Privacy Policy
We are very delighted that you have shown interest in our
enterprise. Data protection is of a particularly high priority for the
management of Alex Freeman. The use of the Internet pages of
Alex Freeman is possible without any indication of personal data;
however, if a data subject wants to use special enterprise services
via our website, processing of personal data could become
necessary. If the processing of personal data is necessary and there
is no statutory basis for such processing, we generally obtain
consent from the data subject.
The processing of personal data, such as the name, address, e-mail
address, or telephone number of a data subject shall always be in
line with the General Data Protection Regulation (GDPR), and in
accordance with the country-specific data protection regulations
applicable to Alex Freeman. By means of this data protection
declaration, our enterprise would like to inform the general public
of the nature, scope, and purpose of the personal data we collect,
use and process. Furthermore, data subjects are informed, by
means of this data protection declaration, of the rights to which
they are entitled.
As the controller, Alex Freeman has implemented numerous
technical and organizational measures to ensure the most
complete protection of personal data processed through this
website. However, Internet-based data transmissions may in
principle have security gaps, so absolute protection may not be
guaranteed. For this reason, every data subject is free to transfer
personal data to us via alternative means, e.g. by telephone.
1. Definitions
The data protection declaration of Alex Freeman is based on the
terms used by the European legislator for the adoption of the
General Data Protection Regulation (GDPR). Our data protection
declaration should be legible and understandable for the general
public, as well as our customers and business partners. To ensure
this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the
following terms:
a) Personal data
Personal data means any information relating to an identified or
identifiable natural person (“data subject”). An identifiable
natural person is one who can be identified, directly or indirectly,
in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one
or more factors specific to the physical, physiological, genetic,
mental, economic, cultural or social identity of that natural
person.
b) Data subject
Data subject is any identified or identifiable natural person, whose
personal data is processed by the controller responsible for the
processing.
c) Processing
Processing is any operation or set of operations which is performed
on personal data or on sets of personal data, whether or not by
automated means, such as collection, recording, organisation,
structuring, storage, adaptation or alteration, retrieval,
consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction,
erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data
with the aim of limiting their processing in the future.
e) Profiling
Profiling means any form of automated processing of personal data
consisting of the use of personal data to evaluate certain personal
aspects relating to a natural person, in particular to analyse or
predict aspects concerning that natural person's performance at
work, economic situation, health, personal preferences, interests,
reliability, behaviour, location or movements.
f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a
manner that the personal data can no longer be attributed to a
specific data subject without the use of additional information,
provided that such additional information is kept separately and is
subject to technical and organisational measures to ensure that
the personal data are not attributed to an identified or identifiable
natural person.
g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the
natural or legal person, public authority, agency or other body
which, alone or jointly with others, determines the purposes and
means of the processing of personal data; where the purposes and
means of such processing are determined by Union or Member
State law, the controller or the specific criteria for its nomination
may be provided for by Union or Member State law.
h) Processor
Processor is a natural or legal person, public authority, agency or
other body which processes personal data on behalf of the
controller.
i) Recipient
Recipient is a natural or legal person, public authority, agency or
another body, to which the personal data are disclosed, whether a
third party or not. However, public authorities which may receive
personal data in the framework of a particular inquiry in
accordance with Union or Member State law shall not be regarded
as recipients; the processing of those data by those public
authorities shall be in compliance with the applicable data
protection rules according to the purposes of the processing.
j) Third party
Third party is a natural or legal person, public authority, agency or
body other than the data subject, controller, processor and persons
who, under the direct authority of the controller or processor, are
authorised to process personal data.
k) Consent
Consent of the data subject is any freely given, specific, informed
and unambiguous indication of the data subject's wishes by which
he or she, by a statement or by a clear affirmative action, signifies
agreement to the processing of personal data relating to him or
her.
2. Name and Address of the controller
Controller for the purposes of the General Data Protection
Regulation (GDPR), other data protection laws applicable in
Member states of the European Union and other provisions related
to data protection is:
Alex Freeman
Rüdesheimer Str. 29
53175 Bonn
Germany
Email: contact(a)alexfreeman.biz
3. Name and Address of the Data Protection Officer
The Data Protection Officer of the controller is:
Alex Freeman
Rüdesheimer Str. 29
53175 Bonn
Germany
Email: dataprotection(a)alexfreeman.biz
Any data subject may, at any time, contact our Data Protection
Officer directly with all questions and suggestions concerning data
protection.
4. Cookies
The Internet pages of Alex Freeman use cookies. Cookies are text
files that are stored in a computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a
so-called cookie ID. A cookie ID is a unique identifier of the cookie.
