Privacy Policy

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Privacy policy

Data protection is of great importance to us. Generally speaking, you can use our website without providing personal data. If a data subject wishes to use special services of our company through our website, however, it might be necessary to process personal data. If the processing of personal data is necessary and there are no legal grounds on which to process such data, we will seek the consent of the data subject.

Personal data such as the name, address, email address or phone number of a data subject are always processed in accordance with the European General Data Protection Regulation (GDPR) and the national data protection regulations that apply to us. This privacy policy provides users and the general public with information about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, this privacy policy informs data subjects of their rights.

As the controller, we have implemented numerous technical and organisational measures in order to ensure that the personal data processed through this website are protected as comprehensively as possible. Nevertheless, data transfers over the Internet might still have security problems, which means that absolute protection cannot be guaranteed. For this reason, every data subject is free to provide us with personal data in other ways, for instance by phone.

  1. Definitions
  2. Name and address of the controller
  3. Contact for data subjects
  4. Cookies
  5. Collection of general data and information
  6. Contact through the website
  7. Routine erasure and blocking of personal data
  8. Rights of the data subject
  9. Privacy policy regarding the use of Google Analytics (with anonymisation active)
  10. YouTube privacy policy
  11. Legal grounds for processing
  12. BLegitimate interests in processing pursued by the controller or a third party
  13. Duration for which personal data may be stored
  14. Legal or contractual regulations
  15. Existence of automated decision-making
  1. Definitions

This privacy policy is based on the terminology used by European directive and ordinance committees in the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understandable for the public as well as our customers and business partners. In order to ensure this, we would like to take this opportunity to provide definitions for the terminology used herein. We use the following terms in this privacy policy:

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

The data subject is an identified or identifiable natural person whose personal data are processed by the controller.

c) Processing

Processing means 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’ means 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’ means 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

‘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. 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’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

‘Recipient’ means 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 are not regarded as recipients.

j) Third party

‘Third party’ means 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 means 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.

  1. Name and address of the controller

The controller in the sense of the GDPR, other data protection acts in the Member States of the EU and other data protection regulations is:

Sanvitra GmbH

Kleiststr. 1

71229 Leonberg

Germany

Phone: +49 (0) 7152 61 315 38

E-Mail: info@sanvitra.com

Website: www.sanvitra.com

  1. Contact for data subjects

If he/she has any questions or suggestions concerning data protection, the data subject can contact our office at any time under datenschutz@sanvitra.com

  1. Cookies

Our website uses cookies. Cookies are text files which are stored on a computer system by an Internet browser.

Numerous websites and servers use cookies. Many cookies have a cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a sequence of characters which allow websites and servers to be associated with the specific browser in which the cookie was stored. This makes it possible for the visited websites and servers to differentiate between the individual browser of the data subject and other browsers that contain cookies. A certain browser can be recognised and identified by its unique cookie ID.

Using cookies, we can provide visitors to this website with more user-friendly services that would not be possible without a cookie.

With a cookie, the information, products and services on our website can be optimised based on the interests of the user. Cookies enable us to recognise each user of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to enter his or her login data every time he or she visits the website because the details are stored by the website and the cookie on the user’s computer. Another example is the cookie for a basket in an online shop. Using a cookie, the online shop takes note of the items that a customer places in his or her virtual basket.

The data subject can prevent our website from using cookies by changing the settings of his or her browser and in doing so, deactivate cookies permanently. Furthermore, cookies that are already on the computer can be erased at any time through a browser or other software. This feature is provided by all standard Internet browsers. If the user deactivates cookies in his or her browser, the user might not be able to use all of the features of our website to their full extent.

  1. Collection of general data and information

Whenever visited by a data subject or automated system, our websites (www.sanvitra.com and www.epbmc.eu) collects a series of general data and information. These general data and information are stored in the log files of the server. The following can be collected: (1) browser type and version, (2) operating system, (3) the referrer URL (the website visited previously to ours), (4) the pages through which a system is directed to our website, (5) the date and time of a visit to our website, (6) an IP address, (7) the ISP of the system and (8) other similar data and information that will be used to defend against attacks on our IT systems.

