KlimaInvest Green Concepts GmbH
Managing Directors: Jobst Jenckel, Kai Ristau
Hohe Bleichen 10
20354 Hamburg, Germany
Year of foundation: 2009
Commercial register: Local court HH - HRB: 111 932
Tax number: 48/703/01907
Phone:+49 40 806 007-500 Fax:+49 40 806 007-599
Data protection officer: Stephan Trümper
Types of Data Processed:
- Inventory data (for example, names, addresses).
- Contact data (e.g., e-mail, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., web pages visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (in the following we will refer to the persons concerned collectively as "users").
Purpose of processing
- Provision of the online offer, its functions and contents.
- Answering of contact requests and communication with users.
- security measures.
- Range measurement/Marketing
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable person is one who can be identified, directly or indirectly. This applies by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that specific person.
"Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data.
"Pseudonymisation" means the processing of personal data in such a way that the personal data cannot be attributed to a specific data subject without the inclusion of supplementary information, provided that this supplementary information is kept separate and is subject to technical and organisational measures ensuring that the personal data is not related to an identified or identifiable natural person.
„Profiling“ jede Art der automatisierten Verarbeitung personenbezogener Daten, die darin besteht, dass diese personenbezogenen Daten verwendet werden, um bestimmte persönliche Aspekte, die sich auf eine natürliche Person beziehen, zu bewerten, insbesondere um Aspekte bezüglich Arbeitsleistung, wirtschaftliche Lage, Gesundheit, persönliche Vorlieben, Interessen, Zuverlässigkeit, Verhalten, Aufenthaltsort oder Ortswechsel dieser natürlichen Person zu analysieren oder vorherzusagen.
"Data Controller" means the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data.
"Data Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal basis
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering enquiries is Art. 6 Para. 1 lit. b GDPR, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 Para. 1 lit. c GDPR, and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 Para. 1 lit. f GDPR. In the event of vital interests of the data subject or another natural person require the processing of personal data, Article 6 paragraph 1 letter d GDPR serves as the legal basis.
In accordance with Art. 32 GDPR and taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
These measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling the physical access to the data, as well as the access, input, disclosure, security of availability and separation of the data relating to them. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted, and we respond to any threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly presettings (Art. 25 GDPR).
Cooperation with contract processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this is only done on the basis of a legal authorization (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the performance of the contract in accordance with Art. 6 para. 1 lit. b GDPR), if you have consented, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties to process data on the basis of a so-called "contract processing agreement", this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer the data in a third country if the special requirements of Art. 44 ff. GDPR. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
Rights of the data subjects
You have the right to request confirmation as to whether or not data in question is being processed and to receive information about this data and to receive further information and a copy of the data in accordance with Art. 15 of the Data Protection Act.
You have accordingly to Art. 16 GDPR the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with Art. 18 GDPR, to demand that the processing of the data be restricted.
Right of withdrawal
You have the right to revoke consents granted in accordance with Art. 7 para. 3 GDPR with effect for the future.
Right of objection
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection may in particular be made against processing for the purposes of direct advertising.
Cookies and right of objection for direct advertising
"Cookies" are small files that are stored on the user's computer. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online service. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online store or a login status can be stored. Cookies are described as "permanent" or "persistent" if they remain stored even after the browser is closed. For example, the login status can be saved if the user visits it after several days. Likewise, the interests of the users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if it is only their cookies, it is called "first-party cookies").
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional limitations of this online offer.
Deletion of data
The data processed by us will be deleted or limited in their processing in accordance with articles 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
According to legal requirements in Germany, the storage is in particular for 10 years according to §§ 147 para. 1 AO, 257 para. 1 No. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years according to § 257 para. 1 No. 2 and 3, para. 4 HGB (commercial letters).
According to legal requirements in Austria, the storage is in particular for 7 J according to § 132 para. 1 BAO (accounting documents, vouchers / invoices, accounts, receipts, business documents, statement of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
Additionally we process
- Contract data (e.g., object of contract, duration, customer category),
- Payment data (e.g., bank details, payment history)
by our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
We process the data of our customers within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.
