the recruitment process. Processing may also take place electronically. This is particularly the case where an applicant submits application documents to the controller electronically, for example by email or via a web form on the website. If the controller enters into an employment contract with an applicant, the submitted data will be stored for the purpose of managing the employment relationship in compliance with statutory requirements. If the controller does not enter into an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller prevent deletion. Another legitimate interest in this context may be, for example, a burden of proof in proceedings under the German General Equal Treatment Act (AGG).

12. Data Protection Provisions Concerning the Use of Facebook

The controller has integrated components of the company Facebook into this website. Facebook is a social network.

A social network is an online social meeting place, an online community that generally enables users to communicate with one another and interact in a virtual environment. A social network may serve as a platform for exchanging opinions and experiences or may enable the online community to provide personal or business-related information. Facebook enables users of the social network, among other things, to create private profiles, upload photographs and connect with others through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. Where a data subject lives outside the USA or Canada, the controller responsible for processing personal data is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time one of the individual pages of this website operated by the controller and containing a Facebook component (Facebook plug-in) is accessed, the internet browser on the data subject’s information technology system is automatically prompted by the respective Facebook component to download a representation of the corresponding Facebook component from Facebook. An overview of all Facebook plug-ins is available at https://developers.facebook.com/docs/plugins/?locale=de_DE. As part of this technical process, Facebook becomes aware 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 recognises which specific subpage of our website the data subject visits each time our website is accessed and for the entire duration of the visit. This information is collected by the Facebook component and assigned by Facebook to the data subject’s respective Facebook account. If the data subject clicks one of the Facebook buttons integrated into our website, for example the “Like” button, or leaves a comment, Facebook assigns this information to the data subject’s personal Facebook user account and stores this personal data.

Facebook receives information via the Facebook component that the data subject has visited our website whenever the data subject is logged into Facebook at the time our website is accessed. This occurs regardless of whether the data subject clicks the Facebook component. If the data subject does not wish such information to be transmitted to Facebook, they can prevent this transmission by logging out of their Facebook account before accessing our website.

Facebook’s published data policy, available at https://de-de.facebook.com/about/privacy/, provides information on the collection, processing and use of personal data by Facebook. It also explains which settings Facebook offers to protect the privacy of the data subject. In addition, various applications are available that make it possible to prevent data transmission to Facebook. Such applications may be used by the data subject to prevent data transmission to Facebook.

13. Data Protection Provisions Concerning the Use of Instagram

The controller has integrated components of the Instagram service into this website. Instagram is a service that can be classified as an audiovisual platform and enables users to share photographs and videos and also redistribute such data on other social networks.

The operating company of Instagram services is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time one of the individual pages of this website operated by the controller and containing an Instagram component (Instagram button) is accessed, the internet browser on the data subject’s information technology system is automatically prompted by the respective Instagram component to download a representation of the corresponding Instagram component. As part of this technical process, Instagram becomes aware of which specific subpage of our website is visited by the data subject.

If the data subject is logged into Instagram at the same time, Instagram recognises which specific subpage the data subject visits each time our website is accessed and for the entire duration of the visit. This information is collected by the Instagram component and assigned by Instagram to the data subject’s respective Instagram account. If the data subject clicks one of the Instagram buttons integrated into our website, the data and information transmitted in this way is assigned to the data subject’s personal Instagram user account and stored and processed by Instagram.

Instagram receives information via the Instagram component that the data subject has visited our website whenever the data subject is logged into Instagram at the time our website is accessed. This occurs regardless of whether the data subject clicks the Instagram component. If the data subject does not wish such information to be transmitted to Instagram, they can prevent this transmission by logging out of their Instagram account before accessing our website.

Further information and Instagram’s applicable data protection provisions are available at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

14. Payment Method: Data Protection Provisions Concerning PayPal as a Payment Method

The controller has integrated PayPal components into this website. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. PayPal also offers the option of processing virtual credit card payments where a user does not maintain a PayPal account. A PayPal account is managed using an email address, meaning that there is no conventional account number. PayPal enables online payments to third parties to be initiated and payments to be received. PayPal also performs trustee functions and provides buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22–24 Boulevard Royal, L-2449 Luxembourg.

If the data subject selects “PayPal” as the payment method during the ordering process in our online shop, the data subject’s data is automatically transmitted to PayPal. By selecting this payment option, the data subject consents to the transmission of personal data required for payment processing.

The personal data transmitted to PayPal generally includes first name, surname, address, email address, IP address, telephone number, mobile telephone number and other data required for payment processing. Personal data relating to the respective order is also necessary for processing the purchase contract.

The purpose of transmitting the data is payment processing and fraud prevention. The controller will transmit personal data to PayPal in particular where there is a legitimate interest in doing so. Personal data exchanged between PayPal and the controller may, under certain circumstances, be transmitted by PayPal to credit reference agencies. The purpose of this transmission is identity and creditworthiness checks.

PayPal may disclose personal data to affiliated companies, service providers or subcontractors where this is necessary to fulfil contractual obligations or where the data is to be processed on its behalf.

The data subject has the option of withdrawing consent to the handling of personal data from PayPal at any time. Withdrawal does not affect personal data that must necessarily be processed, used or transmitted for contractual payment processing.

PayPal’s applicable data protection provisions are available at https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

15. Legal Basis for Processing

Article 6(1)(a) GDPR serves as the legal basis for processing operations for which our company obtains 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, for example where processing operations are necessary for the delivery of goods or the provision of another service or consideration, processing is based on Article 6(1)(b) GDPR. The same applies to processing operations necessary for taking steps prior to entering into a contract, for example in cases of enquiries concerning our products or services.

Where our company is subject to a legal obligation requiring the processing of personal data, for example to fulfil tax obligations, processing is based on Article 6(1)(c) GDPR.

In rare cases, the processing of personal data may be necessary in order 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 at our premises and their name, age, health insurance data or other vital information had to be disclosed to a doctor, hospital or other third party. In such a case, processing would be based on Article 6(1)(d) GDPR.

Finally, processing operations may be based on Article 6(1)(f) GDPR. This legal basis applies to processing operations not covered by any of the aforementioned legal bases where processing is necessary for the purposes of a legitimate interest pursued by our company or by a third party, provided that the interests, fundamental rights and freedoms of the data subject do not override such interests. Such processing operations are permitted in particular because they were specifically mentioned by the European legislator. In this respect, the legislator considered that a legitimate interest could be assumed where the data subject is a customer of the controller (Recital 47, sentence 2 GDPR).

16. Legitimate Interests Pursued by the Controller or a Third Party

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

17. Period for Which Personal Data Is Stored

The criterion used to determine the period for which personal data is stored is the respective statutory retention period. After expiry of this period, the relevant data is routinely deleted, provided that it is no longer required for the performance or initiation of a contract.

18. Statutory or Contractual Requirements Concerning 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 (e.g. tax regulations) or may also result from contractual provisions (e.g. information concerning the contractual partner).

In some cases, it may be necessary for a data subject to provide us with personal data in order to enter into a contract, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data where our company concludes a contract with them. Failure to provide personal data would mean that the contract with the data subject could not be concluded.

Before providing personal data, the data subject must contact one of our employees. Our employee 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 entering into a contract, whether there is an obligation to provide the personal data, and what consequences may result from failure to provide such data.

19. Existence of Automated Decision-Making

As a responsible company, we do not use automated decision-making or profiling.

Developed by the Legal Tech specialists at Willing & Able, who also developed the system for digital contracts. The texts of the privacy policy generator were created and published by Prof. Dr. h.c. Heiko Jonny Maniero and attorney Christian Solmecke.

Legal guarantee