Data protection

We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the Dr. Grosch Consulting GmbH. The use of the Internet pages of the Dr. Grosch Consulting GmbH is generally possible without providing any personal data. However, if a data subject wishes to make use of special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Dr. Grosch Consulting GmbH applicable country-specific data protection regulations. By means of this privacy policy, our company wishes to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this privacy policy.

The Dr. Grosch Consulting GmbH as the controller, has implemented numerous technical and organisational measures to ensure that the personal data processed via this website is protected as completely as possible. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. definitions

The privacy policy of the Dr. Grosch Consulting GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

We use the following terms, among others, in this privacy policy:

a) personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as „data subject“). 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.

b) Data subject

Data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

c) Processing

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

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of restricting its future processing.

e) Profiling

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

f) Pseudonymisation

Pseudonymisation is 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the 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.

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular enquiry in accordance with Union or Member State law shall not be regarded as recipients.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent is 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.

2. name and address of the controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is the:

Dr. Grosch Consulting GmbH
Kriegsbergstraße 11
D-71336 Waiblingen
Phone: +49 (0)7151/ 205848-0
Fax: +49 (0)7151/ 205848-99
e-mail: info@grosch-ps.de

Name and address of the data protection officer

The data protection officer of the controller is

Wolfgang Hördt
Dr. Grosch Consulting GmbH
Kriegsbergstraße 11
71336 Waiblingen
Germany
Phone: 071512058480
E-mail: ra.hoerdt@posteo.de
Websites:
www.grosch-ps.de
www.grosch-hebammen-service.de

Any data subject can contact our data protection officer directly at any time with any questions or suggestions regarding data protection.

3. collection of general data and information

The website of Dr. Grosch Consulting GmbH collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites which are accessed via an accessing system on our website can be recorded, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.

When using these general data and information, the Dr. Grosch Consulting GmbH does not draw any conclusions about the data subject. Rather, this information is required to (1) correctly deliver the contents of our website, (2) optimise the contents of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. This anonymously collected data and information is used by the Dr. Grosch Consulting GmbH The server log files are therefore analysed both statistically and with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

4. hosting by Raidboxes

The hosting services on which this website is based are provided by Raidboxes GmbH (Hafenstrasse 32, 48153 Münster, Germany). Raidboxes GmbH offers Software as a Service (SaaS) services in the context of cloud hosting. 

 

Raidboxes GmbH automatically collects and stores server log files with information that your browser transmits to us. These are:

  • Browser type

  • Operating system

  • Referrer URL (previously visited page)

  • Host name (IP address)

Raidboxes GmbH cannot assign this data to specific persons. This data is not merged with other data sources. The data will be deleted after a statistical analysis after 7 days at the latest. Further information can be found in the data protection provisions of Raidboxes GmbH. These can be here can be viewed here.

 

We have also concluded a contract for order data processing (AV). This contract regulates the scope, type and purpose of Raidboxes GmbH's access to data. The access options are limited only to necessary access that is required to fulfil the hosting services.

5. contact possibility via the website

The website of the Dr. Grosch Consulting GmbH contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the data controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purposes of processing or contacting the data subject. This personal data is not passed on to third parties.

6 Routine erasure and blocking of personal data

The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or erased in accordance with the statutory provisions.

7 Rights of the data subject

a) Right to confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right to information

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to obtain from the controller free information about the personal data stored about him/her and a copy of this information at any time. Furthermore, the European legislator has granted the data subject access to the following information:

- the purposes of processing

- the categories of personal data that are processed

- 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 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 the data subject or to object to such processing

- the existence of a right to lodge a complaint with a supervisory authority

- if the personal data is not collected from the data subject: All available information about the origin of the data

- 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 the data subject

Furthermore, the data subject has a right to information as to whether personal data has been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

c) Right to rectification

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to demand the immediate correction of incorrect personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (right to be forgotten)

Each data subject shall have the right granted by the European legislator 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, as long as the processing is not necessary

- The personal data was collected or otherwise processed for purposes for which it is no longer necessary.

- The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.

- The data subject objects to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.

- The personal data was processed unlawfully.

- The deletion of personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the controller is subject.

- The personal data was collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Dr. Grosch Consulting GmbH If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the controller. The employee of the Dr. Grosch Consulting GmbH shall promptly ensure that the erasure request is complied with immediately.

If the personal data was collected by the Dr. Grosch Consulting GmbH made public and if our company is obliged to erase the personal data pursuant to Article 17(1) of the GDPR, the controller is obliged to erase the personal data. Dr. Grosch Consulting GmbH Taking into account the available technology and the cost of implementation, the controller shall take reasonable steps, including technical measures, to inform other controllers 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, as far as processing is not required. The employee of the Dr. Grosch Consulting GmbH will take the necessary steps in individual cases.

e) Right to restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

- 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.

- The processing is unlawful and the data subject opposes the erasure of the personal data and requests 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 the data subject for the establishment, exercise or defence of legal claims.

- The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Dr. Grosch Consulting GmbH If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the controller. The employee of the Dr. Grosch Consulting GmbH will arrange the restriction of the processing.

f) Right to data portability

Any person affected by the processing of personal data has the right, granted by the European legislator, to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. He or she also has 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) of the GDPR or point (a) of Article 9(2) of the GDPR or on a contract pursuant to point (b) of Article 6(1) of the GDPR and the processing is carried out by automated means, unless 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.

