Privacy Protection project urban 2|3 GmbH

I. NAME AND ADDRESS OF THE DATA CONTROLLER
In terms of the General Data Protection Regulation and other national data protection laws of the EU member states and other data protection-related regulations, the data controller is:

project urban 2|3 GmbH
Reesbergstr. 1
36039 Fulda
Germany

Tel.: +49 661 6000-8000
E-mail: info[at]projecturban23.com
Website: www.projecturban23.com

The data protection officer of the controller is
Valantic Management Consulting GmbH and can be contacted at the following: datenschutz[at]edag.com

II. GENERAL DATA PROCESSING INFORMATION
1 Scope and purpose of the processing of personal data
We collect and use our users' personal data only to the extent necessary to provide a functional website and our content and services. The collection and use of our users' personal data only takes place regularly with the user's consent (where required by law). An exception applies in those cases in which prior consent cannot be obtained for factual reasons or in which the processing of the data is permitted by other legal bases in accordance with the applicable data protection law.

2 Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 sentence 1 lit. a EU General Data Protection Regulation (GDPR) and the analogous provisions in accordance with the applicable data protection law serve as the legal basis for the processing of personal data. When processing personal data that is necessary for the fulfilment of a contract to which the data subject is a party, Art. 6 para. 1 sentence 1 lit. b GDPR and the analogous provisions in accordance with the applicable data protection law serve as the legal basis. This also applies to processing operations that are necessary for the performance of pre-contractual measures. Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 sentence 1 lit. c GDPR and the analogous provisions in accordance with the applicable data protection law serve as the legal basis. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 sentence 1 lit. d GDPR and the analogous provisions under the applicable data protection law serve as the legal basis. If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 sentence 1 lit. f GDPR and the analogous provisions in accordance with the applicable data protection law serve as the legal basis for the processing.

3 Data erasure and storage period
The personal data of the data subject will be erased or blocked as soon as the purpose of storage no longer applies. Data may also be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. The data will also be blocked or erased if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.

III. PROVISION OF THE WEBSITE AND CREATION OF LOG FILES
1. Description and scope of data processing
Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer. The following data is collected:

(1) The IP address of the user
(2) Date and time of access.
(3) Opened page / name of the opened file
(4) Web browser and requesting domain
(5) Amount of data transferred
(6) Browser used
(7) Operating system used
(8) Message whether the access was successful or not
The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.

2. legal basis for data processing
The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 sentence 1 lit. f GDPR and the analogous provisions in accordance with the applicable data protection law.

3. purpose of data processing
The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user's computer. The data collected is therefore used for statistical analyses and to improve the website. Your personal data (IP address) is anonymised in advance. Data is stored in log files to ensure the functionality of the website. We also use the data to optimise the website and to ensure the security of our information technology systems. The data is not analysed for marketing purposes in this context. These purposes also constitute our legitimate interest in data processing in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR and the analogous provisions in accordance with the applicable data protection law.

4. duration of storage
The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or anonymised so that it is no longer possible to identify the accessing client.

5. possibility of objection and removal
The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility for the user to object.

IV. USE OF USERCENTRICS (CONSENT MANAGEMENT)
1. Description and scope of data processing
We use the consent management service of Usercentrics GmbH, Sendlinger Str. 7, 80331 Munich (hereinafter "Usercentrics"). Our Usercentrics consent tool is played out via the Google Tag Manager. For this reason, the Google Tag Manager is activated as an essential cookie (unselectable) (first level) during initial visits to our website. Only if you activate a cookie requiring consent through your express consent in our consent tool Usercentrics will the Google Tag Manager establish a connection to this cookie and the corresponding cookie will be loaded. When our website is accessed, the Usercentrics system automatically collects data and information from the computer system of the accessing computer. The following data is collected by or through the use of the service:

o Opt-in and opt-out data
o Referrer URL
o User Agent
o User settings
o Consent ID
o Time of consent
o Consent type
o Template version
o Banner language

2. Legal basis for data processing
Due to the legal obligation to store the aforementioned data, the legal basis is Art. 6 para. 1 sentence 1 lit. c GDPR and the analogous provisions in accordance with the applicable data protection law.

