for the contents and functions of www.re-frame.studio (hereinafter “Services”)
Status: July 2023
The Controller within the meaning of the General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG) and other data protection regulations is the
Re.Frame Studio GbR – Strategic Design Studio for Sustainability
c/o 105 FOURTH Impact Community
Hereinafter referred to as “Controller” or “we”.
2. General information about data processing
2.1 Personal data
Personal data is individual information about personal or factual circumstances of an identified or identifiable natural person.
Individual details about personal or factual circumstances are, for example:
- Name, age, marital status, date of birth
- Address, telephone number, e-mail address
- Account and credit card number
- IP address & location data
2.2 How we process personal data
We process personal data within the legally permissible limits. This means that data processing operations are based on a legal basis. These are standardized in Art. 6 (1) GDPR. Most data processing is based on a legitimate interest on our part (Art. 6 (1) (f) DGPR), on processing operations necessary for the performance of the contract (Art. 6 (1) (b) GDPR) or on the basis of consent given by you (Art. 6 (1) (a) GDPR). In the latter case, you will be informed separately (e.g. via a cookie banner) about the consent process.
Personal data is processed by us only for clear purposes (Art. 5 (1) (b) GDPR). As soon as the purpose of the processing ceases to apply, your personal data will be deleted or protected by technical as well as organizational measures (e.g. by pseudonymization).
The same applies to the expiry of a prescribed storage period, subject to cases in which further storage is necessary for the conclusion or fulfillment of a contract. In addition, there may be a legal obligation to store data for a longer period or to pass it on to third parties (esp. to law enforcement agencies). In other cases, the storage period and type of data collected as well as the type of data processing depends on which functions you use in each individual case. We will be happy to provide you with information about this in individual cases, in accordance with Art. 15 GDPR.
2.3 We process these data categories
Data categories are in particular the following data:
- Master data (e.g. names, addresses, dates of birth),
- Contact data (e.g. email addresses, telephone numbers, messenger services),
- Content data (e.g. text entries, photographs, videos, contents of documents/files),
- Contract data (e.g., subject matter of contract, terms, customer category),
- Payment data (e.g. bank details, payment history, use of other payment service providers),
- Usage data (e.g. history in our services, use of certain content, access times),
- Connection data (e.g. device information, IP addresses, URL referrers).
2.4 We take these security measures
In accordance with legal requirements and taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to your rights and freedoms, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
In particular, the measures include ensuring that your data is stored and processed confidentially, with integrity and available at all times. Furthermore, the security measures we implement include controls on access to your data as well as access, input, disclosure, ensuring availability and their separation from data of other natural persons. Furthermore, we have established procedures to ensure the exercise of data subject rights (see under Section 5), the deletion of data and responses in the event of a risk to your data. Furthermore, we already take the protection of personal data into account in the development of our software and through procedures that comply with the principle of data protection through technology design and through data protection-friendly default settings.
2.5 How we transfer or disclose personal data to third parties
As part of our processing activities of your personal data, it happens that this data is transferred or disclosed to other bodies, companies, legally independent organizational units or persons. These third parties may include, for example, payment institutions in the context of payment transactions, service providers entrusted with IT tasks or providers of services and content that we have integrated into our website. If we transfer or disclose your personal data to third parties, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.
2.6 How a third country transfer takes place
If this data protection statement shows that we transfer your personal data to a third country, i.e. a country outside the EU or outside the EEA, the following applies.
Should we process your data in a third country or should the processing take place in the context of using third-party services in a third country, this will only be done in accordance with the legal requirements.
