Statement of Online Data Protection Policy for projectpromise.eu

We are delighted that you are interested in our services and want to make sure that you feel you have come to the right place – including when it comes to how we handle your personal data. We take protecting your personal data very seriously. We want you to know when we collect data, what data we collect and how we use it. Below, you will find details on the type of personal data we collect, on the extent of the collected data, on the reasons why we do so and what we use the collected data for. You can check back to these details on our website at any time.

To ensure that your personal data remains safe, we ensure that your data is protected from access by unauthorised parties and from unauthorised disclosure. Your data will not be supplied to third parties without authorisation.

If you have any questions or suggestions regarding this data policy, or concerning data protection in general, please feel free to get in touch with our (external) data protection officer under the contact details below.

I. Name and address of controller

The controller as defined in the General Data Protection Regulation and other data protection laws nationally applicable in the EU member states or other regulations related to data protection is:

adelphi
Alt-Moabit 91
10559 Berlin
Germany

Phone: +49 (30) 8900068-0
Fax: +49 (30) 8900068-10
email: office@adelphi.de
Website: https://www.adelphi.de

II. Name and address of data protection officer

The controller’s data protection officer is:

Sema Karakas
c/o Althammer & Kill GmbH & Co. KG
Thielenplatz 3
30159 Hanover
Germany

Phone: +49 (511) 330603-26
email: privacy@adelphi.de
Website: https://www.althammer-kill.de

III. General information about data processing

1. Extent of personal data processing

We process our users’ personal data only to the extent required for providing a functional website and supplying our content and services. We process our users’ personal data regularly only if the respective users have given their consent. The only exception to this is where it is actually impossible for us to obtain prior consent and processing of the data is legally allowed.

2. Legal basis for processing personal data

Where we obtain the corresponding data subjects’ consent for processing their personal data, art. 6 paragraph 1 point a of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

Where we need to process personal data for the purposes of fulfilling a contract, and the data subject is party to the contract, art. 6 paragraph 1 point b of the GDPR serves as the legal basis. This also applies to processing necessary to accommodate preparations for entering into a contract.

Where processing of personal data is necessary for our company to fulfil a legal obligation, art. 6 paragraph 1 point c of the GDPR serves as the legal basis.

Where processing of personal data is necessary for protecting the vital interests of the data subject, or those of another individual, art. 6 paragraph 1 point d of the GDPR serves as the legal basis.

Where processing is necessary to protect our company's or a third party’s legitimate interests, and such interests are not overridden by the interests, fundamental rights and freedoms of the data subject, art. 6 paragraph 1 point f of the GDPR serves as the legal basis.

3. Deletion of data and data storage period

The data subject’s personal data will be deleted or blocked as soon as the purpose for which it has been collected has been fulfilled. Data may remain on record beyond this period if such is specified in European or national legislation from European Union Regulations, laws or other provisions to which the controller is subject. Data will also be deleted if a storage period specified in the above standards expires unless conclusion or fulfilment of a contract requires the data to remain on record further.

IV. Provision of website and creation of log files

1. Details and extent of data processing

Any time our website is accessed, our system automatically records data and information concerning the accessing computer.

The following data is recorded:

Information on the browser type and version used
The user’s operating system
The user’s Internet service provider
The user’s IP address
Date and time of access
Websites from which the user’s system reaches our website
Websites the user’s system accesses from our website

This data is also recorded in our system’s log files. This data is not stored together with any of the user’s other personal data.

2. Legal basis for data processing

The legal basis for temporary recording of this data in our log files is art. 6 paragraph 1 point f GDPR.

3. Purpose of data processing

Our system needs to temporarily record the IP address in order to provide the website to the user’s computer. This also requires that the user’s IP address remains logged throughout the session.

Recording the data in log files is necessary to ensure that the website operates correctly. The data further helps us optimise the website and ensure that our computer systems remain secure. No data is processed for marketing purposes in this context.

The above purposes also constitute our legitimate interests in data processing under art. 6 paragraph 1 point f GDPR.