3. Purpose of data processing
The service is used to manage consents. This serves to comply with legal obligations, according to which data processing requiring consent may only be carried out via the website if users have given their consent. The Usercentrics service is used to store the consent obtained and to manage it. This also applies in the event that consent is withdrawn. Usercentrics is used as a processor. We have therefore concluded an data processing agreement with Usercentrics in accordance with the legal requirements.

4. Duration of storage; possibility of objection and removal
The retention period is the period of time during which the collected data is stored for processing. The data must be deleted as soon as it is no longer required for the specified processing purposes. The consent data (consent given and revocation of consent) will be stored for three years. The data will be deleted immediately. The collection and storage of data is required by law for the operation of the website. Consequently, the user has no option to object. You can find the data protection provisions of the data processor here: https://usercentrics.com/de/datenschutzerklaerung/

V. USE OF GOOGLE TAG MANAGER
1. Description and scope of personal data processing
This website uses Google Tag Manager. This is a tool that allows marketers to manage their website tags through a single interface. A tag manager itself, which implements the tags, is a service that can collect personal data by setting cookies. The tool triggers other tags that may collect data under certain circumstances. We use Google Tag Manager on two levels when you visit our website. Initially, when you access our website, Google Tag Manager is activated as an essential cookie (unselectable) (first level). At this stage, however, it serves only the function of displaying our cookie consent tool Usercentrics – see III. – which gives you the opportunity to decide on the activation of the various cookies used on our website. Until this point in time, the web tracking functions of Google Tag Manager are deactivated and it serves only as an administration and activation tool for Usercentrics. Only at the second level do we use the Google Tag Manager to manage and activate further cookies that require your consent. Only if you explicitly consent to a cookie requiring consent by activating it in our Usercentrics consent tool, will the Google Tag Manager establish a connection to that cookie and load the corresponding cookie. Until such activation, the web tracking functions of the Google Tag Manager remain deactivated.

2. Purpose and legal basis for processing personal data
The Google Tag Manager is used to manage third-party tags in an organised manner and to implement your selection of activated technologies accordingly. We have a legitimate interest in this, Art. 6 (1) 1 lit. f GDPR. If you activate further services in our Usercentrics consent tool, their processing is based on your consent, Art. 6 (1) 1 lit. a GDPR.

3. Duration of storage, right to object and opt out
The Google Tag Manager itself triggers other tags that may collect data under certain circumstances. The Google Tag Manager does not access this data. If disabled at the domain or cookie level, it will remain disabled for all tracking tags implemented with Google Tag Manager. You can find more information here: Google Tag Manager Use Policy | Google Tag Manager – Google When Google Tag Manager is activated, a connection to Google is established. We would like to point out that we have no influence on the storage of your data by Google. We have also concluded a data processing agreement with Google for this purpose. Otherwise, the storage of your data is based on the respective storage period of the tools activated by the Google Tag Manager. You cannot activate the Google Tag Manager itself, as it manages and plays essential technologies for the operation of the website and is therefore an essential technology of our website. Insofar as tools requiring consent are played by the Google Tag Manager, their use can be eliminated by deactivating the affected activity.

4. Disclosure of personal data
Third-party information: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. The terms of use can be found at: www.google.com /analytics/terms/de.html; an overview of data protection can be found at: www.google.com/intl/de/analytics/learn/privacy.html, and the data protection declaration at: www.google.de/intl/de/policies/privacy. We would also like to point out that we cannot rule out data transfer to the USA (to Google LLC based in the USA) in this context. However, since the EU-US adequacy decision, the Data Privacy Framework (DPF), which has been in force since 10 July 2023, the USA is certified as having a level of data protection equivalent to that in the EU, in that the company receiving the data in the USA is certified in accordance with the provisions of the DPF, which is the case for Google LLC (see positive certification in the list of the US Department of Commerce).

VI. USE OF COOKIES
1 Description and scope of data processing
Our website uses cookies. Cookies are data records that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. We use cookies to make our website more user-friendly. Some elements of our website require that the accessing browser can be identified even after a page change.

The following data is stored and transmitted in the cookies:

(1) The IP address of the user
(2) Date and time of access
(3) Log information
(4) Amount of data transferred
(5) Requesting domain
We also use cookies on our website that enable an analysis of the user's surfing behaviour.