It consists of a character string through which Internet pages and
servers can be assigned to the specific Internet browser in which
the cookie was stored. This allows visited Internet sites and servers
to differentiate the individual browser of the dats subject from
other Internet browsers that contain other cookies. A specific
Internet browser can be recognized and identified using the unique
cookie ID.
Through the use of cookies, Alex Freeman can provide the users of
this website with more user-friendly services that would not be
possible without the cookie setting.
By means of a cookie, the information and offers on our website
can be optimized with the user in mind. Cookies allow us, as
previously mentioned, to recognize our website users. The purpose
of this recognition is to make it easier for users to utilize our
website. The website user that uses cookies, e.g. does not have to
enter access data each time the website is accessed, because this
is taken over by the website, and the cookie is thus stored on the
user's computer system. Another example is the cookie of a
shopping cart in an online shop. The online store remembers the
articles that a customer has placed in the virtual shopping cart via
a cookie.
The data subject may, at any time, prevent the setting of cookies
through our website by means of a corresponding setting of the
Internet browser used, and may thus permanently deny the setting
of cookies. Furthermore, already set cookies may be deleted at
any time via an Internet browser or other software programs. This
is possible in all popular Internet browsers. If the data subject
deactivates the setting of cookies in the Internet browser used,
not all functions of our website may be entirely usable.
5. Collection of general data and information
The website of Alex Freeman collects a series of general data and
information when a data subject or automated system calls up the
website. This general data and information are stored in the server
log files. Collected may be (1) the browser types and versions
used, (2) the operating system used by the accessing system, (3)
the website from which an accessing system reaches our website
(so-called referrers), (4) the sub-websites, (5) the date and time of
access to the Internet site, (6) an Internet protocol address (IP
address), (7) the Internet service provider of the accessing system,
and (8) any other similar data and information that may be used in
the event of attacks on our information technology systems.
When using these general data and information, Alex Freeman does
not draw any conclusions about the data subject. Rather, this
information is needed to (1) deliver the content of our website
correctly, (2) optimize the content of our website as well as its
advertisement, (3) ensure the long-term viability of our
information technology systems and website technology, and (4)
provide law enforcement authorities with the information
necessary for criminal prosecution in case of a cyber-attack.
Therefore, Alex Freeman analyzes anonymously collected data and
information statistically, with the aim of increasing the data
protection and data security of our enterprise, and to ensure an
optimal level of protection for the personal data we process. The
anonymous data of the server log files are stored separately from
all personal data provided by a data subject.
6. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of
the data subject only for the period necessary to achieve the
purpose of storage, or as far as this is granted by the European
legislator or other legislators in laws or regulations to which the
controller is subject to.
If the storage purpose is not applicable, or if a storage period
prescribed by the European legislator or another competent
legislator expires, the personal data are routinely blocked or
erased in accordance with legal requirements.
7. Rights of the data subject
a) Right of confirmation
Each data subject shall have the right granted by the European
legislator to obtain from the controller the confirmation as to
whether or not personal data concerning him or her are being
processed. If a data subject wishes to avail himself of this right of
confirmation, he or she may, at any time, contact any employee of
the controller.
b) Right of access
Each data subject shall have the right granted by the European
legislator to obtain from the controller free information about his
or her personal data stored at any time and a copy of this
information. Furthermore, the European directives and regulations
grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal
data have been or will be disclosed, in particular recipients in
third countries or international organisations;
- where possible, the envisaged period for which the personal
data will be stored, or, if not possible, the criteria used to
determine that period;
- the existence of the right to request from the controller
rectification or erasure of personal data, or restriction of
processing of personal data concerning the data subject, or to
object to such processing;
- the existence of the right to lodge a complaint with a
supervisory authority;
- where the personal data are not collected from the data
subject, any available information as to their source;
- the existence of automated decision-making, including
profiling, referred to in Article 22(1) and (4) of the GDPR and,
at least in those cases, meaningful information about the
logic involved, as well as the significance and envisaged
consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain
information as to whether personal data are transferred to a third
country or to an international organisation. Where this is the case,
the data subject shall have the right to be informed of the
appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he
or she may, at any time, contact any employee of the controller.
c) Right to rectification
Each data subject shall have the right granted by the European
legislator to obtain from the controller without undue delay the
rectification of inaccurate personal data concerning him or her.
Taking into account the purposes of the processing, the data
subject shall have the right to have incomplete personal data
completed, including by means of providing a supplementary
statement.