4. Data storage period

The data is deleted as soon as it is no longer required for achieving the purpose for which it was recorded. With respect to data being recorded in order to provide the website, the data is no longer required as soon as the respective session ends.

With respect to data being recorded in log files, the data is no longer required after fourteen days at the latest. Data may remain on record for longer. If so, the users’ IP addresses are deleted or rendered untraceable to make identification of the accessing client impossible.

5. Right to object and options for avoidance

The website cannot be provided without recording the data and the operation of the site in the Internet is impossible without storing the data in log files. There is correspondingly no option for the user to object.

V. Use of cookies

1. Details and extent of data processing

Our website uses cookies. Cookies are text files saved in the Internet browser or by the Internet browser on the user’s computer. When a user accesses a website, a cookie may be stored in the user’s operating system. This cookie contains a unique character string that allows the website to identify the browser when it accesses the website again.

We use cookies to improve the user experience when accessing our website. Some of our website’s elements need to be able to identify the accessing browser even after it has left the site.

The following data is recorded and transferred in the cookies:

Availability of JavaScript in the browser

Our website further employs cookies that facilitate analysis of the users’ web-surfing behaviour.

This can entail transfer of the following data:

Randomly generated user ID
Time of first access
Time of last access
Number of visits

User data recorded this way is pseudonymised through technical measures. It cannot be used to identify the accessing user. This data is not stored together with any of the user’s other personal data.

2. Legal basis for data processing

The legal basis for the processing of personal data using cookies for analysis purposes is art. 6 paragraph 1 point a GDPR if the user has consented to this.

3. Purpose of data processing

The purpose of using technically necessary cookies is to make using our website easier for users. Several of our website’s functions will not work without using cookies. These functions require the browser to be recognised again after leaving and returning to our website.

The following functions require cookies:

Detection of JavaScript support

The user data recorded in technically necessary cookies is not used to create user profiles.

We use analysis cookies to improve the quality of our website and its contents. The analysis cookies tell us how the website is being used and this way allow us to keep on improving it.

For further details on the analysis cookies used, refer to the section on web analysis by Matomo below.

The above purposes also constitute our legitimate interests in processing personal data under art. 6 paragraph 1 point f GDPR.

4. Data storage period, right to object and options for avoidance

Cookies are stored on the user’s computer and transferred to us by that computer. As the user, you therefore have complete control over the use of cookies. You can use our cookie constent tool to adjust your preferences for this specific site or you can restrict or prevent your computer from sending cookies by adjusting your Internet browser’s settings. You can delete any saved cookies at any time. You can even automate deletion. If you disable cookies for our website, you may no longer be able to use the site’s full range of functions.

VI. Encryption

To keep your data secure during transmission, we use the latest state of the art in encryption technology (e.g. TLS/SSL) via HTTPS.

VII. Newsletter

1. Details and extent of data processing

Our website offers you the option of subscribing to our free newsletter. When you register a subscription, the data you enter in the input screen is sent to us.

Email address
Company/organisation (optional)
Salutation (optional)
First name (optional)
Surname (optional)
Country (optional)
Selected interests (optional)

We also record the following data as part of registration:

The IP address of the computer accessing our website
Date and time of registration

During the registration process, we will ask you to give your consent to our processing the data and will point you towards this data policy.

No data will be forwarded to third parties as part of data processing when supplying the newsletter. The data will be used solely for supplying the newsletter.

2. Legal basis for data processing

The legal basis for processing data after newsletter subscription and with the user’s consent is art. 6 paragraph 1 point a GDPR.

3. Purpose of data processing

We record the user’s email address to allow us to send out the newsletter.

We collect the other data as part of subscription registration to prevent our services from being used inappropriately and to prevent the email address from being fraudulently used. The data also helps us provide tailored information.

4. Data storage period

The data is deleted as soon as it is no longer required for achieving the purpose for which it was recorded. We therefore keep the user’s email address on record for as long as the user remains subscribed to the newsletter.

