Privacy Policy

We are very pleased about your interest in our company. Data protection (all to be read here in the Privacy Policy) is of a particularly high priority for the management of Circolution. The use of the Internet pages of the Circolution is possible without any indication of personal data. However, if a data subject wants to use special services of our enterprise via our website, processing of personal data could become necessary. If processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation, and in accordance with the country-specific data protection regulations applicable to the Circolution. By means of this data protection declaration, our enterprise would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this data protection declaration.

As the controller, the Circolution has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can always be vulnerable to security risks, 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 in writing.

1. definitions
The data protection declaration of the Circolution is based on the notions used by the European Directive and Ordinance when issuing the Data Protection Regulation (DS-GVO). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

a) Personal dataPersonal data means any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subjectData subject means any identified or identifiable natural person whose personal data are processed by the controller.
c) ProcessingProcessing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processingRestriction of processing is the marking of stored personal data with the aim of limiting their future processing.
e) ProfilingProfiling is any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
f) PseudonymizationPseudonymization is the processing of personal data in such a way 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 separate 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 data controllerThe controller or data processor 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 determined by Union or Member State law.

h) ProcessorA processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) RecipientRecipient means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.
j) Third PartyThird party means a natural or legal person, public authority, agency or other body other than the Data Subject, the Controller, the Processor and the persons authorized to process the Personal Data under the direct responsibility of the Controller or the Processor.
k) ConsentConsent shall mean any freely given indication of the data subject’s wishes for the specific case in an informed and unambiguous manner, in the form of a statement or any other unambiguous affirmative act by which the data subject indicates that he or she consents 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:

circolution GmbH
Munich Street 10
60329 Frankfurt
Germany

e-mail: info@circolution.com

Website: www.circolution.com

3. cookies
The internet pages of Circolution use cookies. Cookies are text files that are placed and stored on a computer system via an internet browser.

Numerous internet pages and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters by which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the visited Internet pages and servers to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID.

Through the use of cookies, the Circolution can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized in the sense of the user. Cookies allow us, as already mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter his or her access data each time he or she visits the website, because this is handled by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online store. The online store remembers the items that a customer has placed in the virtual shopping cart via a cookie.

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

4. collection of general data and information
The website of the Circolution collects a series of general data and information with each call-up of the website by a data subject or automated system. This general data and information is stored in the log files of the server. The following data 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 accesses 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 an access to the website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.

When using these general data and information, the Circolution does not draw any conclusions about the data subject. Rather, this information is needed (1) to deliver the contents of our website correctly, (2) to optimize the contents of our website and the advertising for these, (3) to ensure the long-term functionality of our information technology systems and the technology of our website, and (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Therefore, the Circolution analyzes anonymously collected data and information on one hand, and on the other hand, with the aim of increasing the data protection and data security of our enterprise, to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.

5. subscription to our newsletter
On the website of the Circolution, users are given the opportunity to subscribe to our enterprise’s newsletter. The personal data transmitted to the controller when the newsletter is subscribed to is specified in the input mask used for this purpose.

The Circolution informs its customers and business partners at regular intervals by means of a newsletter about enterprise offers. The newsletter of our enterprise can basically only be received by the data subject, if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter mailing. For legal reasons, a confirmation e-mail will be sent to the e-mail address entered by a data subject for the first time for newsletter dispatch using the double opt-in procedure. This confirmation e-mail serves to verify whether the owner of the e-mail address as the data subject has authorized the receipt of the newsletter.

When registering for the newsletter, we also store the IP address of the computer system used by the data subject at the time of registration, as assigned by the Internet service provider (ISP), as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject’s e-mail address at a later point in time and therefore serves as a legal safeguard for the controller.

The personal data collected in the context of a registration for the newsletter are used exclusively for sending our newsletter.

Furthermore, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service or a related registration, as could be the case in the event of changes to the newsletter offer or changes in the technical circumstances. No personal data collected as part of the newsletter service will be passed on to third parties. The subscription to our newsletter can be cancelled by the data subject at any time. The consent to the storage of personal data that the data subject has given us for the newsletter mailing can be revoked at any time. For the purpose of revoking consent, a corresponding link can be found in each newsletter. Furthermore, it is also possible to unsubscribe from the newsletter mailing directly on the website of the controller at any time or to inform the controller of this in another way.

6 Newsletter tracking
The newsletters of the Circolution contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in such emails that are sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the Circolution may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by the data subject.

Such personal data collected via the tracking pixel contained in the newsletters are stored and analyzed by the controller in order to optimize the newsletter dispatch and to better tailor the content of future newsletters to the interests of the data subject. This personal data will not be disclosed to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via the double opt-in procedure. After a revocation, this personal data will be deleted by the controller. The Circolution automatically regards a withdrawal from the receipt of the newsletter as a revocation.

7. contact possibility via the website
Based on statutory provisions, the website of the Circolution contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or by using a contact form, the personal data transmitted by the data subject will be stored automatically.

Such personal data transmitted on a voluntary basis by a data subject to the controller will be stored for the purposes of processing or contacting the data subject. There is no disclosure of this personal data to third parties.

8. routine erasure and blocking of personal data.
The controller processes and stores personal data of the data subject only for the period of time necessary to achieve the purpose of storage or insofar as this has been provided for by the European Directive and Regulation or other legislator in laws or regulations to which the controller is subject.

If the storage purpose ceases to apply or if a storage period prescribed by the European Directive and Regulation Maker or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

9. rights of the data subject
a) Right to confirmationEvery data subject has the right, granted by the European Directives and Regulations legislator, to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact any employee of the controller.
b) Right of accessEvery data subject concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to obtain at any time from the controller, free of charge, information about personal data concerning him or her, and a copy of such information. In addition, the European Directive and Regulation Legislator has granted the data subject access to the following information:
the purposes of processing
the categories of personal data processed
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations
if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
the existence of a right to obtain the rectification or erasure of personal data concerning him or her, or to obtain the restriction of processing by the controller, or a right to object to such processing
the existence of a right of appeal to a supervisory authority
if the personal data are not collected from the data subject: Any available information about the origin of the data.

This data protection declaration was created by the data protection declaration generator of the DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as the External Data Protection Officer Munich, in cooperation with the data protection lawyer Christian Solmecke.