Privacy policy (valid until 10/12/2020)

This Privacy Policy applies to HANSEKONTOR Maklergesellschaft mbH, HANSEKONTOR Nord West Maklergesellschaft mbH, HANSEKONTOR West Maklergesellschaft mbH, HANSEKONTOR Mitte Maklergesellschaft mbH and to HANSEKONTOR Süd Maklergesellschaft mbH.

The General Data Protection Regulation (hereafter GDPR) applies EU-wide. This Privacy Policy will inform you about the processing of personal data at our company in compliance with this regulation (cf. Art. 13 & 14 GDPR). If you have any questions or comments about this Privacy Policy, please do not hesitate to contact us at the email address provided in Sections 2 & 3.

Contents:

1. Overview
   1. Applicability
   2. Controller
   3. Data Protection Officer
   4. Data Security
      
      
2. Data Processing Details
   1. Data Processing
   2. Visiting the Website/Application
   3. Newsletter
   4. Applications
   5. Customer Support
   6. Tracking with Google Analytics
      
      
3. Data Subject Rights
   1. Right to Object
   2. Right of Access
   3. Right to Rectification
   4. Right to Erasure ("Right to be Forgotten")
   5. Right to Restriction of Processing
   6. Right to Data Portability
   7. Withdrawal of Consent
   8. Right to Lodge a Complaint
      
      
4. Glossary

This section of our Privacy Policy will inform you about the applicability of this Privacy Policy and about the data processing controller, the data protection officer and data security.

1. Applicability

   Data processing can be divided into two categories:
   All the data necessary for the execution of a contract will be processed for this purpose. If external service providers are involved in the execution of a contract, your data will be transferred to them to the necessary extent.

   When you visit our website/applications, various information will be exchanged between your device and our server. This may include personal data.

2. Controller

   The data controller—i.e., the person who decides on the purposes and means of personal data processing —for the services is the respective managing director of the individual company (see Imprint)

3. Data Protection Officer

   You may contact our data protection officer as follows: Contact Form

   DS EXTERN GmbH
   Dipl.-Kfm. Marc Althaus
   Bredkamp 53a
   D-22589 Hamburg
   Germany

4. Data Security

   To implement the measures required under Art. 32 GDPR and achieve a risk-adequate level of protection, we have established an information security management system at our company.

This section of our Privacy Policy will inform you in detail about the processing of personal data as part of our services. For the sake of clarity, we will structure this information according to the functionalities of our services. In the normal course of using the services, different functionalities and therefore different processing operations may take effect one after the other or simultaneously.

1. Data Processing

   Unless otherwise stated, the following applies to the processing described hereafter:

   1. No Duty to Disclose

      There is no contractual or legal duty to disclose personal data. You are not required to provide personal data.

   2. Consequences of Non-Disclosure

      For necessary data (data marked as mandatory on the entry form), non-disclosure means that the respective service cannot be performed. Non-disclosure may also prevent our services from being provided in the same form or with the same quality.

   3. Consent

      In a number of cases you have the option of granting us your consent to further processing in connection with the processing operations described below (where applicable, for part of the data). In these cases we will inform you separately, in connection with the submission of the respective declaration of consent, about all the modalities and the scope of the consent and about the purposes that we pursue with these processing operations.

   4. Transmission of Personal Data to Third Countries

      We will only transmit data to third countries, i.e., countries outside of the European Union, in compliance with the applicable legal admissibility requirements.

      The admissibility requirements are regulated in Art. 44 – 49 GDPR.

   5. Hosting by External Service Providers

      To a large extent, we process data through so-called hosting service providers who provide memory and processing capacities to us at their data centers and process personal data on our behalf and according to our directives. These service providers either process data exclusively in the EU or we will guarantee an adequate level of data protection through EU standard data protection clauses.

   6. Transmissions to Public Authorities

      We will transmit personal data to public authorities (including law enforcement authorities) if required by law (legal basis: Art. 6(1) Letter c GDPR) or for the exercise, establishment or defense of legal claims (legal basis: Art. 6(1) Letter f GDPR).

   7. Storage Duration

      We will only store your data for as long as it is necessary for the respective processing purposes. If the data is no longer necessary for the fulfillment of legal or contractual obligations, the data will be erased, unless continued temporary storage is necessary. Reasons for this may include:

      - Commercial and tax law storage obligations
      - Maintaining evidence for legal disputes within limitation periods

      Likewise, we may continue to store your data with your express consent.