If a data subject wishes to exercise this right to rectification, he or
she may, at any time, contact any employee of the controller.
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European
legislator to obtain from the controller the erasure of personal
data concerning him or her without undue delay, and the controller
shall have the obligation to erase personal data without undue
delay where one of the following grounds applies, as long as the
processing is not necessary:
- The personal data are no longer necessary in relation to the
purposes for which they were collected or otherwise
processed.
- The data subject withdraws consent to which the processing is
based according to point (a) of Article 6(1) of the GDPR, or
point (a) of Article 9(2) of the GDPR, and where there is no
other legal ground for the processing.
- The data subject objects to the processing pursuant to Article
21(1) of the GDPR and there are no overriding legitimate
grounds for the processing, or the data subject objects to the
processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal
obligation in Union or Member State law to which the
controller is subject.
- The personal data have been collected in relation to the offer
of information society services referred to in Article 8(1) of
the GDPR.
If one of the aforementioned reasons applies, and a data subject
wishes to request the erasure of personal data stored by Alex
Freeman, he or she may, at any time, contact any employee of the
controller. An employee of Alex Freeman shall promptly ensure
that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged
pursuant to Article 17(1) to erase the personal data, the controller,
taking account of available technology and the cost of
implementation, shall take reasonable steps, including technical
measures, to inform other controllers processing the personal data
that the data subject has requested erasure by such controllers of
any links to, or copy or replication of, those personal data, as far
as processing is not required. An employees of Alex Freeman will
arrange the necessary measures in individual cases.
e) Right of restriction of processing
Each data subject shall have the right granted by the European
legislator to obtain from the controller restriction of processing
where one of the following applies:
- The accuracy of the personal data is contested by the data
subject, for a period enabling the controller to verify the accuracy
of the personal data.
- The processing is unlawful and the data subject opposes the
erasure of the personal data and requests instead the restriction of
their use instead.
- The controller no longer needs the personal data for the
purposes of the processing, but they are required by the data
subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to
Article 21(1) of the GDPR pending the verification whether the
legitimate grounds of the controller override those of the data
subject.
If one of the aforementioned conditions is met, and a data subject
wishes to request the restriction of the processing of personal data
stored by Alex Freeman, he or she may at any time contact any
employee of the controller. The employee of Alex Freeman will
arrange the restriction of the processing.
f) Right to data portability
Each data subject shall have the right granted by the European
legislator, to receive the personal data concerning him or her,
which was provided to a controller, in a structured, commonly used
and machine-readable format. He or she shall have the right to
transmit those data to another controller without hindrance from
the controller to which the personal data have been provided, as
long as the processing is based on consent pursuant to point (a) of
Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or
on a contract pursuant to point (b) of Article 6(1) of the GDPR, and
the processing is carried out by automated means, as long as the
processing is not necessary for the performance of a task carried
out in the public interest or in the exercise of official authority
vested in the controller.
Furthermore, in exercising his or her right to data portability
pursuant to Article 20(1) of the GDPR, the data subject shall have
the right to have personal data transmitted directly from one
controller to another, where technically feasible and when doing so
does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject
may at any time contact any employee of Alex Freeman.
g) Right to object
Each data subject shall have the right granted by the European
legislator to object, on grounds relating to his or her particular
situation, at any time, to processing of personal data concerning
him or her, which is based on point (e) or (f) of Article 6(1) of the
GDPR. This also applies to profiling based on these provisions.
Alex Freeman shall no longer process the personal data in the
event of the objection, unless we can demonstrate compelling
legitimate grounds for the processing which override the interests,
rights and freedoms of the data subject, or for the establishment,
exercise or defence of legal claims.
If Alex Freeman processes personal data for direct marketing
purposes, the data subject shall have the right to object at any
time to processing of personal data concerning him or her for such
marketing. This applies to profiling to the extent that it is related
to such direct marketing. If the data subject objects to Alex
Freeman to the processing for direct marketing purposes, Alex
Freeman will no longer process the personal data for these
purposes.
In addition, the data subject has the right, on grounds relating to
his or her particular situation, to object to processing of personal
data concerning him or her by Alex Freeman for scientific or
historical research purposes, or for statistical purposes pursuant to
Article 89(1) of the GDPR, unless the processing is necessary for
the performance of a task carried out for reasons of public
interest.
In order to exercise the right to object, the data subject may
contact any employee of Alex Freeman. In addition, the data
subject is free in the context of the use of information society
services, and notwithstanding Directive 2002/58/EC, to use his or
her right to object by automated means using technical
specifications.
