Privacy Policy
Data protection is of particularly high importance to us. The use of our website is generally possible without providing any personal data. However, if a data subject wishes to use special services offered through our website, processing of personal data might become necessary. If processing of personal data is required and there is no legal basis for such processing, we generally obtain the data subject’s consent.
The processing of personal data—for example, a name, address, email address or telephone number—is always done in accordance with the General Data Protection Regulation (GDPR) and in compliance with applicable national data protection regulations. With this privacy policy, we inform the public about the nature, scope and purpose of the personal data we collect, use and process. We also inform data subjects of the rights to which they are entitled.
As the controller responsible for processing, we have implemented numerous technical and organizational measures to ensure the most complete protection possible of personal data processed through this website. However, internet-based data transmissions can generally exhibit security vulnerabilities, so absolute protection cannot be guaranteed. Therefore, every data subject is free to transmit personal data to us via alternative means, such as by telephone.
1. Definitions
Our privacy policy is based on the terms used by the European legislator when drafting the GDPR. Our privacy policy should be easily understandable for the public as well as our customers and business partners. To ensure this, we would like to first explain the terms used.
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 (“data subject”). A person is considered identifiable if they can be identified, directly or indirectly—particularly by reference to an identifier such as name, identification number, location data, online identifier, or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.
b) Data subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller.
c) Processing
Processing means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making data available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is marking stored personal data with the aim of restricting their future processing.
e) Profiling
Profiling means any form of automated processing of personal data to evaluate certain personal aspects related to a natural person, particularly to analyze or predict performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
f) Pseudonymization
Pseudonymization means processing personal data in such a way that it can no longer be attributed to a specific data subject without the use of additional information, provided that such information is kept separately and subject to technical and organizational measures preventing re-identification.
g) Controller or data controller
The controller is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing personal data. If the purposes and means of processing are determined by Union or Member State law, the controller or the specific criteria for their appointment may be prescribed 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 other body to whom 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 are not regarded as recipients under Union law.
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 authorized 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 they signify agreement to the processing of personal data relating to them, by statement or clear affirmative action.
2. Name and Address of the Controller
Controller within the meaning of the GDPR, other applicable data protection laws in Member States, and other data protection provisions is:
Dali Project Management GmbH
Darya Ali
Robert‑Bosch‑Straße 8
40789 Monheim
Phone: +49 (0)176 / 219 49 803
Email: info@dali-project.com
3. Collection of General Data and Information
Our website collects a range of general data and information with each access by a data subject or automated system. This general data and information is stored in the server’s log files. Collected may be: (1) browser types and versions used, (2) operating system used by the accessing system, (3) the website from which an accessing system reached our site (so-called referrer), (4) sub‑websites accessed on our site, (5) date and time of access, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information used for defense in case of attacks on our IT systems.
We do not draw conclusions about the data subject from this general data. This information is needed to (1) correctly deliver the contents of our internet offering, (2) optimize the content of our website and its advertising, (3) ensure the ongoing functionality of our IT systems and web technology, and (4) provide law enforcement authorities with necessary information in the event of a cyberattack. This anonymized data and information is analyzed by us statistically and additionally with the aim of increasing data protection and data security within our company to ensure the optimal level of protection for the personal data we process. The anonymized data in the server log files is kept separately from all personal data provided by a data subject.
4. Contact Options via the Website
Our website contains information enabling fast electronic contact to our company and immediate communication with us, including a general electronic mail address (email address), as required by law. If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically saved. Such voluntarily provided personal data is stored to process or contact the data subject. There is no disclosure of this personal data to third parties.
5. Routine Erasure and Blocking of Personal Data
The controller processes and stores personal data of the data subject only for the period necessary to achieve the storage purpose or required by the European legislator or another legislator to which the controller is subject by law.
Once the storage purpose ceases or a storage period prescribed by the European legislator expires, the personal data is routinely blocked or erased in accordance with legal requirements.