We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of the contract, duration), payment data (e.g., bank details, payment history), usage and meta data (e.g., in the context of evaluation and performance measurement of marketing measures). As a matter of principle, we do not process special categories of personal data, unless they are part of a commissioned processing. Those affected include our customers, interested parties and their customers, users, website visitors or employees as well as third parties. The purpose of processing is to provide contractual services, billing and our customer service. The legal basis of the processing is derived from Art. 6 para. 1 letter b GDPR (contractual services), Art. 6 para. 1 letter f GDPR (analysis, statistics, optimization, security measures). We process data which are necessary for the justification and fulfilment of the contractual services and point out the necessity of their disclosure. Disclosure to external parties will only be made if it is necessary within the scope of an order. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client and the legal requirements of an order processing in accordance with Art. 28 GDPR and do not process the data for any other purposes than those specified in the order.
We delete the data after the expiry of legal warranty and comparable obligations. The necessity of keeping the data is reviewed every three years; in the case of legal archiving obligations, deletion takes place after the expiry of these obligations (6 years, according to § 257 para. 1 HGB, 10 years, according to § 147 para. 1 AO). In the case of data that has been disclosed to us by the client within the scope of an order, we delete the data in accordance with the specifications of the order, in principle after the end of the order.
We process the data of our contractual partners and interested parties as well as other principals, customers, clients, clients or contractual partners (uniformly referred to as "contractual partners") in accordance with Art. 6 para. 1 lit. b. GDPR in order to provide them with our contractual or pre-contractual services. The data processed in this context, the nature, scope and purpose and the necessity of their processing, are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
As a matter of principle, we do not process special categories of personal data, unless these are part of a commissioned or contractual processing.
We process data which are necessary for the justification and fulfilment of the contractual services and point out the necessity of their disclosure, if this is not evident to the contractual partners. Disclosure to external persons or companies will only be made if it is necessary within the scope of a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client and the legal requirements.
When using our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of the users in protection against misuse and other unauthorized use. This data will not be passed on to third parties, unless it is necessary to pursue our claims in accordance with Art. 6 Par. 1 lit. f. GDPR or if there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. c. GDPR.
The data will be deleted when the data is no longer necessary for the fulfilment of contractual or statutory duties of care and for dealing with any warranty or comparable duties, whereby the necessity of keeping the data will be reviewed every three years; otherwise the statutory duties of safekeeping apply.
Administration, financial accounting, office organization, contact management
We process data within the framework of administrative tasks as well as the organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process within the scope of providing our contractual services. The basis for processing is art. 6 par. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose of and our interest in processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.
We disclose or transfer data to the tax authorities, consultants, such as tax consultants or auditors, as well as other fee agencies and payment service providers.
Furthermore, we store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We store these mostly company-related data permanently.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the user's details are processed for the purpose of processing the contact request and its handling in accordance with Art. 6 Para. 1 lit. b) GDPR. The user's details may be stored in a customer relationship management system ("CRM system") or comparable inquiry organization.
We will delete the inquiries if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
If you have given your consent, this website uses Google Analytics, a web analysis service of Google LLC. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").Scope of processing
We use the function 'anonymizeIP' (so-called IP-Masking): Due to the activation of IP-anonymization on this website, your IP-address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area. Only in exceptional cases the full IP address will be transferred to a Google server in the USA and shortened there. The IP address transmitted by your browser within the framework of Google Analytics is not merged with other data from Google.
During your website visit the following data will be collected:
- the pages you call up, your "click behaviour“
- Achievement of "website goals" (conversions, e.g. newsletter registrations, downloads, purchases)
- Your user behavior (for example clicks, dwell time, bounce rates)
- Your approximate location (region)
- Your IP address (in abbreviated form)
- technical information about your browser and the end devices you use (e.g. language settings, screen resolution)
- Your internet provider
- the referrer URL (via which website/advertising medium you came to this website)
On behalf of the operator of this website, Google will use this information to evaluate your (pseudonymous) use of the website and to compile reports on website activity. The reports provided by Google Analytics serve to analyse the performance of our website and the success of our marketing campaigns.Recipient
The data recipient is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland as data processor. For this purpose we have concluded a contract with Google. Google LLC, headquartered in California, USA, and, if applicable, US authorities can access the data stored at Google.Transfer to third countries
A transfer of data to the USA cannot be excluded.Duration of storage
The data sent by us and linked to cookies is automatically deleted after 14 months. Data is automatically deleted once a month as soon as the storage period is reached.
You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by
a. not giving your consent to the setting of the cookie or
b. downloading and installing the browser add-on to disable Google Analytics.
By setting your browser software accordingsly you can also prevent the storage of cookies. If your browser is set to refuse all cookies, the functionality of this and other websites may be limited.
