We are delighted that you are interested in our company!
Data protection is particularly important to us. This privacy policy therefore provides detailed information about the type, scope, and purpose of personal data within our online offering.
But first, the most important thing:
It is generally possible to use the Sontheimer + Partners website without providing any personal data.
However, if you wish to contact us, it may be necessary to process personal data in accordance with Art. 6 (1) (b) GDPR. If further processing of personal data is necessary and there is no direct legal basis for this, we generally obtain the consent of the person concerned first.
And now in detail:
The privacy policy applies regardless of the domains, systems, platforms, and devices (e.g., desktop or mobile) used to access the online offering.
The processing of personal data, such as the name, address, email 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 Sontheimer + Partners. 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 about their rights.
As the controller, Sontheimer + Partners has implemented numerous technical and organizational measures to ensure the most complete protection possible of the personal data processed via this website. This includes, for example, the encrypted transmission of data between your browser and our server. Nevertheless, Internet-based data transmissions can generally have security gaps, so that 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.
1. Definitions
The privacy policy of Sontheimer + Partners is based on the terminology used by the European legislators and regulators when enacting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.
In this privacy policy, we use the following terms, among others:
a) Personal data
Personal data is any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”). A natural person is considered identifiable if they can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier, or one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural, or social identity of that natural person.
b) Data subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller.
c) Processing
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, distribution, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
e) Profiling
Profiling is any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. As a responsible company, we refrain from automated decision-making or profiling.
f) Pseudonymization
Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Controller or controller responsible for processing
The controller or controller responsible for processing is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are laid down by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
h) Processor
A processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) Recipient
A recipient is a natural or legal person, public authority, agency, or another body to which personal data are disclosed, whether a third party or not. However, public authorities that may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.
j) Third party
A third party is a natural or legal person, public authority, agency or other body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
k) Consent
Consent is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and address of the controller
The 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 provisions of a data protection nature is:
Sontheimer + Partners
Markus Sontheimer
Kapellenweg 18
70378 Stuttgart
E-mail: markus@sontheimer-partners.com
Website: sontheimer-partners.com
3. Name and address of the data protection officer
The data protection officers of the controller are:
Sontheimer + Partners
Markus Sontheimer
Kapellenweg 18
70378 Stuttgart
E-mail: markus@sontheimer-partners.com
Website: sontheimer-partners.com
Any data subject can contact our data protection officer directly at any time with any questions or suggestions regarding data protection.
4. Cookies
Like many other websites, the Sontheimer + Partners website uses cookies. Cookies are text files that are stored on a computer system via an Internet browser.
Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier for the cookie. It consists of a string of characters that can be used to assign websites and servers to the specific internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the person concerned from other internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID. By using cookies, Sontheimer + Partners can provide users of this website with more user-friendly services that would not be possible without the use of cookies.
Cookies enable us to optimize the information and offers on our website for the benefit of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. The data subject can prevent the setting of cookies by our website at any time by means of a corresponding 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 or performance may be restricted.
5. Collection of general data and information
The Sontheimer + Partners website collects a range of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol (IP) address, (7) the Internet service provider of the accessing system, and (8) other similar data and information that serves to avert danger in the event of attacks on our information technology systems.
When using this general data and information, Sontheimer + Partners does not draw any conclusions about the data subject. Rather, this information is required in order to (1) deliver the content of our website correctly, (2) optimize the content of our website, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack. This anonymously collected data and information is therefore evaluated by Sontheimer + Partners on the one hand statistically and on the other hand with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.
6. Contact option via the website
Due to legal requirements, the Sontheimer + Partners website contains information that enables quick electronic contact with our company and direct communication with us, which also includes a general address for electronic mail (e-mail address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted voluntarily by a data subject to the controller is stored for the purpose of processing or contacting the data subject. This personal data is not passed on to third parties.
7. 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 if this has been provided for 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 will be routinely blocked or deleted in accordance with the statutory provisions.
