Privacy Policy

We inform you below in accordance with the legal requirements of data protection law (in particular BDSG (new version) and the European General Data Protection Regulation (GDPR) on the nature, scope, and purpose of the processing of personal data by our company. This privacy policy also applies to our websites and social media profiles. For the definition of terms such as "personal data" or "processing," please refer to Art. 4 GDPR.

Name and contact details of the responsible person

Our responsible person (hereinafter "responsible person") within the meaning of Art. 4 No. 7 GDPR is:

Sebastian Oelke
Nong 903, Hutai Road, Nr. 31
Room 102
Shanghai 200072
Email address: blog@soelke.de

Data types, purposes of processing and categories of data subjects

Below we inform you about the type, scope and purpose of the collection, processing and use of personal data.

1. Types of data we process

Usage data (access times, websites visited, etc.), inventory data (name, address, etc.), contact details (telephone number, email, fax, etc.), payment data (bank details, account details, payment history, etc.),

Processing of contracts, optimizing the website technically and economically, enabling easy access to the website, fulfilling contractual obligations, optimizing and statistically evaluating our services, supporting commercial use of the website, preventing SPAM and misuse, processing contact requests, providing websites with functions and content, ensuring uninterrupted, secure operation of our website,

Visitors/users of the website, customers,

The data subjects are collectively referred to as “users”.

Legal basis for the processing of personal data

Below we inform you about the legal basis for the processing of personal data:

If we have obtained your consent to process personal data, Art. 6 (1) (a) GDPR is the legal basis.
If the processing is necessary to fulfil a contract or to carry out pre-contractual measures necessary, which are carried out at your request, Art. 6 (1) (b) GDPR is the legal basis.
If processing is necessary to fulfill a legal obligation to which we are subject (e.g. statutory retention periods), Art. 6 (1) (c) GDPR is the legal basis.
If processing is necessary to protect the vital interests of the data subject or of another natural person, Article 6 (1) (d) GDPR shall be the legal basis.
If processing is necessary to protect our legitimate interests or the legitimate interests of a third party and your interests or fundamental rights and freedoms do not outweigh them, Art. 6 (1) (f) GDPR is the legal basis.

Transfer of personal data to third parties and processors

We generally do not share data with third parties without your consent. Should this be the case, the transfer will be based on the aforementioned legal grounds, e.g., when sharing data with online payment providers for
contract fulfillment or due to a court order or a legal obligation to disclose data for the purposes of criminal prosecution, threat prevention, or the enforcement of intellectual property rights.

We also use contract processors (external service providers, e.g., for web hosting our websites and databases) to process your data. If data is passed on to the contract processors as part of a contract processing agreement, this is always done in accordance with Art. 28 GDPR. We carefully select our processors, monitor them regularly, and have been granted the right to issue instructions regarding the data. Furthermore, the processors must have implemented appropriate technical and organizational measures and comply with the data protection regulations in accordance with the new version of the Federal Data Protection Act (BDSG) and the GDPR.

Data transfer to third countries

The adoption of the European General Data Protection Regulation (GDPR) created a uniform basis for data protection in Europe. Your data will therefore primarily be processed by companies to which the GDPR applies. Should processing take place through third-party services outside the European Union or the European Economic Area, these services must meet the specific requirements of Articles 44 et seq. of the GDPR. This means that processing is carried out on the basis of special guarantees, such as the EU Commission's official determination of a level of data protection equivalent to that of the EU or compliance with officially recognized specific contractual obligations, the so-called "standard contractual clauses." Insofar as we obtain your express consent to the transfer of data to the USA due to the ineffectiveness of the so- called “Privacy Shield” in accordance with Art. 49 (1) (a) GDPR, we would like to point out the risk of secret access by US authorities and the use of the data for surveillance purposes, possibly without legal remedies for EU citizens.

Deletion of data and storage period

Unless expressly stated in this privacy policy, your personal data will be deleted or blocked as soon as you revoke your consent to processing, or the purpose for storage no longer applies, or the data is no longer required for that purpose, unless further storage is necessary for evidentiary purposes or if statutory retention periods conflict with this. This includes, for example, commercial retention obligations for business letters pursuant to Section 257 (1) of the German Commercial Code (HGB) (6 years) and tax retention obligations for receipts pursuant to Section 147 (1) of the German Fiscal Code (AO) (10 years). When the prescribed retention period expires, your data will be blocked or deleted unless storage is still required to conclude or fulfill a contract.

Existence of automated decision-making

We do not use automated decision-making or profiling.

Provision of our website and creation of log files

If you use our website purely for information purposes (i.e., you do not register or otherwise transmit information), we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data:
1. IP address;
2. User's Internet service provider;
3. Date and time of access;
4. Browser type;
5. Language and browser version;
6. Content of the access;
7. Time zone;
8. Access status/HTTP status code;
9. Data volume;
10. Websites from which the request came;
11. Operating system.

