Privacy Policy

We are very pleased about your interest in our company. Data protection has a particularly high priority for the management of CSF Consulting & Service Freiburg GmbH. The use of the Internet pages of CSF Consulting & Service Freiburg GmbH is generally possible without any indication of personal data. However, if a data subject wants to use special services of our company via our website, the processing of personal data may become necessary. If the processing of personal data is required and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to CSF Consulting & Service Freiburg GmbH. Through this privacy policy, our company wishes to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, this privacy policy informs data subjects of the rights to which they are entitled.

CSF Consulting & Service Freiburg GmbH, as the controller responsible for processing, has implemented numerous technical and organizational measures to ensure the most complete protection possible of personal data processed through this website. Nevertheless, internet-based data transmissions may have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example, by telephone.

Cookie Settings

1. Definitions

The privacy policy of CSF Consulting & Service Freiburg GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

We use the following terms in this privacy policy:
a) Personal data
All information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, by reference to identifiers such as name, identification number, location data, online identifier, or characteristics reflecting identity.
b) Data subject
Any identified or identifiable natural person whose personal data are processed.
c) Processing
Any operation performed on personal data—automated or not—such as collection, storage, alteration, retrieval, use, disclosure, deletion, etc.
d) Restriction of processing
The marking of stored personal data with the aim of limiting future processing.
e) Profiling
Any automated processing used to evaluate or predict aspects concerning a person’s performance, economic situation, health, preferences, behavior, or location.
 f) Pseudonymization
Processing personal data so they cannot be attributed to a specific individual without additional information, stored separately.
 g) Controller
A person or entity that determines the purposes and means of processing personal data.
 h) Processor
A person or entity that processes personal data on behalf of the controller.
i) Recipient
A person or body to whom personal data are disclosed, whether or not a third party.
 j) Third party
Anyone other than the data subject, controller, processor, or authorized persons.
k) Consent
Freely given, specific, informed, and unambiguous indication by which the data subject agrees to the processing.

2. Name and Address of the Controller

Controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the member states of the European Union, and other regulations of a data protection nature is:

CSF Consulting & Service Freiburg GmbH
Tullastraße 89
79108 Freiburg im Breisgau
Germany
Tel.: +49 (0) 761 4898 7534
E-Mail: info@cpf-injoy.com
Website: www.cpf-injoy.com

3. Cookies

Cookies are used to provide more user-friendly services. They allow recognition of browser sessions and storage of items such as login data and cart content. Cookies can be disabled at any time in browser settings, though this may limit site functionality.

Numerous websites and servers use cookies. Many cookies contain what is known as a cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This enables the visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain different cookies. A particular internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, CSF Consulting & Service Freiburg GmbH can provide users of this website with more user-friendly services that would not be possible without the cookie placement.

By means of a cookie, the information and offers on our website can be optimized in the interests of the user. As already mentioned, cookies allow us to recognize the users of our website. The purpose of this recognition is to make it easier for users to utilize our website. For example, the user of a website that uses cookies does not have to enter their access data again each time they visit the website, because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online store. The online store remembers the items that a customer has placed in the virtual shopping cart via a cookie.

The data subject can prevent the setting of cookies by our website at any time by means of an appropriate setting in the internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.

4. Collection of General Data

Upon accessing the site, general data such as browser type, OS, referrer, subpages, access time, IP address, and ISP are collected for system security and optimization. These are not linked to any individual and are used to ensure functionality and prevent cyberattacks.

5. Contact Option via Website

The website of CSF Consulting & Service Freiburg GmbH contains, due to legal requirements, information that enables quick electronic contact with our company, as well as direct communication with us, which also includes a general address for what is known as electronic mail (email address). If a data subject contacts the controller via email or through a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller is stored for the purpose of processing or contacting the data subject. There is no disclosure of this personal data to third parties.

6. Routine Deletion and Blocking of Personal Data

The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage or as stipulated by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or deleted in accordance with the legal regulations.