The following data can be transmitted in this way

(1) Device type, model, brand, screen resolution
(2) Operating system, versions, families
(3) Browser, version, configuration, engines, plugins, language, language code
(4) Location data
(5) Provider details
(6) Pages per visit,
(7) Entry pages, exit pages, page URL, page title, search terms, downloads
(8) Search engines, search term, websites, social networks
(9) Campaigns, campaign keyword

When accessing our website, the user is informed about the use of functional cookies as well as cookies for analysis and marketing purposes and his consent to the processing of the personal data used in this context is obtained using a cookie consent manager (Usercentrics, see point III.). In this context, reference is also made to this privacy policy. In the Cookie Consent Manager, you will also find detailed information on how the individual cookies work, information on the duration of their function and information on whether third parties have access to these cookies. You can access the Cookie Consent Manager at any time via a corresponding button in the footer of our website.

2 Legal basis for data processing
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 sentence 1 lit. f GDPR. The legal basis for the processing of personal data using functional cookies and cookies for analysis and marketing purposes is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR together with the analogous provisions in accordance with the applicable data protection law.

3. Purpose of data processing
Depending on the purpose and function, we divide cookies into the following categories:

a) Technically necessary cookies
Technically necessary cookies guarantee functions without which our website cannot be used as intended. These cookies are used exclusively by us and are therefore first party cookies. This means that all information stored in the cookies is sent back to our website. Technically necessary cookies are used, for example, to ensure that logged-in users always remain logged in when accessing various subpages of our website and therefore do not have to re-enter login data each time they access a new page. The use of technically necessary cookies on our website is possible and permitted without consent. For this reason, technically necessary cookies cannot be deactivated or activated individually. These purposes also constitute our legitimate interest in the processing of personal data in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR. Our interest in the technically smooth provision of our website and the services offered through it prevails.

b) Functional cookies
Functional cookies enable our website to save information that has already been entered (such as registered name, language selection or the location of the user) and to offer improved and more personalised functions based on this. These cookies only collect and store data in such a way that user behaviour on other websites cannot be tracked.

c) Performance cookies
Performance cookies collect aggregated information about how our website is used in order to improve its attractiveness, content and functionality. These cookies help us to determine whether, which, how often and for how long subpages of our website are visited and what content users are particularly interested in. These cookies do not store any information that allows the user to be identified. The information collected is aggregated and does not allow us to draw any direct conclusions about the individual person. They are used solely to compile statistics in order to tailor the content of our website more specifically to the needs of our users, improve the user experience and optimise our offering.

d) Marketing cookies
Marketing cookies originate from external advertising companies (third-party cookies) and are used to collect information about the websites visited by the user in order to create targeted advertising for the user and to display adverts based on the user's interests. They are also used to limit the frequency with which an advert appears and to measure the effectiveness of advertising campaigns. This information can be shared with third parties, e.g. advertisers.

4. Duration of storage, objection and removal options
Cookies are stored on the user's computer and transmitted by it to our site. As a user, you therefore have full control over the use of cookies. You can revoke your consent to the use of cookies at any time with effect for the future. Please use one of the following options to do so:

o You inform us that you wish to withdraw your consent or change your settings in our Cookie Consent Manager, which can be accessed at any time via the website.
o You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.
o Cookies that have already been saved can be deleted at any time in your settings. This can also be done automatically.
o You can also prevent the collection of the data generated by the respective cookie and related to your use of our websites (including your IP address) and the processing of this data by downloading and installing the plugin available for your browser.
o You can also manage marketing cookies using the tools developed in many countries as part of self-regulation programmes, such as https://www.aboutads.info/choices/ (USA) or http://www.youronlinechoices.com/uk/your-ad-choices (EU).

