Privacy policy
We are very pleased about your interest in our company. Data protection is of particular importance to the management of ESPRIX Excellence Suisse. The use of the ESPRIX Excellence Suisse website is generally possible without providing any personal data. However, if a data subject wishes to make use of special services of our company via our website, it may be necessary to process personal data. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in accordance with the country-specific data protection provisions applicable to ESPRIX Excellence Suisse. Through this privacy policy, our company would like to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects will be informed of their rights by means of this privacy policy.
As the controller, ESPRIX Excellence Suisse has implemented numerous technical and organizational measures to ensure the most complete protection possible for personal data processed via this website. Nevertheless, Internet-based data transmissions can, in principle, have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example, by telephone.
1. Definitions
The privacy policy of ESPRIX Excellence Suisse is based on the terms used by the European Directive and Regulation Giver in the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.
We use the following terms, among others, in this privacy policy:
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.
c) processing
Processing means 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 future processing.
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 or controller responsible for the processing
Controller or controller responsible for the processing means 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 means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
i) recipient
Recipient means 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.
j) third party
Third party means 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 means 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 within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions with a data protection character is:
ESPRIX Excellence Suisse
Scheuchzerstrasse 126
8006 Zurich
Switzerland
Tel.: +41442810013
E-mail: excellence@esprix.ch
Website: www.excellence-framework.eu
3. Cookies
The Internet pages of ESPRIX Excellence Suisse use cookies. Cookies are text files that are stored in a computer system via an Internet browser.
Numerous websites 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 string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A particular Internet browser can be recognized and identified by the unique cookie ID.
By using cookies, ESPRIX Excellence Suisse can provide 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 in the interests of the user. Cookies enable us, as already mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to enter his access data each time he visits the website, because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a cookie.
The data subject can prevent the setting of cookies through our website at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.
4. Collection of general data and information
The ESPRIX Excellence Suisse website collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server’s log files. The following can be recorded: (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 referrer), (4) the sub-websites which are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information used to avert dangers in the event of attacks on our information technology systems.
When using this general data and information, ESPRIX Excellence Suisse 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 and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. This anonymously collected data and information is therefore evaluated by ESPRIX Excellence Suisse both statistically and with the aim of increasing data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
5. Registration on our website
The data subject has the possibility to register on the website of the controller, providing personal data. Which personal data are transmitted to the controller is determined by the respective input mask that is used for registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the transfer to one or more processors, such as a parcel service provider, who also uses the personal data exclusively for internal use attributable to the controller.
By registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) to the data subject, the date and time of registration are also stored. The storage of this data takes place against the background that only in this way can the misuse of our services be prevented, and this data makes it possible, if necessary, to investigate committed criminal offences. In this respect, the storage of this data is necessary to secure the controller. A transfer of this data to third parties does not take place in principle, unless there is a legal obligation to pass it on or the transfer serves the purpose of criminal prosecution.
The registration of the data subject, with voluntary disclosure of personal data, is intended to enable the controller to offer the data subject content or services that, due to the nature of the matter, can only be offered to registered users. Registered persons are free to modify the personal data provided during registration at any time or to have them completely deleted from the data stock of the controller.
The controller shall, at any time upon request, provide information to each data subject as to which personal data relating to the data subject are stored. Furthermore, the controller shall correct or delete personal data at the request or notice of the data subject, insofar as there are no legal storage obligations to the contrary. The entirety of the employees of the controller are available to the data subject as contact persons in this context.
6. Subscription to our newsletter
On the website of ESPRIX Excellence Suisse, users are given the opportunity to subscribe to our company’s newsletter. Which personal data are transmitted to the controller when ordering the newsletter is determined by the input mask used for this purpose.
ESPRIX Excellence Suisse informs its customers and business partners at regular intervals by means of a newsletter about company offers. In principle, the newsletter of our company can only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter dispatch. For legal reasons, a confirmation email in the double opt-in procedure is sent to the email address first registered by a data subject for newsletter dispatch. This confirmation email serves to check whether the owner of the email address as the data subject has authorized the receipt of the newsletter.
When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) to the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject’s email address at a later point in time and therefore serves to legally safeguard the controller.
The personal data collected as part of a newsletter registration will be used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter may be informed by email, provided this is necessary for the operation of the newsletter service or a related registration, as might be the case in the event of changes to the newsletter offer or changes to the technical circumstances. There will be no transfer of personal data collected as part of the newsletter service to third parties. The subscription to our newsletter can be terminated by the data subject at any time. The consent to the storage of personal data that the data subject has given us for the newsletter dispatch can be revoked at any time. For the purpose of revoking the consent, a corresponding link can be found in each newsletter. Furthermore, it is possible to unsubscribe from the newsletter dispatch at any time directly on the website of the controller or to inform the controller of this in another way.
7. Newsletter tracking
The newsletters of ESPRIX Excellence Suisse contain so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded in such emails that are sent in HTML format to enable a log file recording and a log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns to be carried out. Based on the embedded tracking pixel, ESPRIX Excellence Suisse can recognize if and when an email was opened by a data subject and which links in the email were accessed by the data subject.
Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the controller in order to optimise the dispatch of the newsletter and to better adapt the content of future newsletters to the interests of the data subject. This personal data will not be disclosed to third parties. Data subjects are entitled to revoke the relevant separate declaration of consent submitted via the double opt-in procedure at any time. After revocation, this personal data will be deleted by the controller. Unsubscribing from receiving the newsletter is automatically interpreted as a revocation by ESPRIX Excellence Suisse.
8. Contact option via the website
Due to legal regulations, the website of ESPRIX Excellence Suisse contains information that enables quick electronic contact with our company and direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject will be automatically stored. Such personal data voluntarily transmitted by a data subject to the controller is stored for the purposes of processing or contacting the data subject. This personal data will not be disclosed to third parties.
9. Routine erasure and blocking of personal data
The controller shall process and store personal data of the data subject only for the period necessary to achieve the purpose of storage or where provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.
If the storage purpose no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data shall be routinely blocked or erased in accordance with the statutory provisions.
10. Rights of the data subject
a) Right to confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to exercise this right to confirmation, he or she may, at any time, contact an employee of the controller.
b) Right to information
Each data subject affected by the processing of personal data has the right granted by the European legislator to obtain, at any time, from the controller, free information about the personal data stored about him or her and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:
- the purposes of the processing
- the categories of personal data that are processed
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
- if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
- the existence of a right to rectification or erasure of personal data concerning him or her or to restriction of processing by the controller or a right to object to such processing
- the existence of a right of appeal to a supervisory authority
- if the personal data are not collected from the data subject: All available information on the origin of the data
- the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) GDPR and — at least in these cases — meaningful information about the logic involved and the scope and intended effects of such processing for the data subject
Furthermore, the data subject has a right to information as to whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to be informed of the appropriate guarantees in connection with the transfer.
If a data subject wishes to exercise this right to information, he or she may, at any time, contact an employee of the controller.
c) Right to rectification
Each data subject affected by the processing of personal data has the right granted by the European legislator to demand the immediate rectification of inaccurate personal data concerning him or her. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact an employee of the controller.
d) Right to erasure (right to be forgotten)
Each data subject affected by the processing of personal data has the right granted by the European legislator to demand from the controller that the personal data concerning him or her be erased immediately, provided that one of the following reasons applies and insofar as the processing is not necessary:
- The personal data have been collected or otherwise processed for such purposes for which they are no longer necessary.
- The data subject withdraws his or her consent on which the processing was based pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
- The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
- The personal data have been processed unlawfully.
- The erasure of the personal data is necessary to fulfil a legal obligation under Union law or the law of the member states to which the controller is subject.
- The personal data were collected in relation to services offered by the information society pursuant to Art. 8(1) GDPR.
If one of the above-mentioned reasons applies and a data subject wishes to have personal data stored at ESPRIX Excellence Suisse erased, he or she may, at any time, contact an employee of the controller. The employee of ESPRIX Excellence Suisse will arrange for the erasure request to be complied with immediately.
If the personal data have been made public by ESPRIX Excellence Suisse and our company, as the controller, is obliged to erase the personal data pursuant to Art. 17(1) GDPR, ESPRIX Excellence Suisse shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data controllers who process the published personal data that the data subject has requested from these other data controllers the erasure of all links to these personal data or of copies or replications of these personal data, insofar as the processing is not necessary. The employee of ESPRIX Excellence Suisse will arrange what is necessary in individual cases.
e) Right to restriction of processing
Each data subject affected by the processing of personal data has the right granted by the European legislator to demand from the controller the restriction of processing if one of the following conditions is met:
- The accuracy of the personal data is disputed by the data subject, for a period that enables the controller to verify the accuracy of the personal data.
- The processing is unlawful, the data subject refuses the erasure of the personal data and instead demands the restriction of the use of the personal data.
- The controller no longer needs the personal data for the purposes of the processing, but the data subject needs them for the assertion, exercise or defence of legal claims.
- The data subject has objected to the processing pursuant to Art. 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override those of the data subject.
If one of the above-mentioned conditions is met and a data subject wishes to request the restriction of personal data stored at ESPRIX Excellence Suisse, he or she may, at any time, contact an employee of the controller. The employee of ESPRIX Excellence Suisse will arrange for the restriction of processing.
f) Right to data portability
Each data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning him or her which have been provided to a controller by the data subject in a structured, commonly used and machine-readable format. He or she also has the right to transfer this data to another controller without hindrance from the controller to whom the personal data have been provided, provided that the processing is based on the consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out by means of automated procedures, unless the processing is 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 Art. 20(1) GDPR, the data subject has the right to have the personal data transferred directly from one controller to another, insofar as this is technically feasible and insofar as this does not adversely affect the rights and freedoms of other persons.
