An important piece of information to note initially:
I. Responsible entity (“Controller”) and your rights as the data subject
1. Responsible entity
3, Kashtanova st.
Dnipro, Ukraine 49000
2. Data Protection Officer
Dr Stefanie Wegener
20148 Hamburg, Germany
3. Your rights as a data subject
You may exercise your data protection rights against NTC Kamerton insofar as the NTC Kamerton companies are jointly responsible for data processing in connection with our website. The NTC Kamerton Companies have agreed to this.
You have the following data subject rights:
You have the right to information about the processing of your personal data (for example, the origin of this data, the purpose of processing, and the modalities of data processing). Furthermore, under certain conditions, you are entitled to object to the future processing of your data, as well as the right to restrict the use or the deletion of said data. Finally, you may at any time stop the sending of advertising material or the execution of market research or commercial communications.
In summary, you have a right to:
- Deletion (or request to be forgotten),
- Restriction of processing,
- Data portability,
- Object to the processing of your personal data,
- Complaint to supervisory authorities.
In addition, you have the right, at any time, to object to the processing of your personal data for direct marketing purposes. If you object to the processing for direct marketing purposes, we will no longer process your personal data for these purposes.
According to Art. 7 III of the EU General Data Protection Regulation (hereinafter "GDPR"), you may at any time revoke your initial consent towards us. Once the consent is revoked we will no longer continue to process the data.
Please note that your right to the deletion of your data is subject to certain restrictions. For example, we do not have to or are not allowed to delete data that we are required to retain due to legal retention periods. Data that we need to assert, exercise or defend due to legal claims are also excluded from your right of deletion.
If you have a complaint about the way we process your data, you have the recourse to a supervisory authority, in particular in the member state of your residence, workplace or the place of the alleged breach.
We reserve the right to disclose information about you if we are required to do so by law enforcement bodies or other lawful authorities. Legal basis: Art. 6 I sentence 1 lit. c GDPR (legal obligation).
II. Collection and processing of personal data when visiting our Website
1. What data do we process from you (hereinafter referred to as "you" or "user")?
When you use our Website, we process personal data, in particular:
- The e-mail address, first name, last name, title, address, telephone number, property data, participation in events and webinars, hereinafter referred to as "data" or "personal data", provided to us by you in the event that you use individual services offered by us or an NTC Kamerton Company via our Website (e.g. in the context of contact enquiries, newsletter mailings, webinars as well as the market price determination of properties); mandatory fields are marked with an "asterisk";
- Personal data (also hereinafter referred to as "user data") transmitted by the user's internet browser each time they access the Website and stored as part of log files, also known as server log files. This data includes: the IP address (Internet Protocol address) of the accessing computer; the name of the accessed page; date and time of access; URL from which the user accesses the page; the volume of data transmitted; status message for successful access; session ID number;
- Personal data in the form of location data (GPS data, so-called "Locate Me" function), which is transmitted by your Internet browser each time you have activated this setting on the browser by default or application-based.
