Thank you for your interest in our company. Data protection is of the utmost importance to the ISL Internet Sicherheitslösungen GmbH management team. In principle, the ISL Internet Sicherheitslösungen GmbH website can be used without the disclosure of any personal data. However, if the data subject uses certain services offered by the company on our website, the processing of personal data may be necessary. In cases when the processing of personal data is necessary and there is no legal basis for the respective processing, we will generally obtain consent from the data subject.
As the controller for the processing, ISL Internet Sicherheitslösungen GmbH has implemented various technical and organizational measures in order to ensure the maximum level of protection for personal data processed on our website. Nevertheless, by virtue of their nature, web-based data transfers may be subject to security breaches and, as such, absolute protection cannot be ensured. For this reason, data subjects are at liberty to select alternative methods, such as a phone call, to disclose personal data to us.
The ISL Internet Sicherheitslösungen GmbH Privacy Statement is based on the terms used by the European Legislator for the adoption of the General Data Protection Regulation (GDPR). Our Privacy Statement should be legible and understandable for the general public, as well as our customers and business partners. In order to ensure this, we have provided definitions for the terms found in this Privacy Statement.
We use the terms listed below, among others, in this Privacy Statement:
a) personal data
‘Personal data’ means any information relating to an identified or identifiable natural person (‘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 to 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 an identified or identifiable natural person whose personal data is processed by the controller;
‘Processing’ means any operation or set of operations which is performed on personal data or on sets of 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’ means the marking of stored personal data with the aim of limiting their processing in the future;
‘Pseudonymization’ means 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;
‘Controller’ means 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;
‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
‘Recipient’ means 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 which 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
‘Third party’ means 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;
‘Consent’ of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
2. Name and address of the controller
The controller for the purposes of the General Data Protection Regulation and other data protection laws applicable in Member States of the European Union and other provisions related to data protection is:
ISL Internet Sicherheitslösungen GmbH
Wittener Straße 2
Phone: +49 234 976672-0
Cookies are widely used by websites and servers. Most cookies contain a unique identifier called a cookie ID: a string of characters that websites and servers associate with the browser on which the cookie is stored. This allows visited websites and servers to distinguish your browser from other browsers that store different cookies, and to recognize each browser by its unique cookie ID.
The data subject can prevent the placement of cookies on our website at any time by permanently rejecting all cookies in their browser settings. Furthermore, previously placed cookies can be deleted at any time on the data subject's browser or another software program. The above is possible with all common web browsers. If the data subject deactivates cookies in their browser, certain features may be restricted on our website in individual cases.
4. Collection of general data and information
Each time the data subject or an automated system visits the ISL Internet Sicherheitslösungen GmbH website, the website collects a series of general data and information. This general data and information is stored in server log files. We collect information on the (1) used browser types and versions, (2) the operating system used by the accessing system, (3) the last web address accessed by a browser prior to loading our website (referrer), (4) the subpages accessed by the accessing system on our website, (5) the date and time of the visit to our website, (6) the accessing system’s internet protocol address (IP address), (7) the accessing system's internet service provider and (8) other similar data and information used to defend our IT systems against threats posed by attacks.
ISL Internet Sicherheitslösungen GmbH does not make any assumptions about the data subject when it uses this general data and information. This information is primarily required to (1) correctly deliver the contents of our website, (2) to optimize the contents or our website and related advertising, (3) to ensure the permanent functionality of our IT systems and our website technology, and (4) to provide information required for prosecution to the law enforcement agencies in the event of a cyber attack. To this end, ISL Internet Sicherheitslösungen GmbH statistically analyzes this anonymously collected data and information with the aim of improving data protection and security within our company to ensure the optimal protection of personal data processed by us. The anonymous data in the server log files is stored separately from all other personal data disclosed by a data subject.
5. Registering on our website
Data subjects can register for the controller’s website by submitting personal data. The personal data disclosed to the controller is specified in the respective input mask used for registration. Personal data entered by the data subject will solely be used internally by the controller, and collected and stored for the controller’s own purposes. The controller may disclose the data subject's personal data to one or several processors, e.g. parcel services, that also require the personal data for solely internal use in relation to services for the controller.
