Privacy Policy • Enterstrategy - Legal Strategy for SME

This page provides information about the collection and processing of data and documents.

1. Secure Connection

If your browser has not established a secure, encrypted connection to this website (HTTPS), you can click on this link to establish such a connection directly and terminate the unsecured connection.

2. Use of the Website

By using our website, you consent to the collection, processing and use of data in accordance with the following provision:

2.1 General Information

Our website may generally be accessed without registration. In this case, data such as the pages accessed or the name of the retrieved file, as well as the date and time of access, are stored on the server for statistical purposes without being directly attributable to you. Personal data, in particular your name, address or e-mail address, are collected on a voluntary basis wherever possible. Your data will not be disclosed to third parties without your consent.

2.2. Privacy Policy Regarding Cookies

Our website uses cookies provided by WordPress that are necessary for the proper display of the website’s content on your device.

The use of these cookies is lawful pursuant to Article 6(1)(f) of the General Data Protection Regulation (GDPR).

If you do not wish to accept cookies, you should configure your internet browser to refuse them.

You may also adjust your cookie preferences using the settings available in the footer of this website.

3. Contact Form and E-mail Enquiries

If you use the contact form or send us an e-mail, the data entered and transmitted will be stored for the purpose of processing your enquiry and preparing a quotation or proposal.

Further information regarding the processing of your personal data will be provided to you following your enquiry.

By transmitting your Personal Data, you voluntarily consent to the Processing of the Personal Data you have entered or transmitted for the purposes of processing the inquiry and contacting you.

By transmitting your data to us, you also voluntarily give your explicit Consent in accordance with Art. 49 (1) (1) (a) GDPR to data transfers to third countries to and by the companies named in this Privacy Policy and for the purposes stated, in particular for such transfers to third countries for which there is or is not an adequacy decision by the EU/EEA and to companies or other bodies that are not subject to an existing adequacy decision on the basis of self-certification or other accession criteria and in which or for which there are significant risks and no suitable guarantees for the protection of your Personal Data (e.g., due to Section 702 FISA, Executive Order EO12333 and the CloudAct in the USA).

When you gave your voluntary and explicit Consent, you were aware that there may not be an adequate level of data protection in third countries and that your data subject rights may not be enforceable. You can withdraw your Consent under data protection law at any time with effect for the future. The withdrawal of Consent does not affect the lawfulness of Processing based on Consent before its withdrawal. With a single action (entry and transmission), you give several Consents.

These are Consents under EU/EEA data protection law as well as those under the CCPA/CPRA, ePrivacy and Digital Services Act, and other international legislation, which are required, among other things, as a legal basis for any planned further Processing of your Personal Data. With your action, you also confirm that you have read and taken note of this Privacy Policy.

4. Responsible Data Controller

The Controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and the European Economic Area, British data protection laws, Swiss data protection laws (DSG, DSV), Californian data protection law (CCPA/CPRA), Chinese data protection law (PIPL), as well as international laws and provisions with a data protection nature is:

Rechtsanwalt Stefan Musiol

Heideweg 29f
D-22952 Lütjensee (Hamburg), Germany

5. Your Rights of the Data Subject according to GDPR

a) Right to confirmation
Each Data Subject has the right to obtain from the Controlling person confirmation as to whether or not Personal Data concerning him or her is being processed.
If a Data Subject wishes to exercise this right, he or she may contact us at any time.

b) Right to information
Each Data Subject has the right to obtain from the Controlling person free information about the Personal Data stored about him/her and a copy of this data at any time. Furthermore, the European legislator has granted the Data Subject access to the following information:
• the purposes of processing,
• the categories of Personal Data that are processed,
• 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 organizations,
• where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period,
• the existence of the right to request from the Controlling person rectification or erasure of Personal Data or Restriction of Processing of Personal Data concerning the Data Subject or to object to such Processing,
• the existence of a right to lodge a complaint with a supervisory authority,
• if the Personal Data is not collected from the Data Subject: All available information about the origin of the data,
• the existence of automated decision-making, including Profiling, referred to in Art. 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such Processing for the Data Subject.
Furthermore, the Data Subject has a right to information as to whether Personal Data has been transferred to a third country or to an international organization. If this is the case, the Data Subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.
If a Data Subject wishes to exercise this right, he or she may contact us at any time.

