Data Policy

Responsible

Responsible body in the sense of the Basic Data Protection Regulation (DSGVO), is:

PSI Transcom GmbH
Dircksenstraße 42-44
D-10178 Berlin

Phone: +49 30 2801-1610
Telefax: +49 30 2801-1032
E-Mail: 
Internet: www.psitranscom.de

Management:
Dipl.-Ing, Dipl.-Wirtsch.-Ing. (FH) Torsten Vogel

Contact details of our data protection officer:

Christian Regnery
PSI Software AG
Dircksenstraße 42-44
10178 Berlin

or
E-Mail:

Information on the processing of your personal data

PSI Transcom GmbH takes the protection of personal data very seriously. Therefore, we treat your personal data confidentially and comply with the legal provisions on data protection, and here specifically the European Data Protection Regulation (DSGVO), the Federal Data Protection Act (BDSG) and the Telecommunications and Telemedia Data Protection Act (TTDSG). Therefore, we would like to inform you below which data of your visit will be used for which purposes.

Scope of the processing of personal data

As a matter of principle, we only collect data whose processing is either required by law, contractually agreed, necessary for the conclusion and performance of the contract, or voluntarily provided to us on the basis of consent.

We collect, store and use personal data from you as a visitor to our websites only to the extent necessary to provide functional websites and to present our content and services. Beyond that, the collection and use of your personal data is regularly only carried out with your consent. An exception applies in those cases where it is not possible to obtain prior consent for factual reasons and the processing of the data is permitted by legal regulations.

 

1. Data processing for contract fulfillment
   

When processing personal data that is necessary for the performance of a contract to which you are a party, Art. 6 (1) lit. b DSGVO serves as the legal basis. This also applies to processing operations that are necessary for the implementation of pre-contractual measures.

1. Data processing on the basis of consent

Insofar as we obtain your consent for processing operations of personal data, Art. 6 (1) lit. a DSGVO serves as the legal basis for the data processing. We only base the processing of your personal data on consent if processing is not already justified on other legal grounds.

We also request consent if we wish to provide information about the company’s own products and services as well as events and corresponding data processing to protect legitimate interests is not possible (see also below).

 

3. Data processing for the protection of legitimate interests
   

We only process your personal data in accordance with Art. 6 (1) lit. f DSGVO to protect legitimate interests if the further requirements of Art. 6 (1) lit. f DSGVO are met, i.e. if our interests in the data processing or the interests of a third party outweigh your interests or fundamental rights and freedoms in the individual case.

Furthermore, we use your personal data if and insofar as this is necessary to protect our legitimate interests, for example, to defend and enforce claims. In this respect, too, the data processing is based on Art. 6 para. 1 lit. f DSGVO.

 

4. Data processing for the fulfillment of legal obligations

If and to the extent necessary, we process your personal data in order to comply with any statutory documentation obligations, e.g. vis-à-vis tax offices and supervisory and investigative authorities. In this case, the data processing is based on Art. 6 para. 1 lit. c DSGVO. A legal obligation arises in particular from § 147 AO.

5. Processing of personal data for the protection of vital interests

In rare cases, processing of your personal data may be necessary for your vital interests or those of another natural person. Here, Art. 6 para. 1 lit. d DSGVO is the legal basis. 

Deletion or blocking of data

We adhere to the principles of data avoidance and data economy. We therefore only store your personal data for as long as is necessary to achieve the purposes stated here or as stipulated by the various storage periods provided for by law. After the respective purpose has ceased to exist or these periods have expired, the corresponding data is routinely blocked or deleted in accordance with the statutory provisions.

Data protection and security (TSL/SSL procedure)

As a rule, it is possible to use our website without providing personal data. Insofar as personal data (e.g. name, address or e-mail addresses) is collected on our website, this is always done on a voluntary basis as far as possible.

If you transmit your personal data to us via our websites, we use current secure technologies, in particular the so-called „Transport Layer Security“ transmission (TLS) (previously also known as „Secure Socket Layer“ transmission (SSL)), with the highest security level supported by your browser. All information and data transmitted using these secure methods is encrypted before it is sent to us. To further protect you and us from misuse, the IP address of your computer is transmitted to us. We would like to point out that encryption using these technical methods only works if the corresponding technical requirements are also met on your side. In addition, data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible. 

Cookies

To make visiting our websites attractive and to enable the use of certain functions, we use so-called cookies. Cookies are small text files that are automatically stored on your terminal device. The cookies we use are deleted at the end of the browser session, i.e. after closing the browser (so-called session cookies). 

Processing operations

Technically necessary data processing operations

Each time our websites are called up, our system automatically collects data and information from the computer system of the calling computer.

The following data is collected:

• Browser type and browser version
• Date and time of the visit to the website
• Duration of the visit to the website
• Internet page/source/reference from which the visit to the website is made.

This data is not stored together with your other personal data.

The temporary storage of the IP address by the system is necessary to enable delivery of the websites to your computer. For this purpose, your IP address must remain stored for the duration of the session. The storage in log files is done to ensure the functionality of the websites. In addition, we use the data to optimize the websites and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

This is also our legitimate interest in data processing within the meaning of Art. 6 (1) lit. f DSGVO, which serves as the legal basis for the processing of your personal data.

The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the collection of data for the provision of the websites, this is the case when the respective session has ended. In the case of storage of data in log files, this is the case after seven days at the latest. Storage beyond this period is possible. In this case, your IP address will be deleted or alienated, so that an assignment of the calling client is no longer possible.

The collection of data for the provision of the websites and the storage of the data in log files is absolutely necessary for the operation of the websites. Consequently, there is no possibility to object.

