+49 (0)211-987 402 31
info@thraki-personal.de

Privacy Policy

We are very pleased about your interest in our company. Data protection is of particular importance to the management of Thraki Personal GmbH.

Using the websites of Thraki Personal GmbH is generally possible without providing any personal data. However, if an individual wishes to use specific services of our company via our website, the processing of personal data may become necessary.

If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject. The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to Thraki Personal GmbH.

Through this privacy policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed about their rights through this privacy policy.

Thraki Personal GmbH, as the controller responsible for processing, has implemented numerous technical and organizational measures to ensure the most comprehensive protection possible for personal data processed via this website. However, internet-based data transmissions may inherently have security vulnerabilities, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us through alternative means, such as by telephone.

1. Definitions

The privacy policy of Thraki Personal GmbH is based on the terminology used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easily readable and understandable for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance. In this privacy policy, we use, among others, the following terms:

a) Personal Data

Personal data refers to any information relating to an identified or identifiable natural person (hereinafter “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

b) Data Subject

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

c) Processing

Processing is any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

d) Restriction of Processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

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

f) Pseudonymization

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or Data Controller

The controller or data controller is the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

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

i) Recipient

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

j) Third Party

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

k) Consent

Consent is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

2. Name and Address of the Controller

The controller, within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions related to data protection, is: Thraki Personal GmbH, Grafenberger Allee 368, 40235 Düsseldorf, Germany, Phone: +49 (0)211-987 402 31, Fax: +49 (0)211-987 402 32, Email: info@thraki-personal.de

3. Cookies

The websites of Thraki Personal GmbH use cookies. Cookies are text files that are stored on a computer system via an internet browser. Many websites and servers use cookies. Many cookies contain a so-called cookie ID, a unique identifier of the cookie. It consists of a character string through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified via the unique cookie ID. Through the use of cookies, Thraki Personal GmbH can provide users of this website with more user-friendly services that would not be possible without the cookie setting. By means of a cookie, the information and offers on our website can be optimized for the user. Cookies allow us, as previously mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website, as this is handled by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a cookie. The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting in the internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.

4. Collection of General Data and Information

The website of Thraki Personal GmbH collects a series of general data and information with each visit to the website by a data subject or an automated system. This general data and information are stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems. When using this general data and information, Thraki Personal GmbH does not draw any conclusions about the data subject. This information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website and its advertising, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. This anonymously collected data and information is therefore evaluated by Thraki Personal GmbH statistically and with the aim of increasing data protection and data security in our company to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Routine Erasure and Blocking of Personal Data

The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or as provided by the European legislator or another legislator in laws or regulations to which the controller is subject. If the storage purpose ceases to apply or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

6. Rights of the Data Subject

a) Right to Confirmation

Every data subject has the right, granted by the European legislator, to obtain from the controller confirmation as to whether personal data concerning them are being processed. If a data subject wishes to exercise this right to confirmation, they can contact an employee of the controller at any time.

b) Right to Access

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to obtain from the controller free information about the personal data stored about them and a copy of this information at any time. Furthermore, the European legislator has granted the data subject access to the following information:

  • the purposes of the processing
  • the categories of personal data being processed
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
  • the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
  • the right to lodge a complaint with a supervisory authority
  • where the personal data are not collected from the data subject: any available information as to their source
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has the right to obtain information as to whether personal data have been transferred to a third country or an international organization. If this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to exercise this right to access, they can contact an employee of the controller at any time.

c) Right to Rectification

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to request the immediate rectification of inaccurate personal data concerning them. Furthermore, taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, they can contact an employee of the controller at any time.

d) Right to Erasure (Right to be Forgotten)

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to request from the controller the erasure of personal data concerning them without undue delay, provided one of the following grounds applies and as long as the processing is not necessary:

  • The personal data were collected or otherwise processed for purposes for which they are no longer necessary.
  • The data subject withdraws consent on which the processing is based according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
  • The personal data have been unlawfully processed.
  • The erasure of personal data is necessary to fulfill a legal obligation under Union or Member State law to which the controller is subject.
  • The personal data were collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