The other personal data collected during registration will also be deleted when the user unsubscribes from the newsletter.

5. Right to object and options for avoidance

Users can unsubscribe from the newsletter at any time. The newsletter itself includes a corresponding link.

This also allows users to withdraw their consent regarding our storing of the personal data collected during registration.

VIII. Contact form and contact by email

1. Details and extent of data processing

You have the option to contact us under the email address provided. If you do so, we will store the personal user data included in the email.

We will not give this data to anybody else. The data will be used solely for handling our conversation.

2. Legal basis for data processing

The legal basis for processing data with the user’s consent is art. 6 paragraph 1 point a GDPR.

The legal basis for processing data received as part of email communication is art. 6 paragraph 1 point f GDPR. If email communication pursues conclusion of a contract, the legal basis shall further be art. 6 paragraph 1 point b GDPR.

3. Purpose of data processing

We process the personal data obtained from users contacting us via email solely for the purposes of handling contact.solely for the purposes of handling contact.

4. Data storage period

The data is deleted as soon as it is no longer required for achieving the purpose for which it was recorded. In terms of a contact received by email, this applies when the respective conversation with the user has concluded. The conversation has concluded when the circumstances indicate that the respective subject has been fully resolved.

The additional personal data collected during transmission will be deleted after seven days at the latest.

5. Right to object and options for avoidance

All users can at any time withdraw their consent to our processing their personal data. If a user contacts us by email, they can object at any time to our storing their personal data. If they do so, the conversation cannot be pursued further.

You can withdraw your consent and object to our storing data by phone (name and address of controller) or by sending an email to withdrawal@adelphi.de.

If you do so, we will delete all personal data recorded as part of our contact.

IX. Embedded YouTube videos

We embed YouTube videos on some of our websites. These plug-ins are operated by YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you access a web page with the YouTube plug-in and click the video, you will be connected to YouTube’s servers. When this happens, YouTube receives information on the sites you are visiting. If you are logged in to your YouTube account, YouTube will be able to trace your surfing behaviour. You can prevent this by logging out of your YouTube account beforehand.

When you start a YouTube video, the provider uses cookies that collect data on user behaviour.

If you have disabled cookies for the Google Ad program, these YouTube cookies will also be disabled. However, YouTube stores further, non-personal user data in other cookies. If you want to prevent this, you will need to disable YouTube cookies in our cookie constent tool or your browser settings.

For more information on data protection and YouTube, refer to the provider’s data policy here: https://www.google.com/intl/en/policies/privacy/

X. Embedded Vimeo videos

We embed Vimeo videos on some of our websites. These plug-ins are operated by Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. When you access a web page with the Vimeo plug-in and click the video, you will be connected to Vimeo’s servers. When this happens, Vimeo receives information on the sites you are visiting. If you are logged in to your Vimeo account, Vimeo will be able to trace your surfing behaviour. You can prevent this by disabling Vimeo cookies in our cookie constent tool or by logging out of your Vimeo account beforehand.

Please note that Vimeo may employ Google Analytics; see the data policy (https://www.google.com/policies/privacy) and your opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout) and the Google settings relating to data use for marketing purposes (https://adssettings.google.com/).

For more information on data protection and Vimeo, refer to the provider’s data policy here: https://vimeo.com/privacy

XI. Social Media

We maintain an online presence in social media and platforms to communicate with the prospects and users active there and to keep them up-to-date on our services. When accessing social media networks and platforms, the respective operators’ terms and conditions and data policies will apply.

Unless noted otherwise in our data policy, we process the data of users who communicate with us through social media networks or platforms, e.g. by leaving comments on our websites or sending us messages.

1. Facebook components

The social media buttons we use on our website comply with data protection rules. They do not automatically connect you to Facebook (facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA).

By clicking Facebook’s Like button when logged in to your Facebook account, you can link our website content to your Facebook account. This will allow Facebook to trace your visit to our website to your user account. Please note that we as the provider of our sites are not informed of the data transmitted or of how Facebook uses the data. For more information, see Facebook’s data policy at https://facebook.com/policy.php

2. X recommendation components (former "Twitter")

The social media buttons we use on our website comply with data protection rules. They do not automatically connect you to X (X Corp. 1355 Market St, Suite 900, San Francisco, CA 94103, USA.).