This data will not be stored together with your other personal data.

This data serves the purpose of delivering our website to you in a user-friendly, functional and secure manner, with functions and content, as well as their optimization and statistical evaluation.
The legal basis for this is our legitimate interest in the purposes above and data processing in accordance with Art. 6 (1) (f) GDPR.
For security reasons, we store this data in server log files for the storage period of days. After this period, they will be automatically deleted unless we need to retain them for evidentiary purposes in the event of attacks on the server infrastructure or other violations of law.

Cookies

We use so-called cookies when you visit our website. Cookies are small text files that your internet browser saves on your computer. When you visit our website again, these cookies provide information to automatically recognize you. Cookies also include so-called "user IDs," where user information is stored using pseudonymized profiles. When you visit our website, we will inform you about the use of cookies for the aforementioned purposes and how you can object to these cookies or prevent their storage ("opt-out") by means of a reference to our privacy policy.

The following types of cookies are distinguished:

Necessary, essential cookies: Essential cookies are cookies that are absolutely necessary for the operation of the website in order to save certain functions of the website such as logins, shopping cart or user inputs, e.g. regarding the language of the website.
Session cookies: Session cookies are required to recognize repeated use of an offering by the same user (e.g., if you have logged in to determine your login status). When you visit our site again, these cookies provide information to automatically recognize you. The information obtained in this way is used to optimize our offerings and provide you with easier access to our site. When you close your browser or log out, the session cookies are deleted.
Persistent cookies: These cookies remain stored even after the browser is closed. They are used to store login details, measure reach, and for marketing purposes. They are automatically deleted after a specified period of time, which may vary depending on the cookie. You can delete cookies at any time in your browser's security settings.
Third-party cookies (especially from advertisers): You can configure your browser settings according to your preferences and, for example, refuse to accept third-party cookies or all cookies. However, we would like to point out that if you do this, you may not be able to use all the features of this website. For more information about these cookies, please refer to the respective third-party privacy policies.

Data categories: User data, cookies, user ID (including pages visited, device information, access times and IP addresses).
Purposes of processing: The information obtained in this way serves the purpose to optimize our web offerings technically and economically and to provide you with easier and more secure access to our website.
Legal basis: If we process your personal data with the help of cookies based on your consent (“opt-in”), then Art. 6 (1) (a) GDPR is the legal basis. Otherwise, we have a legitimate interest in the effective functionality, improvement, and economic operation of the website, so that in this case, Art. 6 (1) (f) GDPR serves as the legal basis. Art. 6 (1) (b) GDPR also serves as the legal basis if the cookies are set to initiate a contract, e.g., for orders.
Storage period/deletion: The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. If the data is collected to provide the website, this is the case when the respective session ends.
Cookies are otherwise stored on your computer and transmitted from there to our site. Therefore, as a user, you have full control over the use of cookies. You can deactivate or restrict the transfer of cookies by changing the settings in your internet browser. Cookies already stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, you may no longer be able to fully use all of the website's functions.
Objection and “Opt-Out”: You can prevent cookies from being stored on your hard drive, regardless of consent or legal permission, by selecting "do not accept cookies" in your browser settings. However, this may result in a restriction of the functionality of our offerings. You can object to the use of third-party cookies for advertising purposes via a so-called "opt-out" on this American website (https://optout.aboutads.info) or this European website (http://www.youronlinechoices.com/de/praferenzmanagement).

Processing of contracts

We process inventory data (e.g. company, title/academic degree, names and addresses as well as contact details of users, e-mail), contract data (e.g. services used, names of contact persons) and payment data (e.g. bank details, payment history) for the purpose of fulfilling our contractual obligations (knowledge of the contractual partner; justification, content and processing of the contract; checking the plausibility of the data) and services (e.g. contacting customer service) in accordance with Art. 6 (1) (b) GDPR. The entries marked as mandatory in online forms are required for the conclusion of the contract.
These data will not be passed on to third parties unless it is necessary for the purpose of tracking our claims (e.g. handing over to a lawyer for debt collection) or to fulfill the contract (e.g. handing over the data to a payment provider) or there is a legal obligation to do so in accordance with Art. 6 (1) (c) GDPR.
We may also process the data you provide to inform you about other interesting products from our portfolio or to send you emails with technical information.
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. are required. This is the case for inventory and contract data when the data is no longer required for the execution of the contract and no further claims can be asserted under the contract because they have expired (warranty: two years / standard limitation period: three years). Due to commercial and tax law requirements, we are obliged to store your address, payment, and order data for a period of ten years. However, upon termination of the contract after three years, we restrict processing, i.e. your data will only be used to comply with legal obligations. Information in your user account will remain stored until it is deleted.

Use of blog functions / comments

You can post public comments on our blog, which contains articles on topics from our website. Submit comments. You can use a pseudonym instead of your real name. Your post will then be published under that pseudonym. Providing your email address is mandatory; all other information is voluntary.
When you post a comment, we save your IP address with the date and time, which we delete after a few days. This storage serves the legitimate interest of defending against third- party claims for the publication of illegal or untrue content by you. We store your email address for the purpose of contacting you in the event that third parties file legal objections to your comments.
The legal basis is Article 6 (1) (b) and (f) GDPR.
We do not review your comments prior to publication. In the event of third-party complaints, we reserve the right to delete your comments. We will not share your data with third parties unless it is necessary to pursue our claims or there is a legal obligation (Article 6 (1) (c) GDPR).
The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected or to execute the contract because the contract has been terminated.

Contact via contact form / email / fax / post

When you contact us via contact form, fax, post or email, your details will be for the purpose of processing the contact request.
The legal basis for the processing of data is Art. 6 Paragraph 1, sentence 1, letter a) GDPR. The legal basis for the processing of data transmitted in the course of a contact request or email, letter or fax is Article 6, paragraph 1, sentence 1, letter f) GDPR. The controller has a legitimate interest in processing and storing data in order to respond to user inquiries, to preserve evidence for liability reasons, and, if necessary, to comply with its statutory retention obligations for business correspondence. If the contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) (b) GDPR.
We may store your information and contact request in our Customer Relationship Management System ("CRM System") or a similar system.
The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. For personal data from the contact form input mask and those sent by email, this is the case when the respective conversation with you has ended. The conversation is ended when it can be inferred from the circumstances that the matter in question has been conclusively clarified. We store inquiries from users who have an account or contract with us for a period of two years after the contract has ended. In the case of statutory archiving obligations, deletion occurs after their expiration: end of commercial law (6 years) and tax law (10 years).
You have the option at any time to withdraw your consent in accordance with Art. 6 (1) (a) GDPR to revoke the processing of your personal data. If you contact us by email, you can revoke the storage of your personal data at any time.

You can subscribe to our newsletter with your voluntary consent by entering your email address. Subscribe to our newsletter with your email address. Only this is required. Providing further information is voluntary and is used solely for the purpose of personal contact. We use the so-called "double opt-in process" for registration. After you register with your email address, you will receive an email from us with a confirmation link to confirm your registration. If you click this confirmation link, your email address will be added to the newsletter distribution list and saved for the purpose of sending emails. If you do not click the confirmation link within a few hours, your registration data will be blocked and automatically deleted after a few days.
We also log the IP address you used during registration, as well as the date and time of the double opt-in (registration and confirmation). The purpose of this storage is to fulfill legal requirements regarding proof of registration and to prevent misuse of your email address.
Within the scope of your declaration of consent, the contents (e.g. advertised products/services, offers, advertising and topics) of the newsletter will be described in detail.
When sending the newsletter, we evaluate your user behavior. The newsletters contain so-called "web beacons" or "tracking pixels", which are called up when the newsletter is opened. For the purpose of evaluation, we link the web beacons to your email address and an individual ID. Links received in the newsletter also contain this ID. The data is collected exclusively in a pseudonymous manner, i.e. the IDs are not linked to your other personal data, and direct personal reference is excluded. With this data, we can determine whether and when you opened the newsletter and which links in the newsletter were clicked. This serves the purpose of optimizing and statistically evaluating our Newsletters.
We create a user profile with the data obtained above in order to understand the reading habits and
To identify the interests of our users and thus personalize the newsletter. If you have also performed other actions on our website, we will also link this data to adapt our newsletter content to your interests.
The legal basis for sending the newsletter, measuring success and storing the email is your consent in accordance with Art. 6 (1) (a) GDPR in conjunction with Section 7 (2) No. 3 UWG and for logging the consent Art. 6 (1) (f) GDPR, as this serves our legitimate interest in legal evidence.
You can object to tracking at any time by clicking on the unsubscribe link at the end of the Newsletter. In this case, however, your newsletter subscription would also be terminated. If you deactivate the display of images in your email software, tracking is also not possible. However, this may limit the functionality of the newsletter, and the images contained therein will then not be displayed.
You can revoke your consent to receive the newsletter at any time. You can revoke your consent by clicking the unsubscribe link at the end of the newsletter, by sending an email, or by contacting us using the contact details above. We will store your data as long as you are subscribed to the newsletter. After unsubscribing, your data will only be stored anonymously for statistical purposes.