8. Rights of the data subject
a) Right to confirmation
Every data subject has the right granted by European directives and regulations to request confirmation from the controller as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right to confirmation, they may contact an employee of the controller at any time.
b) Right to information
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller, free of charge, information about the personal data stored about them and a copy of this information at any time. Furthermore, the European legislator has granted the data subject the right to obtain the following information:
- the purposes of the processing
- the categories of personal data that are 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
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
- the existence of a right to rectification or erasure of personal data concerning them or to restriction of processing by the controller or a right to object to such processing
- the existence of a right to lodge a complaint with a supervisory authority
- if the personal data are not collected from the data subject: all available information on the origin of the data
- the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Furthermore, the data subject has the right to obtain information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.
If a data subject wishes to exercise this right of access, they may contact an employee of the controller at any time.
c) Right to rectification
Any person affected by the processing of personal data has the right, granted by European directives and regulations, to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, taking into account the purposes of the processing, including by means of a supplementary statement.
If a data subject wishes to exercise this right of rectification, they may contact an employee of the controller at any time.
d) Right to erasure (right to be forgotten)
Any person affected by the processing of personal data has the right granted by the European legislator to request the controller to erase personal data concerning them without delay, provided that one of the following reasons applies and insofar as the processing is not necessary:
- The personal data has been collected or otherwise processed for purposes for which it is no longer necessary
- The data subject withdraws their consent on which the processing was based in accordance with Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR, and there is no other legal basis 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 to the processing pursuant to Art. 21(2) GDPR.
- The personal data has been processed unlawfully.
- The erasure of the personal data is necessary for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
- If one of the above reasons applies and a data subject wishes to have personal data stored by Sontheimer + Partners deleted, they can contact an employee of the controller at any time. The Sontheimer + Partners employee will ensure that the deletion request is complied with immediately.
- If the personal data has been made public by Sontheimer + Partners and our company is obliged to delete the personal data as the controller pursuant to Art. 17 (1) GDPR, Sontheimer + Partners shall take appropriate measures, including technical measures, taking into account the available technology and implementation costs, to inform other controllers who process the published personal data that the data subject has requested these other data controllers to delete all links to this personal data or copies or replications of this personal data, unless processing is necessary. The employee of Sontheimer + Partners will take the necessary steps in each individual case.
e) Right to restriction of processing
Any person affected by the processing of personal data has the right granted by the European legislator to request the controller to restrict processing if one of the following conditions 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, the data subject opposes the erasure of the personal data and requests the restriction of use of the personal data instead.
- The controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise, or defense of legal claims.
- The data subject has objected to the processing pursuant to Art. 21 (1) GDPR and it is not yet clear 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 Sontheimer + Partners, they may contact an employee of the controller at any time. The Sontheimer + Partners employee will arrange for the restriction of processing.
f) Right to data portability
Any person affected by the processing of personal data 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 this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out using automated means, unless the 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, when exercising their right to data portability pursuant to Art. 20 (1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another controller, insofar as this is technically feasible and does not adversely affect the rights and freedoms of others. To assert the right to data portability, the data subject may contact an employee of Sontheimer + Partners at any time.
g) Right to object
Any person affected by the processing of personal data 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 carried out on the basis of Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions. In the event of an objection, Sontheimer + Partners will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or the processing serves to assert, exercise, or defend legal claims.
If Sontheimer + Partners ever uses personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing purposes. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to Sontheimer + Partners processing their data for direct marketing purposes, Sontheimer + Partners will no longer process the personal data for these purposes.
In addition, the data subject has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them carried out by Sontheimer + Partners for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 (1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.
To exercise the right to object, the data subject may contact any employee of Sontheimer + Partners directly. The data subject is also free to exercise their right to object in relation to the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.
i) Right to withdraw consent under data protection law
Any person affected by the processing of personal data has the right, granted by European directives and regulations, to withdraw their consent to the processing of personal data at any time.
If the person concerned wishes to exercise their right to withdraw consent, they can contact an employee of the controller at any time.
