Website Privacy Policy

Below, we will inform you about the processing of your personal data by us and your claims and rights under the data protection law, especially the General Data Protection Regulation (GDPR).

This Privacy Policy explains nature, scope and purpose of the processing of personal data by our website (collectively referred to as "Website"). The Privacy Policy applies regardless of the domains, systems and devices used (e.g., desktop, mobile, etc.).

Personal data are any data that are personally attributable to you, e.g. name, address, e-mail addresses, user behavior. Which data are processed in detail and how they are used depends largely on which of our services are used.

In our Privacy Policy we use various other terms in the sense of the GDPR. This includes terms such as processing, restriction of processing, profiling, pseudonymisation, controller, processor, recipient, third party, consent, supervisory authority and international organisation. Art. 4 GDPR you can find corresponding definitions for these terms.

1. Who is responsible for data processing and whom can I contact?

You can contact us for data protection relevant questions under:

DSB@officefirst.com

2. Which sources and data do we use?

We process personal data that we receive from you as part of your use of our website and, if applicable, our business relationship.

In the case of purely informative use of the website, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser transmits to our server. When you visit our website, we collect the following access data that we technically require to display our website and to ensure stability and security. The access data include the IP address, date and time of the visit, time zone difference compared to Greenwich mean time (GMT), content of the request (i.e. name of the specific visited web page), access status/HTTP status code, respective amount of transmitted data, referrer URL (previously visited page), browser type and version, operating system and its interface, language and version of the browser software, message about successful retrieval.

In addition, we obtain your personal data when your company registers to the 5-Star Service Program provided to the tenants of the Airport Plaza Campus. Personal data here include name, company and e-mail (hereinafter called "contact information").

3. What do we process your data for (purpose of processing) and on what legal basis?

We process personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and the Federal Data Protection Act (BDSG) for the following purposes and on the following legal bases:

PurposesLegal basis

Insofar as you consent to the processing of personal data for specific purposes, in particular for contacting you (e.g. via our contact form or by e-mail for handling and processing the request, advertising by telephone, e-mail, SMS, etc.), such processing is legal as you have consented.

Your consent may be withdrawn at any time. Please note that any withdrawal is effective for the future only. It does not affect any processing that was done prior to the withdrawal. Any withdrawal may be addressed to the above-mentioned contact data or to gdestruel@freestate-partners.com.

Consent, Art. 6 (1a) GDPR

When you contact us (via contact form or by e-mail), in addition to any consent given to processing the contact request and its handling, your details are also processed based on steps taken prior to entering into a contract, Art. 6 (1b) GDPR.

Steps taken at the request of the data subject prior to entering into a contract, Art. 6 (1b) GDPR

We process your access data (see data specified under item 2 above) to safeguard our legitimate interests or those of third parties. In particular, we pursue the following legitimate interests:

  • Ensuring IT security, in particular the security of the Website; we also store the IP address in the event that someone leaves behind illegal content using the comment function (insults, prohibited propaganda, etc.) and we must be able to determine the author's identity for our own legal protection.
  • Advertising or market and opinion research, unless you have objected to the use of your data;
  • Assertion of legal claims and defense in case of legal disputes;

As part of the balancing of interests for the safeguarding of legitimate interests, Art. 6 (1f) GDPR

4. Who can access my data?

Within the organization, entities that need to know your data to fulfill our contractual and regulatory obligations can access your data.

In addition, processors (Art. 28 GDPR) engaged by us may also obtain access to data for the above-mentioned purposes. These are companies in the IT services. If we use processors to provide our services, we will take appropriate legal precautions as well as the relevant technical and organizational measures to protect personal data in accordance with applicable law.

Any transfer of data to third parties will be made only within the scope of legal requirements. We will disclose user data to third parties only if this is required, for example, under Art. 6 (1) (b) GDPR for contract purposes or based on legitimate interests pursuant to Art. 6 (1) (f.) GDPR in the economic and effective operation of our business or if you have consented to the data transfer. If the Website is used for purely informational purpose, we generally do not disclose any data to third parties.

5. How long will my data be retained?

For security reasons (e.g. to investigate abusive or fraudulent activities) log-file information is retained for a maximum of two weeks and then deleted (see item 2 above). Data that must be retained further for evidential purposes are exempted from deletion until the respective incident has been finally clarified.

If necessary, we process and retain your personal data for the duration of our business relationship, which also includes, for example, initiation and performance of a contract via the contact form or by e-mail.

