§ 1 Information regarding the collection of personal data
(1) Below, we provide information on the collection of personal data within our services. Personal data are all data that are personally referable to you, so for example, name, address, email addresses, user behaviour.
(2) Data controller responsible for processing the data collected on this site per Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is
EFJ Advisory Partners GmbH
70195 Stuttgart, Germany
Represented by its Managing Directors Florian Edelmann, Julian Edelmann
A data protection officer has not been appointed.
(3) When you contact us by email or via an application contact form, we will store the data (surname, first name, email address, age, address, information on personal circumstances, your professional situation, your phone number) you provide in order to answer and process your concern and your enquiry as best as possible. We will delete the data collected within this context as soon as processing is no longer necessary, or alternatively, if any obligation of statutory retention exists, processing will be limited. If no contractual relationship with us comes about, the personal data collected in the course of the initiation will be deleted by us immediately.
(4) In case we employ contracted service providers for individual functions of our offer, or would like to use your data for advertising purposes, we will inform you in detail about the respective processes. We will also specify the defined criteria for the storage period.
§ 2 Your rights
(1) You have the following rights concerning us regarding your personal data:
– The right to be informed,
– The right of correction or deletion,
– The right to limitation of processing,
– The right to objection to the processing,
– The right to data portability.
(2) You also have the right to lodge a complaint with a data protection supervisory authority concerning our processing of your personal data. The State Commissioner for Data Protection and Freedom of Information (Landesbeauftragte für den Datenschutz und die Informationsfreiheit) Baden-Württemberg in Stuttgart is responsible for us.
§ 3 Collection of personal data when using our services
(1) If you use our websites solely for information purposes, that is, if you do not register or otherwise provide us with information, we will only collect the personal data that your browser transmits to our server. If you wish to view our website, we will collect the following data, which is technically necessary to enable us to display our website to you and to guarantee stability and security (legal basis is Art. 6 (1) clause 1 lit. f) GDPR):
– IP address
– The date and time of your access
– Your time zone
– The content of the request (concrete page)
– Access status/HTTP status code
– Amount of data transferred
– The website making the request
– Your browser
– Your operating system and device
– Language and version of browser software.
(2) In addition to the aforementioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard disk in association with the browser you are using and by which the party which sets the cookie (in this case, us) receives certain information. Cookies cannot run programs or transfer viruses to your computer. They serve to make our website more user-friendly and effective overall.
a) Our offers use the following types of cookies, the scope and functionality of which are explained below:
– Transient cookies (see b)
– Persistent cookies (see c).
b) Transient cookies are automatically deleted when you close the browser. These include session cookies, in particular. These store a so-called session ID, with which various requests from your browser can be assigned to the common session. This allows your computer to be recognised when you return to our website. Session cookies are deleted when you log out or close the browser.
c) Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie in question. You can delete the cookies in the security settings of your browser at any time.
d) You can configure your browser settings as desired and refuse to accept our cookies or those of any third party. However, please note that, if you do so, you may not be able to use all the functions of this website.
f) Flash cookies used are not stored by your browser, but rather by your Flash plug-in. We also use HTML5 storage objects, which are stored on your mobile device. These objects store the required data, independently of your browser, and they do not have an automatic expiry date. If you do not wish the Flash cookies to be processed, you must install an appropriate add-on, e.g. “Better Privacy” for Mozilla Firefox (https://addons.mozilla.org/de/firefox/addon/betterprivacy/) or the Adobe Flash killer cookie for Google Chrome. You can prevent the use of HTML 5 storage objects by using private mode in your browser. We also recommend that you regularly delete your cookies and your browser history manually.
§ 4 Further features and offers on our website
(1) In addition to the purely informative use of our website, we offer various services that you can use if you are interested. For this purpose, you must provide further personal data, which we will use to provide the respective service and to which the aforementioned data processing principles apply.
(2) In some cases, we use external service providers to process your data. They have been carefully selected and commissioned by us, and they are bound by our instructions and checked regularly.