By using X and its re-posts function, the websites you visit are linked to your X account and communicated to other users. This also transmits data to X.

Please note that we as the provider of our sites are not informed of the data transmitted or of how X uses the data. For more information, see X’s data policy at https://x.com/privacy

3. LinkedIn recommendation components

The social media buttons we use on our website comply with data protection rules. They do not automatically connect you to LinkedIn (LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA).

By clicking LinkiedIn’s Recommend button when logged in to your LinkedIn account, you can link our website content to your LinkedIn account. This will allow LinkedIn to trace your visit to our website to your LinkedIn user account.

We have no control over the data LinkedIn records this way, nor over the extent of data LinkedIn collects this way. We are not informed of what data LinkedIn receives. For details on data collected by LinkedIn and on your rights and setting options, see LinkedIn’s data policy here: https://www.linkedin.com/legal/privacy-policy

XII. Google ReCaptcha

We use the reCAPTCHA service provided by Google Inc. to protect the orders you send us using the Internet form. The reCAPTCHA service employs a query to establish whether entries are made by a human being or fraudulently by automated, machine processing. The query includes transmission of the sending IP address and may include further data required by Google to operate the reCAPTCHA service. This entails transmission of your input to Google and its use by them. By using reCAPTCHA, you consent to Google using your recognition input for digitizing other works. If you have enabled IP anonymisation on this website, Google will truncate your IP address before transmission within European Union member states or other states party to the Treaty on the European Economic Area. In some exceptional cases, the full IP address will be transmitted to one of Google’s servers in the USA and truncated there. Google will use this information on behalf of this website’s operator to analyse your use of the service. The IP address sent by your browser as part of reCAPTCHA will not be associated with other data Google has. That data is subject to Google’s remaining data policy. For more information on Google’s data policy, see: https://www.google.com/policies/privacy/

XIII. Web analysis by Matomo (formerly PIWIK)

1. Extent of personal data processing

We use the open-source tool Matomo (formerly PIWIK) on our website to analyse our users’ surfing behaviour. The software stores a cookie on the user’s computer (see above for more on cookies). When any part of our website is accessed, the following data is stored:

Two bytes of the accessing system’s IP address
Date and time the site was accessed
Website accessed (name and URL)
Website from which the user has reached the accessed website (referrer)
Subdomains accessed from the accessed website
Duration of the visit to website
How often the website is accessed
Screen resolution
Time as in user’s time zone
Files clicked and downloaded
Links clicked to external websites
Page build-up time (time required for the page to be generated and displayed)
User’s location: country, region, town, approximate latitude and longitude (geoposition) based on Internet access point
Browser’s principal language
Browser’s user agent

This software runs only on the servers hosting our website. Users’ personal data is saved there and nowhere else. The data is not made accessible to third parties.

The software is set so that it does not save the full IP address but instead masks 2 bytes of the IP address (example: 192.168.xxx.xxx). This makes it impossible to associate the truncated IP address with the accessing computer.

2. Legal basis for processing personal data

The legal basis for processing the users’ personal data is art. 6 paragraph 1 point f GDPR.

3. Purpose of data processing

Processing the users’ personal data allows us to analyse their surfing behaviour. By analysing the obtained data, we can compile information on how the various components of our website are used. This helps us keep on improving our website and its user experience. The above purposes also constitute our legitimate interests in processing the data under art. 6 paragraph 1 point f GDPR. Anonymising the IP addresses adequately satisfies the users’ interests in protecting their personal data.

4. Data storage period

The data is deleted as soon as we no longer need them for our records.

In our cases, this corresponds to six months later.