9. Data protection provisions regarding the use of MATOMO
The controller has integrated the MATOMO component into this website. MATOMO is an open-source software tool for web analysis. Web analysis is the collection, gathering, and evaluation of data about the behavior of visitors to websites. A web analysis tool collects, among other things, data about which website a data subject came to a website from (a so-called referrer), which subpages of the website were accessed, or how often and for how long a subpage was viewed. Web analysis is mainly used to optimize a website.
The software is operated on the server of the controller, and the log files, which are sensitive in terms of data protection, are stored exclusively on this server.
The purpose of the MATOMO component is to analyze visitor traffic on our website. The controller uses the data and information obtained to evaluate the use of this website, among other things, in order to compile internal reports that show the activities on our website.
MATOMO sets a cookie on the system of the data subject. What cookies are has already been explained above. Setting the cookie enables us to analyze the use of our website. Each time one of the individual pages of this website is accessed, the MATOMO component automatically causes the Internet browser on the system of the data subject to transmit data to our server for the purpose of online analysis. As part of this technical process, we receive personal data, such as the IP address of the data subject (anonymized), which we use, among other things, to track the origin of visitors and clicks.
The cookie is used to store personal information, such as the access time, the location from which access originated, and the frequency of visits to our website. Each time you visit our website, this personal data, including the IP address (anonymized) of the Internet connection used by the data subject, is transmitted to our server. This personal data is stored by us. We do not pass this personal data on to third parties.
As described above, the data subject can prevent the setting of cookies by our website at any time by adjusting the settings of the Internet browser used and thus permanently object to the setting of cookies. Such a setting in the Internet browser used would also prevent MATOMO from setting a cookie on the data subject's system. In addition, a cookie already set by MATOMO can be deleted at any time via an Internet browser or other software programs.
Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by MATOMO relating to the use of this website. To do this, the data subject must set an opt-out cookie. If the data subject's information technology system is deleted, formatted, or reinstalled at a later date, the data subject must set an opt-out cookie again.
However, setting the opt-out cookie may mean that the data controller's websites are no longer fully usable for the data subject.
Further information and the applicable data protection provisions of MATOMO can be found at matomo.org.
10. Presence on social networks (social media)
We maintain an online presence on social networks and process user data in this context in order to communicate with users active there or to provide information about us.
We would like to point out that user data may be processed outside the European Union. This may pose risks for users, as it could make it more difficult to enforce their rights, for example.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be most effectively asserted with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. However, if you still need help, you can contact us.
A) Types of data processed:
Inventory data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., entries in online forms), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
B) Data subjects:
Users (e.g., website visitors, users of online services).
C) Purposes of processing:
Contact requests and communication, tracking (e.g., interest/behavior-based profiling, use of cookies), remarketing, reach measurement (e.g., access statistics, recognition of returning visitors).
D) Legal basis:
Legitimate interests (see below, Art. 6 (1) (f) GDPR).
E) Services used and service providers:
a) LinkedIn: Social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: www.linkedin.com; Privacy policy: www.linkedin.com/legal/privacy-policy; Opt-out option: www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
b) YouTube: We host our videos on the video portal “YouTube” operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: “Google”). The implementation is based on Art. 6 (1) (f) GDPR, whereby our interest lies in the smooth integration of the videos and the appealing design of our website. In doing so, we use the “extended data protection mode” option provided by Google.
When you visit a page that has an embedded video, a connection to the Google servers is established and the content is displayed on the website by notifying your browser.
According to Google, in “extended data protection mode,” your data—in particular, which of our web pages you have visited and device-specific information, including your IP address—will only be transmitted to the YouTube server in the USA when you watch the video. By clicking on the video, you consent to this transmission. If you are logged in to Google at the same time, this information will be assigned to your YouTube member account. You can prevent this by logging out of your member account before visiting our website. In some cases, information is transmitted to the parent company Google Inc. based in the USA, to other Google companies and to external partners of Google, which may be located outside the European Union. Google uses standard contractual clauses approved by the European Commission for this purpose and relies on the adequacy decisions issued by the European Commission with regard to certain countries.
For more information on data protection in connection with YouTube, please refer to Google's privacy policy: policies.google.com/privacy