7. Rights of the Data Subject

a) Right to Confirmation
Every data subject has the right, granted by the European legislator, to obtain from the controller confirmation as to whether or not personal data concerning them is being processed. If a data subject wishes to exercise this right of confirmation, they may contact any employee of the controller at any time.

b) Right of Access
Every data subject has the right, granted by the European legislator, to obtain at any time, free of charge, information from the controller about their stored personal data and a copy of this information. Furthermore, the European legislator grants the data subject access to the following information:

• The purposes of the processing

• The categories of personal data being processed

• 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 organizations

• If possible, the intended duration of the storage of the personal data, or, if not possible, the criteria used to determine that duration

• The existence of the right to rectification or erasure of personal data or restriction of processing by the controller, or the right 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 about their source

• The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) 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

The data subject also has the right to be informed whether personal data are transferred to a third country or an international organization. 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 exercise this right of access, they may contact any employee of the controller at any time.

c) Right to Rectification
Every data subject has the right, granted by the European legislator, to obtain without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject also 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, they may contact any employee of the controller at any time.

d) Right to Erasure (Right to be Forgotten)
Every data subject has the right, granted by the European legislator, to obtain from the controller the erasure of personal data concerning them without undue delay where one of the following grounds applies, and 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 on which the processing is based according to Art. 6(1)(a) or Art. 9(2)(a) GDPR, and there is no other legal ground for the processing.

• The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects pursuant to Art. 21(2) GDPR.

• The personal data have been unlawfully processed.

• The personal data must be erased for compliance with a legal obligation under 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 Art. 8(1) GDPR.

If one of the above grounds applies and a data subject wishes to request the erasure of personal data stored by CSF Consulting & Service Freiburg GmbH, they may contact any employee of the controller at any time. That employee will ensure that the erasure request is complied with immediately.

Where CSF Consulting & Service Freiburg GmbH has made personal data public and is obliged under Art. 17(1) GDPR to erase the personal data, it shall take reasonable steps, including technical measures, taking into account available technology and the cost of implementation, to inform other controllers processing the published personal data that the data subject has requested the erasure of any links to, or copies or replications of, those personal data, insofar as processing is not required. The employee will arrange the necessary measures on a case-by-case basis.

e) Right to Restriction of Processing
Every data subject has 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 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 defense of legal claims.

• The data subject has objected to processing pursuant to Art. 21(1) GDPR, pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by CSF Consulting & Service Freiburg GmbH, they may contact any employee of the controller at any time. That employee will arrange the restriction of processing.

f) Right to Data Portability
Every data subject has the right, granted by the European legislator, to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format. They also have 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 under Art. 6(1)(a) or Art. 9(2)(a) GDPR or on a contract under Art. 6(1)(b) GDPR and the processing is carried out by automated means, unless processing is 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 their right to data portability under Art. 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may contact any employee of CSF Consulting & Service Freiburg GmbH at any time.

g) Right to Object
Every data subject has the right, granted by the European legislator, to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on those provisions.

CSF Consulting & Service Freiburg GmbH 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 the processing is for the establishment, exercise, or defense of legal claims.

Where CSF Consulting & Service Freiburg GmbH 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 them for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to processing by CSF Consulting & Service Freiburg GmbH for direct marketing purposes, the personal data will no longer be processed for these purposes.

In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them which is carried out by CSF Consulting & Service Freiburg GmbH for scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may contact any employee of CSF Consulting & Service Freiburg GmbH directly or another employee. The data subject is also free, in the context of the use of information society services — notwithstanding Directive 2002/58/EC — to exercise their right to object by automated means using technical specifications.

h) Automated Individual Decision-Making, Including Profiling
Every data subject has 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 them or similarly significantly affects them, unless the decision (1) is necessary for entering into or the performance of a contract between the data subject and a controller, or (2) is authorized 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, freedoms, and legitimate interests, or (3) is based on the data subject’s explicit consent. If the decision (1) is necessary for the performance of a contract or (2) is based on the data subject’s explicit consent, CSF Consulting & Service Freiburg GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision. If the data subject wishes to exercise rights concerning automated decisions, they may contact an employee of the controller at any time.

i) Right to Withdraw Consent under Data Protection Law
Every data subject has the right, granted by the European legislator, to withdraw consent to the processing of personal data at any time. If the data subject wishes to exercise their right to withdraw consent, they may contact an employee of the controller at any time.

