Privacy Policy 

1. Name and contact details of the data controller and the internal data protection officer

This privacy policy applies to data processing by:

finlit foundation gGmbH

Steindamm 71

20099 Hamburg, Germany
Tel.: +49 40 2850-2596


Email: [email protected]

Management: Jana Titov, Sebastian Richter

AG Hamburg HRB 158452

German tax number: DE 1744023056

 

The internal data protection officer of finlit foundation gGmbH can be contacted at the above address, attention: Data Protection Officer, or by email at: [email protected].


2. Scope

This privacy policy applies to the collection of personal data on our website and the subsequent processing of these data by us.

3. Collection and storage of personal data and nature and purpose of their processing

a. When you visit the website

When you access our website, the browser used on your device automatically sends information to our website’s server. This information is temporarily saved in a log file. The following information is collected without any action on your part and is stored until it is automatically deleted after 7 days.

  • IP address of retrieving computer,
  • date and time of access,
  • name and URL of retrieved file,
  • website from which access occurred (referrer URL),
  • website accessed from our website,
  • your computer’s browser and, where applicable, operating system as well as the name of your access provider.

 

The above data are processed by us for the following purposes:

  • To ensure trouble-free connection to the website,
  • to ensure comfortable use of our website,
  • to analyze the system security and stability, and
  • for other administrative purposes.


The legal basis for the data processing is Article 6 (1), sentence 1(f) of the GDPR. Our legitimate interest follows from the purposes for data collection listed above. Under no circumstances do we use the collected data for the purpose of drawing conclusions about you.

 

Furthermore, we use cookies and analysis services when you visit our website. You can find more detailed information about this in sections 5 and 6 of this privacy policy.

 

b. Email contact

For any queries, you may contact us via a form provided on the website. This requires you to specify a valid email address so that we know who the query is from and so we can answer it. Providing additional details is optional.

 

Alternatively, you may contact us via the email address provided. If you do so, the personal data transmitted with the email are saved.

 

The legal basis for data processing for the purpose of making contact is Article 6 (1), sentence 1(f) of the GDPR. If contact is made for the purpose of concluding a contract, the additional legal basis for processing is Article 6 (1)(b) of the GDPR.

 

After processing your query, we delete the personal data collected by us, provided we are not legally entitled or obligated to process it further.


4. Data sharing

We only disclose your personal data to other companies of the EOS Group or other third parties (recipients) if:

  • you have given your explicit consent for one or more specific purposes pursuant to Article 6 (1), sentence 1(a) of the GDPR,
  • disclosure pursuant to Article 6 (1), sentence 1(f) of the GDPR is necessary for the establishment, exercise or defense of legal claims and there are no grounds for assuming that you have an overriding and legitimate interest in the non-disclosure of your data,
  • in the event there is a legal obligation for the disclosure pursuant to Article 6 (1), sentence 1(c) of the GDPR, and
  •  this is legally permissible and is required to fulfill our contractual obligations to you pursuant to Article 6 (1), sentence 1(b) of the GDPR,
  • we have engaged another party to manage the data in compliance with Article 28 of the GDPR.


Your personal data is not transmitted for any other purposes than those listed above.


5. Cookies

What are cookies?

 

Cookies are small text files that are created by the browser on your device to store certain information. The next time you access our website on the same device, the information stored in the cookies is returned to our website (first party cookies) or to another website the cookie belongs to (third-party cookie). 


By means of the information stored and returned in the cookie, the particular website recognizes that you have already accessed and visited it with the browser on your device. We use this information to best display the website according to your preferences.

 

In doing so, only the cookie itself is identified on the device. Beyond that, personal information is only stored if you give us explicit consent to do so, or if this storage is strictly necessary for you to be able to use the service offered and accessed.

 

Consent to the use of cookies 

Cookies that are not strictly necessary to access the services on this website are only used with your consent.  By consenting to the use of cookies on the basis of a notice placed by us on the website (cookie banner), you agree to the use of cookies.