Furthermore, the IP address assigned to the data subject by the internet service provider (ISP) along with the date and the time of registration shall be stored when the data subject registers on the controller’s website. This data is stored as it offers the only way to prevent our services from being misused, and this data may be used in the investigation of committed offences where necessary. To this end, storage of this data required to secure the controller’s operations. In the absence of any statutory obligation to hand over data or if the disclosure thereof would assist with criminal prosecution, this data shall not otherwise be passed on to third parties.
Once the data subject has registered on the website by voluntarily providing personal data, the controller will be able to provide certain content or services that are only offered to registered users based on their nature. Registered users can edit personal data provided during registration at any time or completely erase their data from the controller’s database.
When requested, the controller is required to provide each data subject with information on which personal data relating to the respective data subject it stores. Furthermore, the controller must rectify or erase personal data when requested or demanded by the data subject, provided the personal data in question is not subject to statutory retention periods. The data subject can contact the data protection officer specified in this Privacy Statement or any of the controller’s employees at any time if they have any questions related to the above.
6. Subscribing to our newsletter
The ISL Internet Sicherheitslösungen GmbH website offers users the ability to subscribe to our company newsletter. The input mask used for registration specifies which personal data will be transferred to the controller following registration for the newsletter.
ISL Internet Sicherheitslösungen GmbH provides its customers and business partners with regular updates on services provided by the company in its newsletter. Data subjects can only receive our company newsletter if (1) they have a valid email address and (2) they have registered to receive our newsletter.
Furthermore, when a data subject registers for our newsletter, we also store the data subject's IT address assigned by their internet service provider (ISP), the computer system used at the time of registration in addition to the time and date on which the data subject registered. Collection of this data is required to verify (potential) misuse of the data subject's email address at a later point in time, and to consequently legally protect the controller.
Personal data collected during registration for the newsletter is solely used to send our newsletter. Furthermore, subscribers to the newsletter may also be contacted by us when required in relation to provision of the newsletter service or their registration, as may be required in the case of changes to the newsletter services or the technical parameters. Personal data collected in relation to the newsletter service shall not be passed on to third parties. Once subscribed, data subjects can unsubscribe from our newsletter at any time. In addition, consent to the storage of personal data granted when the data subject registered for our newsletter can be withdrawn at any time. A corresponding link to withdraw previously granted consent can be found in each newsletter. Furthermore, data subjects can also directly unsubscribe from the newsletter on the controller’s website at any time or notify the controller of their unsubscription in other ways.
7. Newsletter tracking
The ISL Internet Sicherheitslösungen GmbH newsletter contains tracking pixels. Tracking pixels are tiny snippets of code embedded in emails send in HTML format to facilitate log file records and analyses. This enables a statistical analysis of the success or failure of an online marketing campaign. ISL Internet Sicherheitslösungen GmbH uses embedded tracking pixels to determine if and when an email was opened by a data subject and which of the links included in the email were visited by the data subject.
Personal data received through tracking pixels included in the newsletters is stored and analyzed by the controller in order to optimize sending of the newsletter and better tailor the contents of future newsletter to the data subject’s interests. This personal data is not passed on to third parties. Data subjects reserve the right to separately withdraw declarations of consent to this processing previously granted via double-opt in at any time. Once consent has been withdrawn, the controller will delete the respective personal data. ISL Internet Sicherheitslösungen GmbH regards unsubscribing from the newsletter as the automatic withdrawal of consent.
8. Contact options on our website
In compliance with legal requirements, the ISL Internet Sicherheitslösungen GmbH website contains information to allow interested parties to quickly contact our company by email or contact us directly, including a general email address. When a data subject contacts the controller by email or using a contact form, personal data transmitted by the data subject will be automatically stored. Personal data voluntarily disclosed to the controller by the data subject will be stored to get in contact with or manage relations with the data subject. This personal data will not be passed on to third parties.
9. Routine erasure and blocking of personal data
The controller only processes and stores the data subject’s personal data for the period required to fulfil the purpose of storage or for the period required according to laws or regulations issued by the European legislator or other legislators to which the controller is subject.