In addition, we are subject to various retention and documentation obligations, inter alia under the German Commercial Code (HGB) and the German Tax Code (AO). The deadlines for retention and documentation specified therein range from two to ten years.

Finally, the retention period also depends on the statutory limitation periods, which for example, usually is 3 years according to Sec. 195 et seqq. of the German Civil Code (BGB), but in some cases may be as long as thirty years, with the standard limitation period being three years.

6. Are data transferred to a third country or to an international organization?

The provided data are processed within the European Union as well as in the case of Google Analytics (see sections below) in the USA. Please note that in case of recipients of your data in countries without an adequacy decision by the Commission according to Art. 45 GDPR, as is the case with the USA, we either ensure that they are certified under the EU-U.S. Privacy Shield (such as e.g. Google) or that we have agreed on EU standard data protection clauses with such recipients. This is done to protect your data and to attain an adequate level of protection for your personal data. You have the option of obtaining a copy of, or perusing, the EU standard data protection clauses. If necessary, please contact us, using the contact details specified in item 1 above.

7. What are my data protection rights?

Each and every data subject has

  • the right of access according to Art. 15 GDPR,
  • the right to rectification according to Art. 16 GDPR,
  • the right to erasure according to Art. 17 GDPR,
  • the right to restriction of processing according to Art. 18 GDPR and
  • the right to data portability under Art. 20 GDPR.

In addition, you may revoke consent in principle with effect for the future.

You furthermore have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR in conjunction with Sec. 19 BDSG).

We would also like to note your right to object according to Art 21. GDPR:

Information about your right to object according to Art. 21 GDPR

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6 (1) (e) GDPR (data processing in the public interest) and Art. 6 (1) (f) of the General Data Protection Regulation (data processing based on balancing of interests); this also includes profiling under these provisions within the meaning of Art. 4 No. 4 GDPR, which we use to analyze questionnaires or for advertising purposes.

If you object, we will no longer process your personal data, unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing serves the purposes of asserting, exercising or defending legal claims.

In individual cases, we process your personal data for direct marketing purposes. You have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is associated with such direct marketing. If you object to the processing for direct marketing purposes, we will no longer process your personal data for such purposes.

Objections do not require a particular form and no costs are incurred, other than the transmission costs according to the basic tariffs.

If possible, any objection should be addressed by e-mail to:

gdestruel@freestate-partners.com

8. To what extent do you apply automated individual decision-making, including profiling?

In principle, we do not use fully automated decision-making pursuant to Art. 22 GDPR as part of access to our Website or in the context of contact via form or by e-mail. Should we use such procedures in individual cases, we will notify you separately, if this is required by law. We do not process your data automatically with the objective of evaluating certain personal aspects (profiling).

9. Am I under any obligation to provide data?

On our Website, you must provide the personal data necessary for using our Website for technical or IT security reasons. You cannot use our Website, unless you provide the above-mentioned data.

When contacting us via form or by e-mail, you only need to provide the personal data required to process your request. Otherwise we will be unable to process your request.

10. Cookies

Cookies are information transmitted from our web server or third-party web servers to the users' web browsers, where they are stored for later retrieval. Cookies are small files or other types of information storage. Cookies are used for security purposes or for the operation of our Website (e.g. for the optimal display of the website on different terminals) or to save your decision when confirming our cookie banner.

We use "session cookies", which are stored only for the duration of the current visit to our Website and are an enabling factor for the use of our Website in the first place. A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the retention period. Session cookies are deleted at the latest when you have finished using our Website and close the browser.

We will explain the use of cookies in the context of website tracking in the following section.

If you do not want cookies to be stored on your computer, you may disable the corresponding option in your browser's system settings. Stored cookies may be deleted in the browser's system settings. Please note that disabling cookies may limit the functionality of this Website.

You may object to the use of cookies for website tracking and advertising purposes through the network advertising initiative http://optout.networkadvertising.org or the American website http://www.aboutads.info/choices or the European website http://www.youronlinechoices.com/uk/your-ad-choices/.

11. Google Analytics

Based on our legitimate interests, i.e. our interest in optimizing and economic operation of our Website, we use the web analytics service Google Analytics of Google Inc. ("Google"). The web analytics service Google Analytics uses cookies. The data generated by these cookies about the use of our Website usually are transmitted to a Google server in the USA and stored there.

Google is certified under the EU-US Privacy Shield Agreement and therefore guarantees compliance with European data protection law (https://www.privacyshield.gov).