 

You can customize your cookie settings at any time by activating or deactivating individual cookie categories, for example.

 

Please refer to “Deactivating or deleting all cookies” for how to deactivate or delete cookies in general (including essential cookies) in your browser.

 

Legal basis

If you have consented to the use of cookies on the basis of a notice placed by us on the website (cookie banner), the legality of the data processing conforms with Article 6 (1), sentence 1(a) of the GDPR. If no consent is requested, our legitimate interest (i.e. interest in the analysis, optimization and economic operation of this website and services) within the meaning of Article 6 (1), sentence 1(f) of the GDPR constitutes the legal basis for the use of cookies.

 

Categories of cookies used

We divide the cookies used by the website into the following categories, depending on the purpose and function:

  • Essential cookies
  • Functional cookies
  • Performance cookies
  • Marketing cookies / third-party cookies / cookies requiring consent

  

Essential cookies

Essential cookies ensure that this website or service functions properly. This means that without these cookies, this website or service cannot be used as intended. This type of cookie is only used by the website owner (first-party cookies) and all information that is stored in the cookies is sent only to this website.

No essential cookies are used on our website.

 

Essential cookies cannot be individually deactivated or activated. You can adjust your cookie settings at any time, or deactivate cookies in general in your browser (see “Deactivating or deleting all cookies”).

 

Functional cookies

Functional cookies allow this website to store information entered, such as user names or language selection, so we can offer improved and personalized functions on this basis.  These cookies collect and store anonymous information only.


The following functional cookies are used on our website:

Name | Provider| Purpose | Duration
These cookies are set by Google as part of the use of Google Maps. Provider: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA or, if you are resident in the EU, Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Cookie Names and Lifetimes: UULE (Lifetime: 1 day), OTZ (Lifetime: 2 weeks), 1P_JAR (Lifetime:1 month), SIDCC (Lifetime: 1 year), _Secure-3PAPISID (Lifetime: 2 years), _Secure-APSID (Lifetime: 2months), _Secure-SSID (Lifetime: 2 years), HSID (Lifetime:2 years), _Secure-3PSID (Lifetime: 2 years), ANID (Lifetime: 1 year), SID (Lifetime:2 years) APISID (Lifetime:2 years), _Secure-HSID (Lifetime: 2 months), SAPISID (Lifetime: 2 years), NID (Lifetime: 6 months)

Name | Provider| Purpose | Duration
This cookie is used to unlock and display Vimeo content on this website. Provider: Vimeo, Inc., 555 West 18th Street, New York, New York 10011 USA Cookie Names and Lifetimes: muxData (Lifetime: 20 years), _ssid (Lifetime: 10 years), language (Lifetime: 10 years), vimeo_gdpr_optin (Lifetime: 10 years), player (Lifetime: 1 year), _qca (Lifetime: 3 months), continuous_play_v3 (Lifetime: 2 months), vuid (Lifetime: 2 years), _derived_epik (Lifetime: 2 months), _ga (Lifetime: 2 years) 


 
Performance cookies

Performance cookies collect information about how our web pages are used so we can improve their attractiveness, content and functionality on this basis. These cookies help us to determine, for example, whether and which subpages of our website are visited and which content you are particularly interested in. We record the number of times a web page is accessed, the number of subpages accessed, the amount of time spent on our website, the order of pages visited, which search terms led our users to us, the country, the region and, where applicable, the city the site was accessed from, and the percentage of mobile devices that access our web pages. The computer’s IP address transmitted for technical reasons is anonymized automatically and does not allow us to draw any conclusions about the individual user.

 

The following performance cookies are used on our website:


Name | Provider | Purpose | Duration
  _ga, _gat und _gid | Google Analytics | These cookies collect anonymous information for analysis purposes, as to how visitors use and interact with this website | 2 years 

 

You can reject the use of performance cookies at any time by adjusting your cookie settings accordingly.

