Privacy Policy

Name and contact details of the controller pursuant to Article 4(7) GDPR

Fink Secure Communication GmbH
Sengelaubstrasse 5
96450 Coburg / Germany

Email: info@fink-secure.com

 

Security and protection of your personal data

We consider it our top priority to maintain the confidentiality of the personal data you provide and to protect it from unauthorized access. That is why we exercise the utmost care and apply state-of-the-art security standards to ensure maximum protection of your personal data.
As a private-sector company, we are subject to the provisions of the European General Data Protection Regulation (GDPR) and the provisions of the German Federal Data Protection Act (BDSG). We have implemented technical and organizational measures to ensure that data protection regulations are observed both by us and by our external service providers.

 

Definitions

The law requires that personal data be processed lawfully, fairly, and in a manner that is transparent to the data subject (“lawfulness, fairness, and transparency”). To ensure this, we provide you with the definitions of the individual legal terms used in this Privacy Policy:

 

Personal Data

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); A natural person is considered identifiable if they 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.

 

Processing

“Processing” means any operation or set of operations performed on 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 any other form of making available, alignment or combination, restriction, erasure, or destruction.

 

Restriction of processing

“Restriction of processing” means the marking of stored personal data with the aim of limiting their future processing.

 

Profiling

“Profiling” means any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements.

 

Pseudonymization

“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data cannot be attributed to an identified or identifiable natural person.

 

File system

“File system” means any structured collection of personal data accessible according to specific criteria, regardless of whether this collection is managed centrally, decentrally, or organized according to functional or geographical criteria.

 

Controller

“Controller” means a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

 

Processor

“Processor” means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

 

Recipient

“Recipient” means a natural or legal person, public authority, agency, or other body to whom personal data is disclosed, regardless of whether that body is a third party or not. However, public authorities that may receive personal data in the course of a specific inquiry under Union law or the law of the Member States are not considered recipients; the processing of such data by those authorities is carried out in accordance with applicable data protection regulations and in line with the purposes of the processing.

 

Third Party

“Third party” means any natural or legal person, public authority, agency, or other body, other than the data subject, the controller, the processor, and the persons who, under the direct authority of the controller or the processor, are authorized to process the personal data.

 

Consent

“Consent” of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

 

Lawfulness of Processing

The processing of personal data is lawful only if there is a legal basis for such processing. Pursuant to Article 6(1) 
(a) – (f) of the GDPR, the legal basis for processing may include, in particular:
a. The data subject has given consent to the processing of personal data concerning him or her for one or more specific purposes;
b. processing is necessary for the performance of a contract to which the data subject is a party, or for the implementation of pre-contractual measures taken at the data subject’s request; processing is necessary for compliance with a legal obligation to which the controller is subject; processing is necessary to protect the vital interests of the data subject or of another natural person;
e. the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
f. the processing is necessary to protect the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data prevail, in particular where the data subject is a child.

 

Information Regarding the Collection of Personal Data

(1) The following provides information about the collection of personal data when you use our website. Personal data includes, for example, your name, address, email address, and user behaviour.

(2) When you contact us via email or through our contact form, we will store the data you provide (your email address, and, if applicable, your name and phone number) in order to answer your questions. We will delete the data collected in this context once storage is no longer necessary, or processing will be restricted if statutory retention obligations apply.

 

Collection of Personal Data When Visiting Our Website

When you use the website for informational purposes only—that is, if you do not register or otherwise provide us with information—we collect only the personal data that your browser transmits to our server. When you view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure its stability and security (the legal basis is Art. 6(1)(f) GDPR):

– IP address
– Date and time of the request
– Time zone difference from Greenwich Mean Time (GMT)
– Content of the request (specific page)
– Access status/HTTP status code
– Amount of data transferred in each case
– Website from which the request originates
– Browser
– Operating system and its user interface
– Language and version of the browser software.

 

Use of Cookies

Our website uses cookies to the extent technically necessary. Cookies are small text files that are stored on your device and save certain settings or information for exchange with our website.
We use cookies solely to ensure the proper functioning of the website.

 

Additional features and services on our website

(1) In addition to the purely informational use of our website, we offer various services that you may use if interested. To do so, you generally need to provide additional personal data, which we 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. These providers have been carefully selected and commissioned by us, are bound by our instructions, and are regularly monitored.
(3) Furthermore, we may disclose your personal data to third parties. You can obtain more detailed information on this when providing your personal data or in the description of the service below.
(4) If our service providers or partners are based in a country outside the European Economic Area (EEA), we will inform you of the consequences of this circumstance in

 

Children

Our services are generally intended for adults. Individuals under the age of 18 should not provide us with any personal information without the consent of their parents or legal guardians.