Google Analytics

We have integrated the website analysis tool “Google Analytics” (service provider: Google Ireland Limited, registration number: 368047, Gordon House, Barrow Street, Dublin 4, Ireland) on our website. Regarding the use of the data, there is joint responsibility for data processing between Google and us pursuant to Art. 26 GDPR. We have agreed with Google that we assume primary responsibility for data processing under the GDPR and that we will fulfill all obligations under the GDPR with regard to data processing (including Art. 12 and 13 GDPR, Art. 15 to 22 GDPR, and Art. 32 to 34 GDPR).
Data categories and description of data processing: User ID, IP address (anonymized). When you visit our website, Google places a cookie on your computer to analyze your use of the website. We have activated IP anonymization "anonymizeIP," which means that IP addresses are only processed in a truncated form. On this website, your IP address will therefore be shortened by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website activity and internet usage to the controller. We have also activated cross-device analysis of website visitors, which is carried out using a so-called user ID. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. Further information on data usage by Google Analytics can be found here: https://www.google.com/analytics/terms (Analytics Terms of Use), https://support.google.com/analytics/answer/6004245 (Information on data protection at Analytics) and Google's privacy policy https://policies.google.com/privacy.
Purpose of processing: The use of Google Analytics serves the purpose of analysis, Optimization and improvement of our website.
Legal basis: If you have given your consent to the processing of your personal data using "Google Analytics" by the third- party provider ("opt-in"), then Art. 6 (1) (a) GDPR forms the legal basis. The legal basis is also our legitimate interest in data processing (the analysis, optimization, and improvement of our website) in accordance with Art. 6 (1) (f) GDPR, which lies in the above-mentioned purposes. For services provided in connection with a contract, the tracking and analysis of user behavior is carried out in accordance with Art. 6 (1) (b) GDPR, in order to be able to offer optimized services to fulfill the contractual purpose using the information obtained in this way.
Storage period: The data we send and which is linked to cookies, user IDs (e.g., user IDs), or advertising IDs is automatically deleted after a certain period of time. Data whose retention period has been reached is automatically deleted once a month.
Data transfer/recipient category: Google, Ireland and USA. We also have a data protection agreement with Google an agreement for order processing in accordance with Art. 28 GDPR has been concluded.
Opt-out and removal options:
1. You can generally prevent cookies from being saved on your hard drive by selecting "do not accept cookies" in your browser settings. However, this may limit the functionality of our offerings. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website, as well as from processing this data, by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout
2. You can deactivate cross-device user analysis in your Google account under “My data > personal data”.
3. You can use this link to update your preferences:

Update cookies preferences

Rights of the data subject

Objection or revocation against the processing of your data

To the extent that the processing is based on your consent pursuant to Art. 6 (1) (a) GDPR, Art. 7 GDPR, you have
the right to revoke your consent at any time. This does not affect the legality of the processing carried out on the basis of your consent until the revocation.

If we base the processing of your personal data on the balancing of interests pursuant to Art. 6 (1) (f) GDPR, you may object to the processing. This is the case if, in particular, the processing is not necessary to fulfill a contract with you, which we will explain in the following description of the functions. If you exercise such an objection, we ask you to explain the reasons why we do not process your personal data as carried out by us. In the event of your justified objection, we will examine the situation and either stop or adjust the data processing or explain to you our compelling legitimate grounds for continuing the processing.

You can object to the processing of your personal data for advertising and data analysis purposes at any time. You can exercise your right of objection free of charge. You can inform us about your objection to advertising at the following contact details:

Sebastian Oelke
Nong 903, Hutai Road, Nr. 31
Room 102
Shanghai 200072
Email address: blog@soelke.de

Right to information

You have the right to information about your personal data stored by us in accordance with Art. 15 GDPR. This includes, in particular, information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, and the origin of your data, unless it was collected directly from you.

Right to rectification

You have the right to have incorrect data rectified or correct data completed in accordance with Art. 16 GDPR.

Right to erasure

You have the right to have your data stored by us deleted in accordance with Art. 17 GDPR, unless statutory or contractual retention periods or other legal obligations or rights to further storage conflict with this.

Right to restriction

You have the right to request that the processing of your personal data be restricted if one of the conditions in Art. 18 (1) (a) to (d) GDPR is met:

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 oppose the erasure of the personal data and request the restriction of their use instead;
the controller no longer needs the personal data for the purposes of processing, but you need them to assert, exercise or defend legal claims, or
if you have objected to processing pursuant to Art. 21 (1) GDPR and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.

Right to data portability

You have a right to data portability according to Art. 20 GDPR, which means that you can receive the personal data we have stored about you in a structured, common and machine-readable format or you can request that it be transmitted to another controller.

Right to complain

You have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority, in particular in the Member State of your residence, place of work, or place of the alleged infringement.

Data security

To protect all personal data transmitted to us and to ensure that we and our external service providers adhere to data protection regulations, we have taken appropriate technical and organizational security measures. Therefore, among other things, all data between your browser and our server is transmitted encrypted via a secure SSL connection.