Furthermore, a third country transfer usually only takes place with your express consent. Whether or not such consent is given, we ensure that we have contractual or legal authorization to transfer and process your data in the third country in question. Furthermore, we only allow your data to be processed by service providers in third countries that, in our view, have a recognized level of data protection. This means that a corresponding adequacy decision exists between the EU and the country in which we transfer your personal data, for example. An “adequacy decision” is a decision adopted by the European Commission pursuant to Article 45 of the GDPR establishing that a third country (i.e., a country not bound by the GDPR) or an international organization provides an adequate level of protection for personal data. Alternatively, for example, if there is no adequacy decision, a third country transfer will only take place if, for example, there are contractual obligations between us and the service provider in the third country through so-called standard contractual clauses of the EU Commission and further technical security precautions have been taken that ensure an adequately equivalent level of protection to that in the EU or the service provider in the third country can show data protection certifications and your data is only processed in accordance with internal data protection regulations (Art. 44 to 49 GDPR. Information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
2.7 Information about the cookies used
Cookies are small text files that contain data from visited websites or domains and are stored on your device (computer, tablet or smartphone). If you access a website, the cookie stored on your device sends information to the party that placed the cookie.
2.7.1 First-party cookies and third-party cookies
Our Services may set third-party cookies and allow third parties to place cookies on your device. The difference between a first party cookie and a third party cookie is the control over the placement of the cookie. First party cookies are cookies that are specific to the Services that created them. Their use allows us to provide an efficient service and to evaluate your user behavior in our Services. Third-party cookies are placed on your device by third parties (i.e., not by us). Although we may allow third parties to access our Services to place cookies on your devices, we do not control the information provided by the cookies nor do we have access to this data. This information is processed entirely by the third parties in accordance with their respective privacy policies and, where applicable, any processing contracts entered into between us and the third parties pursuant to Article 28 of the GDPR or shared responsibility contracts pursuant to Article 26 of the GDPR.
Factually, we distinguish between
- Functional cookies: these cookies are necessary for the basic technical functions of the Services. These cookies enable, for example, a secure login and the storage of the progress of order processes. Furthermore, they enable us, for example, to store your login data, the contents of your shopping cart and the uniform display of page content.
- Statistics Cookies: These cookies allow us to analyze the Services so that we can measure and improve their performance. You can change your personal settings of the statistics cookies by clicking on the appropriate opt-out link.
- Marketing Cookies: These cookies are used by us to serve you advertisements that may be relevant to your interests. These cookies enable, for example, the sharing of pages via social networks and the posting of comments. Likewise, offers that may correspond to your interests are displayed. You can change your personal marketing cookie settings by clicking on the corresponding opt-out link.
2.7.3 Storage period of cookies
Unless we provide you with explicit information about the storage period of cookies (e.g., within the cookie banner), you can assume that the storage period can be up to two years. If cookies were set on the basis of your consent, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”).
3. data processing in connection with the use of our services
The use of our Services with all their features involves the processing of personal data. We explain exactly how this is done here.
3.1 Informational use of our services
The purely informational use of our services requires the processing of the following personal data and information: Browser type and browser version, operating system used, address of previously visited Internet pages, IP address of the terminal device with which you access our Services, as well as the time of the call of our Services. All of this information is automatically transmitted by your browser if you have not configured it in such a way that transmission of the information is suppressed.
This personal data is processed for the purpose of the functionality and optimization of our services, as well as to ensure the security of our information technology systems. These purposes are at the same time legitimate interests according to Art. 6 (1) (f) GDPR, the processing is therefore carried out with legal grounds.
3.2 Contact form / contacting us by e-mail
We process your personal data that you provide to us in the context of contacting us for the purpose of responding to your inquiry, your e-mail or your callback request. Processed data categories are master data, contact data, content data, possibly usage data, connection data and possibly contract data. In individual cases, we forward this data to companies associated with us or to third parties that we commission to process orders. The legal basis of the processing depends on the purpose of the contact.
- Basically, it is based on our legitimate interest and thus on Art. 6 (1) (f) GDPR;
- If a contract conclusion is to be targeted, the authorization is based on Art. 6 (1) (b) GDPR.
We use the appointment scheduling tool Calendly in our Services to arrange appointments with you. You can request and select an appointment for a consultation via the Calendly appointment scheduling tool with its integrated online calendar. “Calendly” is an offering of Calendly, LLC, 3423 Piedmont Road NE, Atlanta, GA 30305-1754, United States.