5. Right to object and options for avoidance

For more details on privacy settings in Matomo, follow the link: https://matomo.org/docs/privacy/

XIV. Data subject’s rights

If your personal data is processed, you are a data subject as defined in the GDPR and consequently have the following rights:

1. Right of access

You are entitled to request information from the controller on whether we are processing any personal data related to yourself.

If we do, you can further request information from the controller on the following:

The purposes to which the personal data is being processed.
The categories of personal data processed.
The recipients or categories of recipients to whom the personal data relating to yourself is or will be disclosed.
The period for which the personal data relating to yourself is intended to remain on record or, if this cannot be specified, the criteria for defining the storage period.
Whether you are entitled to demand correction or deletion of the personal data relating to yourself, to demand limitation of processing by the controller or to object to processing.
Whether you are entitled to file a complaint with a supervisory authority.
Everything available on the data’s source if the entity you are enquiring with did not obtain it themselves.
Whether there was any automated decision-making and profiling as per art. 22 paragraphs 1 and 4 GDPR and – at least where such was the case – useful information on the underlying logic and the impact and pursued effects of this processing on the data subject.

You are entitled to request information on whether the personal data relating to yourself will be transmitted to a non-EU member state or international organisation. You are entitled in this context to request information on suitable safeguards according to art. 46 GDPR related to the transmission.

2. Right to rectification

You are entitled to request that the controller corrects and/or completes the personal data relating to yourself if this data is incorrect or incomplete. The controller is obliged to do so without delay.

3. Right to restriction of processing

You can request limits to the processing of personal data relating to yourself if the following applies:

If you contest the correctness of the personal data relating to yourself for a period that allows the controller to check the data's correctness.
Processing of the data is illegal and you object to deletion of the data in favour of restricting the personal data’s use.
The controller no longer requires the personal data for the purposes of processing, but you need them to legitimise, exercise or defend a legal claim.
You have objected to processing in accordance with art. 21 paragraph 1 GDPR and it has not yet been established whether the controller’s legitimate interests outweigh your own.

If processing the personal data relating to yourself has been limited, the data can without your consent be used neither to assert, exercise or defend legal claims nor to enforce protection of another individual’s or legal entity’s rights nor can it be processed in the public interest of the European Union or one of its member states. This does not apply to the storing of the data.

If processing has been restricted in accordance with the above conditions, you will be notified by the controller before any restrictions are lifted.

4. Right to erasure

a) Obligation to delete

You can request that the controller delete the personal data relating to yourself immediately; the controller is then obliged to delete the data immediately, provided one of the following conditions applies:

The personal data relating to yourself is no longer required to achieve the purposes for which it was collected or otherwise processed.
You withdraw your consent, under which processing became legitimate as per art. 6 paragraph 1 point a or art. 9 paragraph 2 point a GDPR, and there is no other legal basis for processing.
You object to processing as per art. 21 paragraph 1 GDPR and your objection is not overridden by legitimate reasons for processing, or you object to processing as per art. 21 paragraph 2 GDPR.
The personal data relating to yourself have been processed unlawfully.
Deletion of the personal relating to yourself is necessary for the controller to fulfil a legal obligation imposed upon them by European Union law or the national laws of European Union member states.
The personal data relating to yourself has been collected in connection with the offer of information society services as per art. 8 paragraph 1 GDPR.

b) Notification of third parties

If the controller has published personal data relating to yourself and has become obliged to delete it as per art. 17 paragraph 1 GDPR, the controller will take action, including technical measures, using the available technology and at appropriate expense with the aim of notifying any controllers processing your personal data that you as the data subject have requested deletion of all links to said personal data or to copies or reproductions thereof.

c) Exceptions

The right to erasure becomes void if processing is necessary

to exercise of the right to free expression and information;
to fulfil a legal obligation requiring the controller to process the data imposed upon them by European Union law or the national laws of a European Union member state, or to complete a duty in the public interest or to perform executive duties appointed to the controller;
in the interests of public health and safety as per art. 9 paragraph 2 points h and i and art. 9 paragraph 3 GDPR;
for archiving purposes in the public interest, for scientific or historical research or for statistical purposes as per art. 89 paragraph 1 GDPR, provided that the right described in section a) can be reasonably assumed to prevent or seriously impede achievement of the processing purposes;
to assert, exercise or defend legal claims.

