Data Protection

This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services and within our online offer and the websites, functions and content associated with it as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Responsible

Foresight Consulting Limited

17 Brook House, Corrig Avenue

Dun Laoghaire, Co. Dublin, Ireland

Registration number: 637069 Dublin

Tax number: 3579439HH

Represented by Raymond Rieke

Contact

Tel: 0049 178 166 41 03

Email: info@vorblick.com

Responsible for the content: Raymond Rieke

Types of data processed

– Inventory data (e.g., person master data, names or addresses).

– Contact information (e.g., email, phone numbers).

– Content data (e.g., text input, photographs, videos).

– Usage data (e.g., web pages visited, interest in content, access times).

– Meta/communication data (e.g., device information, IP addresses).

Categories of persons concerned

Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as “users”).

Purpose of processing

– Provision of the online offer, its functions and contents.

– Respond to contact requests and communicate with users.

– Safety measures.

– Reach measurement/marketing

Terminology used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data.

“pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.

Relevant legal bases

In accordance with Art. 13 DSGVO, we inform you about the legal basis of our data processing. For users from the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies, unless the legal basis is stated in the privacy policy:

The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO;

The legal basis for the processing for the fulfillment of our services and implementation of contractual measures as well as answering inquiries is Art. 6 para. 1 lit. b GDPR;

The legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR;

In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as the legal basis.

The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 para. 1 lit. e GDPR.

The legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR.

The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 para. 4 GDPR.

The processing of special categories of data (according to Art. 9 (1) of the GDPR) is determined according to the requirements of Art. 9 (1) of the GDPR. 2 GDPR.

Security measures

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and response to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Cooperation with processors, joint controllers and third parties

If, in the course of our processing, we disclose data to other persons and companies (order processors, jointly responsible persons or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the fulfillment of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, in addition, on a basis that complies with the legal requirements.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this is done in the context of using third-party services or disclosing, or transferring data to other persons or companies, this will only be done if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to express consent or contractually required transfer, we only process or allow data to be processed in third countries with a recognized level of data protection, which includes U.S. processors certified under the “Privacy Shield” or on the basis of special guarantees, such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page).

Rights of the data subjects

You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.

You have accordingly. the legal requirements, the right to request that the data concerning you be completed or that the inaccurate data concerning you be corrected.

In accordance with the statutory provisions, you have the right to demand that the data concerned be deleted without delay or, alternatively, to demand restriction of the processing of the data in accordance with the statutory provisions.

You have the right to request that the data concerning you that you have provided to us be received in accordance with the law and to request that it be transferred to other data controllers.

You also have the right to file a complaint with the competent supervisory authority in accordance with the law.

Right of withdrawal

You have the right to revoke given consents with effect for the future.

Right of objection

You may object to the future processing of data relating to you at any time in accordance with the statutory provisions. The objection can be made in particular against the processing for purposes of direct advertising.

Cookies and right to object to direct advertising

Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. The primary purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or after his visit within an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online store or a login status can be stored. Permanent” or “persistent” cookies are those that remain stored even after the browser is closed. For example, the login status can be saved when users visit them after several days. Likewise, such a cookie may store the interests of users, which are used for reach measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies, and we explain this in our privacy policy.

If we ask users to consent to the use of cookies (e.g. in the context of a cookie consent), the legal basis of this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the personal cookies of the users are used in accordance with the following explanations within the scope of this privacy policy on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) or insofar as the use of cookies is necessary for the provision of our contract-related services, pursuant to Art. Art. 6 par. 1 lit. b. DSGVO, or if the use of cookies is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, pursuant to. Art. 6 par. 1 lit. e. DSGVO, processed.

If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the U.S. site www.aboutads.info/choices/ or the EU site www.youronlinechoices.com/ . Furthermore, the storage of cookies can be achieved by means of their deactivation in the browser settings. Please note that then not all functions of this online offer can be used.

Data deletion

The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations.

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.

Changes and updates to the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Business processing

In addition we process

– Contract data (e.g., subject matter of the contract, term, customer category).

– Payment data (e.g., bank details, payment history)

of our customers, prospective customers and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Agency services

We process our customers’ data as part of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.

In doing so, we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), usage data and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing. Data subjects include our customers, prospective customers, as well as their customers, users, website visitors or employees, and third parties. The purpose of the processing is to provide contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b DSGVO (contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimization, security measures). We process data that are necessary for the justification and fulfillment of the contractual services and point out the necessity of their indication. Disclosure to external parties only takes place if it is required as part of an order. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client as well as the legal requirements of a commissioned processing pursuant to §§ 3 and 4 of the German Data Protection Act. Art. 28 DSGVO and do not process the data for any other purposes than those specified in the order.