   8. Data Categories

      Personal master data: Title, gender, first name, last name, date of birth

      Address data: Street, house number, address additions if applicable, ZIP code, city, country

      Contact data: Telephone number(s), fax number(s), email address(es)

      Registration data: Information about the service you have registered for; times and technical information about registration, confirmation and cancellation; data provided by you during registration.

      Applicant data: CV, reports, certificates, work samples, images

      Company figures: Revenue, balance sheet

2. Website/Application

   This section will inform you about how we process your personal data when you are using our services. Please note that, due to the nature of information transfer on the Internet, the transmission of access data to external content providers (see Letter b below) is unavoidable.

   a. Information about processing
   Data category	Intended purpose	Legal basis	Legitimate interest, if applicable	Storage duration
   Access data	Connection, display of service content, discovery of attacks on our pages through suspicious activities, troubleshooting	Art. 6(1) Letter f GDPR	Proper service functionality, security of data and business processes, prevention of misuse, prevention of damage caused by information systems interference	7 days

   b. Personal Data Recipients
   Recipient category	Data concerned	Legal basis of transmission	Legitimate interest, if applicable
   External content providers who provide contents (e.g., images, videos, embedded posts from social networks, advertising banners, fonts, update information) necessary for displaying our services	Access data	Commissioned processing (Art. 28 GDPR)	Orderly functioning of services, (accelerated) content displays
   IT security service provider	Access data	Commissioned processing (Art. 28 GDPR)	Preventing attacks and exploitation of security gaps/vulnerabilities

   c. External content providers who transfer personal data to third countries
   Service description	Function	Data transfer to third countries	If applicable, adequacy decision (Art. 45 GDPR)	If applicable, appropriate safeguards (Art. 46 GDPR)
   Google Maps	Included to offer directions	Yes	Proper function of services, security of data and business processes, prevention of abuse and protection against damage caused by information system interreference	EU-US Privacy Shield: www.privacyshield.gov/participant

    

3. Newsletter

   This section describes what happens to your personal data when subscribing to our newsletter

   a. Information about processing
   Data category	Intended purpose	Legal basis	Legitimate interest, if applicable	Storage duration
   Email address	Verification of registration (closed-loop authentication), sending the newsletter	Art. 6(1) Letter b GDPR		Duration of newsletter subscription
   Personal master data	Personalization of the newsletter	Art. 6(1) Letter b GDPR		Duration of newsletter subscription
   Registration data	Traceability of newsletter subscription/confirmation/unsubscription	Art. 6(1) Letters b & f GDPR	Proof of newsletter subscription/confirmation/unsubscription	Duration of newsletter subscription
   Newsletter user profile data	Interest aligned design of the newsletter	Art. 6(1) Letter f GDPR	Service improvement, advertising purposes	Duration of newsletter subscription

   b. Personal Data Recipients
   Recipient category	Data concerned	Legal basis for transmission	Legitimate interest, if applicable
   Newsletter sending service provider	All data under “a”	Commissioned processing (Art. 28 GDPR)

4. Applicants

   We will process your personal data as follows for application purposes:

   a. Information about processing
   Data category	Intended purpose	Legal basis	Legitimate interest, if applicable	Storage duration
   Address data, contact details	Identification, contacting, communication for contract conclusion	Art. 6(1) Letter b GDPR		6 months
   Personal master data	Identification, contacting, age verification	Art. 6(1) Letter b GDPR		6 months
   Applicant data	Applicant selection	Art. 6(1) Letter b GDPR		6 months

   b. Personal Data Recipients
   Recipient category	Data concerned	Legal basis for transmission	Legitimate interest, if applicable
   Service provider/tools, if applicable
   Job portals	Identification, contacting, communication for contract conclusion	Art. 6(1) Letter b GDPR
   Martens & Prahl Versicherungskontor GmbH & Co. KG (Holding)	Applicant selection, identification, contacting, communication for contract conclusion	Art. 6(1) Letter b GDPR

