Information about your right to object

Information notice acc. Art. 13, 14 of the EU General Data Protection Regulation for the use of your personal data by the Horváth Group for marketing purposes and direct advertising as well as management of contact details in the CRM system

I.    Name and address of the controllers

The controllers in the sense of the EU General Data Protection Regulation (hereinafter "GDPR") and other national data protection laws (in Germany: Federal Data Protection Act hereinafter "BDSG") of the member states as well as other data protection regulations are:

Main controller

Horvath AG   
Rotebühlstraße 100  
D-70178 Stuttgart     
Telephone: +49 711 66919-0           
Fax: +49 711 66919-1075    
E-Mail: dataprotection@horvath-partners.com

Subsidiary controllers within the Horváth Group

If you have any questions or suggestions regarding data protection for the main controller or subsidiary controllers, please feel free to contact us at any time at dataprotection@horvath-partners.com.

II.    Contact details of the data protection officer

Grant Thornton AG   
Wirtschaftsprüfungsgesellschaft
Sebastian Barg         
Johannstraße 39       
40476 Düsseldorf      
Telephone: +49 211 95248548

You can reach our data protection officer at dataprotection@horvath-partners.com or our postal address (clause I.) with the addition of "Data Protection Officer".

III. Terms and definitions

The definitions and terms are based on GDPR, BDSG and other data protection regulations. In particular, the definitions of Art. 4 and Art. 9 GDPR.

IV. Recipients of personal data

Your personal data will only be passed on if confidentiality is maintained and only to the extent permitted by a legal basis. As part of the processing of advertising and marketing measures, including direct advertising and administration of contact data in the customer relationship management system (hereinafter referred to as "CRM system"), our employees will only have access to your data according to the so-called "need-to-know principle". This means that the group of authorized persons is limited to those employees who are required to fulfill the respective processing purpose.

In addition, the following entities may receive your data:

  • Processors we use (Art. 28 GDPR), in particular in the area of IT services and printing services, who process your data for us in accordance with instructions;
  • Public bodies and institutions (e.g., tax authorities) in the event of a legal or official obligation;
  • Other entities for which you have given us your consent to transfer data.

As part of marketing purposes, direct advertising or management of contact details in the CRM system, personal data may be sent within the Horváth Group to a third country. If such a data transfer has to be made outside the European Economic Area (third countries), this will only be done if it is absolutely necessary for the execution of the stated purposes or if it is required by law and the provisions of Chapter 5 of the GDPR are complied with.

V.    Processing of personal data for marketing purposes and direct advertising, as well as management of contacts in the CRM system

Marketing purposes and direct advertising

1 Description and scope of data processing and data categories

Your personal data will only be used for the purpose of advertising and/or marketing measures if you have given your consent or if there is another legal basis that allows us to contact you for advertising and/or marketing purposes even without your consent. As far as legally permissible, we reserve the right to address customers for advertising purposes also based on publicly accessible data and/or address data of third parties, which they extract from publicly accessible sources (e.g., data from company websites, public registers, professional networks and the Internet).

For example, the following categories of data may be processed:

  • Master data, such as salutation, position, first name, last name and date of birth;
  • Contact details, such as company, address, P.O. Box, email address and phone number;
  • Personal data, such as nationality, gender, age

2 Purpose of data processing and its legal basis

We process your personal data on the following legal bases:

  • The legal basis for advertising and/or marketing measures is consent pursuant to. Art. 6 para. 1 lit. a GDPR and/or legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR; this processing operation for the purpose of direct marketing is based on the economic interest of the controller.
  • The legal basis for the use of your personal data for the purpose of letter post advertising is a legitimate interest in accordance with. Art. 6 para. 1 lit. f GDPR. The legitimate interest here is to address potential customers for the purpose of direct advertising for our products and services.
  • The legal basis for advertising and/or marketing measures via telephone calls is § 7 Para. 2 No. 2 UWG. This requires explicit consent in the case of consumers and at least presumed consent in the case of other market participants.
  • For advertising and/or marketing measures via email for the purpose of direct advertising for our own similar goods or services, the legal basis is § 7 Para. 3 UWG. This assumes that we:
  • have received your e-mail address in connection with the provision of a service,
  • you have not objected to the use of your e-mail address for the purpose of direct marketing and
  • we will clearly inform you when collecting the e-mail address and at each use that you can object to such use of your e-mail address at any time.

3 Storage period and data deletion

Personal data of the data subjects shall be deleted insofar as the data is no longer required for the respective processing purposes or the legal basis for the storage no longer applies. Instead of deletion, the data may be stored under restriction of processing if this is provided for by the European or national legislator in Union regulations, laws or other provisions.

4 Revocation and objection option

You can revoke your consent to the processing of personal data at any time with effect for the future without giving reasons. The revocation can be declared in writing or by e-mail (e. g., an dataprotection@horvath-partners.com). This also applies to data processing based on legitimate interest (right to object).