Data recipient

Your personal data may be passed on by us to third parties. We will only transfer your personal data to third parties if we are authorized to do so under data protection law.

The transfer of data to third parties is based either on the fulfillment of legal obligations, on legitimate interests, on the need to fulfill a contract or on the basis of any consent given. Insofar as the external service provider acts as a processor, the data transfer takes place within the framework of a contract processing agreement (AVV). If a data transfer to processors in countries outside the European Economic Area (EEA) is necessary, this will take place in countries for which an EU adequacy decision is available or on the basis of the EU standard contractual clauses, if necessary supplemented by a transfer impact assessment.

Emails and contact form

If you contact us by e-mail, the personal data you send us with your e-mail will be stored. In addition, there is the possibility to use the contact form on the website. The data you enter in the input mask will be transmitted to us and stored: Salutation, first name, last name, e-mail address, telephone number, subject, message. In addition, we record your IP address and the time of sending.

We need your e-mail address to send you our reply. The other data enables us to address you personally (title, first name, last name).

The processing of your personal data is based on your consent in accordance with Art. 6 para. 1 lit. a DSGVO.

Data subject rights

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights against us as the controller:

Right to information

You may request confirmation from us as to whether your personal data is being processed by us. If such processing is taking place, you may request information about the following from us in accordance with Article 15 of the GDPR:

• the purposes for which your personal data are processed
• the categories of personal data which are processed
• the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed
• the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage duration
• the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by us or a right to object to such processing
• the existence of a right of appeal to a supervisory authority
• any available information about the origin of the data, if the personal data is not collected from the data subject
• the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and – at least in these cases – meaningful information about the logic involved and the scope and intended effects of such processing on you.

Furthermore, you have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 DSGVO in connection with the transfer.

 

Right to rectification

Pursuant to Art. 16 DSGVO, you have a right to rectification and/or completion vis-à-vis us if the processed data concerning you is incorrect and/or incomplete. We must carry out the correction without delay.

 

Right to restriction of processing

Under the following conditions, you may request the restriction of the processing of personal data concerning you in accordance with Art. 18 GDPR:

• if you dispute the accuracy of the personal data concerning you for a period of time that allows us to verify the accuracy of the personal data
• the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data
• we no longer need the personal data for the purposes of processing, but you need them for the assertion, exercise or defense of legal claims; or
• if you have objected to the processing pursuant to Art. 21 (1) DSGVO and it has not yet been determined whether our legitimate grounds override your grounds.

If the processing of personal data concerning you has been restricted, such data may – apart from being stored – only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State. You will be informed by us before the restriction is lifted.

 

Right to deletion, obligation to delete

Pursuant to Art. 17 DSGVO, you may request that we delete the personal data concerning you without undue delay. We are obliged to delete this data without delay if one of the following reasons applies:

• the personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed
• Your consent on which the processing is based pursuant to Art. 6 (1) a DSGVO or Art. 9 (2) a DSGVO is revoked by you and there is no other legal basis for the processing.
• You object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing
• you object to the processing pursuant to Art. 21 (2) DSGVO
• the personal data concerning you has been processed unlawfully
• the erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which we are subject
• the personal data concerning you has been collected in relation to information society services offered in accordance with Article 8(1) of the GDPR

Information to third parties

If we have made the personal data concerning you public and we are obliged to erase it pursuant to Article 17(1) of the GDPR, we shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers that process the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.

Exceptions to the right to erasure

The right to erasure does not exist insofar as the processing is necessary:

• for the exercise of the right to freedom of expression and information
• for compliance with a legal obligation which requires processing under Union or Member State law to which we are subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us
• for reasons of public interest in the area of public health pursuant to Art. 9(2)(h) and (i) and Art. 9(3) DSGVO
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89(1) DSGVO, insofar as the right referred to in Section 1 is likely to render impossible or seriously prejudice the achievement of the purposes of such processing
• for the assertion, exercise or defense of legal claims.

 

Right to information

If you have asserted the right to rectification, erasure or restriction of processing against us, we are obliged pursuant to Article 19 DSGVO to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort. You have the right to be informed about these recipients.

 

Right to data portability

In accordance with Art. 20 DSGVO, you have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format. You also have the right to transfer this data to another controller to whom the personal data has been provided without hindrance from us, provided that

• the processing is based on consent pursuant to Art. 6 (1) a DSGVO or Art. 9 (2) a DSGVO or on a contract pursuant to Art. 6 (1) b DSGVO and
• the processing is carried out with the help of automated procedures.

In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.

The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

Right of objection

Pursuant to Art. 21 DSGVO, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. The objection must be substantiated.

Upon receipt of an objection, we will no longer process the personal data concerning you, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.

If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You have the possibility, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures using technical specifications.

 

Right to revoke the declaration of consent under data protection law

Pursuant to Art. 7(3) of the GDPR, you have the right to revoke your declaration of consent under data protection law – even before the GDPR applies (i.e. before May 25, 2018) – at any time. The revocation does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. The revocation of consent can be declared via e-mail, letter or telephone to our contact details above.

 

Automated decision in individual cases including profiling

Pursuant to Art. 22 DSGVO, you have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision is necessary for the conclusion or performance of a contract between you and us or is permitted by Union or Member State law to which we are subject and that law contains adequate measures to safeguard your rights and freedoms and your legitimate interests or is made with your explicit consent.

 

However, these decisions may not be based on special categories of personal data pursuant to Article 9(1) of the GDPR, unless Article 9(2)(a) or (g) of the GDPR applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.

 

We do not use automated individual decisions.