 

Marketing cookies / third-party cookies

Marketing cookies / third-party cookies / cookies requiring consent come from external advertising companies, among others, and are used to collect information about the websites you visit to create advertising for the user aimed at a specific target group.
 
No marketing cookies / third-party cookies / cookies requiring consent are used on our website.

 

Cookie management:

Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or so that a notification always appears before a new cookie is set. Each browser differs depending on your cookie settings. This is described in each browser's help menu, which explains how to change your cookie settings. Follow the links below depending on the browser you are using:


However, completely deactivating cookies may mean that you will not be able to use all the functions of our website. 

 6. Analysis tools

The tracking measures listed below and used by us are carried out on the basis of your consent according to Article 6 (1), sentence 1(f) of the GDPR. We use these tracking measures to ensure that our website is designed according to requirements and optimized on an ongoing basis. We also use the tracking measures to record statistics on the use of our website and analyze them for the purpose of optimizing our offer for you.

The specific data processing purposes and data categories can be found in the corresponding tracking tools in this section.

 

Google Analytics

For the purposes of designing the website according to requirements and the ongoing optimization of our site, we use Google Analytics, a web analytics service by Google Ireland Limited (“Google”), headquartered in Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, on the basis of your consent according to Article 6 (1), sentence 1(f) of the GDPR. Google uses cookies, or text files, that are stored on your computer and allow an analysis of your use of the website. In this context, pseudonymous usage profiles are created and cookies are used. The information collected using cookies includes


  • browser type/version,
  • operating system used,
  • referrer URL (the page visited before),
  • host name of the computer accessing the page (IP address),
  • time of server request


and is generally transferred to a Google server in the USA and stored there.


In the event that IP anonymization is activated on this website, your IP address will be truncated by Google beforehand within the member states of the European Union or in other states outside of the European Economic Area which are party to the Agreement. The complete IP address is transferred to a Google server in the USA and truncated there in exceptional cases only. The IP address transmitted from your browser within the scope of Google Analytics is not merged with other data by Google. On behalf of the owner of this website, Google will use this information to analyze your use of the website, compile reports on website activity and to offer the website owner other services related to the use of the website and the Internet. 

 

You can prevent cookies being stored by selecting the appropriate settings on your browser software; please note, however, that by doing so you may not be able to make full use of all the functions of this website.

 

For further information on Google’s use of data, please see Google’s privacy policy (https://policies.google.com/privacy?fg=1). 

 

The user’s personal data are deleted or anonymized after 14 months.

Disable tracking by Google Analytics.


7. Data subject rights

You have the right:

  • pursuant to Article 15 of the GDPR, to request information about your personal data processed by us. In particular, you can request information about the purposes for processing, the personal data category, the categories of the recipients to whom your data have been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, processing restriction or objection, the existence of a right to file a complaint, the origin of your data if they were not collected by us and the existence of automated decision making including profiling and, where applicable, information about their details;
  • pursuant to Article 16 of the GDPR, to demand the immediate rectification of incorrect personal data or completion of the personal data stored by us about you;
  • pursuant to Article 17 of the GDPR, to demand the erasure of the personal data stored by us about you, provided the processing is not required for exercising the right to freedom of expression and information, to meet a legal obligation, for reasons of public interest or for the establishment, exercising or defense of legal claims;
  • pursuant to Article 18 of the GDPR, to demand that the processing of your personal data is restricted, as long as the accuracy of the data is contested by you, the processing is illegal but you oppose their erasure and we no longer need the data but you require them for the establishment, exercising or defense of legal claims, or you have filed an objection to the processing in accordance with Article 21 of the GDPR;
  • pursuant to Article 20 of the GDPR, to demand receipt in a structured, standard and machine-readable format of your personal data which you provided to us or transmission to another responsible party;
  • pursuant to Article 7 (3) of the GDPR, to withdraw the consent you previously granted us at any time. This has the consequence that we may not continue the data processing based on this consent in the future and
  • pursuant to Article 77 of the GDPR, to file a complaint with a supervisory authority. As a rule, you can contact the supervisory authority at your usual place of residence or workplace or at the location of our company headquarters.