2. Purpose of the processing
We process the personal data of the users of our Website for the following purposes:
- Provision of online offers for own and third-party advertising (legal basis is the legitimate interest of NTC Kamerton in marketing its own services as well as the services of the companies of the NTC Kamerton as described above);
- Fulfilment of user contact requests to the NTC Kamerton (legal basis is the fulfilment of the contract as well as, in the event of the user data being passed on, your consent or the legitimate interest of NTC Kamerton to pass on contact or service requests within the NTC Kamerton to the relevant (licence partner) company of this NTC Kamerton which is responsible in terms of expertise and/or geographical location;
- If applicable, for the purpose of fulfilment of a valuation request of the property as described by the user, as well as the implied interest in the sale of the property as submitted by the valuation request (The legal basis is (a) the fulfilment of the contract as well as, (b) your consent in the event that we need to share your contact data with (i) a suitable licence partner of the NTC Kamerton based on expertise or geographical location (for the definition, please see section 3 below)) or (ii) to the company technically implementing the evaluation and (c) the legitimate interest in marketing our services or your consent in the case of the use of your contact data for direct marketing);
- The organisation of webinars (legal basis is the fulfilment of the contract by NTC Kamerton and, in case your contact details are passed on to the lecturer, your consent);
- Contact by telephone by NTC Kamerton or the NTC Kamerton (legal basis is the fulfilment of the contract or, in the case of the use of the telephone number for advertising purposes, your consent);
- Sending out an e-mail newsletter by NTC Kamerton or the NTC Kamerton containing our offers as well as self and third-party advertising to the extent permitted by law or based on the consent given (the legal basis is either your consent or NTC Kamerton´ legitimate interest in direct marketing, as long as the marketing is carried out in compliance with data protection and competition law requirements of the applicable national regulations);
- For the optimisation and operability of the Website (legal basis is the legitimate interest of NTC Kamerton to constantly improve the quality of the Website and to ensure ease of use);
- If necessary, identification and, if applicable, blocking of users who have installed a so-called adblocker and thus block advertising (legal basis is the legitimate interest of NTC Kamerton to make fully or partially advertising-financed offers available to users who do not block advertising);
- To prevent fraudulent activity or abuse on or in connection with the Website and to be able to ensure the legal requirements that the Website is secure (legal basis is the legitimate interest of NTC Kamerton to eliminate malfunctions, to ensure system security and to detect unauthorised access attempts or access).
In summary: The legal basis for the processing of your personal data is Art. 6 I sentence 1 lit. a GDPR if the processing is based on consent, Art. 6 I sentence 1 lit. b GDPR if the processing is based on a (possibly pre-contractual) contractual relationship Art. 6 I sentence 1 lit. f GDPR if the processing is based on the legitimate interest of NTC Kamerton. If the processing of personal data is necessary to comply with a legal obligation to which NTC Kamerton is subject, Article 6 I sentence 1 lit. c GDPR is the relevant legal basis.
If the legal basis is your consent, you are entitled to revoke your consent at any time without affecting the lawfulness of the processing of your personal data carried out based on the consent until revocation. If the legal basis is the legitimate interest, you are also generally entitled to object to the processing of personal data relating to you at any time for reasons arising from your particular situation. In this respect, Art. 21 GDPR applies.
3. Disclosure of your personal data
Due to the scale and complexity of data processing by the NTC Kamerton, it is not possible to list each recipient of your personal data individually in this data protection policy, which is why, as a rule, only categories of recipients are indicated.
Within the NTC Kamerton, your data will be disclosed to those NTC Kamerton Companies or entities that require the data to fulfil our contractual and legal obligations and to pursue legitimate interests in the context of this Website service or based on your consent. This includes NTC Kamerton Companies that support the provision of our website, direct marketing or other IT infrastructure, that provide webinar events, that carry out the valuation of properties or that send out newsletters.
If your contact request relates to offers from other companies of the NTC Kamerton, NTC Kamerton will transmit the personal data you have entered to the respective company based on a so-called legitimate interest within the NTC Kamerton.
If, on the other hand, your contact request concerns offers from other companies of the NTC Kamerton (i.e. our licence partners), we will pass on your personal data from the NTC Kamerton with your prior consent.
4. Transfer of data to non-EEA countries
In addition to the above paragraph "Disclosure of your personal data", the following applies:
Recipients of personal data may be located outside the EEA/UK. Where personal data is transferred to locations outside the EEA/UK, we will ensure, as required by law, that your data protection rights are adequately protected, either because the European Commission has decided that the country to which personal data is transferred ensures an adequate level of protection (Art. 45 GDPR) or the transfer is subject to adequate safeguards (e.g. standard contractual clauses) as agreed by the European Union and the recipient of the data (Art. 46 GDPR) unless the GDPR provides for an exception (Art. 49 GDPR). Furthermore, where necessary, we intend to agree to additional measures with recipients to ensure an adequate level of data protection.
Copies of the adequate safeguards (where we rely on them) and a list of recipients outside the EEA/UK are available on request. Please note that these copies may be redacted to the necessary extent to protect trade secrets or other confidential information.
5. Storage and deletion of your data
NTC Kamerton will retain your personal data for the time necessary to achieve the purposes for which data is collected, including any retention period required by the applicable law (e.g. retention of accounting records).