CRM system from SugarCRM
We use the CRM system of the provider SugarCRM Inc. 10050 N Wolfe Rd, Cupertino, CA 95014, in order to be able to process user inquiries faster and more efficiently (legitimate interest according to Art. 6 para. 1 lit. f. GDPR ).
SugarCRM is certified under the Privacy-Shield Agreement and thus offers an additional guarantee to comply with European data protection law, if data is processed in the USA (https://www.privacyshield.gov/participant?id=a2zt0000000TNjnAAG).
SugarCRM uses the data of users only for the technical processing of the requests and will not pass them on to third parties. In order to use SugarCRM, it is necessary to provide at least a correct e-mail address. A pseudonymous use is possible. In the course of processing service requests, it may be necessary to collect additional data (name, address). The use of SugarCRM is optional and serves to improve and accelerate our customer and user service.
If users do not agree to the collection of data via and storage of data in the external system of SugarCRM, we offer them alternative ways to submit service requests via e-mail, phone, fax or mail.
We use our own KlimaPartnerPortal (in short "KPP") in order to be able to process user requests faster and more efficiently (legitimate interest according to Art. 6 Par. 1 lit. f. GDPR ). The data is stored at Microsoft Azure GDPR compliant in Northern Europe. For more information, please visit https://privacy.microsoft.com/de-de/privacystatement.
The KPP uses the users' data only for the technical processing of the requests and does not pass them on to third parties. To use the KPP at least the indication of a correct e-mail address is necessary. A pseudonymous use is possible. In the course of processing service requests it may be necessary to collect further data (name, address). The use of the KPP is optional and serves to improve and accelerate our customer and user service.
If users do not agree with data collection via and data storage in the external system of the KPP, we offer them alternative contact possibilities to submit service requests via e-mail, phone, fax or mail.
With the following notes we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the described procedures.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter referred to as "newsletter") only with the consent of the recipients or a legal permission. If, in the course of registering for the newsletter, its contents are specifically described, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and us.
Double-Opt-In and logging: The registration to our newsletter is done in a so-called Double-Opt-In procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Registration data: To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name for personal contact in the newsletter.
The dispatch of the newsletter and the associated measurement of success are based on the consent of the recipients in accordance with Art. 6 Para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 Para. 2 No. 3 UWG or, if consent is not required, on our legitimate interests in direct marketing in accordance with Art. 6 Para. 1 lt. f. GDPR in conjunction with § Section 7 para. 3 of the UWG.
The logging of the registration procedure is based on our legitimate interests in accordance with Art. 6 para. 1 lit. f GDPR. We are interested in the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and also allows us to prove their consent.
Cancellation/revocation - You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years based on our legitimate interests before we delete them to prove that you have previously given your consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Newsletter - Mailing service provider
We use "dialog-Mail", a software of the Austrian company dialog-Mail eMarketing Systems GmbH, located in Nussgasse 31, 3434 Wilfersdorf, for the creation and dispatch of our e-mailings. We also use it to analyze openings or clicks so that we can adapt our information offering to the needs of our readers and provide them with targeted information. IP addresses are not analyzed by us. All data is processed by dialog-Mail in a high-security data center in Vienna.
You can unsubscribe from the mail service (e.g. the newsletter) at any time and without giving reasons by clicking on the appropriate "unsubscribe" link in each e-mail or simply send us an e-mail to that effect. If you want to change or correct your data, you can also use the corresponding link in each e-mail or contact us by e-mail.
If you unsubscribe from all our newsletters and we are not obliged to keep your data due to other regulations, we will delete your data after you have unsubscribed.
Newsletter - Measurement of success
The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and time of retrieval are initially collected.
This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined by means of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the mailing service provider, if used, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
Unfortunately, it is not possible to cancel the success measurement separately. In this case, the entire newsletter subscription must be cancelled.
Hosting and e-mailing
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services as well as technical maintenance services that we use for the purpose of operating this online offer.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of contract processing agreement).
Collection of access data and log files
We, or our hosting provider, on the basis of our legitimate interests as defined in Art. 6 para. 1 lit. f. GDPR data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited site), IP address and the requesting provider.
For security reasons (e.g. to clarify misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further storage is required for evidence purposes is excluded from deletion until the respective incident has been finally clarified.
Online presence in social media
We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Integration of third-party services and content
We set within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR), we use content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content").
This always presupposes that the third-party providers of such content are aware of the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore necessary for the display of this content. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain technical information about the browser and operating system, referring websites, visiting times and other details about the use of our online offer, as well as being linked to such information from other sources.