When we use these general data and information, we draw no conclusions regarding the data subject. Rather, this information is required in order to (1) deliver the content of our website correctly, (2) optimise the content of our website as well as advertisements for it, (3) ensure the ongoing functionality of our IT systems and website technology, and (4) provide law enforcement agencies with the information necessary for prosecution in the event of a cyberattack. Therefore, we evaluate these anonymous data and information for statistical purposes and in order to improve data protection and data security in our company, ultimately with a view to ensuring an optimal level of protection for the personal data we process. The anonymous data in the server log files are stored separately from all personal data provided by a data subject.

  1. Contact through the website

In accordance with the statutory regulations, our website contains information (including an email address) that enables you to contact our company electronically and communicate with us directly. If a data subject contacts the controller by email or through a contact form, the personal data transmitted by the data subject are stored automatically. Personal data that have been provided to the controller voluntarily by a data subject are used for the purposes of processing enquiries or contacting the data subject. These personal data are not shared with third parties.

  1. Routine erasure and blocking of personal data

The controller only processes and stores personal data relating to the data subject for the period that is necessary in order to fulfil the purpose for which the data are being stored or for the period prescribed by the European Commission or other legislators in laws or regulations to which the controller is subject.

When the purpose for which the data are being stored no longer applies or if a storage period prescribed by the European Commission or another legislator expires, the personal data will be blocked or erased routinely and in line with the statutory regulations.

  1. Rights of the data subject

a) Right to confirmation

The European Commission grants the data subject the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to exercise this right to confirmation, he or she can contact an employee of the controller at any time.

b) Right of access

The European Commission grants the data subject the right to obtain from the controller, at any time, free information about the personal data concerning him or her that it has stored, and to receive a copy of the information. Furthermore, the European Commission grants the data subject the right to access the following information:

– the purposes of the processing;

– the categories of personal data concerned;

– the recipients or categories of recipient 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 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 individual decision-making, including profiling, in the sense of Article 22, paragraphs 1 and 4, of the GDPR and – at least in these cases – meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Furthermore, the data subject has the right to be informed if personal data have been transferred to a third country or to an international organisation. Where this is the case, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, he or she can contact an employee of the controller at any time.

c) Right to rectification

The European Commission grants the data subject the right 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 has 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 can contact an employee of the controller at any time.

d) Right to erasure

The European Commission grants the data subject the right 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 and where the processing of the data 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 on which the processing is based according to point (a) of Article 6, paragraph 1, of the GDPR, or point (a) of Article 9, paragraph 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, paragraph 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, paragraph 2, of the GDPR;

– the personal data have been unlawfully processed;

– the personal data have to 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, paragraph 1, of the GDPR.

If any of the criteria above are met and the data subject wishes to have us erase the personal data that we are storing, the data subject can contact an employee of the controller at any time. The employee will ensure that the request for erasure is fulfilled without undue delay.

Where we have made the personal data public and are, as the controller, obliged pursuant to Article 17, paragraph 1, of the GDPR to erase the personal data, we, 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 the data subject has requested the erasure by such controllers of any links to, or copies or replications of, those personal data. On an individual basis, our employee will initiate the necessary measures.

e) Right to restriction of processing

The European Commission grants the data subject the right 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 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, paragraph 1, of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If any of the criteria above are met and the data subject wishes to request the restriction of personal data that we are storing, the data subject can contact an employee of the controller at any time. Our employee will have the processing of the data restricted.

f) Right to data portability

The European Commission grants the data subject the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format The data subject also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to point (a) of Article 6, paragraph 1, of the GDPR or point (a) of Article 9, paragraph 2, of the GDPR or on a contract pursuant to point (b) of Article 6, paragraph 1, of the GDPR, and the processing is carried out by automated means; this right does not apply to 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.

Furthermore, in exercising his or her right to data portability pursuant to Article 20, paragraph 1, of the GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible, provided that this does not adversely affect the rights and freedoms of others.

The data subject can contact one of our employees at any time in order to exercise this right to data portability.

g) Right to object

The European Commission grants the data subject the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6, paragraph 1, of the GDPR, including profiling based on those provisions.