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European
legislator not to be subject to a decision based solely on
automated processing, including profiling, which produces legal
effects concerning him or her, or similarly significantly affects him
or her, as long as the decision (1) is not is necessary for entering
into, or the performance of, a contract between the data subject
and a data controller, or (2) is not authorised by Union or Member
State law to which the controller is subject and which also lays
down suitable measures to safeguard the data subject's rights and
freedoms and legitimate interests, or (3) is not based on the data
subject's explicit consent.
If the decision (1) is necessary for entering into, or the
performance of, a contract between the data subject and a data
controller, or (2) it is based on the data subject's explicit consent,
Alex Freeman shall implement suitable measures to safeguard the
data subject's rights and freedoms and legitimate interests, at
least the right to obtain human intervention on the part of the
controller, to express his or her point of view and contest the
decision.
If the data subject wishes to exercise the rights concerning
automated individual decision-making, he or she may, at any time,
contact any employee of Alex Freeman.
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European
legislator to withdraw his or her consent to processing of his or her
personal data at any time.
If the data subject wishes to exercise the right to withdraw the
consent, he or she may, at any time, contact any employee of Alex
Freeman.
8. Data protection provisions about the application and use of
Google Analytics (with anonymization function)
On this website, the controller has integrated the component of
Google Analytics (with the anonymizer function). Google Analytics
is a web analytics service. Web analytics is the collection,
gathering, and analysis of data about the behavior of visitors to
websites. A web analysis service collects, inter alia, data about the
website from which a person has come (the so-called referrer),
which sub-pages were visited, or how often and for what duration
a sub-page was viewed. Web analytics are mainly used for the
optimization of a website and in order to carry out a cost-benefit
analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc.,
1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United
States.
For the web analytics through Google Analytics the controller uses
the application "_gat. _anonymizeIp". By means of this application
the IP address of the Internet connection of the data subject is
abridged by Google and anonymised when accessing our websites
from a Member State of the European Union or another Contracting
State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the
traffic on our website. Google uses the collected data and
information, inter alia, to evaluate the use of our website and to
provide online reports, which show the activities on our websites,
and to provide other services concerning the use of our Internet
site for us.
Google Analytics places a cookie on the information technology
system of the data subject. The definition of cookies is explained
above. With the setting of the cookie, Google is enabled to analyze
the use of our website. With each call-up to one of the individual
pages of this Internet site, which is operated by the controller and
into which a Google Analytics component was integrated, the
Internet browser on the information technology system of the data
subject will automatically submit data through the Google
Analytics component for the purpose of online advertising and the
settlement of commissions to Google. During the course of this
technical procedure, the enterprise Google gains knowledge of
personal information, such as the IP address of the data subject,
which serves Google, inter alia, to understand the origin of visitors
and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the
access time, the location from which the access was made, and
the frequency of visits of our website by the data subject. With
each visit to our Internet site, such personal data, including the IP
address of the Internet access used by the data subject, will be
transmitted to Google in the United States of America. These
personal data are stored by Google in the United States of
America. Google may pass these personal data collected through
the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of
cookies through our website at any time by means of a
corresponding adjustment of the web browser used and thus
permanently deny the setting of cookies. Such an adjustment to
the Internet browser used would also prevent Google Analytics
from setting a cookie on the information technology system of the
data subject. In addition, cookies already in use by Google
Analytics may be deleted at any time via a web browser or other
software programs.
In addition, the data subject has the possibility of objecting to a
collection of data that are generated by Google Analytics, which is
related to the use of this website, as well as the processing of this
data by Google and the chance to preclude any such. For this
purpose, the data subject must download a browser add-on under
the link https://tools.google.com/dlpage/gaoptout and install it.
This browser add-on tells Google Analytics through a JavaScript,
that any data and information about the visits of Internet pages
may not be transmitted to Google Analytics. The installation of the
browser add-ons is considered an objection by Google. If the
information technology system of the data subject is later deleted,
formatted, or newly installed, then the data subject must reinstall
the browser add-ons to disable Google Analytics. If the browser
add-on was uninstalled by the data subject or any other person
who is attributable to their sphere of competence, or is disabled,
it is possible to execute the reinstallation or reactivation of the
browser add-ons.
Further information and the applicable data protection provisions
of Google may be retrieved under
https://www.google.com/intl/en/policies/privacy/ and under
http://www.google.com/analytics/terms/us.html. Google
Analytics is further explained under the following Link
https://www.google.com/analytics/.
9. Data protection provisions about the application and use of
YouTube
On this website, the controller has integrated components of
YouTube. YouTube is an Internet video portal that enables video
publishers to set video clips and other users free of charge, which
also provides free viewing, review and commenting on them.
