Privacy Policy
A. Responsible
asandco™ Executive Search, Alexandra Semmelrock is responsible in accordance with the EU General Data Protection Regulation (GDPR) and any other applicable national data protection laws and regulations:
asandco™ EXECUTIVE SEARCH
Mrs. Alexandra Semmelrock
Ebersberger Str. 11
81679 München
Germany
Tel.: +49 89 45 22 88 70
E-Mail: info@asandco.de
Website: www.asandco.de
B. Data processing activities
I. Purpose and Scope of personal data processing
We collect and use personal data of our users only when needed and as required to facilitate our online services. We ask for your consent before any collection and usage of your personal data, except where prior consent cannot be obtained for practical reasons and where the use of personal data is permitted by law.
II. Legal Basis for processing personal data
Art. 6 Abs. 1 lit. a) GDPR is used as the legal basis for any processing activities where user consent is required.
When we have a contractual or precontractual relationship, we will use Art. 6 Abs. 1 lit. b) GDPR as legal basis or Art. 6 Abs. 1 lit. f) GDPR to pursue our legitimate interests, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject.
III. Data deletion and retention period
Any and all personal data will be deleted and/or use of such personal data will be suspended when the purpose for which the personal data was collected has been attained.
If required by EU-regulations, national law or other laws and regulations personal data will be deleted. Any use of the personal data will also be suspended when the retention period has expired, unless we require the data for other contractual purposes.
C. Website and Log files
I. Scope of personal data processing
Every time you access our website, the following data is transmitted to us by your internet browser and will be automatically stored by us:
- Information on type of browser and version
- Date and Time of access
- Site openings
- Site count
The data is also automatically stored in Logfiles on our system. We will not collect and store IP-address or other user data that would allow us to designate such information to a specific user. We will not store any such data together with any other personal data of the user.
II. Purpose for processing personal data
Storing logfiles will allow us to ensure website functionality. Further we use such data to enhance the user experience as well as the security of our IT systems. We will not use the data for any other purpose as stated above.
III. Retention period
Any and all personal data will be deleted and/or use of such personal data will be suspended when the purpose for which the personal data was collected has been attained. When we use the data to facilitate our online services, namely our website, this is when the session has ended.
IV. Objection and disposal
As collection of the data as specified in C. I. above is necessary to facilitate our online services the user has no right to object such usage.
D. E-Mail
I. Purpose and Scope of personal data processing
Contact can be made using the provided E-Mail contact information. In case we receive an E-Mail, we will use and store any personal data send with the E-Mail, but we will not provide such data to any third party. The data is only used for the purpose of having an E-Mail conversation with you.
II. Objection and disposal
The user may at all times object the use of its data. In case the user has initiated the E-Mail conversation he may object to the use of his data at all times and such data will be disposed; but please note that in this case we cannot continue our conversation.
E. Data subject rights under GDPR
When we use your personal data, you are considered the data subject in accordance with GDPR. Under GDPR you have the following rights:
I. Right to access
You have the right to obtain a confirmation from the controller as to whether or not your personal data is being processed.
Where that is the case, you can access the personal data and the following information:
- the purposes of the processing
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
- the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from you, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
Where your personal data are transferred to a third country or to an international organization, you shall have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.
II. Right to rectification
You shall have the right to obtain from the controller without undue delay the rectification of your inaccurate personal data. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
III. Right to ristrict processing
You shall have the right to obtain from the controller restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by you, for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and you oppose the erasure of personal data and request the restriction of their use instead;
- the controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;
- you have objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override your own.
Where processing has been restricted as above, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, 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 of a Member State.
If you have obtained restriction of processing as stated above you shall be informed by the controller before the restriction of processing is lifted.
IV. Right to erasure (right to be forgotten)
You shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR;
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
Where the controller has made the personal data public and is obliged pursuant to the above to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
The above rights shall not apply to the extent that processing is necessary:
- or exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
- or the establishment, exercise or defence of legal claims.
V. Notification obligation
The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance the above Sections II - IV to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. You shall be informed about those recipients if when you request it.
VI. Right to data portability
You shall have the right to receive your personal data, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
- the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1) GDPR; and
- the processing is carried out by automated means.
In exercising your right to data portability pursuant to the above, you shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
VII. Right to object
You shall have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions.
The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
VIII. Right to withdraw your consent
You shall have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
IX. Right of appeal to a supervisory authority
Without prejudice to any other administrative or non-judicial remedy, you shall have the right to an effective judicial remedy where the supervisory authority which is competent pursuant to Articles 55 and 56 GDPR does not handle a complaint or does not inform you within three months on the progress or outcome of the complaint lodged pursuant to Article 77.