5. Notification obligation

If you have asserted your right to rectification, erasure or restriction of processing against the controller, the controller is under obligation to notify all recipients to whom the personal data relating to yourself has been disclosed of the corresponding rectification or erasure of data or of the restriction of their processing. The controller is exempted from this obligation where such notification proves impossible or unreasonable.

You have the right to be informed of who these recipients are.

6. Right to data portability

You have the right to receive the personal data concerning yourself that you have provided to a controller in a structured, commonly used and machine-readable format. You are also entitled to transmit this data to another controller without the controller to whom you have provided the data hindering you from doing so and if

you have consented to processing as per art. 6 paragraph 1 point a GDPR or art. 9 paragraph 2 point a GDPR or processing is governed by a contract as per art. 6 paragraph 1 point b GDPR and
processing occurs using automated methods.

When exercising this right, you can further request controllers to send the personal data relating to yourself directly to another controller, provided this is technically feasible. This must not adversely affect the liberties and rights of others.

The right to data portability does not extend to the processing of personal data where such processing is necessary for fulfilling a duty in the public interest or for exercising executive duties appointed to the controller.

7. Right to object

You are entitled to object for reasons arising from your own personal situation at any time against processing of personal data relating to yourself where processing is legitimised by art. 6 paragraph 1 points e or f GDPR; this applies in equal measure to profiling legitimised by these provisions.

The controller will cease to process your personal data unless they can prove compelling legitimate reasons for processing that override your interests, rights and liberties or processing pursues the assertion, exercise or defence of legal claims.

If personal data relating to yourself is processed for the purpose of direct advertising, you are entitled to object at any time to the processing of your personal data for this purpose; this applies equally to profiling where it occurs in connection with such direct advertising.

If you object to processing for direct advertising, the personal data relating to yourself will no longer be processed for this purpose.

You may, in connection with the use of information society services – Directive 2002/58/EC notwithstanding – exercise your right to object by means of automated methods that are subject to technical specifications.

8. Right to withdraw your consent under data protection law

You are entitled to withdraw your consent under data protection law at any time. Your withdrawing consent does not affect legitimacy of any processing that has occurred with your consent prior to withdrawal.

9. Automated individual decision-making, including profiling

You have the right not to be subject to any decision that entails legal implications for yourself or has similar, substantially adverse effects on yourself, if said decision is based solely on automated processing; this includes profiling. You do not have this right if the decision

is necessary to allow conclusion or fulfilment of a contract between yourself and the controller;
is legitimate under the legal provisions of the European Union or its member states to which the controller is subject and these legal provisions include appropriate measures safeguarding your rights, liberties and legitimate personal interests or
is made with your express consent.

However, such decisions may have been made based on personal data of special categories as per art. 9 paragraph 1 GDPR unless art. 9 paragraph 2 points a or g GDPR also apply and appropriate measures have been taken to protect your rights, liberties and legitimate personal interests.

With respect to cases (1) and (3), the controller shall take appropriate precautions to protect your rights, liberties and legitimate personal interests; such precautions will include at least the right to enforce intervention by a human individual at the controller’s, to put forward your own opinion and to contest the decision.

10. Right to complain with a supervisory authority

If you believe that processing of personal data relating to yourself is in breach of the GDPR, you have the right to lodge a complaint with a supervisory authority, particularly in the EU member state you, your place of work or the locale of the alleged infringement are in. This does not affect your recourse to other administrative or judicial remedies.

The supervisory authority receiving the complaint will keep the appellant up to date on status and results of the complaint, including on recourse to judicial remedies as per art. 78 GDPR.

XV. Changes to our data policy

We reserve the right to amend this data policy to keep it in line with the latest legal requirements or to adjust it to reflect changes to our services, e.g. if we introduce new services. The latest version of our data policy will apply to any further visits.

Latest version: 08 June 2022