c) Right to rectification
Each Data Subject has the right to demand the immediate correction of incorrect Personal Data concerning them. Furthermore, the Data Subject has the right to request the completion of incomplete Personal Data, including by means of a supplementary declaration, taking into account the purposes of the Processing.
If a Data Subject wishes to exercise this right, he or she may contact us at any time.
d) Right to erasure (right to be forgotten)
Each Data Subject has the right, to obtain from the Controlling person the erasure of Personal Data concerning him or her without undue delay, and the Controlling person 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:
• Personal Data was collected or otherwise processed for purposes for which it is no longer necessary.
• The Data Subject withdraws Consent on which the Processing is based according to Art. 6 (1) (a) GDPR, or Art. 9 (2) (a) GDPR, and where there is no other legal ground for the Processing.
• The Data Subject objects to the Processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the Processing, or the Data Subject objects to the Processing pursuant to Art. 21 (2) GDPR.
• Personal Data was processed unlawfully.
• The deletion of Personal Data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the Controlling person is subject.
• The Personal Data was collected in relation to information society services offered in accordance with Art. 8 (1) GDPR.
If one of the aforementioned reasons applies, and a Data Subject wishes to request the erasure of Personal Data stored by us, he or she may contact us at any time.
If we have made the Personal Data public and if our organisation is obliged to delete the Personal Data in accordance with Art. 17 (1) GDPR, we shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data Controlling person s who process the published Personal Data that the Data Subject has requested the deletion of all links to this Personal Data or of copies or replications of this Personal Data from these other data Controlling person s, insofar as the Processing is not necessary.

e) Right to Restriction of Processing
Each Data Subject has the right to obtain from the Controlling person Restriction of Processing where one of the following applies:
• The accuracy of the Personal Data is contested by the Data Subject, for a period enabling the Controlling person 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 their use instead.
• The Controlling person 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 defense of legal claims.
• The Data Subject has objected to Processing pursuant to Art. 21 (1) GDPR pending the verification whether the legitimate grounds of the Controlling person 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 us, he or she may contact us at any time.

f) Right to data portability
Each Data Subject has the right to receive the Personal Data concerning him or her, which he or she has provided to a Controlling person , in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another Controlling person without hindrance from the Controlling person to which the Personal Data have been provided, where Processing is based on Consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR and the Processing is carried out by automated means, unless the Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controlling person .
Furthermore, in exercising their right to data portability pursuant to Art. 20 (1) GDPR, the Data Subject has the right to have the Personal Data transmitted directly from one Controlling person to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.
If a Data Subject wishes to exercise this right, he or she may contact us at any time.

g) Right to object
Each Data Subject has the right 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.
In the event of an objection, we will 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 for the establishment, exercise or defense of legal claims.
If we process 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 also applies to Profiling insofar as it is associated with such direct advertising. If the Data Subject objects to us to the Processing for direct marketing purposes, we 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 us 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.
If a Data Subject wishes to exercise this right, he or she may contact us at any time. The Data Subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

h) Automated decisions in individual cases including Profiling
Each Data Subject has the right 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, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the Data Subject and the Controlling person, or (2) is authorized by Union or Member State law to which the Controlling person is subject and which also lays down suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests, or (3) is 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 Controlling person , or (2) it is based on the Data Subject’s explicit Consent, we 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 Controlling person , to express his or her point of view and contest the decision.
If a Data Subject wishes to exercise this right, he or she may contact us at any time.

i) Right to withdraw Consent under data protection law
Each Data Subject has the right to withdraw Consent to the Processing of Personal Data at any time.

6. General purpose of Processing, categories of processed data and categories of recipients

The general purpose of processing Personal Data is the handling of quotes and preparation of offered services.
The categories of Personal Data that we process are client data, prospective client data, employee data (including applicant data) and supplier data. The categories of recipients of Personal Data are public bodies, external bodies, internal processing, intragroup processing and other bodies.
A list of our Processors and data recipients in third countries and, if applicable, international organizations is either published on our website or can be requested from us free of charge.