We shall no longer process the personal data unless we 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.

Where personal data are processed for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89, paragraph 1, of the GDPR, the data subject, on grounds relating to his or her particular situation, has the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

The data subject can contact one of our employees at any time in order to exercise this right to object. In the context of the use of information society services, and Directive 2002/58/EC notwithstanding, the data subject may also exercise his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

The European Commission grants the data subject the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision (1) is necessary for entering into, or performance of, a contract between the data subject and a data controller, or (2) is 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 based on the data subject’s explicit consent.

If the decision is (1) necessary for entering into, or performance of, a contract between the data subject and the data controller, or (2) based on the data subject’s explicit consent, we shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If a data subject wishes to exercise rights in connection with automated decision-making, he or she can contact an employee of the controller at any time.

i) Right to withdraw consent

The European Commission grants the data subject the right to withdraw consent to the processing of personal data at any time.

If a data subject wishes to exercise his or her right to withdraw consent, he or she can contact an employee of the controller at any time.

  1. Privacy policy regarding the use of Google Analytics (with anonymisation active)

The controller has integrated the component Google Analytics (with anonymisation active) into this website. Google Analytics is a web analytics service. Web analytics is the collection and evaluation of data relating to the usage habits of website users. For example, a web analytics service collects data relating to the website the data subject was visiting prior to the current website (the referrer), what pages of the website are accessed or how often or for how long a page is viewed. A web analytics service is primarily used to optimise a website and to analyse the cost-effectiveness of Internet advertising.

Google Analytics is operated by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The controller uses the tag ‘_gat._anonymizeIp’ in Google Analytics. When this tag is active, the IP address of the data subject is shortened and anonymised by Google if our website is accessed from a Member State of the EU or from another signatory to the Agreement on the European Economic Area.

The purpose of Google Analytics is to analyse visits to our website. For example, Google uses the data and information it obtains in this way to evaluate the use of our website, compile online reports on website activity and provide us with other services in connection with the use of our website.

Google Analytics installs a cookie on the computer of the data subject. Cookies are defined above. The installation of the cookie enables Google to analyse how our website is used. Whenever the data subject visits one of the pages of the website of the controller on which Google Analytics is active, Google Analytics has the browser on the IT system of the data subject automatically transmit data to Google for online analysis. Through this technical process, Google gains access to personal data such as the IP address of the data subject which enable Google to track the origins of visitors and clicks and then calculate commission.

The cookie stores personal information such as the date and time of the visit, the location from which the website is being visited and the frequency of visits to our website by the data subject. Whenever the data subject visits our website, these personal data, including the IP address of the data subject, are transmitted to Google in the USA. Google stores these personal data in the USA. Under certain circumstances, Google shares these personal data with third parties.

The data subject can prevent our website from using cookies as described above by changing the settings of his or her browser and in doing so, deactivate cookies permanently. Changing browser settings in this way would also prevent Google from installing a cookie on the IT system of the data subject. Additionally, cookies that have already been installed by Google Analytics can be erased at any time through the browser or using other software.

Furthermore, the data subject can object to and prevent the collection and processing of the data generated by Google Analytics relating to the use of this website. To do so, the data subject must download and install a browser add-on from https://tools.google.com/dlpage/gaoptout. Through JavaScript, this browser add-on notifies Google that no data or information relating to the visitors of website may be transmitted to Google Analytics. Google views the installation of the browser add-on as an objection. If, at a later date, the IT system of the data subject is erased, formatted or reinstalled, the data subject must re-install the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person in the sphere of control of the data subject, the browser add-on can be reinstalled or reactivated.

For more information as well as the privacy policy of Google, see https://www.google.de/intl/us/policies/privacy/ and http://www.google.com/analytics/terms/us.html. For more details about Google Analytics, see https://www.google.com/intl/us/analytics/.

  1. YouTube privacy policy

The controller has integrated components of YouTube into this website. YouTube is an Internet-based video portal which allows video publishers to upload video clips free of charge and other users to watch, rate and comment on videos free of charge. YouTube permits the publication of all types of videos, which is why even entire films and TV programmes as well as music videos, trailers and videos made by users themselves are accessible on YouTube.