We delete the data after expiration of legal warranty and comparable obligations. the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, deletion takes place after their expiry (6 years, according to § 257 para. 1 HGB, 10 years, according to § 147 para. 1 AO). In the case of data disclosed to us by the client as part of an order, we delete the data in accordance with the specifications of the order, generally after the end of the order.

Brokerage services

We process the data of our customers, clients and interested parties (uniformly referred to as “customers”) in accordance with Art. 6 para. 1 lit. b. DSGVO in order to provide them with our contractual or pre-contractual services. The data processed in this context, the type, scope and purpose and the necessity of their processing are determined by the underlying order. In principle, this includes inventory and master data of customers (name, address, etc.), as well as contact data (e-mail address, telephone, etc.), contract data (content of the order, fees, terms, information on the mediated companies/insurers/services) and payment data (commissions, payment history, etc.). We may also process the information on the characteristics and circumstances of persons or things belonging to them, if this is part of the subject of our order. This can be, for example, information on personal circumstances, mobile or immobile tangible assets.

Within the scope of our commissioning, it may also be necessary for us to process special categories of data pursuant to Art. 9 Para. 1 DSGVO, in this case in particular information on the health of a person. For this purpose, we obtain, if necessary, according to Art. 6 para. 1 lit a., Art. 7, Art. 9 para. 2 lit a DSGVO an explicit consent of the customer.

To the extent necessary for the performance of the contract or required by law, we disclose or transmit customer data in connection with coverage requests, the conclusion and processing of contracts to providers of the brokered services/objects, insurers, reinsurers, broker pools, technical service providers, other service providers, such as cooperating associations, as well as financial service providers, credit institutions and investment companies, as well as social insurance carriers, tax authorities, legal advisors, auditors and insurance ombudsmen.e.g. cooperating associations, as well as financial service providers, credit institutions and investment companies, as well as social insurance institutions, tax authorities, tax advisors, legal advisors, auditors, insurance ombudsmen and the Federal Financial Supervisory Authority (BaFin). Further, we may engage subcontractors, such as sub-brokers. We obtain consent from customers if this is required for the disclosure/transfer of customer consent (which may be the case, for example, in the case of special categories of data pursuant to Art. 9 DSGVO).

The deletion of the data takes place after the expiry of legal warranty and comparable obligations, whereby the necessity of the retention of the data is reviewed every three years; in all other respects, the legal retention obligations apply.

In the case of legal archiving obligations, deletion takes place after their expiry. In particular, under German law in the insurance and finance industry, consulting protocols must be retained for 5 years, broker contract notes for 7 years and broker contracts for 5 years, as well as generally 6 years for documents relevant under commercial law and 10 years for documents relevant under tax law.

Administration, financial accounting, office organization, contact management

We process data within the framework of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The cancellation of the data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.

We disclose or transfer data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, we store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We store this data, which is mostly company-related, permanently.

Business analyses and market research

In order to operate our business economically, to be able to recognize market trends, wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc.. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we can take into account the profiles of registered users with information, for example, about the services they have used. The analyses serve us to increase the user-friendliness, the optimization of our offer and the operational economy. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized values.

If these analyses or profiles are personal, they are deleted or anonymized upon termination by the user, otherwise after two years from the conclusion of the contract. In other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.

Google Cloud Services

We use the cloud and cloud software services offered by Google (so-called Software as a Service, e.g. Google Suite) for the following purposes: document storage and management, calendar management, emailing, spreadsheets and presentations, sharing documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

In this context, the personal data of users are processed to the extent that they become part of the documents and content processed within the services described or are part of communication processes. This may include, for example, master data and contact data of users, data on transactions, contracts, other processes and their contents. Google also processes usage data and metadata that is used by Google for security purposes and service optimization.

In the course of using publicly available documents, web pages or other content, Google may store cookies on users’ computers for purposes of web analytics or to remember users’ preferences.

We use the Google Cloud services on the basis of our legitimate interests according to. Art. 6 par. 1 lit. f GDPR to efficient and secure management and collaboration processes. Furthermore, the processing is carried out on the basis of an order processing agreement with Google(https://cloud.google.com/terms/data-processing-terms).

