Privacy Policy
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We are very delighted that you have shown interest in our enterprise. Data
protection is of a particularly high priority for the management of COMPANYNAME.
The use of the Internet pages of COMPANYNAME is possible without any indication
of personal data; however, if a data subject wants to use special enterprise
services via our website, processing of personal data could become necessary.
If the processing of personal data is necessary and there is no statutory basis
for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address,
or telephone number of a data subject shall always be in line with the General
Data Protection Regulation (GDPR), and in accordance with the country-specific
data protection regulations applicable to COMPANYNAME. By means of this data
protection declaration, our enterprise would like to inform the general public
of the nature, scope, and purpose of the personal data we collect, use and
process. Furthermore, data subjects are informed, by means of this data
protection declaration, of the rights to which they are entitled.
As the controller, COMPANYNAME has implemented
numerous technical and organizational measures to ensure the most complete
protection of personal data processed through this website. However,
Internet-based data transmissions may in principle have security gaps, so
absolute protection may not be guaranteed. For this reason, every data subject
is free to transfer personal data to us via alternative means, e.g. by
telephone.
1. Definitions
The data protection declaration of COMPANYNAME is based on the terms used
by the European legislator for the adoption of the General Data Protection
Regulation (GDPR). Our data protection declaration should be legible and
understandable for the general public, as well as our customers and business
partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following
terms:
- a)
Personal data
Personal data means any information
relating to an identified or identifiable natural person (“data subject”). An
identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person.
- b) Data subject
Data subject is any identified or
identifiable natural person, whose personal data is processed by the controller
responsible for the processing.
- c)
Processing
Processing is any operation or set of
operations which is performed on personal data or on sets of personal data,
whether or not by automated means, such as collection, recording, organization,
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 is the marking
of stored personal data with the aim of limiting their processing in the
future.
- e)
Profiling
Profiling means any form of automated
processing of personal data consisting of the use of personal data to evaluate
certain personal aspects relating to a natural person, in particular to analyse
or predict aspects concerning that natural person's performance at work,
economic situation, health, personal preferences, interests, reliability,
behaviour, location or movements.
- f)
Pseudonymization
Pseudonymization is 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 organizational measures to ensure that the personal
data are not attributed to an identified or identifiable natural person.
- g)
Controller or controller responsible for the processing
Controller or controller responsible for
the 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 the processing of personal data; where the purposes and means of such
processing are determined by Union or Member State law, the controller or the
specific criteria for its nomination may be provided for by Union or Member
State law.
- h)
Processor
Processor is a natural or legal person,
public authority, agency or other body which processes personal data on behalf
of the controller.
- i)
Recipient
Recipient is a natural or legal person,
public authority, agency or another body, to which the personal data are
disclosed, whether a third party or not. However, public authorities which may
receive personal data in the framework of a particular inquiry in accordance
with Union or Member State law shall not be regarded as recipients; the
processing of those data by those public authorities shall be in compliance
with the applicable data protection rules according to the purposes of the
processing.
- j)
Third Party
Third party is a natural or legal
person, public authority, agency or body other than the data subject,
controller, processor and persons who, under the direct authority of the
controller or processor, are authorized to process personal data.
- k)
Consent
2. Name and address of the controller
Controller for the purposes of the
General Data Protection Regulation (GDPR), other data protection laws
applicable in Member states of the European Union and other provisions related
to data protection is:
COMPANYNAME
COMPANYSTREET, COMPANYHOUSENUMBER
COMPANYPOSTALCODE COMPANYCITY
COMPANYSTATE
COMPANYPHONENUMBER
COMPANYEMAIL
COMPANYWEBSITE
3. Cookies
The Internet pages of COMPANYNAME use
cookies. Cookies are text files that are stored in a computer system via an
Internet browser.