(3) Furthermore, we may disclose your personal data to third parties if we offer promotions, competitions, contracts or similar services together with partners. For more information, please provide your personal data or see the description of the offer below.
(4) If our service providers or partners are located in a country outside the European Economic Area (EEA), we will inform you of the consequences of this circumstance in the description of the offer.
§ 5 Objection to or revocation of your consent for the processing of your data
(1) If you have given your consent to the processing of your data, you can revoke this at any time. If you exercise this right, it will affect our ability to process your personal data for which you have given your consent.
(2) Insofar as we base the processing of your personal data on the balance of interests, you may object to the processing. This is the case if processing is not necessary, particularly for the fulfilment of a contract with you. This is described in the following descriptions of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have been doing. In the event of your justified objection, we will examine the situation and either stop or adjust the data processing or point out to you our compelling legitimate grounds, on the basis of which we will continue processing the data.
(3) You may of course object to the processing of your personal data for advertising and data analysis purposes at any time. You can inform us about your objection to the processing for advertising purposes via the following contact information:
§ 6 Newsletter / Mailings
(1) With your consent, you can, if necessary, subscribe to our newsletter/mailing, which we use to keep you informed about our services and individual programs.
(2) To subscribe to our newsletter/mailing, we use the “double opt-in” procedure. This means that after you have registered, we will send you an email to the email address provided, in which we will ask you to confirm that you wish to receive the newsletter. If you do not confirm the registration, your information will be blocked and automatically deleted. We will also store your IP address and the time of registration and confirmation. The purpose of this process is to verify your registration and, if necessary, resolve any possible misuse of your data.
(3) The only mandatory information we require for sending the newsletter/mailing is your email address and your first name. The provision of further, separately marked data is voluntary and used to address you personally. After your confirmation, we will save your email address for the purpose of sending the newsletter/mailing. The legal basis is Art. 6 (1) clause 1 lit. a) GDPR.
(4) You can revoke your consent to receive the newsletter at any time and unsubscribe from the newsletter. You can declare your revocation by clicking on the link provided in every newsletter email or by email to the email address or by contacting us in one of the ways listed in the legal notice.
§ 7 Use of Google Analytics
(1) We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files that are placed on your computer in order to analyse your use of our website. The information generated by the cookie on your use of the website is usually transmitted to and stored by Google on servers in the United States. However, if IP anonymisation is activated on this website, Google will first shorten your IP address in a member state of the European Union or in other states that are parties to the Agreement governing the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and truncated there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, compile reports on website activity and provide other services to the website operator relating to website activity and internet usage.
(2) The IP address provided by your browser in the framework of Google Analytics will not be combined with other data from Google.
(4) This website uses Google Analytics with the “_anonymizeIP()” extension. As a result, IP addresses are only processed in truncated form, in order to prevent Google from identifying specific individuals. If any of your data that is collected can identify you personally, it will be blocked immediately and deleted as soon as possible.
(5) We use Google Analytics to analyse and regularly improve the function of our website. The statistics we collect allow us to improve our site and make it more interesting for you as a user. Google has agreed to comply with the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework, with regard to any personal data which are transferred to the USA. The legal basis for the use of Google Analytics is Art. 6 (1) clause 1 lit. f) GDPR.
§ 8 Use of social media plug-ins
(1) We currently use the following social media plug-ins:
The data mentioned under Paragraph 3 of this declaration will be transmitted to Facebook. Facebook will anonymise your IP address immediately after it has been collected. By activating the plug-in, your personal data are transferred to the respective plug-in provider and stored there (in the case of US providers in the USA). Since the plug-in provider collects data mainly via cookies, we recommend that you delete all cookies using your browser’s security settings before clicking on the greyed-out box.
(2) We have no influence on the data collected and the platforms’ data processing nor are we aware of the full extent of data collection, the purposes of such processing, or for how long they will store your data. We also have no information on the deletion of the data collected by the plug-in provider.