YouTube is operated by YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Whenever the data subject visits one of the pages of the website of the controller on which a YouTube component (a YouTube video) is active, the YouTube component has the browser on the IT system of the data subject automatically download the YouTube component from YouTube. For more information about YouTube, see https://www.youtube.com/yt/about/. As part of this technical process, YouTube and Google obtain information on what specific page of our website the data subject is visiting.

If the data subject is logged into YouTube at the same time as he or she visits a page containing a YouTube video, YouTube knows what specific page of our website the data subject is visiting. YouTube and Google collect this information and attribute it to the YouTube account of the data subject.

Even if the data subject is not logged into YouTube when he or she visits our website, YouTube and Google still obtain information from the YouTube component that the data subject has visited our website, regardless of whether or not the data subject clicks on a YouTube video. If the data subject does not want this information to be transmitted to YouTube and Google, the data subject can prevent it by logging out of YouTube before visiting our website.

The privacy policy of YouTube at https://www.google.de/intl/us/policies/privacy/ provides details about the collection, processing and use of personal data by YouTube and Google.

  1. Legal grounds for processing

Point (a) of Article 6, paragraph 1, of the GDPR serves as the legal grounds if we obtain your consent to process your data for a specific purpose. Point (b) of Article 6, paragraph 1, of the GDPR serves as the legal grounds if the processing of personal data is necessary in order to perform a contract to which the data subject is party, as is the case with the processing necessary for the delivery of goods or the performance of another service or consideration. The same applies to processing that is necessary to take steps prior to entering into a contract, e.g. queries regarding our products or services. Point (c) of Article 6, paragraph 1, of the GDPR serves as the legal grounds if the processing of personal data is necessary in order for our company to comply with a legal obligation, e.g. the fulfilment of duties under tax law. In rare cases, it might be necessary to process personal data in order to protect the vital interests of the data subject or the vital interests of another natural person. This would be the case, for example, if a visitor to our company were injured and his or her name, age, health insurance data or other vital information had to be disclosed to a doctor, hospital or other third party. The processing would then be based on point (d) of Article 6, paragraph 1, of the GDPR. Finally, processing might be based on point (f) of Article 6, paragraph 1, of the GDPR. Point (f) of Article 6, paragraph 1, of the GDPR serves as legal grounds where 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. Therefore, such processing is admissible because it has been mentioned by European legislators. In this context, the European Commission is of the opinion that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, line 2, of the GDPR).

  1. Legitimate interests in processing pursued by the controller or a third party

If personal data are being processed on the basis of point (f) of Article 6, paragraph 1, of the GDPR, our legitimate interest is the performance of our business activities for the well-being of all of our employees and shareholders. According to §6 Paragraph 1 Letter F of the GDPR, the Sanvitra GmbH reserves the right to forward lead- and costumer contact data for consulting to the C.T.L. M.A.T. LLC. located in Cleveland, Ohio for consulting purposes only.

  1. Duration for which personal data may be stored

The relevant statutory storage period determines the period of time for which personal data may be stored. Upon expiry of this deadline, the data in question are routinely erased unless they are necessary for the performance or initiation of a contract.

  1. Legal or contractual regulations on the provision of personal data; necessity for the conclusion of a contract; obligation of the data subject to provide personal data; potential consequences of refusal to provide personal data

Please be aware that the provision of personal data is legally mandatory to a certain extent (e.g. tax regulations) or might be required by contractual provisions (e.g. information about a contractual partner). Occasionally, for the purposes of concluding a contract, it might be necessary for a data subject to provide us with personal data that we will then have to process. For example, the data subject is obliged to provide us with personal data if our company enters into a contract with him or her. A refusal to provide personal data will make it impossible to conclude the contract with the data subject. Before the data subject provides personal data, he or she must contact one of our employees. Our employee will then notify the data subject of whether the provision of personal data is legally or contractually mandatory, whether it is necessary for the conclusion of a contract, whether the data subject is obliged to provide the personal data and what consequences a refusal to provide personal data would have.

  1. Existence of automated decision-making

As a conscientious company, we do not use automated decision-making or profiling.