The information you provide in the Calendly form, including the data you enter there, will be stored by us for the purpose of processing your request or for the purpose of processing a corresponding contractual relationship. If your inquiry is answered or the purpose ceases to exist (e.g. the contractual relationship ends), we will promptly delete your data, subject to contractual or legal retention options. If you would like your data to be deleted prematurely, you can request us to delete it or revoke your consent to its storage. Mandatory legal provisions – in particular retention periods – remain unaffected. Our legal basis for using the Calendly appointment scheduling tool results from Art. 6 (1) (f) GDPR (legitimate interest), as Calendly allows us to fully automate appointment scheduling and thus make the process for corresponding appointment requests and meetings more efficient. Furthermore, the legal basis for data processing using Calendly is Art. 6 (1) (b) GDPR, insofar as the appointment scheduling is carried out within the scope of our contractual relationships.
3.4 Web hosting
3.4.1 Provision of our services
In order to provide you with our services, we use the services of a web hosting provider. Our services are accessed from the servers of these web hosting providers. For these purposes, we use the web hosting provider’s infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.
The processed data includes all such data that you enter or that is collected by you in the course of your use and communication in connection with your visit to our services (e.g. your IP address). Our legal basis for using a web hosting provider to provide our services results from Art. 6 (1) (f) GDPR (legitimate interest).
3.4.2 Receiving and sending e-mails
The services of the web host used by us may also include the sending, receiving as well as storing of e-mails. For these purposes, the addresses of the recipients of your e-mails as well as the senders as well as further information concerning the e-mail dispatch (e.g. the providers involved) as well as the contents of the respective e-mails are processed. The aforementioned data is processed, among other things, for the purpose of recognizing SPAM. E-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless end-to-end encryption is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server. Our legal basis for using a web hosting provider to receive and send e-mails results from Art. 6 (1) (f) GDPR (legitimate interest).
3.4.3 Collection of access data and log files
We ourselves (or our web hosting provider) collect data on each access to the server (server log files). The server log files may include the address and name of the services and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, your operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files may be used on the one hand for security purposes, e.g. to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability. Our legal basis for using a web hosting provider to collect access data and log files results from Art. 6 (1) (f) GDPR (legitimate interest).
3.5 Tracking & Tools
In order to ensure a smooth technical process and optimal user-friendly use of our services, we use the following services:
We use Google Analytics for the purpose of statistical evaluation of your use of our Services. Your IP address is collected by us before it is anonymized by Google by shortening it before it is permanently stored on their servers. Processed data are usage data & connection data. The recipient of the data is Google Ireland Ltd, Gordon House, Barrow Street Dublin 4 Ireland (as joint controller, Art. 26 GDPR). Should Google transfer this data to a third country (e.g. the USA), this will only be done on a case-by-case basis, on the basis of an order processing agreement concluded with Google and in accordance with standard contractual clauses agreed with Google and other security measures permitted by the GDPR, which ensure the security of the processing of your personal data with a level of protection identical to that in the EU. The legal basis for the use of Google Analytics is your consent (e.g. via an opt-in in the cookie banner), provided that you have given it to us in the context of your visit to our services and therefore results from Art. 6 (1) (a) GDPR. Based on your consent, cookies are stored on your terminal device and personal data is read through this. If you have not given us your consent to use Google Analytics (no opt-in in the cookie banner or revocation of your consent), we will not (or no longer) use Google Analytics in the context of your visits to our services.
3.6 Newsletter dispatch
With your consent (regularly by subscribing), we will send you newsletters, e-mails and other electronic notifications (hereinafter “newsletter”). Our newsletters usually contain technical, commercial and promotional information about our services.
To subscribe to our newsletter, it is generally sufficient for you to provide your e-mail address. If necessary, we ask you to provide additional information such as your name or similar.
The registration for our newsletter always takes place in a so-called double opt-in procedure. After registering for our newsletter, you will receive an e-mail in which you will be asked to confirm your registration by clicking on a confirmation link. This confirmation is necessary to prevent someone else from registering for a newsletter using your e-mail address. We log the registrations for the newsletter for the purpose of being able to prove the registration process in accordance with legal requirements. For this purpose, we store the registration and confirmation time as well as your IP address. Likewise, changes to your data stored with the shipping service provider are logged.