(3) Facebook stores the data collected about you as user profiles and uses it for the purposes of advertising, market research, and/or demand-oriented design of its website. Such evaluation is also made for users who are not logged in, to display customised advertising, and to inform other users of the social network about your activities on our website. You have a right to object to the creation of these user profiles. You must contact the respective plug-in provider to exercise this right. Through the plug-ins, we offer you a way to interact with social networks and other users, so that we can improve our service and make it more interesting for you as a user. The legal basis for the use of the plug-ins is Art. 6 (1) clause 1 lit. f) GDPR.
(4) Data are passed on regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, your data collected from us will be assigned directly to your existing account with the plug-in provider. When activating the activated button and linking the page, for example, the plug-in provider also stores this information in your user account and communicates this to your contacts in public. We recommend that you log out regularly after using a social network, especially before activating the button, as this way you can avoid things being assigned to your profile by the plug-in provider.
(5) For more information on the purpose and extent of the data collection and its processing by Facebook, please refer to their respective privacy statements linked below. There you will also find further information about your rights and options for protecting your privacy.
(6) Facebook’s address and URL with data protection information:
Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA; http://www.facebook.com/policy.php; more information about data collection: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other#applications and http://www.facebook.com/about/privacy/your-info#everyoneinfo. Facebook has made itself subject to the EU-US privacy shield: https://www.privacyshield.gov/EU-US-Framework.
§ 9 Inclusion of YouTube videos
(1) We may have included YouTube videos in our online offers that are stored on http://www.YouTube.com and are directly playable from our website.
(2) By using our services, YouTube receives information that you have accessed the corresponding subpage of our website. Furthermore, the data mentioned under Paragraph 3 of this declaration will be transmitted to them. This takes place, regardless whether YouTube provides a user account, via which you are logged in, or if no user account exists. If you are logged into Google, your information will be directly associated with your account. If you do not wish to be associated with your profile when using YouTube, you must first log out before clicking the button. YouTube/Vimeo stores your data as usage profiles and uses it for the purposes of advertising, market research and/or requirements-oriented design of its website. Such evaluation also takes place (even for users who are not logged in) for the purposes of providing customised advertising and to inform other social network users about activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube/Vimeo to exercise this right.
§ 10 Use of Google AdWords Conversion
(1) We use the offer of Google Adwords to draw attention to our offers with the help of advertising materials (so-called Google Adwords) on external websites. We can determine how successful the individual advertising measures are in relation to the data from the advertising campaigns. In doing this, we are pursuing our interest in showing you advertisements which are of interest to you, in making our website more interesting for you and in achieving a fair calculation of advertising costs.
(2) This advertising media is delivered by Google via “Ad Servers”. For this purpose, we use Ad Server cookies through which certain parameters for measuring success can be measured, such as the display of advertisements or of clicks by users. If you access our website via a Google ad, Google Adwords will store a cookie on your device. These cookies usually expire after 30 days and are not used with the intention of personally identifying you. The unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (a mark that the user no longer wishes to be addressed) are usually stored as analysis values for this cookie.
(3) These cookies enable Google to recognise your internet browser. If you visit certain pages of an Adwords customer’s website and the cookie stored on your computer has not expired, both Google and the customer are able to recognise that you have clicked on the ad and have been redirected to this page. Each Adwords customer is assigned a different cookie. Thus, cookies cannot be tracked using the website of an Adwords advertiser. The aforementioned advertising measures/activities do not involve us collecting or processing any personal data. We only receive statistical evaluations from Google. We are able to recognise which of the advertising measures are particularly effective on the basis of these evaluations. We do not receive any further data from the use of advertising material; in particular, we cannot identify users on the basis of this information.