 

8. Right to object

If your personal data are processed on the basis of legitimate interests in accordance with Article 6 (1), sentence 1(f) of the GDPR, you have the right pursuant to Article 21 of the GDPR to object to the processing of your personal data, provided there are reasons arising from your particular situation or the objection is directed against direct advertising. In the latter case you have a general right to object which will be implemented by us without having to specify a particular situation.


If you would like to exercise your right of withdrawal or right to object, it is sufficient to send an email to [email protected].

 


9. Data security

Within the website visit, we use the widespread SSL (secure socket layer) method in conjunction with the highest level of encryption supported by your browser. As a rule, this is 256-bit encryption. If your browser does not support 256-bit encryption, we fall back on 128-bit v3 technology instead. You can see whether an individual page of our website is being transmitted in encrypted form by the closed key or padlock icon in the bottom status bar of your browser.

 

We also take appropriate technical and organizational security measures to protect your data from accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are being improved continuously in line with technological developments.

 


10. Up-to-dateness of this privacy policy

This privacy policy is currently valid and was last updated in November 2020.

Information requirements

finlit foundation gGmbH: Information for service providers, customers, interested parties, course participants and teachers 

Information in accordance with Art. 13/14 of the EU General Data Protection Regulation (GDPR)


Responsible party 

finlit foundation gGmbH, Steindamm 71, 20099 Hamburg

 

Contact information of the Data Protection Officer

Data Protection Officer at finlit foundation gGmbH, Steindamm 71, 20099 Hamburg or at [email protected]

 

Purpose of processing and legal basis

The data processing is carried out for contract initiation as well as to fulfil the contract with you in accordance with Art. 6 (1)(b) GDPR.

For employees/contacts of our service providers and clients, the further purpose of the data processing is correspondence before a contract is signed and after within the scope of the business relationship pursuant to Art. 6 (1)(f) GDPR as well as targeted advertising using the email address for services within the scope of receivables management pursuant to Art. 6 (1)(f) GDPR. It is possible to unsubscribe at any time. Data processing is necessary for the protection of our legitimate interests. Our legitimate interests exist in connection with the business relationship. Data processing is necessary for the protection of our legitimate interests. 

As far as a consent for data processing was given, finlit foundation gGmbH collects, processes and uses the received data on the basis of Art. 6 (1)(a) GDPR.

Our legitimate interests exist in connection with the business relationship. 

Insofar as the processing is necessary to fulfil legal obligations, the legal basis is also Art. 6 (1)(c) GDPR.


Data categories and data source 

We process the following categories of data:

Master data, address data, communication data, contract data and bank and payment data. The data from the above-mentioned data categories were transmitted to us by you or were taken from publicly accessible data sources. 

 

Recipients

We only pass on data to other companies of the EOS Group or other recipients if:

  • this is legally permissible and necessary for the processing of contractual relationships in accordance with Art. 6 (1)(b) GDPR,
  • the disclosure pursuant to Art. 6 (1)(f) GDPR is necessary for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding protection-worthy interests in not disclosing your data,
  • there is a legal obligation to pass on the data in accordance with Art. 6 (1)(c) GDPR,
  • you have given your express consent for one or more specific purposes in accordance with Art. 6 (1)(a) GDPR, and
  • we have the data administered by order in compliance with Art. 28 GDPR.

 

Duration of storage

Personal data will be processed until the above-mentioned purposes are fully achieved. This includes, among other things, the legal storage obligations of the German Fiscal Code/Tax Code (Abgabenordnung, AO), theGerman Commercial Code (Handelsgesetzbuch, HGB), German law on sales tax (Umsatzsteuergesetz, UstG). The data will be deleted when the purpose is fully achieved.