Furthermore, in exercising their right to data portability pursuant to Art. 20 (1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of the Dr. Grosch Consulting GmbH turn.

g) Right to object

Any person affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

The Dr. Grosch Consulting GmbH shall no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

Processes the Dr. Grosch Consulting GmbH If the controller processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This also applies to profiling insofar as it is associated with such direct advertising. If the data subject objects to the Dr. Grosch Consulting GmbH processing for the purposes of direct marketing, the Dr. Grosch Consulting GmbH no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Dr. Grosch Consulting GmbH for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR, unless such processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of the Dr. Grosch Consulting GmbH or another employee. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

h) Automated decisions in individual cases including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the Dr. Grosch Consulting GmbH The data controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the controller.

i) Right to withdraw consent under data protection law

Any person affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the controller.

8. data protection for applications and in the application process

The controller collects and processes the personal data of applicants for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits relevant application documents to the controller by electronic means, for example by email or via a web form on the website. If the controller concludes an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, unless deletion conflicts with any other legitimate interests of the controller. Other legitimate interest in this sense is, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).

9. data protection provisions about the application and use of Instagram

The data controller has integrated components of the Instagram service on this website. Instagram is a service that qualifies as an audiovisual platform and allows users to share photos and videos and also to redistribute such data in other social networks.

The operating company of the Instagram services is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which an Instagram component (Insta button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding Instagram component of Instagram. During the course of this technical procedure, Instagram is made aware of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in to Instagram at the same time, Instagram recognises which specific sub-page the data subject is visiting each time the data subject accesses our website and for the entire duration of their stay on our website. This information is collected by the Instagram component and assigned by Instagram to the respective Instagram account of the data subject. If the data subject clicks on one of the Instagram buttons integrated on our website, the data and information transmitted with it is assigned to the personal Instagram user account of the data subject and stored and processed by Instagram.

Instagram always receives information via the Instagram component that the data subject has visited our website if the data subject is logged in to Instagram at the same time as accessing our website; this takes place regardless of whether the data subject clicks on the Instagram component or not. If the data subject does not want this information to be transmitted to Instagram, they can prevent the transmission by logging out of their Instagram account before accessing our website.

Further information and the applicable data protection provisions of Instagram can be found at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

10. legal basis of the processing

Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the fulfilment of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary for the performance of pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and their name, age, health insurance details or other vital information would have to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).

11. legitimate interests in the processing pursued by the controller or a third party

Where the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the performance of our business activities for the benefit of the well-being of all our employees and our shareholders.

12. duration for which the personal data is stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After this period has expired, the corresponding data is routinely deleted, provided it is no longer required for the fulfilment or initiation of a contract.

13. legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided.

14. existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

Developed by the LegalTech Specialists from Willing & Able, who also developed the system for GDPR procedure directories have developed. The texts of the privacy policy generator were developed by Prof. Dr h.c. Heiko Jonny Maniero and lawyer Christian Solmecke created and published.

15. information pursuant to Art. 13 of the General Data Protection Regulation for whistleblowers

Person responsible for data processing

Internal reporting office of Dr. Grosch Consulting GmbH
Lawyer Wolfgang Hördt
Friedenstrasse 9
71334 Waiblingen
Germany

Phone: 0163 9232166
E-mail: ra.hoerdt@posteo.de

Responsible party from the time the data is transferred by the internal reporting office:
Dr. Grosch Consulting GmbH
Kriegsbergstraße 11
71336 Waiblingen
Germany

Phone: 07151 205848 0
E-mail: info@grosch-ps.de

Categories of personal data that are processed

The following personal data and information that is transmitted to our internal reporting centre by telephone, in writing or by direct contact, insofar as this is provided, is processed:

- Name of the whistleblower and other persons named in the report and their contact details (telephone number, e-mail address, etc.)
- the company through which the notice is issued
- the information described/the alleged misconduct
- if applicable, special categories of personal data pursuant to Art. 9 GDPR

Use of the reporting channels is voluntary.

Purpose of data processing

The data is processed to give whistleblowers the opportunity to report violations of laws, internal guidelines or other grievances in their workplace confidentially, securely and, if necessary, anonymously.

The processing of the data serves the purpose of recording the facts, investigating allegations and taking and initiating follow-up measures to remedy the misconduct.

Legal basis for data processing

Insofar as no more specific legal provisions apply, the legal basis for the processing of personal data for the above-mentioned purposes is Art. 6 para. 1 sentence 1 lit. c) GDPR in conjunction with § 10 HinSchG,

Duration of data storage

The personal data will only be stored for the period of time required for the clarification and final assessment of the report or if there is any other legal authorisation or obligation to do so. As a rule, the data is deleted three years after completion of the procedure in accordance with Section 11 (5) HinSchG.

Transmission of data to third parties

The data will not be passed on to third parties unless this relates to the exceptions provided for in the Whistleblower Protection Act.

In accordance with the Whistleblower Protection Act, only those persons who require access to the personal data for data processing in accordance with the Whistleblower Protection Act and for its fulfilment will have access to it (see also „Purpose of data processing“).

Rights of the data subjects

Data subjects have the right of access pursuant to Art. 15 GDPR, the right to rectification pursuant to Art. 16 GDPR, the right to erasure pursuant to Art. 17 GDPR, the right to restriction of processing (Art. 18 GDPR) and the right to data portability (Art. 20 GDPR).

If there are legal grounds to the contrary, data protection rights may be restricted. This applies, for example, if the rights of third parties are affected (Art. 15 GDPR in conjunction with Section 29 BDSG).

Pursuant to Art. 77 GDPR, you have the right to lodge a complaint with the competent supervisory authority.

 

For further details, please refer to our data protection information.