7. Legal basis for the Processing

Art. 6 (1) (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 or consideration, Processing is based on Art. 6 (1) (b) GDPR. The same applies to such Processing operations that are necessary to carry out pre-contractual measures, for example in cases of inquiries about our products or services. If we are subject to a legal obligation which requires the Processing of Personal Data, such as for the fulfillment of tax obligations, Processing is based on Art. 6 (1) (c) GDPR.
In rare cases, it may be necessary to process Personal Data 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 in our organisation and their name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other Third Party. The Processing would then be based on Art. 6 (1) (d) GDPR.
If the Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controlling person , the legal basis is Art. 6 (1) (e) GDPR.

Ultimately, Processing operations could be based on Art. 6 (1) (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 organisation 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. We are permitted to carry out such Processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed, for example, if the Data Subject is a client of the Controlling person (Recital 47 Sentence 2 GDPR).

8. Legitimate interests in Processing pursued by the Controlling person or a Third Party and direct marketing

If the Processing of Personal Data is based on Art. 6 (1) (f) GDPR and no more specific legitimate interests are stated, our legitimate interest is the performance of our business activities for the benefit of our clients and staff.

We may send you direct advertising about our own goods or services that are similar to the goods or services you have requested, commissioned or purchased. You may object to direct advertising at any time (e.g. by email). You will not incur any costs other than the transmission costs according to the basic rates. The Processing of Personal Data for direct marketing purposes is based on Art. 6 (1) (f) GDPR. The legitimate interest is direct marketing.

Our messages and newsletters may also constitute direct marketing communications within the meaning of Article 13(2) of EU Directive 2002/58 (Directive on privacy and electronic communications) and the national law resulting from the Directive, provided that we have obtained your electronic and other contact information in connection with the sale of a service or product, which includes the creation of a free user account that allows you, among other things, to access free content on our websites and publications (newsletters, etc.), provided that we advertise similar products or services through direct marketing, so that direct marketing is also permissible without consent. In such cases, you can refuse the use of your contact information at any time free of charge.

9. Duration for which the Personal Data is stored

The criterion for the duration of the storage of Personal Data is the respective statutory retention period of 6 years after completion of the mandate or quote. If there is no statutory retention period, the criterion is the contractual or internal retention period. After this period has expired, the corresponding data is routinely deleted if it is no longer required to fulfill or initiate a contract. This applies in particular to all Processing operations for which no more specific criteria have been defined.

10. Legal or contractual provisions for the provision of Personal Data; necessity for the conclusion of the contract; obligation of the Data Subject to provide the Personal Data; possible consequences of non-provision

We would like to inform you that the provision of Personal Data is partly required by law (e.g., tax regulations) or may also result from contractual obligations (e.g., information on the contractual partner). Sometimes it may be necessary for a contract to be concluded for a Data Subject to provide us with Personal Data that must subsequently be processed by us. For example, Data Subjects are obliged to provide us with Personal Data if our organisation concludes a contract with them. Failure to provide Personal Data would mean that the contract with the Data Subject could not be concluded. The Data Subject must contact us before providing Personal Data. We will inform the Data Subject on a case-by-case basis 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 what the consequences would be if the Personal Data were not provided.

11. Existence of automated decision-making

As a controlling company, we do not normally use automated decision-making or Profiling. If, in exceptional cases, we carry out automated decision-making or Profiling, we will inform the Data Subject either separately or via a sub-item in our Privacy Policy (here on our website). In this case, the following applies:
Automated decision-making, including Profiling, may take place if (1) this is necessary for the conclusion or performance of a contract between the Data Subject and us, or (2) this is permissible on the basis of Union or Member State legislation to which we are subject and this legislation contains appropriate measures to safeguard the rights and freedoms and legitimate interests of the Data Subject, or (3) this takes place with the explicit Consent of the Data Subject.
In the cases referred to in Art. 22 (2) (a) and (c) GDPR, we shall implement suitable measures to safeguard the Data Subject’s rights and freedoms and legitimate interests. In these cases, you have the right to obtain human intervention on the part of the Controlling person , to express your point of view and to contest the decision.
Meaningful information on the logic involved and the scope and intended effects of such Processing for the Data Subject will be provided in this Privacy Policy where applicable.

12. Recipients in a third country and appropriate or adequate safeguards and how to obtain a copy of them or where they are available.

