Please note, the following is a courtesy translation only
Preamble
We, (hereinafter: "Airmail Center Frankfurt GmbH ", "we" or "us") are concerned about the protection of your privacy as well as your personal data. At this point we would like to inform you about data protection at our company.
(1) General
Within the scope of our responsibility under data protection law, additional obligations have been imposed on us by the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: "GDPR") in order to ensure the protection of personal data of the person affected by a processing operation (hereinafter we also address you as data subject with "customer", "user", "you", "you" or "data subject").
Insofar as we decide either alone or jointly with others on the purposes and means of data processing, this includes above all the obligation to inform you transparently about the nature, scope, purpose, duration and legal basis of the processing (cf. Articles 13 and 14 DSGVO). With the following information and explanations (hereinafter: "Data Protection Notice"), we inform you about the manner in which your personal data is processed by us. Following the example of Art. 4 DSGVO, the following definitions form the basis:
"Personal data" (Art. 4 No. 1 DSGVO) means any information relating to an identified or identifiable natural person ("data subject"). An individual is identifiable if he or she can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or by means of information relating to his or her physical, physiological, genetic, mental, economic, cultural or social identity characteristics. The identifiability can also be given by means of a linkage of such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photographs, video or audio recordings may also contain personal data).
"Processing" (Art. 4 No. 2 GDPR) means any operation which involves the handling of personal data, whether or not by automated (i.e. technology-based) means. This includes, in particular, the collection (i.e., acquisition), recording, organization, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data, as well as the modification of a purpose or intended purpose on which a data processing was originally based.
"Controller" (Art. 4 No. 7 GDPR) 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.
"Third party" (Art. 4 No. 10 GDPR) means any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who, under the direct responsibility of the controller or processor, are authorized to process the personal data; this also includes other group-affiliated legal entities.
"Processor" (Art. 4 No. 8 GDPR) is a natural or legal person, authority, institution or other body that processes personal data on behalf of the controller, in particular in accordance with the controller's instructions (e.g. IT service provider). A processor is therefore not a third party in the sense of data protection law.
"Consent" (Art. 4 No. 11 GDPR) of the data subject means any freely given indication of intention for the specific case, in an informed manner and unambiguously in the form of a statement or other unambiguous affirmative act by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.
(2) Person responsible for processing / data protection officer
The body responsible for the processing of your personal data within the meaning of Art. 4 No. 7 DSGVO is Airmail Center Frankfurt GmbH Flughafen Frankfurt/Main, Airportring Tor 3, Gebäude 189 60549 Frankfurt am Main E-Mail: office[at]airmail-center[Punkt]de Tel.: +49 69 690 77 000 Fax +49 69 690 596-99 This and other information about our company can also be found in the imprint details on our website.
For all questions and as a contact person on the subject of data protection, our data protection officer Ralf Kamnitzer is available to you at any time. You can reach him at: Ralf Kamnitzer Key-Kom Draiser Weg 4 65346 Eltville info@key-kom.de +49 6123 605681
(3) Legal basis for data processing
In principle, any processing of personal data is prohibited by law and only permitted (so-called reservation of permission) if the data processing falls under one of the following justifications:
Art. 6 (1) p. 1 lit. a DSGVO ("consent"): If the data subject has voluntarily, in an informed manner and unambiguously indicated by a statement or other unambiguous confirmatory act that he or she consents to the processing of personal data relating to him or her for one or more specific purposes;
Art. 6 (1) p. 1 lit. b DSGVO: If the processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject's request;
Art. 6 para. 1 sentence 1 lit. c DSGVO: If the processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., a legal obligation to keep records);
Art. 6 para. 1 p. 1 lit. d DSGVO: If the processing is necessary to protect vital interests of the data subject or another natural person;
Art. 6 (1) p. 1 lit. e DSGVO: If the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or
Art. 6 (1) p. 1 lit. f DSGVO ("Legitimate Interests"): Where processing is necessary for the purposes of legitimate (in particular legal or economic) interests of the controller or a third party, unless such interests are overridden by the conflicting interests or rights of the data subject (in particular where the data subject is a minor). Storing information in the end user's terminal equipment or accessing information already stored in the terminal equipment is only permissible if it is covered by one of the following justifications:
Section 25 (1) TTDSG: If the end user has consented on the basis of clear and comprehensive information. The consent has to be given according to Art. 6 para. 1 p. 1 lit. a DSGVO (see above);
Section 25 (2) no. 1 TTDSG: If the sole purpose is to carry out the transmission of a message via a public telecommunications network or
§ 25 para. 2 no. 2 TTDSG: If the storage or access is absolutely necessary so that the provider of a telemedia service can provide a telemedia service expressly requested by the user. For the processing operations carried out by us, we indicate below each time the applicable legal basis. A processing operation may also be based on several legal bases.
