Privacy policy
1. Data protection at a glance
General information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data means all data that can be used to personally identify you. Detailed information on data protection can be found in the privacy policy set out below.
Data collection on this website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. Their contact details can be found in the section “Information about the Data Controller” in this privacy policy.
How data is collected?
On the one hand, your data is collected by you providing it to us. This may, for example, be data that you enter into a contact form.
Other data is collected automatically or after your consent when you visit the website by our IT systems. This is mainly technical data (e.g. internet browser, operating system or time of the page view). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Part of the data is collected in order to ensure the error‑free provision of the website. Other data may be used to analyse your user behaviour. Where contracts can be concluded or initiated via the website, the data transmitted will also be processed for contract offers, orders or other enquiries relating to assignments.
What rights do you have regarding your data?
You have the right at any time to obtain information free of charge about the origin, recipients and purpose of your stored personal data. You also have the right to request the rectification or deletion of this data. If you have given consent to data processing, you may withdraw this consent at any time with effect for the future. You also have the right, under certain circumstances, to request restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
You can contact us at any time about this and about any other questions you may have on the subject of data protection.
Analytics tools and tools from third parties
When you visit this website, your browsing behaviour may be statistically evaluated. This happens mainly with so‑called analysis programmes. Detailed information about these analysis programmes can be found in the following privacy policy.
2. Hosting
We host the content of our website with the following provider:
Strato
Provider is Strato AG, Otto‑Ostrowski‑Straße 7, 10249 Berlin, Germany (hereinafter “Strato”). When you visit our website, Strato records various log files including your IP address. Further information can be found in Strato’s privacy policy:
https://www.strato.de/datenschutz/
The use of Strato is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in the most reliable presentation of our website possible. Where consent has been obtained, processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and section 25 para. 1 TDDDG, insofar as the consent covers the storage of cookies or access to information in the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG.
Consent can be revoked at any time.
Data processing agreement
We have concluded a data processing agreement (DPA) with the provider named above. This is a contract required under data protection law, which ensures that this provider only processes the personal data of visitors to our website in accordance with our instructions and in compliance with the GDPR.
3. General notes and mandatory information
Privacy policy
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
When you use this website, various personal data are collected. Personal data is data that can be used to personally identify you. This privacy policy explains which data we collect and what we use it for. It also explains how and for what purpose this happens.
Please note that data transmission on the internet (e.g. when communicating by email) may have security vulnerabilities. Complete protection of the data from access by third parties is not possible.
Information about the Data Controller
The data controller responsible for data processing on this website is:
Wronin Business Solution CC
Shareholder Martin Horenburg und Katrin Schleiff
Von Eckenbrecher Street 26
PO BOX 11482 Windhoek Namibia
Phone: +49 175 6521363
Email: wronin.business.solution@gmail.com
The data controller is the natural or legal person who, alone or jointly with others, decides on the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).
Storage period
Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for the data processing ceases to apply. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion will take place after these reasons no longer apply.
General information on the legal bases of data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a GDPR and, where special categories of data are processed, Art. 9 para. 2 lit. a GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also based on Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or access to information in your terminal device (e.g. via device fingerprinting), data processing is additionally based on section 25 para. 1 TDDDG. Consent can be revoked at any time.
If your data is required for the performance of a contract or for the implementation of pre‑contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, if your data is required for the fulfilment of a legal obligation, we process it on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. The relevant legal basis in the individual case is explained in the following paragraphs of this privacy policy.
Recipients of personal data
In the course of our business activities, we work with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary for the performance of a contract, if we are legally obliged to do so (e.g. transfer of data to tax authorities), if we have a legitimate interest in the transfer within the meaning of Art. 6 para. 1 lit. f GDPR, or if another legal basis permits the transfer of data.
Where processors are used, we only transfer personal data of our customers on the basis of a valid data processing agreement. In the case of joint processing, a joint controller agreement is concluded.
Revocation of your consent to data processing
Many data processing operations are only possible with your explicit consent. You may revoke any consent you have already given at any time. The lawfulness of the data processing carried out up to the revocation remains unaffected by the revocation.