Many Internet sites 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 character string through which
Internet pages and servers can be assigned to the specific Internet browser in
which the cookie was stored. This allows visited Internet sites and servers to
differentiate the individual browser of the dats subject from other Internet
browsers that contain other cookies. A specific Internet browser can be
recognized and identified using the unique cookie ID.
Through the use of cookies, COMPANYNAME
can provide the users of this website with more user-friendly services that
would not be possible without the cookie setting.
By means of a cookie, the information
and offers on our website can be optimized with the user in mind. Cookies allow
us, as previously mentioned, to recognize our website users. The purpose of
this recognition is to make it easier for users to utilize our website. The
website user that uses cookies, e.g. does not have to enter access data each
time the website is accessed, because this is taken over by the website, and
the cookie is thus stored on the user's computer system. Another example is the
cookie of a shopping cart in an online shop. The online store remembers the
articles that a customer has placed in the virtual shopping cart via a cookie.
The data subject may, at any time,
prevent the setting of cookies through our website by means of a corresponding
setting of the Internet browser used, and may thus permanently deny the setting
of cookies. Furthermore, already set cookies may be deleted at any time via an
Internet browser or other software programs. This is possible in all popular
Internet browsers. If the data subject deactivates the setting of cookies in
the Internet browser used, not all functions of our website may be entirely
usable.
4. Collection of general data and information
The website of COMPANYNAME collects a
series of general data and information when a data subject or automated system
calls up the website. This general data and information are stored in the
server log files. Collected may be (1) the browser types and versions used, (2)
the operating system used by the accessing system, (3) the website from which
an accessing system reaches our website (so-called referrers), (4) the
sub-websites, (5) the date and time of access to the Internet site, (6) an
Internet protocol address (IP address), (7) the Internet service provider of
the accessing system, and (8) any other similar data and information that may
be used in the event of attacks on our information technology systems.
When using these general data and
information, COMPANYNAME does not draw any conclusions about the data subject.
Rather, this information is needed to (1) deliver the content of our website
correctly, (2) optimize the content of our website as well as its
advertisement, (3) ensure the long-term viability of our information technology
systems and website technology, and (4) provide law enforcement authorities
with the information necessary for criminal prosecution in case of a
cyber-attack. Therefore, COMPANYNAME analyzes anonymously collected data and
information statistically, with the aim of increasing the data protection and
data security of our enterprise, and to ensure an optimal level of protection
for the personal data we process. The anonymous data of the server log files
are stored separately from all personal data provided by a data subject.
5. Registration on our website
The data subject has the possibility to
register on the website of the controller with the indication of personal data.
Which personal data are transmitted to the controller is determined by the respective
input mask used for the registration. The personal data entered by the data
subject are collected and stored exclusively for internal use by the
controller, and for his own purposes. The controller may request transfer to
one or more processors (e.g. a parcel service) that also uses personal data for
an internal purpose which is attributable to the controller.
By registering on the website of the
controller, the IP address—assigned by the Internet service provider (ISP) and
used by the data subject—date, and time of the registration are also stored.
The storage of this data takes place against the background that this is the
only way to prevent the misuse of our services, and, if necessary, to make it
possible to investigate committed offenses. Insofar, the storage of this data
is necessary to secure the controller. This data is not passed on to third
parties unless there is a statutory obligation to pass on the data, or if the
transfer serves the aim of criminal prosecution.
The registration of the data subject,
with the voluntary indication of personal data, is intended to enable the
controller to offer the data subject contents or services that may only be
offered to registered users due to the nature of the matter in question.
Registered persons are free to change the personal data specified during the
registration at any time, or to have them completely deleted from the data
stock of the controller.
The data controller shall, at any time, provide
information upon request to each data subject as to what personal data are
stored about the data subject. In addition, the data controller shall correct
or erase personal data at the request or indication of the data subject,
insofar as there are no statutory storage obligations. The entirety of the controller’s
employees are available to the data subject in this respect as contact persons.