You can unsubscribe from our newsletter at any time. To do so, simply click on the “Unsubscribe” button contained in the footer of each newsletter. Should you unsubscribe from our newsletter, your e-mail address may be stored for up to three years on the basis of our legitimate interests before we delete it, so that we can prove your formerly given consent.
If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure mailing system.
The legal basis for sending newsletters is your consent, insofar as you have given it to us by subscribing to the newsletter, and therefore results from Art. 6 (1) (a) GDPR. If you have not given us your consent to send newsletters, we will not send (any more) newsletters to you.
3.7 Fan pages on social media websites
We maintain fan pages on the websites of social networks on the Internet and process personal data in this context in order to communicate with users active there or to offer information about us. We would like to point out that your data may be processed outside the area of the European Union when you visit our fan pages. The operators of the respective social networks are responsible for this. You can find a detailed description of the respective forms of processing and the options to object (e.g. opt-out) in the privacy statements of the operators of the respective social networks.
We operate a so-called Instagram fan page for our company on Instagram. When you visit the Instagram fan page, Meta may evaluate your usage behavior and provide us with information obtained from this (“insights”). The use of the page insights is for the purpose of economic optimization and demand-oriented design of our website/our services. The categories of data processed include master data, contact data, content data, usage data and connection data. The recipient of the data is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, as joint controller pursuant to Art. 26 GDPR. The legal basis for processing the data according to the stipulation mentioned here results from our legitimate interest and thus from Art. 6 (1) (f) GDPR.
Meta is responsible for the implementation of your data protection rights. Meta will inform you about your data subject rights at: https://privacycenter.instagram.com/policy . You can also assert your rights against us, we will then forward your request to Meta immediately.
We operate a LinkedIn fan page for our company on LinkedIn. When you visit and use the LinkedIn fan page, LinkedIn may evaluate your usage behavior and provide us with information obtained from this. This information is used for the purpose of economic optimization and demand-oriented design of our website/our services. Processed data categories are master data, contact data, content data, usage data, connection data. The recipient of the data is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, as joint controller pursuant to Art. 26 GDPR. The legal basis for processing the data according to the stipulation mentioned here results from our legitimate interest and thus from Art. 6 (1) (f) GDPR.
LinkedIn is responsible for the implementation of your data subject rights. LinkedIn will inform you about your data subject rights at: https://linkedin.com/legal/privacy-policy. You can also assert your rights against us, we will then forward your request to LinkedIn immediately.
We operate a fan page about our company on reflecta. When you visit and use the fan page, your usage behavior may be evaluated and information obtained from this may be communicated to us. This information is used for the purposes of economic optimization and needs-based design of our website/our services. Processed data categories are master data, contact data, content data, usage data, connection data. The recipient of the data is Reflecta gGmbH, An der Kolonnade 11, 10117 Berlin, as joint controller pursuant to Art. 26 GDPR. The legal basis for processing the data according to the stipulation mentioned here results from our legitimate interest and thus from Art. 6 (1) (f) GDPR.
Reflecta is responsible for the implementation of your data protection rights. LinkedIn informs you about your data subject rights at: https://www.reflecta.network/datenschutz. You can also assert your rights against us, we will then forward your request immediately.
4. commissioned processing
If we use external service providers to process your data, they will be carefully selected and commissioned by us. If the services provided by these service providers are commissioned processing within the meaning of Art. 28 GDPR, the service providers are bound by our instructions and are regularly monitored. In this regard, our order processing contracts comply with the strict requirements of Art. 28 GDPR as well as the requirements of the German data protection authorities.
5. data subject rights
If your personal data is processed, you are a data subject within the meaning of the GDPR and as a user you are entitled to the following rights vis-à-vis the controller:
5.1 Right to information
You may request confirmation from the controller as to whether personal data concerning you is being processed by us.