Widerspruchsrecht gegen die Datenerhebung in besonderen Fällen sowie gegen Direktwerbung (Art. 21 DSGVO)
IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 PARA. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT, AT ANY TIME AND ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS.
THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21 PARA. 1 GDPR).
WHERE YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS ASSOCIATED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21 PARA. 2 GDPR).
Right to lodge a complaint with the competent supervisory authority
In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.
Right to data portability
You have the right to have data which we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a commonly used, machine‑readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.
Access, rectification and deletion
Within the framework of the applicable legal provisions, you have the right to obtain information free of charge about your stored personal data, its origin and recipients and the purpose of the data processing and, if applicable, a right to rectification or deletion of this data. You can contact us at any time about this and about any other questions you may have on the subject of personal data.
Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You can contact us at any time about this. The right to restriction of processing exists in the following cases:
- If you contest the accuracy of your personal data stored by us, we usually need time to verify this.
- For the duration of the verification, you have the right to request restriction of the processing of your personal data.
- If the processing of your personal data has been/is unlawful, you may request restriction of data processing instead of deletion.
- If we no longer need your personal data, but you need it for the establishment, exercise or defence of legal claims, you have the right to request restriction of the processing of your personal data instead of deletion.
- If you have lodged an objection pursuant to Art. 21 para. 1 GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request restriction of the processing of your personal data.
zu verlangen.
If you have restricted the processing of your personal data, such data – apart from its storage – may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.
SSL and TLS encryption
For security reasons and to protect the transmission of confidential content, such as orders or enquiries you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the browser’s address line changes from “http://” to “https://” and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Objection to advertising emails
We hereby object to the use of contact data published in the context of the legal notice obligation for the purpose of sending unsolicited advertising and information material. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, for example through spam emails.
4. Data collection on this website
Cookies
Our web pages use so‑called “cookies”. Cookies are small data packets and do not cause any damage to your end device. They are either stored temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your end device. Session cookies are automatically deleted after your visit. Permanent cookies remain stored on your end device until you delete them yourself or they are automatically deleted by your web browser.
Cookies can be set by us (first‑party cookies) or by third‑party companies (so‑called third‑party cookies). Third‑party cookies enable the integration of certain services of third‑party companies within websites (e.g. cookies for handling payment services).
Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. shopping cart function or display of videos). Other cookies may be used to analyse user behaviour or for advertising purposes.
Cookies which are necessary to carry out the electronic communication process, to provide certain functions requested by you (e.g. shopping cart function) or to optimise the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 para. 1 lit. f GDPR, unless another legal basis is specified.
The website operator has a legitimate interest in the storage of necessary cookies for the technically error‑free and optimised provision of its services. Where consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a GDPR and section 25 para. 1 TDDDG); consent may be revoked at any time.
You can set your browser in such a way that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies in certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.
Where additional cookies and services are used on this website, this will be set out in this privacy policy.
Server log files
The provider of the pages automatically collects and stores information in so‑called server log files, which your browser automatically transmits to us. These are:
- Browser type and browser version
- Operating system used
- Referrer URL
- Hostname of the accessing computer
- Time of the server request
- IP address
No merging of this data with other data sources is carried out.
The collection of this data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error‑free presentation and optimisation of its website – for this purpose, the server log files must be recorded.
Contact form
If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the enquiry and in case of follow‑up questions. We do not pass on this data without your consent.
The processing of this data is based on Art. 6 para. 1 lit. b GDPR, provided that your enquiry is related to the performance of a contract or is necessary for the implementation of pre‑contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of enquiries directed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.
The data you enter in the contact form will remain with us until you request deletion, revoke your consent to storage or the purpose for data storage ceases to apply (e.g. after your enquiry has been fully processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.
Enquiry by email, phone or fax
If you contact us by email, phone or fax, your enquiry, including all personal data arising from it (name, enquiry), will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.
The processing of this data is based on Art. 6 para. 1 lit. b GDPR, provided that your enquiry is related to the performance of a contract or is necessary for the implementation of pre‑contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of enquiries directed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.