If the reason for which the data was collected ceases to apply or a retention period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely deleted or blocked for continued processing according to the statutory provisions.
10. Rights of the data subject
a) Right to obtain confirmation
As enacted by the European legislator, each data subject has the right to obtain from the controller confirmation as to whether or not data concerning him or her are being processes, and, where this is the case, access to the personal data. If a data subject would like to exercise this right to obtain confirmation, they can contact our data protection officer or other employees at the controller’s company.
b) Right to information
The European legislator grants each data subject the right to receive information from the controller concerning his or her personal data and to receive a copy of this information free of charge. Furthermore, the European legislator permits the data subject to receive the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- 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 Art. 22(1) and (4) 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.
Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject would like to exercise this right to information, they can contact our data protection officer or other employees at the controller’s company.
c) Right to rectify
The European legislator grants all data subjects the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Furthermore, taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject would like to exercise this right to rectification, they can contact our data protection officer or other employees at the controller’s company.
d) Right to erasure (‘right to be forgotten’)
The European legislator further grants each data subject the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies and processing is no longer required:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws consent on which the processing is based according to lit. a of Art. 6(1), or lit. a of Art. 9(2), and where there is no other legal ground for the processing;
- the data subject objects to the processing pursuant to Art. 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2);
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
- the personal data have been collected in relation to the offer of information society services referred to in Art. 8(1).
Where one of the aforementioned grounds applies and a data subject demands the erasure of personal data stored by ISL Internet Sicherheitslösungen GmbH, the data subject can contact our data protection officer or one of the controller’s employees at any time to exercise this right. The ISL Internet Sicherheitslösungen GmbH data protection officer or employee will ensure that the erasure request is executed without undue delay.
Where ISL Internet Sicherheitslösungen GmbH has made the personal data public and our company, as the controller, is obliged pursuant to Art. 17(1) GDPR to erase the personal data, ISL Internet Sicherheitslösungen GmbH, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data, provided personal processing is not necessary. The ISL Internet Sicherheitslösungen GmbH data protection officer or employee will take the necessary steps in individual cases.
e) Right to restriction of processing;
The European legislator grants each data subject the right to obtain from the controller 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 behavior of legal claims;
the data subject has objected to processing pursuant to Art. 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
Where one of the aforementioned grounds applies and a data subject demands the restriction of processing of personal data stored by ISL Internet Sicherheitslösungen GmbH, the data subject can contact our data protection officer or one of the controller’s employees at any time to exercise this right. The ISL Internet Sicherheitslösungen GmbH data protection officer or employee will restrict processing.
f) Right to data portability
The European legislator grants each data subject the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. Data subjects are also entitled to the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to lit. a of Art. 6(1) GDPR or lit. a of Art. 9(2) GDPR or on a contract pursuant to lit. b of Art. 6(1) GDPR; and 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 his or her right to data portability pursuant to Art. 20(1) GDPR, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided this does not adversely affect the rights and freedoms of others.
The data subject can contact the data protection officer appointed by ISL Internet Sicherheitslösungen GmbH or another employee at any time to exercise this right to data portability.
g) Right to object
The European legislator grants each data subject the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on lit. e or f of Art. 6(1) GDPR, including profiling based on those provisions.
In the event of an objection, ISL Internet Sicherheitslösungen GmbH shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or behavior of legal claims.
Where personal data are processed by ISL Internet Sicherheitslösungen GmbH for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing carried out by ISL Internet Sicherheitslösungen GmbH for direct marketing purposes, the personal data shall no longer be processed by ISL Internet Sicherheitslösungen GmbH for such purposes.
Furthermore, where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Art. 89(1) GDPR, the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
The data subject can directly contact the data protection officer appointed by ISL Internet Sicherheitslösungen GmbH or another employee to exercise this right to object. Furthermore, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
The European legislator grants each data subject the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. The above shall not apply if the decision (1) is necessary for entering into, or performance of, a contract between the data subject and a data controller; (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 and 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 performance of, a contract between the data subject and the controller, or (2) is based on the data subject's explicit consent, ISL Internet Sicherheitslösungen GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
If a data subject would like to exercise this right in relation to automated decision making, they can contact our data protection officer or other employees at the controller’s company.
i) Right to revoke consent granted under data protection law
The European legislator grants all data subjects the right to withdraw their previously granted consent to the processing of his or her personal data at any time.
