Privacy

This data protection declaration explains type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the associated websites, functions and contents as well as external online presences, e.g. our social media profiles (hereinafter jointly referred to as “online offer”). With regard to the terms used, such as “personal data” or their “processing”, we refer to the definitions in Art. 4 of General Data Protection Regulation (GDPR).

Person in charge / contact

Name/Company: Lucy Turpin-Hedinger Communications GmbH

Street: Prinzregentenstr. 89

City: Germany, 81675 Munich

Managing Director: Thomas Hahnel

Registration Court: Amtsgericht München

Registration Number: HRB 109924

Phone:  +49 89 4177610

E-Mail: frontdesk@lucyturpin.com

Types of data processed

Inventory data (e.g., names, addresses)

Contact details (e.g., e-mail)

Content data (e.g., text entries)

Usage data (e.g., visited websites, interest in content, access times)

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

Processing of special categories of data (art. 9, para 1 GDPR):

No special categories of data are processed.

Categories of data subjects

Customers, interested parties, suppliers, visitors and users of the online offer. In the following, we will summarise the persons concerned as “users”.

Purpose of processing

Provision of the online offer, its contents and functions. Response to contact requests and communication with users. Marketing, advertising and market research.

Last update: 21.05.2018

1. Applicable legal basis

In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and performance of contractual measures as well as for answering inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.

2. Changes and updates to the privacy policy

We ask you to inform yourself regularly about the contents of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

3. Safety precautions

3.1 We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 of  GDPR, taking into account state of the art, implementation costs and nature, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons; the measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability and their separation. Furthermore, we have established procedures that guarantee the exercise of data subject rights, deletion of data and reaction to data risks. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly presettings (Art. 25 GDPR).

3.2 The security measures include in particular the encrypted transmission of data between your browser and our server.

4. Cooperation with contract processors and third parties

4.1 If we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transfer of the data to third parties, such as to payment service providers, pursuant to Art. 6 para. 1 lit. b GDPR is required for contract fulfilment), if you have consented, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

4.2 If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.

5. Transfers to third countries

If we process data to a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the special requirements of Art. 44 ff. GDPR are given. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).

6. Rights of data subjects

6.1 You have the right to request confirmation as to whether the data concerned are being processed and to request information about these data as well as further information and a copy of the data in accordance with Art. 15 GDPR.

6.2 In accordance with Article 16 GDPR, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you.

6.3 In accordance with Art. 17 DSGVO, you have the right to demand that relevant data be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with Art. 18 GDPR.

6.4 You have the right to request that the data concerning you which you have provided to us be received in accordance with Art. 20 GDPR and to request that it be forwarded to other persons responsible.

6.5 You also have the right to file a complaint with the competent supervisory authority pursuant to Art. 77 GDPR.

7. Right of revocation

SYou have the right to revoke consents granted pursuant to Art. 7 para. 3 GDPR with effect for the future.

8. Right of objection

You can object to the future processing of the data concerning you in accordance with Art. 21 GDPR at any time. The objection may be lodged in particular against processing for direct marketing purposes.

9. Cookies and right of objection in direct advertising

We use temporary and permanent cookies, i.e. small files that are stored on the user’s devices (explanation of the term and function, see last section of this data protection declaration). In part, cookies serve security purposes or are required for the operation of our online offer (e.g., for the presentation of the website) or to save the user’s decision when confirming the cookie banner. In addition, we or our technology partners use cookies to measure reach and for marketing purposes, about which the users will be informed in the course of the data protection declaration.

A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site https://www.aboutads.info/choices/ or the EU site https://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

10. Deletion of data

10.1 The data processed by us will be deleted or their processing restricted in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.

10.2 In accordance with statutory provisions, storage shall be effected in particular for six years in accordance with § 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for ten years in accordance with § 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant to taxation, etc.).

11. Performance of contractual services

We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 (1) lit b. GDPR. The entries marked as obligatory in online forms are required for the conclusion of the contract.

12. Establishing contact

12.1 When contacting us (via contact form or e-mail), the user’s details will be processed for processing the contact request and its handling in accordance with Art. 6 para. 1 lit. b) GDPR.

12.2 User information may be stored in our Customer Relationship Management System (“CRM System”) or comparable request organization.

13. Collection of access data and log files

13.1 On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR we collect on each access to the server on which this service is located (so-called server log files) . Access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

13.2 Log file information is stored for a maximum of seven days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.

14. Cookies & reach measurement

14.1 Cookies are information that is transferred from our web server or third party web servers to the user’s web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.

14.2 Users will be informed about the use of cookies within the scope of pseudonymous range measurement within the scope of this data protection declaration.

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

14.4 You may opt-out of the use of cookies for range measurement and promotional purposes via the deactivation page of the Network Advertising Initiative (https://optout.networkadvertising.org/) and additionally at the US website (https://www.aboutads.info/choices) or at the European website (https://www.youronlinechoices.com/uk/your-ad-choices/).

15. Google Analytics

15.1 Based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) we use Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by users is generally transferred to a Google server in the USA and stored there.

15.2 Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

15.3 Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services connected with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

15.4 We use Google Analytics only with enabled IP anonymization. This means that Google will reduce the IP address of users within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases the full IP address will be transmitted to a Google server in the USA and shortened there.

15.5 The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

15.6 Further information on data use by Google, possible settings and objections can be found on the Google websites: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google when using our partners’ websites or apps”), https://policies.google.com/technologies/ads (“Data use for advertising purposes”), https://adssettings.google.com/authenticated (“Manage information that Google uses to show you advertising”).

16. Integration of third-party services and content

16.1 Within our online offer and on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third parties to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as may be linked to such information from other sources.

16.2 The following presentation provides an overview of third-party providers and their contents, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, possibilities of objection (so-called opt-out):