5. Customer Support

   This section describes how your personal data may be processed and how you may contact our customer support:

   a. Information about processing
   Data category	Intended purpose	Legal basis	Legitimate interest, if applicable	Storage duration
   Personal master data, contact details, contents of inquiries/complaints	Customer inquiry and user complaint handling	Art. 6(1) Letters b & f GDPR	Customer loyalty, service improvement	Inquiry handling

   b. Personal Data Recipients
   Recipient category	Data concerned	Legal basis for transmission	Legitimate interest, if applicable
   Service providers: ID Netsolution GmbH, Segeberstr. 9 -13a, 23863 Kayhude, Germany, email: servicedesk@idmx.de Q-Data Service GmbH, Sachsenstraße 7, 20097 Hamburg, Germany, email: service@qds.de
   Company name	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Insurance companies	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Cooperating brokers	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Underwriting agents	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Reinsurance companies	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Broker pools	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Technical service providers	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Tip providers	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Social insurance carriers	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Insurance ombudsmen	All data under Letter a	Art. 6(1) Letters b & f GDPR
   BaFin [German Federal Financial Supervisory Authority]	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Attorneys	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Tax advisors	All data under Letter a	Art. 6(1) Letters b & f GDPR
   Legal successors	All data under Letter a	Art. 6(1) Letters b & f GDPR

6. Tracking with Google Analytics

   This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

   Google Analytics uses so-called cookies. Cookies are text files, which are stored on your computer and that enable an analysis of the use of the website by users. The information generated by cookies on your use of this website is usually transferred to a Google server in the United States, where it is stored.

   The storage of Google Analytics cookies and the utilization of this analysis tool are based on Art. 6 Sect. 1 lit. f GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities.

   IP anonymization

   On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyse your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

   Browser plug-in

   You do have the option to prevent the archiving of cookies by making pertinent changes to the settings of your browser software. However, we have to point out that in this case you may not be able to use all of the functions of this website to their fullest extent. Moreover, you have the option prevent the recording of the data generated by the cookie and affiliated with your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link:

   https://tools.google.com/dlpage/gaoptout?hl=en.

   Objection to the recording of data

   You have the option to prevent the recording of your data by Google Analytics by clicking on the following link. This will result in the placement of an opt out cookie, which prevents the recording of your data during future visits to this website:
   Google Analytics deactivation.

   For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at:
   https://support.google.com/analytics/answer/6004245?hl=en.

   Archiving period

   Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 month. For details please click the following link:
   https://support.google.com/analytics/answer/7667196?hl=de

1. Right to Object

   You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you.

   You may exercise this right to object free of charge.

2. Right of Access

   You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, which personal data this is.

3. Right to Rectification

   You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you.

4. Right to Erasure (“Right to be Forgotten”)

   You have the right to obtain from us the erasure of personal data concerning you without undue delay.

5. Right to Restriction of Processing

   You have the right to obtain from us restriction of processing for personal data concerning you.

6. Right to Data Portability

   You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to have the personal data transmitted directly from us to another controller.

7. Withdrawal of Consent

   You have the right to withdraw your consent at any time for the future.

8. Right to Lodge a Complaint

   You have the right to lodge a complaint with a competent supervisory authority.

Commissioned processor: A natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Browser: Computer program for accessing websites (e.g., Chrome, Firefox, Safari)

Cookies: In relation to the World Wide Web, cookies mean small text files that are saved locally on the user's computer when visiting a website. These files save data on the user's behavior. Opening one's browser and visiting the same website again will activate the cookie which will transmit information on the user's surfing behavior to the web server based on the data saved by the cookie.

In this regard, cookies are not edible, but information saved locally in a small text file on a user's computer when they visit a website. This may include the user's page settings or information on the user collected independently by the website. These locally saved text files may subsequently be read by the web server that installed them. Most browsers accept cookies automatically. You may manage cookies through your browser settings (usually under "Options" or "Settings"). This allows you to disable, limit or require your consent for the saving of cookies. You may also delete cookies at any time.

Third countries: Countries not bound to the legal requirements of the EU General Data Protection Regulation (a country outside of the EEA).

Personal data: Any information relating to an identified or identifiable natural person; 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.

Pixel: Pixels are also referred to as tracking pixels, web beacons or web bugs. These are small non-visible graphics in HTML emails or on websites. When a document is opened, this small image is loaded by a server on the Internet where the download will be registered. This allows the server operators to see whether and when an email is opened or a website is visited. This is usually achieved by activating a small program (JavaScript). This enables certain types of information on your computer system to be recognized and transmitted, e.g., the contents of cookies, the time and date of page access or a description of the page featuring the tracking pixel.

Profiling: any automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects of that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or movements.

Services: Our offers subject to this Privacy Policy (see Applicability).

Tracking: Collection and assessment of data or user behavior when using our services.

Tracking technologies: Tracking may be performed through the log files saved on our web servers or through data collected from your device via pixels, cookies or similar tracking technologies.

Processing: 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, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.