6. Subscription to our newsletters
On the website of COMPANYNAME, users are
given the opportunity to subscribe to our enterprise's newsletter. The input
mask used for this purpose determines what personal data are transmitted, as
well as when the newsletter is ordered from the controller.
COMPANYNAME informs its customers and
business partners regularly by means of a newsletter about enterprise offers.
The enterprise's newsletter may 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 shipping. A confirmation e-mail will be sent to the e-mail
address registered by a data subject for the first time for newsletter
shipping, for legal reasons, in the double opt-in procedure. This confirmation
e-mail is used to prove whether the owner of the e-mail address as the data
subject is authorized to receive the newsletter.
During the registration for the
newsletter, we also store the IP address of the computer system assigned by the
Internet service provider (ISP) and used by the data subject at the time of the
registration, as well as the date and time of the registration. The collection
of this data is necessary in order to understand the (possible) misuse of the
e-mail address of a data subject at a later date, and it therefore serves the
aim of the legal protection of the controller.
The personal data collected as part of a
registration for the newsletter will only be used to send our newsletter. In
addition, subscribers to the newsletter may be informed by e-mail, as long as
this is necessary for the operation of the newsletter service or a registration
in question, as this could be the case in the event of modifications to the
newsletter offer, or in the event of a change in technical circumstances. There
will be no transfer of personal data collected by the newsletter service to
third parties. The subscription to our newsletter may be terminated by the data
subject at any time. The consent to the storage of personal data, which the
data subject has given for shipping the newsletter, may be revoked at any time.
For the purpose of revocation of consent, a corresponding link is found in each
newsletter. It is also possible to unsubscribe from the newsletter at any time
directly on the website of the controller, or to communicate this to the
controller in a different way.
7. Newsletter-Tracking
The newsletter of COMPANYNAME contains
so-called tracking pixels. A tracking pixel is a miniature graphic embedded in
such e-mails, which are sent in HTML format to enable log file recording and
analysis. This allows a statistical analysis of the success or failure of
online marketing campaigns. Based on the embedded tracking pixel, COMPANYNAME
may see if and when an e-mail was opened by a data subject, and which links in
the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels
contained in the newsletters are stored and analyzed by the controller in order
to optimize the shipping of the newsletter, as well as to adapt the content of
future newsletters even better to the interests of the data subject. These
personal data will not be passed on to third parties. Data subjects are at any
time entitled to revoke the respective separate declaration of consent issued
by means of the double-opt-in procedure. After a revocation, these personal
data will be deleted by the controller. COMPANYNAME automatically regards a
withdrawal from the receipt of the newsletter as a revocation.
8. Contact possibility via the website
The website of COMPANYNAME contains
information that enables a quick electronic contact to our enterprise, as well
as direct communication with us, which also includes a general address of the
so-called electronic mail (e-mail address). If a data subject contacts the
controller by e-mail or via a contact form, the personal data transmitted by
the data subject are automatically stored. Such personal data transmitted on a
voluntary basis by a data subject to the data controller are stored for the
purpose of processing or contacting the data subject. There is no transfer of
this personal data to third parties.
9. Comments function in the blog on the website
COMPANYNAME offers users the possibility
to leave individual comments on individual blog contributions on a blog, which
is on the website of the controller. A blog is a web-based, publicly-accessible
portal, through which one or more people called bloggers or web-bloggers may
post articles or write down thoughts in so-called blogposts. Blogposts may
usually be commented by third parties.
If a data subject leaves a comment on
the blog published on this website, the comments made by the data subject are
also stored and published, as well as information on the date of the commentary
and on the user's (pseudonym) chosen by the data subject. In addition, the IP
address assigned by the Internet service provider (ISP) to the data subject is
also logged. This storage of the IP address takes place for security reasons,
and in case the data subject violates the rights of third parties, or posts illegal
content through a given comment. The storage of these personal data is,
therefore, in the own interest of the data controller, so that he can exculpate
in the event of an infringement. This collected personal data will not be
passed to third parties, unless such a transfer is required by law or serves
the aim of the defense of the data controller.