Processing of contact data in the CRM system

1 Description and scope of data processing and data categories

Your personal data will only be used for the purpose of managing contact data in the CRM system (software solution for the support and management of personal customer data) if there is a legal basis for doing so.

For example, the following categories of data may be processed:

  • Master data, such as salutation, position, first name, last name and date of birth;
  • Contact details, such as company, address, P.O. Box, email address and phone number;
  • Contact history including email communication;
  • Personal information available to us

2 Purpose of data processing and its legal basis

We process your personal data on the legal basis of legitimate interest pursuant to. Art. 6 para. 1 lit. f GDPR. The legitimate interest here is the administration and protection of personal contact data as well as long-term customer retention through comprehensive customer care.

3 Storage period and data deletion

Personal data of the data subjects shall be deleted insofar as the data are no longer required for the respective processing purposes or the legal basis for the storage ceases to apply. Instead of the deletion occurs if necessary. storage under restriction of processing if this is provided for by the European or national legislator in Union regulations, laws or other provisions.

4 Possibility of objection

Processing of personal data on the basis of a legitimate interest pursuant to Art. Art. 6 para. 1 lit. f GDPR, you can object at any time with effect for the future without giving reasons. The objection can be declared in writing or by e-mail (e.g., at dataprotection@horvath-partners.com).

VI.    Automated decision making/profiling and obligation to provide data

For the aforementioned processing operations, we do not use automated decision-making techniques. Should we undertake such procedures in the future? we will inform you about this separately, insofar as this is required by law. Profiling based on the data we collect and process does not take place for these purposes.

Beyond that, there is no obligation to provide your data.

VII.    Your rights

You have the right to receive information about your personal stored data free of charge at any time. In addition, you have the right to request that your data be corrected or deleted at any time, provided that this does not conflict with any statutory regulations or retention periods. You can request the restriction of the processing of your data and object to the processing of your data. You also have the right to data portability. Furthermore, you can complain to the competent data protection supervisory authority about the processing of your personal data by us.

1 Right to information (Art. 15 GDPR)

You may request confirmation from the controller as to whether personal data concerning you is being processed by us.

2 Right to rectification (Art. 16 GDPR)

You have a right to correction and/or completion to the person responsible if the processed personal data concerning you is incorrect or incomplete. The responsible party shall make the correction without undue delay.

3 Right to erasure (Art. 17 GDPR)

You may request the controller to delete the personal data concerning you without undue delay, and the controller is obliged to delete this data without undue delay, unless one of the exceptions regulated in the GDPR applies or other statutory retention obligations oblige us to retain the data in question.

4 Right to restriction of processing (Art. 18 GDPR)

Under the conditions regulated in the GDPR, you may request the restriction of the processing of personal data concerning you.

5 Right to data portability (Art. 20 GDPR)

You have the right to receive the personal data concerning you, which you have provided to the controller and the processing of which is based on consent or on a contract with you, in a structured, commonly used and machine-readable format. In addition, under the conditions regulated by the GDPR, you have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided.

In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one controller to another controller, insofar as this is technically feasible. Freedoms and rights of other persons may not be impaired thereby.

6 Right of object (Art. 21 GDPR)

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR to lodge an objection; This also applies to profiling based on these provisions.

If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing. In the event of an objection, the personal data concerning you will no longer be processed for these purposes.

7 Right to withdraw consent (Art. 7 para. 3 GDPR)

You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. This also applies to the revocation of declarations of consent given to us prior to the application of the GDPR, i.e., prior to May 25, 2018. All personal data stored on the basis of the consent given in each case will be deleted in this case, unless there is another legal basis for further storage according to the law. You can give your consent informally at dataprotection@horvath-partners.com revoked.

VIII.    Right of appeal

In the event of violations of data protection regulations, the data subjects shall have a right of appeal to a data protection supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged violation. The right of appeal is without prejudice to other administrative or judicial remedies. Our responsible data protection supervisory authority (Horváth AG) is:

State Commissioner for Data Protection and Freedom of Information Baden-Württemberg

Prof. Dr. Tobias Keber          
Address: Lautenschlagerstraße 20, 70173 Stuttgart         
Postal address: 10 29 32, 70025 Stuttgart 
Switchboard: 0711 61 55 41 0         
E-mail: poststelle@lfdi.bwl.de

The contact details of other data protection supervisory authorities can be found at the following link :https://www.bfdi.bottom.en/EN/Infothek/Addresses_links/addresses_links-node.html

IX.    Change of the information notice

We reserve the right to change the information notice at irregular intervals as data protection law develops and technological or organizational changes occur and will inform you of any significant changes that affect the use of your personal data. Our general privacy policy can be found on our website.