The data you send to us in contact enquiries will remain with us until you request deletion, revoke your consent to storage or the purpose for data storage ceases to apply (e.g. after your request has been fully processed).
Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
We use the WhatsApp messenger service for communication. The provider is WhatsApp Ireland Limited, Dublin, Ireland. When contacting us via WhatsApp, personal data (e.g. phone number and message contents) is processed. Use is voluntary and based on your consent. Further information can be found in WhatsApp’s privacy policy:
5. Social media
Functions of the Instagram service are integrated on this website. These functions are provided by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
When the social media element is active, a direct connection is established between your device and the Instagram server. Instagram thereby receives information that you have visited this website.
If you are logged into your Instagram account, you can link the content of this website to your Instagram profile by clicking the Instagram button. This allows Instagram to associate the visit to this website with your user account. We would like to point out that, as the provider of these pages, we have no knowledge of the content of the data transmitted or of its use by Instagram.
The use of this service is based on your consent under Art. 6 para. 1 lit. a GDPR and section 25 para. 1 TDDDG.
Consent can be revoked at any time.
Where personal data is collected on our website with the help of the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Dublin, D04 X2K5, Ireland are jointly responsible for this data processing (Art. 26 GDPR).
DSGVO).
Joint responsibility is limited solely to the collection of the data and its transfer to Facebook or Instagram. The subsequent processing by Facebook or Instagram is not part of the joint responsibility.
The obligations incumbent on us jointly have been set out in an agreement on joint processing. The wording of the agreement can be found at:
https://www.facebook.com/legal/controller_addendum. Laut dieser Vereinbarung sind wir für die Erteilung der Datenschutzinformationen beim Einsatz des Facebook- bzw. Instagram-Tools und für die datenschutzrechtlich sichere Implementierung des Tools auf unserer Website verantwortlich. Für die Datensicherheit der Facebook bzw. Instagram-Produkte ist Facebook verantwortlich.
According to this agreement, we are responsible for providing the privacy information for the use of the Facebook or Instagram tools and for implementing the tools on our website in a manner secure under data protection law. Facebook is responsible for the data security of the Facebook and Instagram products.
Data subject rights (e.g. requests for information) with regard to the data processed by Facebook or Instagram can be asserted directly with Facebook. If you assert your data subject rights with us, we are obliged to forward them to Facebook.
The transfer of data to the USA is based on the EU Commission’s standard contractual clauses.
Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum,
https://privacycenter.instagram.com/policy/
https://de-de.facebook.com/help/566994660333381.
Further information can be found in Instagram’s privacy policy:
https://privacycenter.instagram.com/policy/.
The company is certified under the EU‑US Data Privacy Framework (“DPF”). The DPF is an arrangement between the European Union and the United States intended to ensure compliance with European data protection standards for data processing in the United States. Each company certified under the DPF undertakes to comply with these data protection standards.
Further information is available from the provider at:
https://www.dataprivacyframework.gov/participant/4452.
Our website contains a link to our profile on LinkedIn. When you click the link, you will be redirected to the LinkedIn platform. The provider is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Further information on the processing of personal data can be found in LinkedIn’s privacy policy:
6. Newsletter
Newsletter data
If you wish to subscribe to the newsletter offered on the website, we require an email address from you as well as information which allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. No other data will be collected, or only on a voluntary basis.
We use this data exclusively for sending the requested information and do not pass it on to third parties.
The processing of the data entered in the newsletter registration form is based exclusively on your consent (Art. 6 para. 1 lit. a GDPR). The consent given to the storage of the data, the email address and its use for sending the newsletter can be revoked at any time, for example via the “unsubscribe” link in the newsletter.
The lawfulness of the data processing already carried out remains unaffected by the revocation.
The data you provide to us for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe or once the purpose has ceased to apply. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR.
Data which has been stored by us for other purposes remains unaffected.
After you have unsubscribed from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist, if this is necessary to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with legal requirements for sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Storage in the blacklist is not time‑limited. You may object to this storage if your interests outweigh our legitimate interest.
Source: https://www.e-recht24.de