For more information, please see Google’s privacy policy(https://www.google.com/policies/privacy) and the Google Cloud Services Security Notice(https://cloud.google.com/security/privacy/). You can object to the processing of your data in the Google Cloud to us in accordance with the legal requirements. Otherwise, the deletion of data within Google’s cloud services is determined by the other processing processes in the context of which the data are processed (e.g., deletion of data no longer required for contractual purposes or storage of data required for taxation purposes).

Google Cloud Services are provided by Google Ireland Limited. Insofar as a transfer to the USA takes place, we refer to the certification of Google USA under the Privacy Shield(https://www.privacyshield.gov/participant?id=a2zt0000000000001L5AAI&status=Aktive) and standard protection clauses(https://cloud.google.com/terms/data-processing-terms).

Microsoft Cloud Services

We use the cloud and cloud software services offered by Microsoft (so-called Software as a Service, e.g. Microsoft Office) for the following purposes: document storage and management, calendar management, sending e-mails, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

In this context, the personal data of users are processed to the extent that they become part of the documents and content processed within the services described or are part of communication processes. This may include, for example, master data and contact data of users, data on transactions, contracts, other processes and their contents. Microsoft also processes usage data and metadata that Microsoft uses for security and service optimization purposes.

In the course of using publicly available documents, web pages or other content, Microsoft may store cookies on users’ computers for purposes of web analytics or to remember users’ preferences.

We use the Microsoft Cloud Services on the basis of our legitimate interests pursuant to. Art. 6 par. 1 lit. f GDPR to efficient and secure management and collaboration processes. Furthermore, the processing is carried out on the basis of an order processing agreement with Microsoft.

For more information, see the Microsoft privacy statement(https://privacy.microsoft.com/de-de/privacystatement) and the Microsoft cloud services security notices(https://www.microsoft.com/de-de/trustcenter). You can object to the processing of your data in the Microsoft Cloud in accordance with the legal requirements. Otherwise, the deletion of data within Microsoft’s cloud services is determined by the other processing processes in the context of which the data are processed (e.g., deletion of data no longer required for contractual purposes or storage of data required for taxation purposes).

Microsoft Cloud Services are provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA. Insofar as any processing of data takes place in the USA, we refer to Microsoft’s certification under the Privacy Shield(https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).

Contact

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user’s data will be used to process the contact request and its handling according to Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relations), Art. 6 para. 1 lit. f. (other requests) DSGVO processed… The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.

We delete the requests if they are no longer necessary. We review the necessity every two years; Furthermore, the legal archiving obligations apply.

Hosting and emailing

The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services, which we use for the purpose of operating this online offering.

In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with the German Data Protection Act. Art. 6 par. 1 lit. f DSGVO in conjunction with. Art. 28 DSGVO (conclusion of order processing contract).

Google Analytics

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transmitted to a Google server in the USA and stored there.

Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Thereby, pseudonymous usage profiles of the users can be created from the processed data.

We use Google Analytics only with IP anonymization enabled. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.

The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

If we ask users for consent (e.g. in the context of a cookie consent), the legal basis of this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the users’ personal data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) are processed.

Insofar as data is processed in the USA, we would like to point out that Google is certified under the Privacy Shield Agreement and thereby assures that it complies with European data protection law(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

For more information about Google’s use of data, settings and opt-out options, please refer to Google’s privacy policy(https://policies.google.com/privacy) and the settings for the display of advertisements by Google(https://adssettings.google.com/authenticated).

Users’ personal data is deleted or anonymized after 14 months.

Google AdWords and conversion measurement

We use the online marketing method Google “AdWords” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our online offering in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products he or she was interested in on other online offers, this is referred to as “remarketing”. For these purposes, when our website and other websites on which the Google advertising network is active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also referred to as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records which web pages the user has visited, which content the user is interested in and which offers the user has clicked on, as well as technical information about the browser and operating system, referring web pages, time of visit and other information about the use of the online offer.

Furthermore, we receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to create conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a conversion tracking tag. However, we do not receive any information that personally identifies users.

User data is processed pseudonymously within the Google advertising network. I.e. Google does not store and process e.g. the name or email address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the USA.

If we ask users for consent (e.g. in the context of a cookie consent), the legal basis of this processing is Art. 6 para. 1 lit. a. GDPR. Otherwise, the users’ personal data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) are processed.

Insofar as data is processed in the USA, we would like to point out that Google is certified under the Privacy Shield Agreement and thereby assures that it complies with European data protection law(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

For more information about Google’s use of data, settings and opt-out options, please refer to Google’s privacy policy(https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google(https://adssettings.google.com/authenticated).

Created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke.