We run our websites according to the following principles: We undertake to comply with the statutory provisions on data protection and endeavour to always observe the principles of data avoidance and data minimisation.
1. the name and address of the person responsible and of the data protection officer
a) The person responsible within the meaning of the Basic Data Protection Regulation and other national data protection laws of the member states of the European Union as well as other provisions of data protection law is
Gambit Consulting GmbH
Vertr. d. d. Geschäftsführer Dipl.-Kfm. Thomas Pasquale and
(b) The data protection officer of the controller is:
2. definitions of terms
We have designed our data protection declaration according to the principles of clarity and transparency. However, if there are any ambiguities regarding the use of different terms, the corresponding definitions can be found here.
3. legal basis for the processing of personal data
We only process your personal data such as your surname and first name, your e-mail address and IP address etc. if there is a legal basis for this. In particular, the basic data protection Regulation provides for three possible rules in this respect:
a) You have given us your consent to the processing of your personal data for one or more purposes, Art. 6 Para. 1 S. 1 lit. a DSGVO. In this context, we will inform you in detail about the purpose or purposes of the processing and we will document your express consent.
b) The processing of your personal data is necessary for the fulfilment of a contract or for the implementation of pre-contractual measures with you, Art. 6 Para. 1 S. 1 lit. b DSGVO.
c) The processing of personal data is necessary to safeguard our legitimate interests, unless your interests or fundamental rights and freedoms prevail, Art. 6 para. 1 sentence 1 lit. f DSGVO. However, we will always point out to you at the respective points on which legal basis the processing of your personal data takes place.
4. disclosure of personal data
Your personal data will not be transferred to third parties for purposes other than those listed below. We will only pass on your personal data to third parties if:
a) you have given your express consent to this pursuant to Art. 6 para. 1 sentence 1 lit. a DSGVO,
b) the disclosure according to Art. 6 para. 1 sentence 1 lit. f DSGVO is necessary for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding legitimate interest in not disclosing your data,
c) there is a legal obligation to pass on data pursuant to Art. 6 para. 1 sentence 1 lit. c DSGVO
d) this is legally permissible and necessary for the execution of contractual relationships with you pursuant to Art. 6 para. 1 sentence 1 lit. b DSGVO.
5. storage duration and deletion
We will store any personal data you provide to us only as long as it is needed to fulfill the purposes for which it was provided or as long as required by law. Upon fulfilment of the purpose and/or expiry of the statutory storage periods, the data will be deleted or blocked by us.
6. SSL encryption
This website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as requests you send to us as a website operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.
If SSL encryption is activated, the data that you transmit to us cannot be read by third parties.
7. collection and storage of personal data as well as their type and purpose of use
a) When visiting the website
When you visit our website, the browser used on your terminal device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file. The following information will be collected without your intervention and stored until automated deletion:
- Date and time of access
- Name and URL of the retrieved file
- Web page from which access is made (referrer URL)
- the browser used and, if applicable, the operating system of your computer as well as the name of your access provider
The data mentioned will be processed by us for the following purposes:
- Ensuring a smooth connection of the website
- Ensuring a comfortable use of our website
- Evaluation of system safety and stability
- for other administrative purposes
Data which allow a conclusion about your person, e.g. the IP address, will be deleted after 7 days at the latest. If we should store the data beyond this period, these data are pseudonymised, so that an allocation to you is no longer possible. The legal basis for data processing is Art. 6 Para. 1 S. 1 lit. f DSGVO. Our justified interest follows from the purposes listed above for the collection of data. Under no circumstances do we use the collected data for the purpose of drawing conclusions about your person.
b) Contact form / e-mail contact
We provide you with a form on our website so that you have the opportunity to contact us at any time. In order to use the contact form, it is necessary to provide a name for a personal salutation and a valid e-mail address for contacting us so that we know who sent the request and can process it.
If you send us enquiries via the contact form, your data from the enquiry form including the contact data provided by you as well as your IP address pursuant to Art. 6 Para. S. 1 lit. b and f DSGVO will be processed in order to carry out pre-contractual measures which are carried out at your request or in order to fulfil our legitimate interest, namely to carry out our business activities.
You can also send us an email instead using the email address provided on our website. In this case, we store and process your e-mail address and the information you provide in the e-mail in accordance with Art. 6 Para. S. 1 lit. b and f DSGVO in order to process your message.
The requests and the associated data will be deleted no later than 3 months after receipt, unless they are required for a further contractual relationship.
The data processed by cookies are necessary for the purposes mentioned to safeguard our legitimate interests and those of third parties in accordance with Art. 6 Para. S. 1 lit. f DSGVO.
Most browsers automatically accept cookies due to the default browser settings. However, you can configure your browser so that either no cookies are stored on your end device or at least a message is displayed before a new cookie is stored. If you completely deactivate the cookie function in your browser, you may not be able to use all the functions of our website.
Below we explain the different types of cookies we use.
a) Session cookies
In order to make the use of our website more pleasant for you, we use so-called session cookies to recognize that you have already visited individual pages on our website. These session cookies are automatically deleted after leaving our site.
b) Temporary Cookies
c) Cookies for marketing and optimization purposes
These cookies are automatically deleted after a defined period of time.
9. analysis and tracking tools
We use the following analysis and tracking tools on our website. These are used to ensure the ongoing optimisation of our website and to design it to meet your needs.
We use these tools on the basis of your consent pursuant to Art. 6 para. 1 p. 1 lit. a DSGVO. You can revoke your consent at any time by changing the cookie settings. The processing remains lawful until revocation.
The respective data processing purposes and data categories can be found in the corresponding tools. We would like to point out that we have no influence on whether and to what extent the service providers carry out further data processing.
a) Google Analytics
On our website, we use Google Analytics, a web analysis service provided by Google Inc. (https://www.google.de/intl/de/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter "Google").
- Name and version of the browser used
- Operating system of your computer
- Web page from which access is made (referrer URL)
- IP address of the requesting computer
- Time of the server request
are usually transferred to a Google server in the USA and stored there.
However, because we have enabled IP anonymization on our website, Google will previously truncate your IP address within member states of the European Union or other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
On our behalf, Google will use this information to evaluate your use of our website, to compile reports on website activity and to provide us with other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google.
You can prevent the storage of cookies by setting your browser software accordingly. However, we would like to point out that in this case you may not be able to use all the functions of our website to their full extent.
You can also prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) as well as Google from processing this data by downloading and installing the browser plugin available under the following link http://tools.google.com/dlpage/gaoptout?hl=de
You can prevent Google Analytics from collecting your data by clicking on the following link. An opt-out cookie is set to prevent your information from being collected on future visits to our website:
b) Google Remarketing
We use Google Analytics' remarketing feature to target advertising campaigns - including Google AdWords campaigns - to visitors to our website.
Based on your previous visits to our website, you will be presented with relevant advertisements from other websites on the Google Display Network when you visit our website.
The DoubleClick cookie enables Google to target advertisements to us and other third parties that match the interests identified based on your previous visits to our website and/or other websites. This advertising may be displayed on Google and/or other Google network operators' websites. We also use Google Analytics advertising features to analyze the effectiveness of our own advertising campaigns.
You can personalize your Google ad settings and disagree with Google's interest-based ads. In this case, the cookie ID (assigned individually for each cookie) of the DoubleClick cookie is overwritten and can no longer be associated with a specific browser.
If you delete all cookies from your device, a new DoubleClick cookie may be placed. Then you may need to renew your opposition settings. You can permanently disable the DoubleClick cookie by downloading and installing the appropriate browser plugin here: http://www.google.com/settings/ads/plugin You may opt out of the use of third-party cookies for online advertising purposes on the U.S. http://www.aboutads.info/choices/ websiteor the EUhttp://www.youronlinechoices.com/ website.
If you have agreed in your Google Account that Google will link your web and app browsing history to your Google Account and use information from your Google Account to personalize ads, Google will use data from you, along with Google Analytics data, to create cross-device remarketing audience lists. Google Analytics first collects Google-authenticated IDs associated with your Google Account for you as a user on our website. Google Analytics then temporarily links these IDs to Google Analytics data to optimize our target audiences.
Please click here for an overview of data protection at Google.
c) Google AdWords
On our website we use Google AdWords, an online advertising program of Google Inc. which also uses conversion tracking. With this tool, Google AdWords places a cookie on your device when you come to our website via a Google advertisement.
The cookie is no longer valid after 30 days. It does not serve any personal traceability. If you visit our website as a user and the cookie is still working, we will recognize together with Google that you have clicked on the corresponding advertisement and have been forwarded to our website. Each Google AdWords customer will be assigned a different cookie. Cookies are thus not traceable via the web pages of AdWords customers.
Conversion statistics for AdWords customers are created using the data collected by conversion cookies. As Google AdWords customers, we learn the total number of users who responded to our ad and were then redirected to a website that was tagged with a conversion tracking tag. During this process, we do not receive any information with which we could personally identify you as a user.
If you reject the tracking procedure, the Google Conversion Tracking cookie can be deactivated via your Internet browser.
d) Facebook Conversion Pixel
We use the "conversion pixel" or visitor action pixel of Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland). By calling up this pixel from your browser, Facebook can subsequently recognise whether a Facebook advertisement was successful, e.g. led to an online purchase.
We only receive statistical data from Facebook for this purpose without any reference to a specific person. This allows us to record the effectiveness of the Facebook ads for statistical and market research purposes. In particular, if you are registered with Facebook, we refer you to their data protection information https://www.facebook.com/about/privacy/.
You have the option of changing your settings on Facebook at https://www.facebook.com/settings?tab=ads or you can click here if you wish to revoke your consent to the conversion pixel.
e) LinkedIn Conversion Tracking
We use the conversion tracking function of LinkedIn on our website. This enables us to target you with advertisements following a visit to our website. In addition, LinkedIn provides reporting that shows how successful our advertisements are and how users interact with our site in general. If you have logged in via LinkedIn before visiting our site, this will be recognised as part of the conversion tracking and you will be associated with your LinkedIn account as a visitor to our site.
You also have the option to unsubscribe from interest-based advertising via LinkedIn. This is possible via the following link:
10. rights of the data subject
You have the following rights:
Pursuant to Art. 15 DSGVO, you have the right to request information about your personal data processed by us. This right to information shall include information on
- the processing purposes
- the categories of personal data
- the recipients or categories of recipients to whom your information has been or will be disclosed
- the planned storage period or at least the criteria for determining the storage period
- the existence of a right to rectification, erasure, limitation of processing or opposition
- the existence of a right of appeal to a supervisory authority
- the origin of your personal data, if not collected by us
- the existence of automated decision making, including profiling and, where appropriate, meaningful information on its details
According to Art. 16 DSGVO, you have the right to immediate correction of incorrect or incomplete personal data stored by us.
According to Art. 17 DSGVO, you have the right to demand the immediate deletion of your personal data from us unless further processing is necessary for one of the following reasons:
- on the exercise of freedom of expression and of information
- to fulfil a legal obligation which processing is subject to under the law of the European Union or of the Member States to which the controller is subject or to perform a task carried out in the public interest or in the exercise of official authority vested in the controller
- on grounds of public interest in the field of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) DSGVO
- for archive purposes in the public interest, for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 DSGVO, insofar as the law referred to under section a) presumably makes the attainment of the objectives of such processing impossible or seriously impairs them
- for the assertion, exercise or defence of legal claims
(d) Limitation of processing
Pursuant to Art. 18 DSGVO, you may request the restriction of the processing of your personal data for one of the following reasons:
- You dispute the accuracy of your personal data.
- The processing is unlawful and you refuse the deletion of personal data.
- We no longer need the personal data for the purposes of processing, but you need it to assert, exercise or defend legal claims.
- They lodge an objection against the processing pursuant to Art. 21 (1) DSGVO.
If you have requested the correction or deletion of your personal data or a restriction on processing in accordance with Art. 16, Art. 17 Para. 1 and Art. 18 DSGVO, we will inform all recipients to whom your personal data has been disclosed of this, unless this proves to be impossible or involves a disproportionate effort. You can ask us to inform you of these recipients.
You have the right to receive the personal data you have provided to us in a structured, common and machine-readable format.
You also have the right to request the transfer of this data to a third party if the processing was carried out using automated procedures and is based on consent pursuant to Art. 6 Para. 1 Sentence 1 lit. a or Art. 9 Para. 2 lit. a or on a contract pursuant to Art. 6 Para. 1 Sentence 1 lit. b DSGVO.
Pursuant to Art. 7 para. 3 DSGVO, you have the right to revoke your consent to us at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation. In the future, we may no longer continue the data processing based on your revoked consent.
Pursuant to Art. 77 DSGVO, you have the right to complain to a supervisory authority if you are of the opinion that the processing of your personal data violates the DSGVO.
If your personal data are processed on the basis of legitimate interests pursuant to Art. 6 para. 1 sentence 1 lit. f DSGVO, you have the right, pursuant to Art. 21 DSGVO, to object to the processing of your personal data if there are reasons for doing so which arise from your particular situation or if the objection is directed against direct advertising. In the latter case, you have a general right of objection, which will be implemented by us without stating the particular situation. If you wish to exercise your right of revocation or objection, simply send an e-mail to: firstname.lastname@example.org
j) Automated decision in individual cases including profiling
You have the right not to be subject to any decision based solely on automated processing, including profiling, that has any legal effect on you or similarly significantly affects you. This shall not apply if the decision
- i. is necessary for the conclusion or performance of a contract between you and us
- ii. is permitted by the laws of the European Union or the Member States to which we are subject and those laws contain reasonable measures to protect your rights and freedoms and your legitimate interests
- iii. with your express consent
However, these decisions may not be based on special categories of personal data under Art. 9 para. 1 DSGVO, unless Art. 9 para. 2 lit. a or g DSGVO applies and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.
With respect to cases referred to in i) and iii), we will take reasonable steps to protect your rights and freedoms and your legitimate interests, including, as a minimum, the right to obtain interference from us, to state our point of view and to challenge the decision.
11. amendment of the data protection declaration
If we should change the data security explanation, then this is marked on the web page.