According to Art. 46 (1) GDPR, the controlling person or processor may only transfer Personal Data to a third country if the Controlling person or Processor has provided appropriate safeguards and if enforceable rights and effective legal remedies are available to the Data Subjects. Appropriate safeguards can be provided by standard contractual clauses without the need for special approval from a supervisory authority, Art. 46 (2) (c) GDPR.
The EU standard contractual clauses or other appropriate safeguards are agreed with all recipients from third countries prior to the first transfer of Personal Data, or the transfers are based on adequacy decisions. Consequently, it is ensured that appropriate safeguards, enforceable rights and effective legal remedies are guaranteed for all Processing of Personal Data. Any Data Subject can obtain a copy of the standard contractual clauses or adequacy decisions from us. In addition, the standard contractual clauses and adequacy decisions are available in the Official Journal of the European Union.
Art. 45 (3) GDPR authorizes the European Commission to decide by means of an implementing decision that a non-EU country ensures an adequate level of protection. This means a level of protection for Personal Data that essentially corresponds to the level of protection within the EU. Adequacy decisions mean that Personal Data can flow from the EU (as well as from Norway, Liechtenstein and Iceland) to a third country without further obstacles. Similar regulations apply to the United Kingdom, Switzerland and some other countries.
In all cases where the European Commission, or a government or competent authority of another country, has decided that a third country ensures an adequate level of protection and/or a valid framework exists (e.g., EU-U.S. Data Privacy Framework, Swiss-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Data Privacy Framework), all transfers by us to the members of such frameworks (e.g., self-certified entities) are based solely on the membership of that entity in the respective framework or on the respective adequacy decisions. If we or one of our group companies is a member of such a framework, all transfers to us or our group company are based exclusively on the membership of the respective company in this framework. If we or one of our group companies is located in a third country with an adequate level of protection, all transfers to us or our group company are based solely on the respective adequacy decisions.
Any Data Subject can obtain a copy of the frameworks from us. In addition, the frameworks are also available in the Official Journal of the European Union or in the published legal materials or on the websites of data protection supervisory authorities or other authorities or institutions.

13. Right to lodge a complaint with a data protection supervisory authority

As the Controlling person , we are obliged to inform the Data Subject of the existence of the right to lodge a complaint with a supervisory authority. The right to lodge a complaint is regulated in Art. 77 (1) GDPR. According to this provision, without prejudice to any other administrative or judicial remedy, every Data Subject has the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the Data Subject considers that the Processing of Personal Data relating to him or her infringes the General Data Protection Regulation. The right to lodge a complaint has been restricted by the EU legislator to the effect that it can only be exercised with a single supervisory authority (Recital 141 Sentence 1 GDPR). This provision is intended to avoid duplicate complaints in the same matter by the same Data Subject. If a Data Subject wishes to complain about us, it is therefore requested that only one supervisory authority is contacted.

14. Blog and Comment Function of enterstrategy.eu / ramusiol.com

If you post a comment on our blog, the content of your comment, together with the date and time of submission and the username you have chosen (which may be a pseudonym), will be stored, published and made publicly available with your comment.

The purposes of the processing are the provision of a blog with a comment function and the opportunity for users to submit comments.
Furthermore, the IP address assigned to your internet connection by your internet service provider (ISP) is recorded when you submit a comment. The IP address is stored for security purposes and in the event that you infringe the rights of third parties or publish unlawful content by posting a comment. The storage of this personal data is therefore necessary for our legitimate interests in order to enable us to establish our legal position in the event of any infringement.

The legal basis for such processing is Article 6(1)(f) GDPR.

15. Data protection provisions – Website Hosting STRATO AG enterstrategy.eu / ramusiol.com

The company address: STRATO GmbH, Otto-Ostrowski-Straße 7, 10249 Berlin, Germany, for further information https://www.strato.de .

STRATO is a provider of our web hosting services, domain registrations, cloud storage, online stores and other internet-based services. With an extensive portfolio of products, STRATO supports both private individuals and companies in effectively designing and managing their online presence.

When using STRATO services, Personal Data such as names, addresses, email addresses, telephone numbers, payment information and usage data of the services offered are processed. This information is necessary to provide the services, manage user accounts, make support requests and ensure the security of user data.

Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of data processing lies in the use of the web hosting services and the other products offered. Processing is based on the performance of a contract pursuant to Art. 6 (1) (b) GDPR, to which the Data Subject is a party, and on legitimate interests pursuant to Art. 6 (1) (f) GDPR, such as improving our services, ensuring network and information security and the use of external hosting.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company that operates the service or statutory or contractual retention periods. The provision of Personal Data is not required by law or contract, nor is it necessary for the conclusion of a contract. You are not obliged to provide us or the company that operates the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.