YouTube allows you to publish all kinds of videos, so you can access
both full movies and TV broadcasts, as well as music videos,
trailers, and videos made by users via the Internet portal.
The operating company of YouTube is YouTube, LLC, 901 Cherry
Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a
subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View,
CA 94043-1351, UNITED STATES.
With each call-up to one of the individual pages of this Internet
site, which is operated by the controller and on which a YouTube
component (YouTube video) was integrated, the Internet browser
on the information technology system of the data subject is
automatically prompted to download a display of the
corresponding YouTube component. Further information about
YouTube may be obtained under
https://www.youtube.com/yt/about/en/. During the course of
this technical procedure, YouTube and Google gain knowledge of
what specific sub-page of our website was visited by the data
subject.
If the data subject is logged in on YouTube, YouTube recognizes
with each call-up to a sub-page that contains a YouTube video,
which specific sub-page of our Internet site was visited by the data
subject. This information is collected by YouTube and Google and
assigned to the respective YouTube account of the data subject.
YouTube and Google will receive information through the YouTube
component that the data subject has visited our website, if the
data subject at the time of the call to our website is logged in on
YouTube; this occurs regardless of whether the person clicks on a
YouTube video or not. If such a transmission of this information to
YouTube and Google is not desirable for the data subject, the
delivery may be prevented if the data subject logs off from their
own YouTube account before a call-up to our website is made.
YouTube's data protection provisions, available at
https://www.google.com/intl/en/policies/privacy/, provide
information about the collection, processing and use of personal
data by YouTube and Google.
10. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing
operations for which we obtain consent for a specific processing
purpose. If the processing of personal data is necessary for the
performance of a contract to which the data subject is party, as is
the case, for example, when processing operations are necessary
for the supply of goods or to provide any other service, the
processing is based on Article 6(1) lit. b GDPR. The same applies to
such processing operations which are necessary for carrying out
pre-contractual measures, for example in the case of inquiries
concerning our products or services. Is our company subject to a
legal obligation by which processing of personal data is required,
such as for the fulfillment of tax obligations, the processing is
based on Art. 6(1) lit. c GDPR. In rare cases, the processing of
personal data may be necessary to protect the vital interests of
the data subject or of another natural person. This would be the
case, for example, if a visitor were injured in our company and his
name, age, health insurance data or other vital information would
have to be passed on to a doctor, hospital or other third party.
Then the processing would be based on Art. 6(1) lit. d GDPR.
Finally, processing operations could be based on Article 6(1) lit. f
GDPR. This legal basis is used for processing operations which are
not covered by any of the abovementioned legal grounds, if
processing is necessary for the purposes of the legitimate interests
pursued by our company or by a third party, except where such
interests are overridden by the interests or fundamental rights and
freedoms of the data subject which require protection of personal
data. Such processing operations are particularly permissible
because they have been specifically mentioned by the European
legislator. He considered that a legitimate interest could be
assumed if the data subject is a client of the controller (Recital 47
Sentence 2 GDPR).
11. The legitimate interests pursued by the controller or by a
third party
Where the processing of personal data is based on Article 6(1) lit. f
GDPR our legitimate interest is to carry out our business in favor of
the well-being of all our employees and the shareholders.
12. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal
data is the respective statutory retention period. After expiration
of that period, the corresponding data is routinely deleted, as long
as it is no longer necessary for the fulfillment of the contract or
the initiation of a contract.
13. Provision of personal data as statutory or contractual
requirement; Requirement necessary to enter into a contract;
Obligation of the data subject to provide the personal data;
possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by
law (e.g. tax regulations) or can also result from contractual
provisions (e.g. information on the contractual partner).
Sometimes it may be necessary to conclude a contract that the
data subject provides us with personal data, which must
subsequently be processed by us. The data subject is, for example,
obliged to provide us with personal data when our company signs a
contract with him or her. The non-provision of the personal data
would have the consequence that the contract with the data
subject could not be concluded. Before personal data is provided
by the data subject, the data subject must contact any employee.
The employee clarifies to the data subject whether the provision
of the personal data is required by law or contract or is necessary
for the conclusion of the contract, whether there is an obligation
to provide the personal data and the consequences of non-
provision of the personal data.
14. Existence of automated decision-making
As a responsible company, we do not use automatic decision-
making or profiling.
This Privacy Policy has been generated by the Privacy Policy
Generator of the External Data Protection Officers that was
developed in cooperation with the Media Law Lawyers from WBS-
LAW.