(4) Data deletion and storage period
For the processing operations carried out by us, we indicate below in each case how long the data will be stored by us and when it will be deleted or blocked. If no explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for the storage no longer applies. In principle, your data will only be stored on our servers in Germany or the EU.
However, storage may take place beyond the specified time in the event of a (threatened) legal dispute with you or other legal proceedings, or if storage is required by law due to regulations to which we are subject as the responsible company (e.g. § 257 HGB, § 147 AO). If the storage period prescribed by the legal regulations expires, the personal data will be blocked or deleted unless further storage by us is necessary and there is a legal basis for this.
(5) Data security
We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction, or against unauthorized access by third parties (e.g., the Security Sockets Layer ("SSL") encryption and communication protocol for our websites), taking into account the state of the art, implementation costs and the nature, scope, context and purpose of the processing, as well as the existing risks of a data breach (including its likelihood and impact) for a data subject. We reserve the right to continuously improve our security measures in line with technological developments.
(6) Cooperation with third parties/contract processors
As with any company, we also use external domestic and foreign service providers (e.g. for the areas of IT, telecommunications, airlines, logistics partners) for our entrepreneurial business transactions. They will only act according to our instructions and are contractually obligated to comply with data protection regulations and requirements according to Art. 28 DSGVO.
(7) Conditions for the transfer of personal data to third countries
Within the scope of our business relationships, your personal data may be passed on or disclosed to third-party companies and service providers. These may also be located outside the European Economic Area (EEA), i.e. in third countries.
Such processing takes place exclusively for the fulfillment of our contractual and business obligations and for the maintenance of our business relationship (legal basis is Art. 6 para. 1 lit b or lit f in each case in conjunction with. Art. 44 et seq. DSGVO). We will inform you about the respective details of the transfer in the relevant places below.
Some third countries are certified by the European Commission through so-called adequacy decisions to have a level of data protection that is comparable to our EU/EEA standard (a list of these countries and a copy of the adequacy decisions can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). However, in other third countries to which personal data may be transferred, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is sufficiently guaranteed. This is possible via binding company regulations, standard contractual clauses of the European Commission for the protection of personal data pursuant to Art. 46 Para. 1, 2 lit. c DSGVO (the standard contractual clauses as of June 2021 are available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0915&locale-en), certificates or recognized codes of conduct.
(8) No automated decision making (including profiling).
We do not intend to use any personal data collected from you for any automated decision making process (including profiling).
(9) No obligation to provide personal data.
We do not make the conclusion of contracts with us dependent on you providing us with personal data in advance. For you as a customer, there is in principle also no legal or contractual obligation to provide us with your personal data; however, it may be that we can only provide certain services and offers of our business area to a limited extent or not at all if you do not provide the data required for this. If this should exceptionally be the case in the context of the products we offer presented below, you will be informed of this separately.
(10) Legal obligation to transmit certain data
We may, under certain circumstances, be subject to a specific legal or statutory obligation to provide the lawfully processed personal data to third parties, in particular public bodies (Art. 6 para. 1 p. 1 lit. c DSGVO).
(11) Your rights
You can assert your rights as a data subject with regard to your processed personal data at any time by contacting us using the contact details provided at the beginning above or in our imprint. As a data subject, you have the right
To request information about your data processed by us in accordance with Art. 15 DSGVO. In particular, you can request information about the processing purposes, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information about its details;
in accordance with Art. 16 DSGVO, to demand the correction of incorrect data or the completion of your data stored by us without delay;
pursuant to Art. 17 DSGVO, to request deletion of your data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims;
pursuant to Art. 18 DSGVO, to request the restriction of the processing of your data, insofar as the accuracy of the data is disputed by you or the processing is unlawful;
pursuant to Art. 20 DSGVO, to receive your data that you have provided to us in a structured, common and machine-readable format or to request the transfer to another controller ("data portability");
object to the processing in accordance with Art. 21 DSGVO, provided that the processing is based on Art. 6 (1) p. 1 lit. e or lit. f DSGVO. This is particularly the case if the processing is not necessary for the performance of a contract with you. Unless it is an objection to direct marketing, when exercising such an objection, we ask you to explain the reasons why we should not process your data as we have done. In the event of your justified objection, we will review the merits of the case and either discontinue or adjust the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing;
in accordance with Article 7(3) of the GDPR, to withdraw your consent given once (also before the GDPR came into force, i.e. before 25.5.2018) - i.e. your voluntary will, made understandable in an informed manner and unambiguously by means of a declaration or other unambiguous confirming act, that you agree to the processing of the personal data concerned for one or more specific purposes
to revoke such consent at any time vis-à-vis us, if you have given such consent. This has the consequence that we may no longer continue the data processing based on this consent for the future, and
complain to a data protection supervisory authority about the processing of your personal data by us in accordance with Art. 77 DSGVO, for example to the data protection supervisory authority responsible for us, the Hessian Commissioner for Data Protection and Freedom of Information, Gustav-Stresemann-Ring 1, 65189 Wiesbaden, https://datenschutz.hessen.de.