If such processing exists, you may request information from the controller about the following:
- The purposes for which the personal data are processed;
- the categories of personal data which are processed;
- the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
- the planned duration of the storage of the personal data concerning you or, if concrete information on this is not possible, criteria for determining the storage period;
- the existence of a right to rectification or erasure of the personal data concerning you, a right to restriction of processing by the controller or a right to object to such processing;
- the existence of a right of appeal to a supervisory authority;
- any available information on the origin of the data, if the personal data are not collected from the data subject;
- the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.
- You have the right to request information about whether the personal data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed about the appropriate safeguards pursuant to Article 46 of the GDPR in connection with the transfer.
5.2 Right to rectification
You have a right to rectification and/or completion vis-à-vis the controller if the personal data processed concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
5.3 Right to restriction of processing
Under the following conditions, you may request the restriction of the processing of personal data concerning you:
- if you contest the accuracy of the personal data concerning you for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and you object to the erasure of the personal data and request instead the restriction of the use of the personal data;
- the controller no longer needs the personal data for the purposes of processing, but you need them for the establishment, exercise or defense of legal claims; or
- if you have objected to the processing pursuant to Article 21 (1) GDPR and it is not yet clear whether the legitimate grounds of the controller outweigh your grounds.
- If the processing of personal data relating to you has been restricted, such data may – apart from being stored – only be processed with your consent or for the assertion, 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 a Member State.
If the restriction of processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
5.4 Right to erasure
5.4.1 You may request the controller to erase the personal data concerning you without undue delay, and the controller is obliged to erase this data without undue delay, if one of the following reasons applies:
- The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
- You withdraw your consent on which the processing was based pursuant to Art. 6 (1) a or Art. 9 (2) a GDPR and there is no other legal basis for the processing.
- You object to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the You object to the processing pursuant to Art. 21 (2) GDPR.
- The personal data concerning you have been processed unlawfully.
- The erasure of the personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
- The personal data concerning you has been collected in relation to information society services offered pursuant to Article 8(1) of the GDPR.
5.4.2 If the controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17(1) of the GDPR, it shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers processing the personal data that you, as the data subject, have requested that they erase all links to or copies or replications of such personal data.
5.4.3 The right to erasure shall not apply to the extent that the processing is necessary
- For the exercise of the right to freedom of expression and information;
- for compliance 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 Art. 9 (2) (h) and (i) and Art. 9 (3) GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Art. 89 (1) GDPR, insofar as the right referred to in (1) is likely to render impossible or seriously prejudice the achievement of the purposes of such processing; or
- for the assertion, exercise or defense of legal claims.
5.5 Right to information
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right against the controller to be informed about these recipients.
5.6 Right to data portability
You have the right to receive the personal data concerning you that you have provided to the controller in a structured, common and machine-readable format. In addition, you have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out with the help of automated procedures.
In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.
The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
5.7 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 which is carried out on the basis of Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions.
The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.
If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to processing of the personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right to object by means of automated procedures using technical specifications.
5.8 Right to revoke your declaration of consent under data protection law
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
The processing is lawful until your revocation – the revocation thus only affects the processing after receipt of your revocation. You can declare the revocation informally by mail or e-mail. The processing of your personal data will then no longer take place, subject to permission by another legal basis. If this is not the case, your data must be deleted immediately after the revocation in accordance with Art. 17 (2) GDPR. Your right to revoke your consent subject to the above conditions is guaranteed.
Your revocation should be addressed to:
Re.Frame Studio GbR – Strategic Design Studio for Sustainability
c/o 105 FOURTH Impact Community
5.10 Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.
6. automated decisions in individual cases including profiling.
Automated decisions in individual cases including profiling do not take place.
7. notification obligations of the Controller
If your personal data have been disclosed to other recipients (third parties) with legal grounds, we will notify them of any rectification, erasure or restriction of the processing of your personal data (Art. 16, Art. 17(1) and Art. 18 GDPR). The notification obligation does not apply if it is associated with a disproportionate effort or is impossible. We will also inform you about the recipients upon request.