DATA PROTECTION DECLARATION
1) Information on the Collection of Personal Data and Contact Details of the Controller
1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.
1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Straight Forward Medical Device Consulting GmbH, Beethovenstr. 23, 50674 Köln, Deutschland, Tel.: 0179 - 9120 482, E-Mail: email@example.com. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
1.3 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.
2) Data Collection When You Visit Our Website
When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you: - Our visited website - Date and time at the moment of access - Amount of data sent in bytes - Source/reference from which you came to the page - Browser used - Operating system used - IP address used (if applicable: in anonymized form) Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.
3) Hosting & Content Delivery Network
Hosting by Wix
We use the website building system of Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo, Israel ("Wix") for the purpose of hosting and displaying the website based on processing on our behalf. All data collected on our website is processed on Wix's servers. As part of the aforementioned services provided by Wix, data may also be transferred to Wix Inc., 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA, as part of further processing on our behalf. In the case of data transfer to Wix in Israel, the adequate level of data protection is guaranteed by an adequacy decision of the European Commission. For further information on data protection at Wix, please visit the following website: https://de.wix.com/about/privacy The extent to which personal data is processed is described below. Any further processing on other servers than the aforementioned of Wix will only take place within the scope communicated below.
To make visiting our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your end device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your terminal and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). If cookies are set, they collect and process specific user information such as browser and location data as well as IP address values according to individual requirements. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can check the duration of the respective cookie storage in the overview of the cookie settings of your web browser. In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the content of a virtual shopping basket for a later visit to the website). If personal data are also processed by individual cookies set by us, the processing is carried out in accordance with Art. 6 (1) point b GDPR either for the execution of the contract or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit. Please note that you can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or generally. Each browser differs in the way it manages the cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You will find these for the respective browsers under the following links:
Please note that the functionality of our website may be limited if cookies are not accepted.
5) Contacting Us
5.1 Own function for online appointments
We process your personal data within the framework of the online appointment arrangement provided. You can find out which data we collect for online appointments from the respective form or the appointment request for making an appointment. If certain data is necessary to make an online appointment, we will indicate this on the form or in the appointment request. If we provide you with a free text field on the form, you can describe your request in more detail there. You can also control which additional data you would like to enter. The data you provide will be stored and used exclusively for the purpose of making an appointment. When processing personal data which are necessary for the fulfilment of a contract with you (this also applies to processing operations which are necessary for the implementation of pre-contractual measures), Art. 6 para. 1 letter b GDPR serves as the legal basis. If you have given us your consent to process your data, the processing will take place on the basis of Art. 6 para. 1 lit. a GDPR. Consent that has been granted can be revoked at any time by sending a message to the person responsible named at the beginning of this declaration.
5.2 When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration. The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.
6) Use of Client Data for Direct Advertising
6.1 Subscribe to our e-mail newsletter
If you register for our e-mail newsletter, we will regularly send you information about our offers. The only mandatory data for sending the newsletter is your e-mail address. The provision of further data is voluntary and will be used to address you personally. We use the so-called double opt-in procedure for sending the newsletter. This means that we will only send you an e-mail newsletter once you have expressly confirmed that you consent to receiving newsletters. We will then send you a confirmation e-mail asking you to confirm that you wish to receive the newsletter in future by clicking on an appropriate link. By activating the confirmation link, you give us your consent for the use of your personal data pursuant to Art. 6 (1) point a GPPR. When you register for the newsletter, we store your IP address entered by your Internet service provider (ISP) as well as the date and time of registration for the purpose of tracing any possible misuse of your e-mail address at a later date. The data collected by us when you register for the newsletter is used exclusively for the promotional purposes by way of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the responsible person named at the beginning. After unsubscribing, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data, or we reserve the right to a more extensive use your data which is permitted by law and about which we inform you in this declaration.
6.2 - Newsletter via Ascend by Wix
Our email newsletters are sent via the technical service provider Wix, HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo, Israel ("Wix") to whom we pass on the data you provided when registering for the newsletter. This transfer takes place in accordance with Art. 6 para. 1 lit. f GDPR and serves our legitimate interest in using an effective, secure and user-friendly newsletter system Within the scope of the aforementioned services of Wix, data may also be transmitted to Wix Inc., 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA, as part of further processing on behalf of Wix. Wix uses this information to send and statistically evaluate the newsletter on our behalf. For the evaluation, the emails sent contain so-called web beacons or tracking pixels, which are single-pixel image files stored on our website. This makes it possible to determine whether a newsletter message has been opened and which links, if any, have been clicked on. With the help of so-called conversion tracking, it can also be analysed whether a predefined action (e.g., purchase of a product on our website) has taken place after clicking on the link in the newsletter. In addition, technical information is recorded (e.g., time of retrieval, IP address, browser type and operating system). The data is collected exclusively in pseudonymised form and is not linked to your other personal data; direct personal reference is excluded. This data is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients. If you wish to object to the data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter. In the event that data is transferred to Wix in Israel, the adequate level of data protection is guaranteed by adequacy decision of the European Commission. We have concluded an order processing agreement with Wix, by which we oblige Wix to protect our customers' data and not to pass it on to third parties. You can obtain further information on data protection from Wix at the following website: https://www.wix.com/about/privacy
7) Processing of Data for the Purpose of Order Handling
7.1 Insofar as necessary for the processing of the contract for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 (1) lit. b GDPR. If we owe you updates for goods with digital elements or for digital products on the basis of a corresponding contract, we will process the contact data (name, address, e-mail address) provided by you when placing the order in order to inform you personally by suitable means of communication (e.g. by post or e-mail) about upcoming updates within the legally stipulated period of time within the framework of our statutory duty to inform pursuant to Art. 6 (1) lit. c GDPR. Your contact details will be used strictly for the purpose of informing you about updates owed by us and will only be processed by us for this purpose to the extent necessary for the respective information. In order to process your order, we also work together with the following service provider(s), who support us in whole or in part in the execution of concluded contracts. Certain personal data is transmitted to these service providers in accordance with the following information.