(12) Visit to our website
You will receive information about us and our offers and services when you call up and visit our web pages. During the informative use of our websites, the following categories of personal data are collected, stored and processed by us: "Protocol data": When you visit our websites, a so-called protocol data record (so-called server log files) is stored temporarily and anonymously on our web server. This consists in detail of: - Page from which our website was requested (so-called referrer URL) - Name and URL of the requested page - Date and time of the call - GMT time zone difference - Description of the type, language and version of the web browser used - IP address of the requesting computer (shortened so that a personal reference can no longer be established), - Volume of data transferred - Operating system - Message as to whether the call was successful (access status/Http status code) "Contact form data": When contact or contact forms are used, the data transmitted as a result are processed (e.g. gender, surname and first name, address, company, e-mail address and the time of transmission).
(13) Purpose and legal basis of data processing
We process the personal data specified in more detail above in accordance with the provisions of the DSGVO, the other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Art. 6 (1) p. 1 lit. f DSGVO, the stated purposes also represent our legitimate interests. The processing of log data serves to improve the quality as well as statistical purposes of our websites, in particular the stability, optimization and security of the connection (legal basis is Art. 6 para. 1 p. 1 lit. a or lit. f DSGVO).
Contact form data is processed for the purpose of answering, communicating and processing customer inquiries (legal basis is Art. 6 para. 1 p. 1 lit. b or lit. f DSGVO). If the processing of the data requires the storage of information in your terminal equipment or access to information already stored in the terminal equipment, the legal basis for this is § 25 para. 1, 2 TTDSG.
§ Section 2 (2) no. 6 TTDSG defines a terminal equipment as any equipment connected directly or indirectly to the interface of a public telecommunications network for sending, processing or receiving messages.
(14) Duration of data processing
Your data will only be processed for as long as is necessary to achieve the above-mentioned processing purposes; the legal bases stated in the context of the processing purposes apply accordingly.
Third parties engaged by us will store your data on their systems for as long as is necessary in connection with the provision of services for us in accordance with the respective order and contractual relationship.
(15) Transfer of personal data to third parties; basis for justification
The following categories of recipients, which are usually order processors, may receive access to your personal data:
Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data center services, payment processing). The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. b or lit. f DSGVO, insofar as they are not order processors;
Government agencies/authorities, insofar as this is necessary for the fulfillment of a legal obligation. The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. c DSGVO.
Persons employed to carry out our business operations (e.g. banks, notaries, insurance companies, tax and legal advisors, supervisory authorities). The legal basis for the disclosure is then Art. 6 para. 1 p. 1 lit. b or lit. f DSGVO.
In addition, we will only disclose your personal data to third parties if you have given your express and informed consent to do so in accordance with Art. 6 (1) sentence 1 lit. a DSGVO.
(16) Use of cookies
We use cookies on our website and on our web pages. Cookies are small text files that are assigned to the browser you are using and stored on your hard drive by means of a characteristic string of characters, and through which certain information flows to the body that sets the cookie. Cookies cannot execute programs or transfer viruses to your computer and therefore cannot cause any damage. They serve to make the Internet offer as a whole more user-friendly and effective, i.e. more pleasant for you. Cookies can contain data that make it possible to recognize the device used. In some cases, however, cookies only contain information on certain settings that cannot be related to a specific person. However, cookies cannot directly identify a user.
A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. With regard to their function, a distinction is made between cookies:
Technical cookies: these are mandatory in order to navigate the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes, nor do they store which web pages you have visited;
Performance cookies: these collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect information that could identify you - all information collected is anonymous and is only used to improve our website and find out what interests our users;
Advertising cookies, targeting cookies: these are used to provide the website user with tailored advertising on the website or offers from third parties and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;
Sharing cookies: these are used to improve the interactivity of our website with other services (e.g. social media); sharing cookies are stored for a maximum of 13 months. The legal basis for cookies that are absolutely necessary to provide you with the explicitly requested service is Section 25 (2) No. 2 TTDSG. In addition, we will only disclose your personal data processed by cookies to third parties if you have given your explicit and informed consent to do so in accordance with Art. 6 (1) p. 1 lit. a DSGVO.
(17) Up-to-dateness and changes of our data protection information
We reserve the right to regularly review our data protection information for the need to adapt or supplement it as part of the further development of data protection law and technological or organizational changes. When visiting our website, the current data protection information will apply, which can be accessed and printed out from our website at any time. If you have any questions or comments regarding data protection, please contact our e-mail address given in the imprint, our data protection officer or by post at the address given in the imprint.
Our data protection notice is current as of December 2022.