10. Subscription to comments in the blog on the website
The comments made in the blog of COMPANYNAME
may be subscribed to by third parties. In particular, there is the possibility
that a commenter subscribes to the comments following his comments on a
particular blog post.
If a data subject decides to subscribe
to the option, the controller will send an automatic confirmation e-mail to
check the double opt-in procedure as to whether the owner of the specified
e-mail address decided in favor of this option. The option to subscribe to
comments may be terminated at any time.
11. Routine erasure and blocking of personal data
The data controller shall process and store
the personal data of the data subject only for the period necessary to achieve
the purpose of storage, or as far as this is granted by the European legislator
or other legislators in laws or regulations to which the controller is subject
to.
If the storage purpose is not
applicable, or if a storage period prescribed by the European legislator or
another competent legislator expires, the personal data are routinely blocked
or erased in accordance with legal requirements.
12. Rights of the data subject
·
a) Right of confirmation
Each data subject shall have the right
granted by the European legislator to obtain from the controller the
confirmation as to whether or not personal data concerning him or her are being
processed. If a data subject wishes to avail himself of this right of
confirmation, he or she may, at any time, contact any employee of the
controller.
·
b) Right of access
Each data subject shall have the right
granted by the European legislator to obtain from the controller free
information about his or her personal data stored at any time and a copy of
this information. Furthermore, the European directives and regulations grant
the data subject access to the following information:
o
the purposes of the processing;
o
the categories of personal data concerned;
o
the recipients or categories of recipients to whom the personal data have
been or will be disclosed, in particular recipients in third countries or
international organisations;
o
where possible, the envisaged period for which the personal data will be
stored, or, if not possible, the criteria used to determine that period;
o
the existence of the right to request from the controller rectification or
erasure of personal data, or restriction of processing of personal data
concerning the data subject, or to object to such processing;
o
the existence of the right to lodge a complaint with a supervisory
authority;
o
where the personal data are not collected from the data subject, any
available information as to their source;
o
the existence of automated decision-making, including profiling, referred
to in Article 22(1) and (4) of the GDPR and, at least in those cases,
meaningful information about the logic involved, as well as the significance
and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have
a right to obtain information as to whether personal data are transferred to a
third country or to an international organisation. Where this is the case, the
data subject shall have the right to be informed of the appropriate safeguards
relating to the transfer.
If a data subject wishes to avail
himself of this right of access, he or she may, at any time, contact any
employee of the controller.
·
c) Right to rectification
Each data subject shall have the right
granted by the European legislator to obtain from the controller without undue
delay the rectification of inaccurate personal data concerning him or her.
Taking into account the purposes of the processing, the data subject shall have
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, he or she may, at any time, contact any employee
of the controller.
·
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right
granted by the European legislator to obtain from the controller the erasure of
personal data concerning him or her without undue delay, and the controller
shall have the obligation to erase personal data without undue delay where one
of the following grounds applies, as long as the processing is not necessary:
o
The personal data are no longer necessary in relation to the purposes for
which they were collected or otherwise processed.
o
The data subject withdraws consent to which the processing is based
according to point (a) of Article 6(1) of the GDPR, or point (a) of Article
9(2) of the GDPR, and where there is no other legal ground for the processing.
o
The data subject objects to the processing pursuant to Article 21(1) of the
GDPR and there are no overriding legitimate grounds for the processing, or the
data subject objects to the processing pursuant to Article 21(2) of the GDPR.
o
The personal data have been unlawfully processed.
o
The personal data must be erased for compliance with a legal obligation in
Union or Member State law to which the controller is subject.
o
The personal data have been collected in relation to the offer of
information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons
applies, and a data subject wishes to request the erasure of personal data
stored by COMPANYNAME, he or she may, at any time, contact any employee of the
controller. An employee of COMPANYNAME shall promptly ensure that the erasure
request is complied with immediately.