16. Data protection provisions about the application and use of Google Analytics

Address: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics is a tool that provides operators of websites and apps with detailed statistics on traffic and user behavior. It enables the collection and analysis of data on website visits, user interactions and conversion rates, which helps operators to understand and optimize their online presence. Google Analytics uses cookies to collect information about user behavior, including page views, time spent on the site and the paths users take on the site.

Google Analytics mainly uses first-party cookies to report on visitor (aka. user) interactions on Google Analytics customers’ websites. Users may disable cookies or delete any individual cookie. Learn more about How Google uses cookies

In addition, Google Analytics supports an optional browser add-on that – once installed and enabled – disables measurement by Google Analytics for any site a user visits. Note that this add-on only disables Google Analytics measurement.

Where a site or app uses Google Analytics for Apps or the Google Analytics for Firebase SDKs, Google Analytics collects an app-instance identifier — a randomly generated number that identifies a unique installation of an App. Whenever a user resets their Advertising Identifier (Advertising ID on Android, and ID for Advertisers on iOS), the app-instance identifier is also reset.

Where sites or apps have implemented Google Analytics with other Google Advertising products, like Google Ads, additional advertising identifiers may be collected. Users can opt-out of this feature and manage their settings for this cookie using the Ads Settings. Learn more about Purposes of cookies

When using Google Analytics, Personal Data such as IP addresses, browser information and interaction data are processed. This data helps website operators to measure the performance of their website, improve the user experience and develop targeted marketing strategies.

Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of processing is the analysis and optimization of websites, apps, and advertising. Processing is based on Art. 6 (1) (f) GDPR, whereby our legitimate interest lies in improving the website, increasing user-friendliness and the effectiveness of online marketing.

The company that operates the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of Standard Contractual Clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The company that operates the service may be a certified member of one or more of the data privacy frameworks. You can find more information at https://www.dataprivacyframework.gov/list. You can request a copy of the suitable or appropriate safeguards from us.

The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company that operates the service or statutory or contractual retention periods. The provision of Personal Data is not required by law or contract, nor is it necessary for the conclusion of a contract. You are not obliged to provide us or the company that operates the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.
Further information and the applicable data protection provisions of Google Analytics can be found at https://policies.google.com/privacy.

17. Data protection provisions about the application and use of Vimeo (Video Homepage)

Vimeo provides a platform for sharing, viewing, and creating videos. Vimeo enables creators, video artists, and companies to share, promote and monetize high-quality content with a global audience. The platform is characterized by a user-centric approach that values quality, creative freedom, and a supportive community environment.
When using Vimeo services, Personal Data such as names, email addresses, profile information, video data, interaction data (such as views and likes) and payment information are processed. This data is required to operate the platform, manage user accounts, offer personalized recommendations, improve support, and process payments for premium services.

The company that operates the service and thus the recipient of personal data is: Vimeo.com, Inc., 330 West 34th Street, 10th Floor, New York, NY 10001, USA. For data subjects in the EU and EEA, EDPO (European Data Protection Office), Avenue Huart Hamoir 71, 1030 Brussels, Belgium, acts as contact and representative within the meaning of Art. 27 GDPR. The representative under Art. 14 of the Federal Act on Data Protection (FADP) in Switzerland is: EDPO Switzerland Sàrl, Rue de Lausanne 37, 1201 Geneva, Switzerland.

Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of data processing is the use of the video platform. Processing is based on the performance of a contract pursuant to Art. 6 (1) (b) GDPR, to which the Data Subject is a party, and on legitimate interests pursuant to Art. 6 (1) (f) GDPR, such as the use of an efficient platform for videos, the optimization of the user experience and the use of efficient client support.
The company that operates the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of Standard Contractual Clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The company that operates the service may have concluded one of the EU Standard Contractual Clauses with us. You can request a copy of the suitable or appropriate safeguards from us.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company that operates the service or statutory or contractual retention periods. The provision of Personal Data is not required by law or contract, nor is it necessary for the conclusion of a contract. You are not obliged to provide us or the company that operates the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.

