Privacy Policy
Privacy Policy Chris Twellmann
I – Chris Twellmann („Twellmann“ or „I“) – would like to inform you about the processing of your personal data in accordance with the General Data Protection Regulation (“GDPR”).
The privacy policy is modular in structure. It consists of a general part which applies for all processing of personal data (I.) and special parts, which cover additional information regarding specific processing situations (II. et sqq.). To find the parts relevant to you, please see below:
I. General
II. Additional information for the provision of the Website
III. Additional information for communication
IV. Additional information for Contractual Partner
I. General
1. Controller
The controller within the meaning of the GDPR and other national data protection laws and other provisions of data protection law for the processing of data is
Christian Twellmann
Eimsbütteler Chaussee 39
20259 Hamburg, Germany
web [at] mpilot.de
2. Legal basis for the processing of personal data
Your personal data is processed on the basis of the following legal bases:
a) Consent of the data subject
Insofar as I obtain the consent of the data subject for processing personal data, Art. 6 para. 1 s. 1 lit. a GDPR serves as the legal basis for the processing of personal data.
b) Performance of contractual obligations
If I process personal data that is necessary for the performance of a contract to which the data subject is a party of, Art. 6 para. 1 s. 1 lit. b GDPR serves as the legal basis. This also applies to processing which is necessary to carry out pre-contractual measures.
c) Legal requirements and obligations
Insofar as the processing of personal data is necessary for the fulfilment of a legal obligation to which I am subject to, Art. 6 para. 1 s. 1 lit. c GDPR serves as the legal basis.
d) Safeguarding legitimate interests
If the processing is necessary to safeguard a legitimate interest of mine or of a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis.
3. Data deletion and storage period
The personal data of the data subject will be deleted or blocked as soon as the purpose of the processing no longer applies.
4. Recipients of your data
Internally, only those entities process personal data that require it for the fulfilment of their processing purposes. This also applies to the processors, service providers and vicarious agents I use. All bodies and persons who work with personal data are obliged to maintain data secrecy and have been made aware of the sensitive nature of handling such data.
Personal data will only be passed on to third parties if this is in accordance with data protection regulations. In particular, persons assigned to carry out my business operations (e.g., banks, tax consultants, service providers for IT services) as well as government agencies/authorities may receive your personal data insofar as this is necessary to fulfil a statutory obligation.
5. Data subject rights
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights against the controller:
a) Right of access
In accordance with Art. 15 GDPR, you have the right to request information about the personal data I process. In particular, you can request to be informed regarding:
– 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 organizations (in this context, you may request to be informed about the appropriate safeguards pursuant to Art. 46 GDPR),
– the planned storage period,
– the right to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing,
– the right to lodge a complaint with a supervisory authority,
– if the personal data are not collected from you, to about the source of the personal data,
– and the existence of automated decision-making, including profiling, referred to in Art. 22 para. 1 and 4 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 you.
b) Right to rectification
In accordance with Art. 16 GDPR, you have the right to have your personal data corrected and/or completed if it is incorrect or incomplete. I must carry out the correction without delay.
c) Right to restriction of processing
In accordance with Art. 18 GDPR, you have the right 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. If the processing has been restricted, you will be informed by me before the restriction is lifted.
d) Right to erasure
In accordance with Art. 17 GDPR, you have the right to erasure of your personal data, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims.
e) Notification regarding rectification or erasure of personal data or restriction of processing
If you have asserted the right to rectification, erasure or restriction of processing, all recipients to whom the personal data have been disclosed will be notified of the rectification, erasure of the personal data or restriction of processing, unless this proves impossible or involves disproportionate effort.
f) Right to data portability
You have the right within the limits of Art 20 GDPR to receive the personal data concerning you that you have provided to the controller in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data was provided.
g) Right to object
You have the right within the limits of Art. 21 GDPR to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6 para. 1 s. 1 lit. e or f GDPR.
h) Right to withdraw the consent
You have the right to withdraw your consent at any time according to Art. 7 para. 3 GDPR. The withdraw does not affect the lawfulness of prior processing carried out on the basis of the consent.
i) Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right according to Art. 77 GDPR to lodge a complaint with a supervisory authority.
II. Additional information for the provision of the Website
I am responsible for the websites christiantwellmann.de, christiantwellmann.com, christwellmann.de, christwellmann.com, solutions4mobile.de, ctconsult.biz und mpilot.de and its subpages (“Website”). By using the Website, personal data of the Website visitor (“user”) is processed as follows:
Provision of the Website and creation of Log Files
If you open the Website, so called Log Files will automatically be processed which include data of the user device and therefore also personal data as mentioned below.
Processor
The provision of the Website is made possible with the help of the processor dogado GmbH, Antonio-Segni-Straße 11, D-44263 Dortmund with whom a data processing agreement has been concluded and who processes the personal data exclusively on my behalf. The processor does not process personal data in third countries.
Processed personal data & period of the processing
The following information is processed:
– Hostname / IP of the visitor
– Website visited
– Time at the time of access
– Amount of data sent in bytes
– Source/reference from which the visitor reached the page
– Browser used
– Operating system used
– IP address used by the user
The log files are deleted within fourteen days at the latest.
Purpose of processing & legal basis
The data is required to display the Website on the user’s device, to ensure its functionality and to analyze any malfunctions. In addition, the data is used to optimize the Website and to ensure the security of the IT systems.
The legal basis is Art. 6 para. 1 s. 1 lit. f GDPR. The collection of log files is absolutely necessary for the operation of the Website. Consequently, the user has no option to object.
III. Additional information for communication
The following information applies to all communication.
Processed personal data & period of the processing
In addition to your e-mail address/telephone number, the personal data that you provide in the communication will be processed.
The data will be deleted – unless there is another reason for processing – as soon as the matter with you has been settled.
Purpose of processing & legal basis
The personal data will be processed exclusively for the purpose of processing the request and in the event of follow-up questions.
If the communication is aimed at the conclusion of a contract, the legal basis for the processing is Art. 6 para. 1 s. 1 lit. b GDPR.
In all other cases, Art. 6 para. 1 s. 1 lit. f GDPR is the legal basis. Your interest does not outweigh my interest in responding to your request; since you are writing to me, it is also in your interest to respond and you are aware that I must process your personal data in order to respond to your request.
IV. Additional information for Contractual Partner
In addition, the following information applies to you if a contractual relationship exists.
Processed personal data & period of the processing
Which of your data is processed depends on the tasks within the contractual relationship. The personal data is used exclusively for the purpose for which it was provided. This includes, for example, personal data (name, address and other contact data, date and place of birth). In addition, this may also include order data (e.g. payment order), data from the fulfillment of contractual obligations (e.g. turnover data in payment transactions), information about your financial situation (e.g. creditworthiness data), advertising and sales data as well as other data comparable to the categories mentioned.
The personal data will be deleted as soon as the contractual relationship with you has ended and provided there is no other reason for processing.
This does not apply to personal data that is only processed on your behalf. In this respect, I act solely as your processor.
Purpose of processing & legal basis
The processing is mainly carried out for the purpose of establishing and implementing the contractual relationship; the legal basis is Art. 6 para. 1 s. 1 lit. b GDPR.
In addition, some of the data is also processed on the basis of legitimate interest, namely for the purposes of contact and communication management, profitability checks, contract and project management and to ensure the operation of IT systems. The legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.
In addition, companies are bound by various legal obligations. Therefore Art. 6 para. 1 s. 1 lit. c GDPR is the legal basis. This includes, in particular, retention obligations under tax law.