If the deletion of the data is requested or the processing is opposed, the elimination of the legal basis as well as the purpose for the storage is examined. If there is no legal basis/purpose for storage, the data will be deleted immediately.
 
 

Rights of the data subject
According to Art. 15 to 21 GDPR you are entitled to the following rights if the legal requirements are met: Right of access, rectification, erasure, restriction of processing and data portability.

In addition, if the legal requirements under Art. 21 GDPR are met, you have the right to object to the processing, which is based on Art. 6 (1)(f) GDPR.

According to Art. 7 (3) GDPR, you have the right to revoke the consent you have given us at any time. As a result, we may no longer continue the data processing that was based on the consent for the future.
If you wish to make use of your right of revocation or objection, an e-mail to [email protected] is sufficient.

 

Right to lodge a complaint with the supervisory authority
According to Art. 77 GDPR, you have the right to complaint to a data protection supervisory authority if you believe that your personal data are not being processed lawfully. The supervisory authority responsible for our company is The Hamburg Representative for Data Protection and Freedom of Information, Ludwig-Erhard-Straße 22, 20459 Hamburg.

_________________________________ 

Information for third parties 

Information in accordance with Art. 13/14 of the EU General Data Protection Regulation (GDPR)


The purpose of this document is to inform you of the ways in which we process your data in accordance with Art. 13/14 of the GDPR.

Responsible party
finlit foundation gGmbH, Steindamm 71, 20099 Hamburg


Contact information of the Data Protection Officer
Data Protection Officer at finlit foundation gGmbH, Steindamm 71, 20099 Hamburg or at [email protected].

 

Purpose of processing and legal basis

The legal basis of the data processing for contacting you or otherwise necessary communication with you is Art. 6 (1)(f) GDPR.

Insofar as the processing is necessary to fulfil legal obligations, the legal basis is also Art. 6 (1)(c) GDPR.

Data categories and data source
We process the following categories of data:

Master data, address data, communication data. The data from the above-mentioned data categories was provided to us by you or was taken from publicly available data sources.

 

Recipient

We pass on your personal data to other third parties (recipients) if:

  • this is legally permissible and is required under Art. 6 (1)(b) GDPR for the processing of contractual relationships with you,
  •  the transfer is necessary in accordance with Art. 6 (1)(f) GDPR for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not passing on your data,
  • there is a legal obligation to pass on the data pursuant to Art. 6 (1)(c) GDPR, and
  • you have given your express consent for one or more specific purposes in accordance with Art. 6 (1)(a) GDPR,
  •  we have the data administered by order in compliance with Art. 28 GDPR.


Your personal data will not be transferred for any other purposes than those just mentioned.

 

Duration of storage

The data will be deleted after the above-mentioned purposes have been achieved, unless there are storage obligations which conflict with this.

If the deletion of the data is requested or the processing is opposed, the omission of the legal basis as well as the purpose for the storage will be examined. If there is no legal basis / purpose for storage, the deletion will be carried out immediately.

As far as data of legal persons or publicly accessible data are concerned, there is no claim for deletion.


Rights of the data subject
According to Art. 15 to 21 GDPR you are entitled to the following rights if the legal requirements are met: Right of access, rectification, erasure, restriction of processing and data portability.


In addition, if the legal requirements under Art. 21 of the GDPR are met, you have the right to object to the processing, which is based on Art. 6 (1)(f) GDPR.

Right to lodge a complaint with a supervisory authority
 
According to Art. 77 GDPR, you have the right to complaint to a data protection supervisory authority if you believe that your personal data are not being processed lawfully. The supervisory authority responsible for our company is The Hamburg Representative for Data Protection and Freedom of Information, Ludwig-Erhard-Straße 22, 20459 Hamburg.