Where the controller has made personal
data public and is obliged pursuant to Article 17(1) to erase the personal
data, the controller, taking account of available technology and the cost of
implementation, shall take reasonable steps, including technical measures, to
inform other controllers processing the personal data that the data subject has
requested erasure by such controllers of any links to, or copy or replication
of, those personal data, as far as processing is not required. An employees of COMPANYNAME
will arrange the necessary measures in individual cases.
·
e) Right of restriction of processing
Each data subject shall have the right
granted by the European legislator to obtain from the controller restriction of
processing where one of the following applies:
o
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.
o
The processing is unlawful and the data subject opposes the erasure of the
personal data and requests instead the restriction of their use instead.
o
The controller no longer needs the personal data for the purposes of the
processing, but they are required by the data subject for the establishment, exercise
or defence of legal claims.
o
The data subject has objected to processing pursuant to Article 21(1) of
the GDPR pending the verification whether the legitimate grounds of the
controller override those of the data subject.
If one of the aforementioned conditions
is met, and a data subject wishes to request the restriction of the processing
of personal data stored by COMPANYNAME, he or she may at any time contact any
employee of the controller. The employee of COMPANYNAME will arrange the
restriction of the processing.
·
f) Right to data portability
Each data subject shall have the right
granted by the European legislator, to receive the personal data concerning him
or her, which was provided to a controller, in a structured, commonly used and
machine-readable format. He or she shall have the right to transmit those data
to another controller without hindrance from the controller to which the
personal data have been provided, as long as the processing is based on consent
pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2)
of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the
GDPR, and the processing is carried out by automated means, as long as the
processing is not necessary for the performance of a task carried out in the
public interest or in the exercise of official authority vested in the
controller.
Furthermore, in exercising his or her
right to data portability pursuant to Article 20(1) of the GDPR, the data
subject shall have the right to have personal data transmitted directly from
one controller to another, where technically feasible and when doing so does
not adversely affect the rights and freedoms of others.
In order to assert the right to data
portability, the data subject may at any time contact any employee of COMPANYNAME.
·
g) Right to object
Each data subject shall have the right
granted by the European legislator to object, on grounds relating to his or her
particular situation, at any time, to processing of personal data concerning
him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR.
This also applies to profiling based on these provisions.
COMPANYNAME shall no longer process the
personal data in the event of the objection, unless we can demonstrate
compelling legitimate grounds for the processing which override the interests,
rights and freedoms of the data subject, or for the establishment, exercise or
defence of legal claims.
If COMPANYNAME processes personal data
for direct marketing purposes, the data subject shall have the right to object
at any time to processing of personal data concerning him or her for such
marketing. This applies to profiling to the extent that it is related to such
direct marketing. If the data subject objects to COMPANYNAME to the processing
for direct marketing purposes, COMPANYNAME will no longer process the personal
data for these purposes.
In addition, the data subject has the
right, on grounds relating to his or her particular situation, to object to
processing of personal data concerning him or her by COMPANYNAME for scientific
or historical research purposes, or for statistical purposes pursuant to
Article 89(1) of the GDPR, unless the processing is necessary for the
performance of a task carried out for reasons of public interest.
In order to exercise the right to
object, the data subject may contact any employee of COMPANYNAME. In addition,
the data subject is free in the context of the use of information society
services, and notwithstanding Directive 2002/58/EC, to use his or her right to
object by automated means using technical specifications.
·
h) Automated individual decision-making, including profiling
Each data subject shall have the right
granted by the European legislator not to be subject to a decision based solely
on automated processing, including profiling, which produces legal effects
concerning him or her, or similarly significantly affects him or her, as long
as the decision (1) is not is necessary for entering into, or the performance
of, a contract between the data subject and a data controller, or (2) is not
authorised by Union or Member State law to which the controller is subject and
which also lays down suitable measures to safeguard the data subject's rights
and freedoms and legitimate interests, or (3) is not based on the data
subject's explicit consent.