To assert the right to data portability, the data subject may, at any time, contact an employee of ESPRIX Excellence Suisse.
g) Right to object
Each data subject affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time to the processing of personal data concerning him or her which is carried out on the basis of Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.
In the event of an objection, ESPRIX Excellence Suisse will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.
If ESPRIX Excellence Suisse processes personal data for the purpose of direct marketing, the data subject has the right to object at any time to the processing of personal data for the purpose of such marketing. This also applies to profiling, insofar as it is related to such direct marketing. If the data subject objects to ESPRIX Excellence Suisse to the processing for direct marketing purposes, ESPRIX Excellence Suisse will no longer process the personal data for these purposes.
In addition, the data subject has the right to object, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is carried out at ESPRIX Excellence Suisse for scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.
To exercise the right to object, the data subject may contact any employee of ESPRIX Excellence Suisse directly or another employee. The data subject is also free, in connection with the use of information society services, notwithstanding Directive 2002/58/EC, to exercise his or her right to object by means of automated procedures using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject affected by the processing of personal data has 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, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorised by Union or member state law to which the controller is subject and such law contains appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is based on the data subject’s explicit consent.
If the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller or (2) is based on the data subject’s explicit consent, ESPRIX Excellence Suisse shall take reasonable measures to safeguard the rights and freedoms and legitimate interests of the data subject, which shall include at least the right to obtain the intervention of a person on the part of the controller, to state his or her own position and to contest the decision.
If the data subject wishes to assert rights relating to automated decisions, he or she may, at any time, contact an employee of the controller.
i) Right to withdraw consent under data protection law
Each data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.
If the data subject wishes to exercise his or her right to withdraw consent, he or she may, at any time, contact an employee of the controller.
11. Data protection regulations regarding the use and application of Adobe Analytics (Omniture) / Adobe Marketing Cloud
The controller has integrated components of the company Adobe on this website. Adobe Analytics (Omniture) or the Adobe Marketing Cloud (hereinafter referred to as “Omniture”) is a tool that enables more efficient online marketing and web analysis. Omniture is part of the Adobe Marketing Cloud. The Adobe Marketing Cloud enables real-time analysis of visitor flows on websites. The real-time analyses include project reports and allow ad hoc analysis of website visitors. Customer interactions are presented in such a way that the controller is given a better overview of the online activities of the users of this website by displaying the data in simple and interactive dashboards and converting it into reports. This enables the controller to obtain information in real time and thereby identify problems more quickly.
The operating company of these services is Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland.
Omniture places a cookie on the data subject’s information technology system (cookies have already been explained; the relevant information can be found above). The controller uses a server setting to ensure that the tracking data records transmitted to Adobe’s data center are anonymized before geolocalization. Anonymization is implemented by replacing the last part of the IP address. The controller has made server-side settings that anonymize the data subject’s IP address separately before each processing for geolocalization and reach measurement. On behalf of the controller, Adobe will use the data and information obtained via our website to evaluate the data subject’s user behavior. Furthermore, Adobe will use the data to create reports on user activities on our behalf and to provide other services to our company that are related to the use of our website. The data subject’s IP address will not be merged with other personal data by Adobe.
As described above, the data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Omniture from placing a cookie on the data subject’s information technology system. In addition, cookies already set by Omniture can be deleted at any time via an Internet browser or other software programs.
Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by the Adobe cookie relating to the use of this website and the processing of this data by Adobe. To do this, the data subject must press the opt-out button under the link http://www.adobe.com/de/privacy/opt-out.html, which sets an opt-out cookie. The opt-out cookie set with the objection is stored on the information technology system used by the data subject. If the cookies are deleted from the data subject’s system after an objection, the data subject must call up the link again and set a new opt-out cookie.
However, setting the opt-out cookie may mean that the controller’s websites can no longer be used in full by the data subject.
Adobe’s applicable data protection provisions can be found at http://www.adobe.com/de/privacy.html.
12. Legal basis of processing
Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, such as in cases of inquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as to fulfill tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third parties. Then the processing would be based on Art. 6 I lit. d GDPR.
Finally, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not outweigh them. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In that regard, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 GDPR).
13. Legitimate interests in the processing pursued by the controller or a third party
If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and our shareholders.
14. Duration for which the personal data are stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After the expiry of this period, the corresponding data will be routinely deleted, provided that they are no longer required for the fulfillment or initiation of the contract.
15. Legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision
We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner).
Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data that must then be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him. Failure to provide personal data would mean that the contract with the data subject could not be concluded.
Before the data subject provides personal data, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what consequences the non-provision of the personal data would have.
16. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
This data protection declaration was created by the data protection declaration generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as a data protection officer, in cooperation with the data protection lawyers of the law firm WILDE BEUGER SOLMECKE | Rechtsanwälte.