5. Transfer of personal data
By accepting the functional cookies that go beyond the technically necessary cookies as well as cookies for analysis and advertising purposes, you also consent in accordance with Art. 49 para. 1 sentence 1 lit. a GDPR and the analogous provisions under the applicable data protection law that your data may be processed in the USA if there is no adequate level of data protection. In this respect, there is no comparable level of data protection in the USA as in Europe if the company receiving the data is not certified in accordance with the adequacy decision between the EU and the USA, the Data Privacy Framework (DPF), which has been in force since 10 July 2023. In particular, it is possible that government agencies may access personal data without us or you being aware of this. Prosecution may not be successful. In this case, we transfer personal data to third countries when using cookies on the basis of the EU standard contractual clauses in order to establish an equivalent level of data protection, if necessary. You can find more information here: Standard contractual clauses for international transfers - European Commission (europa.eu)
Insofar as the company receiving the data is certified in accordance with the applicable adequacy decision between the EU and the USA, the Data Privacy Framework (DPF), a level of data protection equivalent to that of the EU is attested in this respect and the data processing is based on the Data Privacy Framework. If you do not want this, click on Reject.

VII. CONTACT FORM AND E-MAIL CONTACT
1 Description and scope of data processing
A contact form is available on our website, which can be used to contact us electronically. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored. This data is mandatory:

(1) My request
(2) E-mail address

In addition, the following data can be entered voluntarily by you:

(3) Salutation
(4) Company
(5) Surname, first name
(6) Telephone no.
(7) Street, house number
(8) Postcode, town
(9) Country
(10) Your message to us

The following data is also stored at the time the message is sent:

(11) The IP address of the user
(12) Date and time of registration

Your consent is obtained for the processing of the data as part of the sending process and reference is made to this privacy policy. Alternatively, it is possible to contact us via the e-mail address provided. In this case, the user's personal data transmitted with the e-mail will be stored.

2. Legal basis for data processing
The legal basis for the processing of the data is Art. 6 para. 1 sentence 1 lit. a GDPR if the user has given his consent. The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 para. 1 sentence 1 lit. f GDPR. If the e-mail contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 sentence 1 lit. b GDPR.

3. Purpose of data processing
The processing of personal data from the input mask serves us to process the contact. In the case of contact by email, this also constitutes the necessary legitimate interest in processing the data. The other personal data processed during the sending process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.

4. Duration of storage
The data is deleted as soon as it is no longer required to fulfil the purpose for which it was collected. For the personal data from the input screen of the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified. The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5 Possibility of objection and removal
The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued. All personal data stored in the course of contacting us will be deleted in this case.

VIII. USE OF GOOGLE WEB FONTS
1. Description and scope of data processing
We use so-called web fonts, which are provided by Google and downloaded locally to our servers, for the standardised display of fonts. The required web fonts are loaded into your browser cache in order to display texts and fonts correctly. If your browser does not support web fonts, a standard font will be used by your computer. No cookies are set when you access the page. There is also no direct connection to the Google servers, as the fonts are integrated locally into our website.

2. Legal basis for data processing
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR due to our legitimate interest in a standardised presentation.

3. Purpose of data processing
Google Web Fonts is a freely available library of over 800 fonts. Google Web Fonts allows us to present our website to the user in an appealing design and in the same quality across all devices. Only in this way is it technically possible for all visitors to our website to have a consistent and pleasant user experience. This is also a legitimate interest within the meaning of Art. 6 para. 1 sentence 1 lit. f GDPR.

4. Duration of storage, possibility of objection and removal
The data is stored for as long as it is required to fulfil the purpose for which it was collected. You have the option to object to its use by changing your browser settings.

IX. USE OF HUBSPOT
1 Description and scope of data processing
On our website we use HubSpot, a service of HubSpot Inc. for analysis purposes as well as for e-mailing, blogs and social media posting. HubSpot Inc. is a US company with a branch in Ireland (HubSpot, 2nd floor 30 North Wall Quay, Dublin 1, Ireland, Tel.: +353 1 5187500). HubSpot uses cookies that are stored on the user's computer and that collect certain data. The following data is collected:

o IP address
o Location
o Browser
o Duration of the visit
o Websites visited

2. Legal basis for data processing
The legal basis for the processing of personal data using the HubSpot service is, in the case of consent by the user for analysis purposes, Art. 6 para. 1 sentence 1 lit. a GDPR and the analogous provisions in accordance with the applicable data protection law. The use of the service for the purpose of e-mailing, blogging and social media postings is otherwise based on our legitimate interest Art. 6 para. 1 sentence 1 lit. f GDPR and the analogous provisions in accordance with the applicable data protection law.