If the decision (1) is necessary for
entering into, or the performance of, a contract between the data subject and a
data controller, or (2) it is based on the data subject's explicit consent, COMPANYNAME
shall implement suitable measures to safeguard the data subject's rights and
freedoms and legitimate interests, at least the right to obtain human
intervention on the part of the controller, to express his or her point of view
and contest the decision.
If the data subject wishes to exercise
the rights concerning automated individual decision-making, he or she may, at
any time, contact any employee of COMPANYNAME.
·
i) Right to withdraw data protection consent
Each data subject shall have the right granted
by the European legislator to withdraw his or her consent to processing of his
or her personal data at any time.
If the data subject wishes to exercise
the right to withdraw the consent, he or she may, at any time, contact any
employee of COMPANYNAME.
13. Data protection for applications and the application procedures
The data controller shall collect and
process the personal data of applicants for the purpose of the processing of
the application procedure. The processing may also be carried out
electronically. This is the case, in particular, if an applicant submits
corresponding application documents by e-mail or by means of a web form on the
website to the controller. If the data controller concludes an employment
contract with an applicant, the submitted data will be stored for the purpose
of processing the employment relationship in compliance with legal
requirements. If no employment contract is concluded with the applicant by the
controller, the application documents shall be automatically erased two months
after notification of the refusal decision, provided that no other legitimate
interests of the controller are opposed to the erasure. Other legitimate
interest in this relation is, e.g. a burden of proof in a procedure under the
General Equal Treatment Act (AGG).
14. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the
legal basis for processing operations for which we obtain consent for a
specific processing purpose. If the processing of personal data is necessary
for the performance of a contract to which the data subject is party, as is the
case, for example, when processing operations are necessary for the supply of
goods or to provide any other service, the processing is based on Article 6(1)
lit. b GDPR. The same applies to such processing operations which are necessary
for carrying out pre-contractual measures, for example in the case of inquiries
concerning our products or services. Is our company subject to a legal
obligation by which processing of personal data is required, such as for the
fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c
GDPR. In rare cases, the processing of personal data may be necessary to
protect the vital interests of the data subject or of another natural person. This
would be the case, for example, if a visitor were injured in our company and
his name, age, health insurance data or other vital information would have to
be passed on to a doctor, hospital or other third party. Then the processing
would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could
be based on Article 6(1) lit. f GDPR. This legal basis is used for processing
operations which are not covered by any of the abovementioned legal grounds, if
processing is necessary for the purposes of the legitimate interests pursued by
our company or by a third party, except where such interests are overridden by
the interests or fundamental rights and freedoms of the data subject which
require protection of personal data. Such processing operations are
particularly permissible because they have been specifically mentioned by the
European legislator. He considered that a legitimate interest could be assumed
if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
15. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is
based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our
business in favor of the well-being of all our employees and the shareholders.
16. Period for which the personal data will be stored
The criteria used to determine the
period of storage of personal data is the respective statutory retention
period. After expiration of that period, the corresponding data is routinely
deleted, as long as it is no longer necessary for the fulfillment of the
contract or the initiation of a contract.
17. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision
of personal data is partly required by law (e.g. tax regulations) or can also
result from contractual provisions (e.g. information on the contractual
partner). Sometimes it may be necessary to conclude a contract that the data
subject provides us with personal data, which must subsequently be processed by
us. The data subject is, for example, obliged to provide us with personal data
when our company signs a contract with him or her. The non-provision of the
personal data would have the consequence that the contract with the data
subject could not be concluded. Before personal data is provided by the data
subject, the data subject must contact any employee. The employee clarifies to
the data subject whether the provision of the personal data is required by law
or contract or is necessary for the conclusion of the contract, whether there
is an obligation to provide the personal data and the consequences of
non-provision of the personal data.
18. Existence of automated decision-making
As a responsible company, we do not use
automatic decision-making or profiling.