Privacy Policy

The use of the Internet pages of the Sepia GmbH & Co. KG is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Sepia GmbH & Co. KG. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this privacy policy, of the rights to which they are entitled.

As the controller, the Sepia GmbH & Co. KG has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1 Definitions

The privacy policy of the Sepia GmbH & Co. KG is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this privacy policy, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as “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

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

c) Processing

Processing is 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, organisation, 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 means 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 analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

Pseudonymisation 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller

Controller or controller responsible for the processing 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

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

i) Recipient

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 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; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j) Third party

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 authorised to process personal data.

k) Consent

Consent of the data subject is 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

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Sepia GmbH & Co. KG

Ernst-Gnoss-Strasse 22

D-40219 Düsseldorf

Deutschland

Telefon: +49 211 51 419 75

Fax: + 49 211 51 41 965

E-Mail: info@sepia.de

3 Name and Address of the Data Protection Officer

The data protection officer of the controller is:

Hendrik Hüttemann

c/o Sepia GmbH & Co. KG

Ernst-Gnoss-Strasse 22

D-40219 Düsseldorf

Deutschland

Telefon: +49 211 51 419 75

Fax: + 49 211 51 41 965

E-Mail:  datenschutz@sepia.de

Each data subject may at any time contact our data protection officer directly with all questions and suggestions regarding data protection.

4 Cookies

The Internet pages of the Sepia GmbH & Co. KG may use cookies in their administrative areas. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the dats subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, the Sepia GmbH & Co. KG can provide the 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 with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

5 Collection of General Data and Information

The website of the Sepia GmbH & Co. KG collects a series of general data and information, when a data subject or an automated system calls up the website. This general data and information are stored in the log files of the server. Collected may be (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, which are controlled by an accessing system on our website, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, the Sepia GmbH & Co. KG does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and the technology of our website, and (4) provide the law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Sepia GmbH & Co. KG analyzes these anonymously collected data and information, on one hand, statistically and besides with the aim of increasing the data protection and data security of our enterprise and, ultimately, to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

6 Registration (e.g., in the Privacy Policy Generator)

The data subject has the possibility to register on the website of the controller with the provisions of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for his own purposes. The controller may request the transfer to one or more processors, for example, a parcel service, who also uses the personal data for an internal use, which is attributable to the controller.

By registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) and used by the data subject, date and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data are not passed on to third parties, unless there is a statutory obligation to pass on the data or the transfer serves the aim of the criminal prosecution.

The registration of the data subject with the voluntary provision of personal data is intended to enable the controller to offer the person concerned contents or services that may only be offered to registered users due to the nature of the matter in question. Furthermore, the registration of the data subject (in the data protection declaration generator) is used to monitor the use of the texts, which we have issued and copyrighted, as well as verify the linkage and the copyright notice as well as our own documentation purposes. In addition, we use the data collected over the privacy policy generator for customer acquisition, in particular for telephone contact and advertising by post and e-mail. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The controller shall at any time provide information on the request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall rectify or erase personal data on the request or at indication of the data subject, insofar as there are no statutory storage obligations. A data protection officer particularly designated in this data protection declaration and the entirety of the employees of the controller are available to the data subject in this respect as contact persons.

7 Routine Erasure or Restriction of Processing of Personal Data

The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of the storage or as far as this is granted by the legislator or by other legislators in laws or regulations, to which the controller is subject to.

If the storage purpose is not applicable, 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.

8 Rights of the Data Subject

a) Right of confirmation

Each data subject shall have shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may at any time contact our data protection officer or another employee of the controller.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European legislator grants the data subject access to the following information:

• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
• 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 existence of 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) of the 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 shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may at any time contact our data protection officer or another employee of the controller.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. 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 wishes to exercise this right to rectification, he or she may at any time contact our data protection officer or another employee of the controller.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator 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 as long as the processing is not is necessary:

• 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 point (a) of Article 6 (1) of the GDPR, or point (a) of Article 9 (2) of the GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Article 21 (1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (2) of the GDPR.
• 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 Article 8 (1) of the GDPR.

If one of the above-mentioned reasons applies and a data subject wishes to request the erasure of personal data stored by the Sepia GmbH & Co. KG, he or she may at any time contact our data protection officer or another employee of the controller. The data protection officer of the Sepia GmbH & Co. KG or another employee shall promptly ensure that the erasure request is complied with immediately.

Where the Sepia GmbH & Co. KG has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the Sepia GmbH & Co. KG, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other 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, as far as processing is not required. The data protection officer of the Sepia GmbH & Co. KG or another employee will arrange the necessary measures in individual cases.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator 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 instead 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 defence of legal claims.
• The data subject has objected to processing pursuant to Article 21 (1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the abovementioned conditions is met and a data subject wishes to request the restriction of the processing of personal data stored by the Sepia GmbH & Co. KG, he or she may at any time contact our data protection officer or another employee of the controller. The data protection officer of the Sepia GmbH & Co. KG or another employee will arrange the restriction of the processing.

f) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall 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 point (a) of Article 6 (1) of the GDPR or point (a) of Article 9 (2) of the GDPR or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as  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 his or her right to data portability pursuant to Article 20 (1) of the GDPR, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible and does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact the data protection officer designated by the Sepia GmbH & Co. KG or another employee.

g) Right to object

Each data subject shall have the right  granted by the European legislator 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 point (e) or (f) of Article 6 (1) of the GDPR. This also applies to profiling based on these provisions.

The Sepia GmbH & Co. KG 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 for the establishment, exercise or defence of legal claims.

If the Sepia GmbH & Co. KG processes personal data 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. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Sepia GmbH & Co. KG to the processing for direct marketing purposes, the Sepia GmbH & Co. KG will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Sepia GmbH & Co. KG for scientific or historical research purposes or statistical purposes pursuant to Article 89 (1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may directly contact the data protection officer of the Sepia GmbH & Co. KG or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

h) Automated individual decision-making in specific case, including profiling

Each data subject shall have 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 him or her or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or performance of, a contract between the data subject and a data controller, or (2) is not authorised 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 not 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 a data controller, or (2) it is based on the data subject’s explicit consent, the Sepia GmbH & Co. KG 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 the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our data protection officer of the Sepia GmbH & Co. KG or another employee of the Collector.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our data protection officer of the Sepia GmbH & Co. KG or another employee of the controller.

9 Data Protection for Applications and Application Procedures

The controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the controller is concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically deleted two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the deletion. Other legitimate interest in this relation is, for example, a burden of proof in a procedure under the General Equal Treatment Act (AGG).