3. Purpose of data processing
The purpose of using the service for analysis is to be able to analyse and regularly improve the use of our website. We can use the statistics obtained to improve our offering and make it more interesting for you as a user. The other data processed using the HubSpot service is used to utilise it for mailing lists, blogs and social media postings and thus to simplify customer care and make it clearer. These purposes also constitute our legitimate interest in the processing of personal data in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR and the analogous provisions in accordance with the applicable data protection law

4. Duration of storage, objection and removal options
We use the data collected using the HubSpot service only for the purposes stated above and do not pass this data on to third parties. We have also concluded an data processing agreement with Hubspot Inc. for this purpose. You can prevent the collection of data by HubSpot by prohibiting the storage of cookies in your browser by making the appropriate settings. Instructions can be found at http://www.meine-cookies.org/cookies_verwalten/index.html If you wish to prevent the use of your data for marketing purposes, you can unsubscribe with one click at http://www.youronlinechoices.eu/ Further information on data processing by Hubspot and Hubspot's data protection conditions can be found at https://legal.hubspot.com/legal-stuff, https://legal.hubspot.com/privacy-policy and https://legal.hubspot.com/website-terms-of-use.

5. Disclosure of personal data
HubSpot processes your personal data in the USA. By consenting to the integration of the service, you also consent to your data being processed in the USA in accordance with Art. 49 para. 1 sentence 1 lit. a GDPR and the analogous provisions under the applicable data protection law. In this respect, we would also like to point out that we cannot rule out a data transfer to the USA (to HubSpot, Inc., based in the USA) in this context. In this respect, there is no comparable level of data protection in the USA as in Europe if the company receiving the data is not certified in accordance with the adequacy decision between the EU and the USA, the Data Privacy Framework (DPF), which has been in force since 10 July 2023. In particular, it is possible that government agencies may access personal data without us or you being aware of this. Legal action may not be successful. The data processing company, HubSpot Inc., is not certified according to the above-mentioned DPF. Suitable guarantees in the form of EU standard contractual clauses have therefore been concluded with HubSpot in order to establish an equivalent level of data protection.

You can find more information here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_de If you do not want this, click on Reject.

X. ONLINE PRESENCE IN SOCIAL MEDIA
We maintain an online presence within social networks in order to communicate with clients, interested parties and users who are active there and to be able to inform them about our services. In this context, only simple links and social media buttons that do not connect to the respective network when the page loads are used on our website. To do this, we use the ‘c't Shariff’ solution, which provides data protection-compliant social media buttons.

This is how the ‘Share’ buttons used here differ from the widespread social media plugins that transmit data to social networks as soon as the page loads, without the button having to be clicked. By contrast, a Shariff button only establishes direct contact between the social network and the visitor when the latter actively clicks on the share button. This way, Shariff prevents users from leaving a digital trail on every page they visit, thus improving data protection. Further information about c't Shariff can be found at https://www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html. Additional information on the processing of data within the respective social networks can be found in the following privacy policy for social media.

XI. USE OF FONTAWESOME
1. Description and scope of data processing
In order to ensure a uniform display of fonts, we use the Fontawesome function of Fonticons, Inc. This is downloaded locally to our servers and retrieved from them when the page is called up. For this purpose, the required fonts and icons are loaded into your browser's cache so that texts and fonts are displayed correctly. If your browser does not support Fontawesome fonts, a standard font from your computer will be used. No cookies are set when you access the page. There is also no direct connection to the Fonticons servers, as the fonts are integrated locally into our website.

2. Legal basis for data processing
Due to our legitimate interest in the uniform presentation of fonts, Art. 6 para. 1 p. 1 lit. f GDPR is the legal basis for the processing.

3. Purpose of data processing
Fontawesome is a freely available library of fonts and icons and enables us to present our website to the user in an appealing design and in the same quality on all devices. Only in this way is it technically possible to offer all visitors to our website a standardised and pleasant user experience. This is also a legitimate interest within the meaning of Art. 6 para. 1 sentence 1 lit. f GDPR.

4. Storage period, right to object and right to erasure
The data is stored for as long as it is required for the purpose for which it was collected. You have the option of objecting to its use by changing your browser settings.