Google uses such data on our behalf to evaluate the use of our Website by our users, to compile reports on the activities on this Website and to provide us with further services related to the use of this Website. The processed data can be used to generate pseudonymous usage profiles.

We use Google Analytics with activated IP anonymization. This means that the users' IP address is shortened by Google within the States that are party to the Agreement on the European Economic Area. The full IP address is sent to a Google server in the USA and shortened there in exceptional cases only.

The IP address transmitted by the user's browser is not merged with other data provided by Google. Users may prevent the storage of cookies by setting their browser software accordingly; in addition, users may also prevent the collection of the data generated by the cookie and their transfer to Google as well as the processing of such data by Google, by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

For more information about data processing by Google, settings and options to object, please visit the websites of Google at: https://www.google.de

12. Other services

On our website, we use third-party services as part of our legitimate interests within the meaning of Art. 6 (1) (f) GDPR, i.e. our interest in an optimal Website. The user's IP address is transmitted to such third-party providers. The IP address is technically required for the contents to be displayed. Third party providers may use so-called web pixels (invisible graphics, also referred to as "web beacons") for evaluation or marketing purposes. The web pixels can be used to evaluate information, such as the traffic of the Website. The third parties may store information in cookies on users' devices.

We use the following third-party providers on our website:

  • YouTube videos

    (1) We have included YouTube videos in our online offering which are stored at http://www.YouTube.com and can be played directly from our website. These are all integrated in the "extended data protection mode", i.e. no data about you as a user is transferred to YouTube if you do not play the videos. Only when you play the videos will the data referred to in paragraph 2 be transmitted. We have no influence on this data transmission.

    (2) By visiting the Website, YouTube receives the information that you have accessed the corresponding subpage of our Website. In addition, the data specified under ยง2 of this declaration will be transmitted. This occurs regardless of whether YouTube provides a user account that you are logged in to or whether there is no user account. If you are logged in at Google, your data will be assigned directly to your account. If you do not wish your profile to be associated with YouTube, you must log out before activating the button. YouTube stores your data as user profiles and uses them for advertising, market research and/or the design of its website to meet your needs. Such evaluation is carried out in particular (even for users who are not logged in) to provide demand-oriented advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

    (3) Further information on the purpose and scope of data collection and processing by YouTube can be found in the Privacy Policy. There you will also find further information on your rights and setting options to protect your privacy: https://www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

  • DoubleClick by Google

    (1) This website uses the online marketing tool DoubleClick by Google. DoubleClick uses cookies to serve ads relevant to users, to improve campaign performance reports, or to prevent a user from seeing the same ads more than once. Google uses a cookie ID to track which ads appear in which browser, thereby preventing them from appearing more than once. In addition, DoubleClick may use cookie IDs to collect conversions related to ad requests. This is the case, for example, when a user sees a DoubleClick ad and later uses the same browser to visit the advertiser's website and makes a purchase. According to Google, DoubleClick cookies do not contain personally identifiable information.

    (2) Because of the marketing tools used, your browser automatically connects directly to Google's server. We have no influence on the extent and further use of the data collected through the use of this tool by Google and therefore inform you according to our state of knowledge: Through the integration of DoubleClick, Google receives the information that you have called pages from our website or have clicked an ad from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible that Google may still find out and store your IP address.

    (3) You can prevent participation in this tracking process in various ways: a) by setting your browser software accordingly, in particular by suppressing third-party cookies, you will not receive any third-party advertisements; b) by deactivating cookies for conversion tracking by setting your browser to block cookies from the "www.googleadservices.com" domain, https://www.google.de/settings/ads, whereby this setting is deleted when you delete your cookies; c) by disabling the interest-based ads of the providers that are part of the "About Ads" self-regulatory campaign via the link http://www.aboutads.info/choices, whereby this setting is deleted when you delete your cookies; d) by permanently disabling it in your Firefox, Internet Explorer or Google Chrome browsers via the link http://www.google.com/settings/ads/plugin. Please note that in this case you may not be able to make full use of all functions of the website.

    (4) The legal basis for the processing of your data is Art. 6 para. 1 S. 1 lit. f GDPR. Further information on DoubleClick by Google can be found at https://www.google.de/doubleclick and http://support.google.com/adsense/answer/2839090, as well as on data protection at Google in general: https://www.google.de/intl/en/policies/privacy. Alternatively, you can visit the Network Advertising Initiative (NAI) website at http://www.networkadvertising.org Google is certified under the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

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