(4) Due to the marketing tools used, your browser is automatically able to establish a direct connection to the Google server. We therefore have no influence on the scope of the data collected by Google through its tools and therefore hereby notify you of the following, which represents the best of our knowledge: By including AdWords Conversion, Google receives the information that you have accessed the relevant part of our website or have clicked on an ad from us. If you are registered with a Google service, Google may associate your visit to our website with your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may obtain and store your IP address.
(5) You can prevent participation in this tracking process in various ways: a) by setting your browser software accordingly, in particular by suppressing third-party cookies so that you will not receive ads from third-party providers; b) by deactivating cookies for conversion tracking, by setting your browser to block cookies from the domain “www.googleadservices.com”, https://www.google.de/settings/ads, this setting being deleted when you delete your cookies; c) by deactivating the interest-based ads of the providers that are part of the “About Ads” self-regulation campaign via the link http://www.aboutads.info/choices, this setting being deleted when you delete your cookies; d) by permanently deactivating in your Firefox, Internet Explorer or Google Chrome browsers under the link http://www.google.com/settings/ads/plugin. Please note that in this case, you may not be able to use all functions of this site in full.
(6) The legal basis for processing is your consent under Art. 6 (1) clause 1 lit. f) GDPR. Further information on data privacy at Google can be found here: http://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/de.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at http://www.networkadvertising.org. Google has submitted to the EU-US privacy shield, https://www.privacyshield.gov/EU-US-Framework.
§ 11 Google remarketing
In addition to Adwords Conversion, we use the Google Remarketing application. This is a process we use to re-establish contact with you. This application allows us to show you our advertisements after you have visited our website whilst you continue to use the internet. This is done using cookies stored in your browser which allow Google to record and evaluate your usage behaviour when you visit various websites. This is how Google can determine your previous visit to our website. Google does not, according to its own statements, combine the data collected in the context of remarketing with your personal data which may be stored by Google. According to Google, remarketing uses pseudonymisation.
§ 12 DoubleClick by Google
(2) Due to the marketing tools used, your browser is automatically able to establish a direct connection to the Google server. We have no influence on the extent and the further use of the data which is collected by Google’s use of this tool, and we therefore inform you according to our knowledge: By integrating DoubleClick, Google receives the information that you accessed the relevant part of our online presence or clicked on one of our advertisements. If you are registered with a Google service, Google may associate your visit to our website with your account. Even if you are not registered with Google or have not logged in, it is possible that the provider may obtain and store your IP address.
(3) You can prevent participation in this tracking process in various ways: a) by setting your browser software accordingly, in particular by suppressing third-party cookies so that you will not receive ads from third-party providers; b) by deactivating cookies for conversion tracking, by setting your browser to block cookies from the domain “www.googleadservices.com”, https://www.google.de/settings/ads, this setting being deleted when you delete your cookies; c) by deactivating the interest-based ads of the providers that are part of the “About Ads” self-regulation campaign via the link http://www.aboutads.info/choices, this setting being deleted when you delete your cookies; d) by permanently deactivating in your Firefox, Internet Explorer or Google Chrome browsers under the link http://www.google.com/settings/ads/plugin. Please note that in this case, you may not be able to use all functions of this site in full.
(4) The legal basis for processing is your consent under Art. 6 (1) clause 1 lit. f) GDPR. For more information about DoubleClick by Google, please visit https://www.google.de/doubleclick and http://support.google.com/adsense/answer/2839090, and Google’s data privacy in general: https://www.google.de/intl/de/policies/privacy. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at http://www.networkadvertising.org. Google has submitted to the EU-US privacy shield, https://www.privacyshield.gov/EU-US-Framework.
§ 13 Google Fonts
This site uses web fonts provided by Google so as to be able to uniformly display web fonts. When you open a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly. To do this, the browser you use must connect to Google’s servers. As a result, Google learns that our website has been accessed via your IP address. The use of Google web fonts is in the interests of a consistent and attractive presentation of our online offers. This constitutes a legitimate interest in accordance with Art. 6 (1) lit. f) GDPR. If your browser does not support web fonts, a default font will be used by your computer.