If a data subject would like to exercise this right to withdraw consent, they can contact our data protection officer or other employees at the controller’s company.
11. Data protection in relation to applications and during the application process
The controller collects and processes personal data from applicants in order to manage the application process. This processing may also take place in electronic form. In particular, the above shall apply if an applicant sends corresponding application documents to the controller in electronic format, e.g. by email or using a web form on the controller’s website. If the controller enters into an employment relationship with the applicant, the data transmitted for the purpose of processing the employment relationship shall be stored in compliance with the pertinent statutory provisions. If the controller does not enter into an employment relationship with the applicant, the application documents shall be deleted within 2 months after the applicant is informed of the rejection in the absence of any other compelling interests of the controller that permit continued storage. Our legitimate interest in this regard may be the requirement to provide evidence in proceedings as per the General Equal Treatment Act (AGG), for example.
12. Lawfulness of processing
Art. 6(1) lit. a GDPR provides the legal basis for processing carried out by our company when we have obtained consent from the data subject for one or more specific purposes. Art. 6(1) lit. b GDPR provides the legal basis where processing is necessary for the performance of a contract to which the data subject is party, for example, in the case of processing required to deliver goods or perform another service or return service. The same applies where processing is necessary in order to take steps prior to entering into a contract, namely in relation to queries related to our products or services. If our company is subject to a legal obligation that requires the processing of personal data, in order to fulfil fiscal obligations, for example, processing takes place on the legal basis of Art. 6(1) lit. c GDPR. In rare cases, processing of personal data may be necessary in order to protect the vital interests of the data subject or of another natural person. For example, this would be deemed the case if a visitor to our premises sustained injuries and we were therefore required to disclose his name, age, health insurance details or other vital information to a doctor, hospital or other third party. In this case, processing would take place on the legal basis of Art. 6(1) lit. d GDPR. Finally, processing may also take place on the legal basis of Art. 6(1) lit. f GDPR. Processing based on this legal basis is processing that is not covered by the above legal bases and is necessary for the protection of legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. We are entitled to perform this processing in particular due to its special mention by the European legislator. To this end, the European legislator deems a legitimate interest to exist where the data subject is a customer of the controller (recital 47, sentence 2 GDPR).
13. Processing for the purposes of legitimate interests pursued by the controller or by a third party
Where personal data is processed on the basis of Art. 6(1) lit. f GDPR, our legitimate interest lies in the operation of our business to the benefit of the well-being of all employees and stockholders.
14. Retention periods for the storage of personal data
Personal data is stored for the amount of time prescribed by the pertinent statutory retention period. Once this period has expired, the corresponding data will be routinely deleted, provided it is no longer required to perform or enter into a contract.
15. Statutory or contractual provisions the require the provision of personal data; necessity to conclude a contract; obligation of the data subject to provide personal data; potential consequences of failure to provide personal data
We will inform you whether the provision of personal data is legally required in certain cases (e.g. fiscal requirements) or may be required according to contractual provisions (e.g. information on the contractual partners). Occasionally, we may require that a data subject provides personal data that we subsequently process in order to conclude a contract. For example, the data subject is required to provide us with personal data if our company concludes a contract with him or her. Failure to provide personal data may entail that we are unable to enter into a contract with the data subject. The data subject shall be required to contact our data protection officer prior to providing personal data. Our data protection officer will then inform the data subject whether the provision of personal data is required by law or contractual provisions in this individual case, whether an obligation exists to provide personal data, and the consequences of failure to provide personal data.
16. Use of automated decision-making
As a responsible company, we do not use automated decision-making or profiling.
This Privacy Statement was generated using the privacy statement generator provided by Datenschutz Karlsruhe in cooperation with RC GmbH, a company that remarkets used laptops, and Filesharing Rechtsanwälten from WBS-LAW.