Further information and the applicable data protection provisions of Vimeo may be retrieved under https://vimeo.com.

18. Data protection provisions about the application and use of YouTube

YouTube is a video sharing and viewing platform used by individuals, artists, businesses, and media companies to publish a variety of content such as music videos, vlogs, educational material and much more. YouTube offers users the ability to upload, share, comment and interact with a broad community.
When using YouTube, Personal Data such as IP addresses, user interactions (e.g., videos viewed, comments), location data (if enabled for services) and information from linked Google accounts are processed. This information is required to provide personalized content and advertising, enable user interactions, keep the platform secure and improve the user experience.
The company that operates the service and thus the recipient of personal data is: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. For data subjects in the EU and EEA, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, acts as contact and representative within the meaning of Art. 27 GDPR. The representative under national law in the United Kingdom is: Google UK Limited, Belgrave House, 76 Buckingham Palace Road, London SW1W 9TQ, United Kingdom. The representative under Art. 14 of the Federal Act on Data Protection (FADP) in Switzerland is: Google Switzerland GmbH, Brandschenkestrasse 110, 8002 Zurich, Switzerland.
Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of data processing lies in the use of the video sharing services. Processing is based on the performance of a contract pursuant to Art. 6 (1) (b) GDPR, to which the Data Subject is a party, and on legitimate interests pursuant to Art. 6 (1) (f) GDPR, such as the use of an efficient video platform, the improvement of the user experience, the use of personalized advertising and the use of embedded videos on our website.
The company that operates the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of Standard Contractual Clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The company that operates the service may be a certified member of one or more of the data privacy frameworks. You can find more information at https://www.dataprivacyframework.gov/list. You can request a copy of the suitable or appropriate safeguards from us.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company that operates the service or statutory or contractual retention periods. The provision of Personal Data is not required by law or contract, nor is it necessary for the conclusion of a contract. You are not obliged to provide us or the company that operates the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.
Further information and the applicable data protection provisions of YouTube can be found at https://policies.google.com.

19. Data protection provisions about the application and use of Facebook

When using Facebook, Personal Data such as names, email addresses, telephone numbers, usage data, location information, and information on shared content is processed. This data is necessary to provide the platform, offer personalized content and advertising, ensure user safety, and develop new services.
The company that operates the service and thus the recipient of personal data is: Meta Platforms, Inc., 1 Meta Way, Menlo Park, CA 94025, USA. For data subjects in the EU and EEA, Meta Platforms Ireland Ltd., Merrion Road, Dublin D04 X2K5, Ireland, acts as contact and representative within the meaning of Art. 27 GDPR. The representative under national law in the United Kingdom is: Meta Platforms Technologies UK Ltd, 10 Brock Street, Regent’s Place, London, NW1 3FG, United Kingdom.

Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of processing is to use and improve the social network functions and network services. Processing is based on Art. 6 (1) (b) GDPR for the performance of a contract to which the Data Subject is party and Art. 6 (1) (f) GDPR, whereby our legitimate interest lies in improving the user experience, providing personalized content and advertising and ensuring the security of the network.
The company that operates the service is located in a third country, namely the USA. Transfers to third countries may be based on the conclusion of Standard Contractual Clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The company that operates the service may be a certified member of one or more of the data privacy frameworks. You can find more information at https://www.dataprivacyframework.gov/list. You can request a copy of the suitable or appropriate safeguards from us.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company that operates the service or statutory or contractual retention periods. The provision of Personal Data is not required by law or contract, nor is it necessary for the conclusion of a contract. You are not obliged to provide us or the company that operates the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.
Further information and the applicable data protection provisions of Facebook can be found at https://facebook.com.