8. Use of Google Analytics (with Anonymization Function)

The controller has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analysis service. Web analysis involves the collection, gathering, and evaluation of data about the behavior of visitors to websites. A web analysis service collects, among other things, data about which website a data subject came from (the so-called referrer), which subpages were accessed, how often, and for what duration a subpage was viewed. Web analysis is mainly used to optimize a website and to perform a cost-benefit analysis of internet advertising.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA.

The controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. By means of this addition, the IP address of the internet connection of the data subject is shortened and anonymized by Google when access to our websites is made from a Member State of the European Union or another contracting state of the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze the flow of visitors to our website. Google uses the data and information obtained to evaluate the use of our website, to compile online reports showing website activity for us, and to provide other services related to the use of our website.

Google Analytics places a cookie on the data subject’s IT system. What cookies are has already been explained above. With the placement of the cookie, Google is enabled to analyze the use of our website. With each visit to one of the individual pages of this website operated by the controller and into which a Google Analytics component has been integrated, the internet browser on the data subject’s IT system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. Through this technical process, Google obtains knowledge of personal data, such as the IP address of the data subject, which serves, among other things, to trace the origin of visitors and clicks and subsequently to enable commission settlements.

By means of the cookie, personal information such as access time, the location from which access was made, and the frequency of visits to our website by the data subject is stored. With each visit to our website, this personal data—including the IP address of the internet connection used by the data subject—is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data collected via the technical process with third parties.

The data subject can prevent the setting of cookies through our website at any time, as already described above, by adjusting the settings of their internet browser and thereby permanently object to the setting of cookies. Such a setting would also prevent Google from placing a cookie on the data subject’s IT system. Additionally, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option to object to and prevent the collection of data generated by Google Analytics related to the use of this website as well as the processing of this data by Google. To do this, the data subject must download and install a browser add-on via the link: https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data or information about website visits may be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the data subject’s IT system is later deleted, formatted, or reinstalled, the data subject must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their sphere of control, it is possible to reinstall or reactivate the browser add-on.

Further information and the applicable privacy policy of Google can be found at:

• https://www.google.de/intl/de/policies/privacy/

• http://www.google.com/analytics/terms/de.html
  More detailed information on Google Analytics can be found at: https://www.google.com/intl/de_de/analytics/.

9. Legal Basis for Processing

Article 6(1)(a) of the GDPR serves as the legal basis for our company for processing operations where 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 a party—as is the case, for example, with processing operations required for the delivery of goods or the provision of another service or consideration—then the processing is based on Article 6(1)(b) GDPR. The same applies to processing operations that are necessary for carrying out pre-contractual measures, such as inquiries regarding our products or services. If our company is subject to a legal obligation that requires the processing of personal data—such as compliance with tax obligations—the processing is based on Article 6(1)(c) GDPR. In rare cases, processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and, as a result, their name, age, health insurance data, or other vital information had to be passed on to a doctor, hospital, or other third party. In such a case, processing would be based on Article 6(1)(d) GDPR. Finally, processing operations could be based on Article 6(1)(f) GDPR. This legal basis applies to processing operations that are not covered by any of the aforementioned legal grounds, if the processing is necessary for the purposes of the legitimate interests pursued by our company or a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject. Such processing operations are particularly permitted because they have been specifically mentioned by the European legislator. The legislator considered that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, Sentence 2 GDPR).

10. Legitimate Interests Pursued by the Controller

Our legitimate interest lies in conducting our business for the well-being of all employees and shareholders.

11. Storage Duration

Data are stored as long as legally required. Once the retention period ends, data are routinely deleted unless needed for contract purposes.

12. Legal/Contractual Requirements for Data Provision

Sometimes, data provision is required by law (e.g. tax) or contract. Failure to provide data may result in the inability to conclude a contract. A staff member can clarify such requirements on a case-by-case basis.

13. Existence of Automated Decision-Making

As a responsible company, we do not use automatic decision-making or profiling.