 

Rights of the Data Subject

Withdrawal of Consent

If the processing of personal data is based on consent you have provided, you have the right to withdraw that consent at any time. Withdrawing your consent does not affect the lawfulness of processing carried out on the basis of your consent prior to its withdrawal.
To exercise your right to withdraw consent, you may contact us at any time.

 

Right to Confirmation

You have the right to request confirmation from the controller as to whether we are processing personal data concerning you. You may request this confirmation at any time using the contact details provided above.

 

Right of access

If personal data is being processed, you may at any time request access to this personal data and to the following information:

a. the purposes of the processing;
b. the categories of personal data being processed;
c. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
d. if possible, the planned duration for which the personal data will be stored, or, if this is not possible, the criteria for determining this duration;
e. the existence of a right to rectification or erasure of personal data concerning you, or to restriction of processing by the controller, or a right to object to such processing;
f. the existence of a right to lodge a complaint with a supervisory authority;
g. where the personal data are not collected from the data subject, any available information as to their source;
h. the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and—at least in such cases—meaningful information regarding the logic involved, as well as the significance and the intended consequences of such processing for the data subject.

If personal data is transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer. We will provide a copy of the personal data being processed. For any additional copies you request, we may charge a reasonable fee based on administrative costs. If you submit the request electronically, the information must be provided in a commonly used electronic format, unless you specify otherwise. The right to receive a copy pursuant to paragraph 3 must not infringe upon the rights and freedoms of others.

 

Right to Rectification 

You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to obtain the completion of incomplete personal data – including by means of a supplementary statement.

 

Right to erasure (“right to be forgotten”)

You have the right to request that the controller erase personal data concerning you without undue delay, and we are obligated to erase personal data without undue delay if one of the following grounds applies:

a. The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
b. The data subject withdraws consent on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR, and there is no other legal basis for the processing.
c. The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
d. The personal data has been unlawfully processed.
e. The erasure of the personal data is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the controller is subject.
f. The personal data was collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.

If the controller has made the personal data public and is obliged to erase it pursuant to paragraph 1, the controller shall, taking into account available technology and the cost of implementation, take reasonable measures, including technical measures, to inform controllers processing the personal data that an erasure has been requested.

The right to erasure (“right to be forgotten”) does not apply where processing is necessary:

– for the exercise of the right to freedom of expression and information;
– to comply with a legal obligation which requires processing under 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;
– for reasons of public interest in the area of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the GDPR;
– for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes pursuant to Article 89(1) of the GDPR, insofar as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of such processing; or
– for the establishment, exercise, or defence of legal claims.

 

Right to Restriction of Processing

You have the right to request that we restrict the processing of your personal data if any of the following conditions apply:

a. the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data,
b. the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
c. the controller no longer needs the personal data for the purposes of the processing, but the data subject needs it to assert, exercise, or defend legal claims, or
d. the data subject has objected to the processing pursuant to Article 21(1) of the GDPR, as long as it has not yet been determined whether the legitimate grounds of the controller override those of the data subject.

If processing has been restricted in accordance with the above conditions, such personal data—apart from its storage—shall be processed only with the data subject’s consent or for the establishment, exercise, or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest

 

Right to Data Portability

You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, and you have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided, provided that:

a. the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b) of the GDPR, and

b. the processing is carried out by automated means.

When exercising the right to data portability pursuant to paragraph 1, you have the right to have the personal data transmitted directly from one controller to another controller, to the extent that this is technically feasible. The exercise of the right to data portability does not affect the right to erasure (“right to be forgotten”). This right does 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.

 

Right to Object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you that is carried out pursuant to Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. The controller shall no longer process the personal data unless it can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or the processing is necessary for the establishment, exercise, or defence of legal claims.

If personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling to the extent that it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data will no longer be processed for these purposes.

In connection with the use of information society services, you may exercise your right to object by automated means using technical specifications, notwithstanding Directive 2002/58/EC.

You have the right to object, on grounds relating to your particular situation, to the processing of your personal data carried out for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1), unless the processing is necessary for the performance of a task carried out in the public interest.

You may exercise your right to object at any time by contacting the respective controller.

 

Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing—including profiling—that produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision:

a. is necessary for entering into or performing a contract between the data subject and the controller,
b. is authorized by Union or Member State law to which the controller is subject, and that law provides for appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject; or
c. is based on the explicit consent of the data subject.

The controller shall take appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, including at least the right to request the controller to involve a person, to present his or her point of view, and to challenge the decision.The data subject may exercise this right at any time by contacting the relevant controller.

 

Right to lodge a complaint with a supervisory authority

You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or the place of the alleged infringement, without prejudice to any other administrative or judicial remedy, if you consider that the processing of personal data relating to you infringes this Regulation.

 

Right to an effective judicial remedy

Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to Article 77 of the GDPR, you have the right to an effective judicial remedy if you consider that your rights under this Regulation have been infringed as a result of the processing of your personal data in a manner not in accordance with this Regulation.