20. Data protection provisions about the application and use of Instagram

Instagram is a widely used social network that allows users to share photos and videos, post stories, and interact with followers and friends. Instagram offers a variety of features, including direct messages, IGTV for longer videos, Instagram Live for real-time broadcasts and a Discover page to find added content and users.
When using Instagram, Personal Data such as names, email addresses, telephone numbers, user content (photos, videos, comments, etc.), location data, usage information and, in certain cases, payment information is processed. This data helps to provide the service, ensure the security of the platform, offer personalized advertising, and improve the user experience.
The company that operates the service and thus the recipient of personal data is: Meta Platforms, Inc., 1 Meta Way, Menlo Park, CA 94025, USA. For data subjects in the EU and EEA, Meta Platforms Ireland Ltd., Merrion Road, Dublin D04 X2K5, Ireland, acts as contact and representative within the meaning of Art. 27 GDPR. The representative under national law in the United Kingdom is: Meta Platforms Technologies UK Ltd, 10 Brock Street, Regent’s Place, London, NW1 3FG, United Kingdom.
Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of processing is the use and optimization of the social network functions. Processing is based on Art. 6 (1) (b) GDPR for the performance of a contract to which the Data Subject is party and Art. 6 (1) (f) GDPR, where our legitimate interest lies in the improvement and personalization of the user experience, the provision of client support and ensuring the security and integrity of the platform, as well as in the use of the platform and marketing.
The company that operates the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of Standard Contractual Clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The company that operates the service may be a certified member of one or more of the data privacy frameworks. You can find more information at https://www.dataprivacyframework.gov/list. You can request a copy of the suitable or appropriate safeguards from us.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company that operates the service or statutory or contractual retention periods. The provision of Personal Data is not required by law or contract, nor is it necessary for the conclusion of a contract. You are not obliged to provide us or the company that operates the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.
Further information and the applicable data protection provisions of Instagram can be viewed at https:// instagram.com.

21. Data protection provisions about the application and use of LinkedIn

The company that operates the service and thus the recipient of the Personal Data is: LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA.

LinkedIn is a social network for professional contacts and career development. The platform allows users to create a professional profile, network with colleagues, business partners and potential employers, share professional experiences and skills, and keep up to date with industry news. LinkedIn also provides tools for companies and recruiters to source talent, post job ads and build a brand presence.
When using LinkedIn, Personal Data such as names, email addresses, professional titles and experience, educational background, skills, interests, and platform usage data are processed. This information is necessary to provide and use the service to create networking opportunities, to present personalized content and job offers and to ensure the security of user data.

Purposes for which the Personal Data is to be processed and the legal basis for the Processing: The purpose of processing is the use and optimization of network and career services. Processing is based on the Consent of the user (Art. 6 (1) (a) GDPR), the performance of a contract (Art. 6 (1) (b) GDPR) to which the Data Subject is party and on legitimate interests (Art. 6 (1) (f) GDPR), such as marketing and recruitment.
The company that operates the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of Standard Contractual Clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The company that operates the service may be a certified member of one or more of the data privacy frameworks. You can find more information at https://www.dataprivacyframework.gov/list. You can request a copy of the suitable or appropriate safeguards from us.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company that operates the service or statutory or contractual retention periods. The provision of Personal Data is not required by law or contract, nor is it necessary for the conclusion of a contract. You are not obliged to provide us or the company that operates the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.

22. Data protection provisions about the application and use of X (formerly Twitter)

X (formerly known as Twitter) is a global platform for public self-expression and real-time conversation. Users can create and share short messages, called tweets, which can include text, images, videos, and links. The platform allows users to follow breaking news, interact with others and participate in global discussions.
When using X, several types of Personal Data are processed, including usernames, email addresses, telephone numbers and location data. This information can be used for account creation, personalization of content, provision of advertising, security purposes and for analytical evaluations.

The company that operates the service and thus the recipient of personal data is: X Corp., 865 FM-1209, Building 2, Bastrop, TX 78602, USA. For data subjects in the EU and EEA, X Internet Unlimited Company, 1 Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, acts as contact and representative within the meaning of Art. 27 GDPR. The representative under Art. 14 of the Federal Act on Data Protection (FADP) in Switzerland is: X Schweiz GmbH, c/o Wasag Treuhand AG, Normannenstrasse 8, 3018 Bern, Switzerland.

The Processing of Personal Data takes place, among other things, on the basis of the user’s Consent (Art. 6 (1) (a) GDPR), for the performance of a contract (Art. 6 (1) (b) GDPR) to which the Data Subject is a party, or on the basis of legitimate interests (Art. 6 (1) (f) GDPR), such as the use of the platform and the improvement of communication with the public.

The company that operates the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of Standard Contractual Clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The company that operates the service may have concluded one of the EU Standard Contractual Clauses with us. You can request a copy of the suitable or appropriate safeguards from us.

Luetjensee (Hamburg), 01.06.2018

Stefan Musiol, Attorney

Enterstrategy