If one of the aforementioned reasons applies and a data subject wishes to request the erasure of personal data stored by Thraki Personal GmbH, they can contact an employee of the controller at any time. The employee of Thraki Personal GmbH will ensure that the erasure request is complied with immediately. If the personal data have been made public by Thraki Personal GmbH, and our company, as the controller, is obliged to erase the personal data pursuant to Article 17(1) GDPR, Thraki Personal GmbH, taking into account available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure of any links to, or copies or replications of, those personal data, as far as processing is not necessary. An employee of Thraki Personal GmbH will arrange the necessary measures in individual cases.

e) Right to Restriction of Processing

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to request from the controller the restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise, or defense of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) GDPR, pending the verification of whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of personal data stored by Thraki Personal GmbH, they can contact an employee of the controller at any time. The employee of Thraki Personal GmbH will arrange the restriction of the processing.

f) Right to Data Portability

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, or on a contract pursuant to Article 6(1)(b) GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising their right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others. To assert the right to data portability, the data subject can contact an employee of Thraki Personal GmbH at any time.

g) Right to Object

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them, which is based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions. Thraki Personal GmbH shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or the processing serves the establishment, exercise, or defense of legal claims. If Thraki Personal GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Thraki Personal GmbH processing for direct marketing purposes, Thraki Personal GmbH will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them by Thraki Personal GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. To exercise the right to object, the data subject may contact any employee of Thraki Personal GmbH directly. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.

h) Automated Individual Decision-Making, Including Profiling

Every data subject affected by the processing of personal data has the right, granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, provided the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights, freedoms, and legitimate interests, or (3) is based on the data subject’s explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, Thraki Personal GmbH shall implement suitable measures to safeguard the data subject’s rights, freedoms, and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision. If the data subject wishes to exercise rights concerning automated decision-making, they can contact an employee of the controller at any time.

i) Right to Withdraw Consent

Every data subject affected by the processing of personal data has the right, granted by the European legislator, to withdraw consent to the processing of personal data at any time. If the data subject wishes to exercise their right to withdraw consent, they can contact an employee of the controller at any time.

7. Data Protection in Applications and the Application Process

The controller collects and processes the personal data of applicants for the purpose of handling the application process. The processing may also take place electronically. This is particularly the case if an applicant submits application documents electronically, for example, via email or through a web form on the website, to the controller. If the controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of managing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents will be automatically deleted two months after notification of the rejection decision, provided no other legitimate interests of the controller oppose the deletion. Another legitimate interest in this sense is, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).

8. Legal Basis for Processing

Article 6(1)(a) GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, in processing operations necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Article 6(1)(b) GDPR. The same applies to processing operations that are necessary for carrying out pre-contractual measures, for example, in cases of inquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Article 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our company were injured and their name, age, health insurance data, or other vital information had to be passed on to a doctor, hospital, or other third party. In such cases, the processing would be based on Article 6(1)(d) GDPR. Finally, processing operations could be based on Article 6(1)(f) GDPR. This legal basis covers processing operations not covered by any of the aforementioned legal bases if the processing is necessary for the purposes of the legitimate interests pursued by our company or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. Such processing operations are permitted, in particular, because they were specifically mentioned by the European legislator. The legislator considered that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, Sentence 2 GDPR).

9. Legitimate Interests Pursued by the Controller or a Third Party

If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and shareholders.

10. Duration of Storage of Personal Data

The criterion for the duration of the storage of personal data is the respective statutory retention period. After the expiration of this period, the corresponding data are routinely deleted, provided they are no longer necessary for the performance or initiation of a contract.

11. Legal or Contractual Provisions for the Provision of Personal Data; Necessity for the Conclusion of a Contract; Obligation of the Data Subject to Provide Personal Data; Possible Consequences of Non-Provision

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

12. Existence of Automated Decision-Making

As a responsible company, we do not use automated decision-making or profiling. This privacy policy was created by the privacy policy generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as an External Data Protection Officer Bremen, in cooperation with the Data Protection Lawyer Christian Solmecke.