XII. RIGHTS OF THE DATA SUBJECT
If your personal data is processed, you are a data subject within the meaning of the GDPR and the analogous provisions in accordance with the applicable data protection law and you have the following rights vis-à-vis the controller:

1. Right of access
You can request confirmation from the controller as to whether personal data concerning you is being processed by us. If such processing has taken place, you can request the following information from the controller:

(1) the purposes for which the personal data are processed;
(2) the categories of personal data that are processed;
(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
(4) the planned duration of storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
(5) the existence of a right to rectification or erasure of personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
(6) the existence of a right of appeal to a supervisory authority;
(7) all available information about the origin of the data if the personal data is not collected from the data subject;
(8) the existence of automated decision-making including profiling in accordance with Art. 22 (1) and (4) GDPR and the analogous provisions under the applicable data protection law and - at least in these cases - meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR and the analogous provisions under the applicable data protection law in connection with the transfer.

2. Right to rectification
You have a right to rectification and/or completion vis-à-vis the controller if the processed personal data concerning you is incorrect or incomplete. The controller must carry out the rectification without undue delay.

3. Right to restriction of processing
Under the following conditions, you may request the restriction of the processing of personal data concerning you:

(1) if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
(3) the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims, or
(4) if you have objected to processing pursuant to Art. 21 (1) GDPR and the analogous provisions under the applicable data protection law and it has not yet been established whether the legitimate reasons of the controller outweigh your reasons.

If the processing of personal data concerning you has been restricted, this data - apart from its storage - may only be processed with your consent (where required by law) or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. If processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.

4. Right to erasure
a) Obligation to erase
You have the right to obtain from the controller the erasure of personal data concerning you without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You revoke your consent on which the processing was based pursuant to Art. 6 para. 1 sentence 1 lit. a or Art. 9 para. 2 lit. a GDPR and the analogous provisions under the applicable data protection law, and there is no other legal basis for the processing.
(3) You object to the processing in accordance with Art. 21 (1) GDPR and the analogous provisions in accordance with the applicable data protection law and there are no overriding legitimate grounds for the processing, or you object to the processing in accordance with Art. 21 (2) GDPR and the analogous provisions in accordance with the applicable data protection law.
(4) The personal data concerning you has been processed unlawfully.
(5) The deletion of personal data concerning you is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.
(6) The personal data concerning you was collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR and the analogous provisions under applicable data protection law.

b) Information to third parties
Where the controller has made the personal data concerning you public and is obliged pursuant to Art. 17 (1) GDPR and the analogous provisions under the applicable data protection law 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 controllers which are processing the personal data that you as the data subject have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

c) Exceptions
The right to erasure does not exist if the processing is necessary

(1) to exercise the right to freedom of expression and information;
(2) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(3) for reasons of public interest in the area of public health in accordance with Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR and the analogous provisions in accordance with the applicable data protection law;
(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 (1) GDPR and the analogous provisions under the applicable data protection law, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
(5) for the assertion, exercise or defence of legal claims.

5. Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients by the controller.

6. Right to data portability
You have the right to receive the personal data concerning you, which you have provided to the controller, in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where

(1) the processing is based on consent pursuant to Art. 6 para. 1 sentence 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR and the analogous provisions pursuant to the applicable data protection law or on a contract pursuant to Art. 6 para. 1 sentence 1 lit. b GDPR and the analogous provisions pursuant to the applicable data protection law and
(2) the processing is carried out using automated procedures. In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. The freedoms and rights of other persons must not be affected by this. The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

7 Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR and the analogous provisions under the applicable data protection law, including profiling based on those provisions. The controller will no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes. You have the option, in connection with the use of information society services - notwithstanding Directive 2002/58/EC and the analogous provisions under the applicable data protection law - to exercise your right of objection by means of automated procedures using technical specifications.

8. Right to revoke the declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

9. Automated decision-making in individual cases, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

(1) is necessary for the conclusion or performance of a contract between you and the controller,
(2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or
(3) is based on your explicit consent.

However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR and the analogous provisions pursuant to the applicable data protection law, unless Art. 9 para. 2 lit. a or g and the analogous provisions pursuant to the applicable data protection law apply and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests. In the cases referred to in (1) and (3), the data controller shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

10. right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR and the analogous provisions under the applicable data protection law. The supervisory authority with which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR and the analogous provisions under the applicable data protection law.

Status: September 2024