7.2 Use of Payment Service Providers
When you pay via PayPal, credit card via PayPal, direct debit via PayPal or - if offered - "purchase on account" or "payment by instalments" via PayPal, we transmit your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). The transfer takes place in accordance with Art. 6 (1) point b GDPR and only insofar as this is necessary for payment processing. PayPal reserves the right to carry out credit checks for the payment methods credit card via PayPal, direct debit via PayPal or, if offered, "purchase on account" or "payment by installments" via PayPal. For this purpose, your payment data may be passed on to credit agencies on the basis of PayPal's legitimate interest in determining your solvency pursuant to Art. 6 (1) point f GDPR. PayPal uses the result of the credit assessment in relation to the statistical probability of non-payment for the purpose of deciding on the provision of the respective payment method. The credit report can contain probability values (so-called score values). If score values are included in the result of the credit report, they are based on recognized scientific, mathematical-statistical methods. The calculation of the score values includes, but is not limited to, address data. For further information on data protection law, including the credit agencies used, please refer to PayPal's data protection declaration at: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full. You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still be entitled to process your personal data if this is necessary for contractual payment processing.
- Wix Payments
If you choose the payment method Wix Payments, the payment will be processed via the payment system of Wix HQ, 6350671, Nemal Tel Aviv St 40, Tel Aviv-Yafo, Israel (hereinafter referred to as "Wix "). Wix Payments enables payments via all major credit card formats and, depending on the region, via additional payment methods. The individual payment methods offered by Wix Payments will be communicated to you on our website. In the case of payments via Wix Payments, your payment data (e.g. payment amount, information on the means of payment used, details of the payee) as well as your confirmation that the payment data is correct will be collected, processed and transferred by Wix to the credit institution commissioned with the payment in accordance with Art. 6 (1) point b GDPR. This processing will only take place to the extent necessary for the execution of the payment. Wix will then authenticate the payment using the authentication procedure provided for you at your bank. In this context, data may also be transferred to Wix Inc., 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA, for further processing on behalf of Wix Inc. You can find further information about Wix's data protection at the following website: https://www.wix.com/about/privacy
8) Web Analysis Services
- Wix Analytics
9) Site Functionalities
10) Tools and Miscellaneous
This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "cookie consent tool" is displayed to users in the form of an interactive user interface when they access the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box. Using the tool, all cookies/services requiring consent are only loaded if the respective user provides the corresponding consent by ticking the corresponding box. This ensures that such cookies are only set on the respective end device of the user if consent has been granted. The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed. If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) point GDPR based on our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website. Further legal basis for the processing is Art. 6 (1) point c GDPR. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent. Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.
11) Rights of the Data Subject
11.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data: - Right of access by the data subject pursuant to Art. 15 GDPR: You shall have the right to receive the following information: The personal data processed by us; the purposes of the processing; the categories of processed personal data; the recipients or categories of recipients to whom the personal data have been or will be disclosed; 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 controller rectification or erasure of personal data or restriction of processing personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling 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; the appropriate safeguards pursuant to Article 46 when personal data is transferred to a third country. - Right to rectification pursuant to Art. 16 GDPR: You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning you and/or the right to have incomplete personal data completed which are stored by us. - Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR: You have the right to obtain from the controller the erasure of personal data concerning you if the conditions of Art. 17 (2) GDPR are fulfilled. However, this right will not apply for exercising the freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims. - Right to restriction of processing pursuant to Art. 18 GDPR: You have the right to obtain from the controller restriction of processing your personal data for the following reasons: As long as the accuracy of your personal data contested by you will be verified. If you oppose the erasure of your personal data because of unlawful processing and you request the restriction of their use instead. If you require the personal data for the establishment, exercise or defense of legal claims, once we no longer need those data for the purposes of the processing. If you have objected to processing on grounds relating to your personal situation pending the verification whether our legitimate grounds override your grounds. - Right to be informed pursuant to Art. 19 GDPR: If you have asserted the right of rectification, erasure or restriction of processing against the controller, he is obliged to communicate to each recipient to whom the personal date has been disclosed any rectification or erasure of personal data or restriction of processing, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients. - Right to data portability pursuant to Art. 20 GDPR: You shall have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format or to require that those data be transmitted to another controller, where technically feasible. - Right to withdraw a given consent pursuant to Art. 7 (3) GDPR: You have the right to withdraw your consent for the processing of personal data at any time with effect for the future. In the event of withdrawal, we will immediately erase the data concerned, unless further processing can be based on a legal basis for processing without consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. - Right to lodge a complaint pursuant to Art. 77 GDPR: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
11.2 RIGHT TO OBJECT IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION. IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS. IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE. IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.
12) Duration of Storage of Personal Data
The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and - if relevant – on the respective legal retention period (e.g. commercial and tax retention periods). If personal data is processed on the basis of an express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent. If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage. When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims. If personal data is processed for the purpose of direct marketing on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR. Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.