6. Rights of the Data Subject
a) Right to Confirmation
Every data subject has the right to obtain confirmation from the controller regarding whether personal data concerning them is being processed. If a data subject wishes to exercise this right, they can contact a controller employee at any time.
b) Right to Access
Every data subject whose personal data is being processed has the right granted by the European legislator to obtain free access to their stored personal data and a copy thereof at any time. Furthermore, the European legislator has granted the data subject access to the following information:
- the purposes of processing
- the categories of personal data processed
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, including recipients in third countries or international organizations
- where possible, the planned duration of storage of the personal data, or, if not possible, the criteria used to determine that period
- the existence of a right to rectification or erasure of personal data or restriction of processing by the controller or to object to such processing
- the right to lodge a complaint with a supervisory authority
- if the personal data is not collected from the data subject – any available information as to its source
- the existence of automated decision-making, including profiling under Article 22(1) and (4) GDPR, and in such cases meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject
- the right to know whether personal data has been transferred to a third country or international organization and, if so, to receive information on appropriate safeguards in this context.
If a data subject wishes to exercise this right, they can contact a controller employee at any time.
c) Right to Rectification
Any person affected by the processing of personal data has the right granted by the European legislator to request the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data — including by means of a supplementary statement — taking into account the purposes of the processing.
If a data subject wishes to exercise this right to rectification, they may contact an employee of the controller at any time.
d) Right to Erasure (Right to be Forgotten)
Any person affected by the processing of personal data has the right granted by the European legislator to request the controller to erase personal data concerning them without undue delay, provided one of the following reasons applies and the processing is not necessary:
- The personal data were collected or otherwise processed for purposes that are no longer necessary.
- The data subject withdraws their consent on which the processing was based according 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 pursuant to Art. 21(2) GDPR.
- The personal data have been unlawfully processed.
- The deletion of the personal data is necessary to comply with a legal obligation under Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.
If one of the above reasons applies and a data subject wishes to request the erasure of personal data stored by us, they may contact an employee of the controller at any time. We will ensure that the request for deletion is complied with immediately.
If the personal data have been made public by us and we are obligated as the controller under Art. 17(1) GDPR to erase the personal data, we shall take reasonable steps, including technical measures, considering available technology and implementation costs, to inform other controllers processing the published personal data that the data subject has requested the erasure of any links to these personal data, or copies or replications thereof, as far as processing is not required. Our employee will arrange what is necessary in individual cases.
e) Right to Restriction of Processing
Any person affected by the processing of personal data has the right granted by the European legislator to request the restriction of processing from the controller if one of the following conditions is met:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of processing, but the data subject requires them for the establishment, exercise, or defense of legal claims.
- The data subject has objected to 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 conditions is met and a data subject wishes to request the restriction of personal data stored by us, they may contact an employee of the controller at any time. Our employee will arrange the restriction of processing.
f) Right to Data Portability
Any person affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which was provided to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on 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 automated means, provided the processing is not 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 their right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that it does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may contact an employee of our organization at any time.
g) Right to Object
Any person affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them based on Art. 6(1)(e) or (f) GDPR, including profiling based on those provisions.
We will no longer process the personal data in the event of an objection 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 the establishment, exercise, or defense of legal claims.
If we process personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing, including profiling related to such direct marketing. If the data subject objects to processing for direct marketing purposes, we will no longer process the personal data for these purposes.
The data subject also has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them for scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the data subject may contact any of our employees directly. The data subject is also free to exercise their right to object in the context of the use of information society services, notwithstanding Directive 2002/58/EC, by automated means using technical specifications.
h) Automated Decisions in Individual Cases Including Profiling
Any person 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 them or similarly significantly affects them, as long as the decision (1) is not necessary for entering into or the performance of a contract between the data subject and a controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into or the performance of a contract between the data subject and a controller, or (2) is based on the data subject’s explicit consent, we will take appropriate measures to safeguard the data subject’s rights and freedoms and legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.
If the data subject wishes to assert rights concerning automated decisions, they may contact an employee of the controller at any time.
i) Right to Withdraw Data Protection Consent
Any person 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 the right to withdraw consent, they may contact an employee of the controller at any time.
7. Legal Basis for Processing
Art. 6(1)(a) GDPR serves as the legal basis for processing operations for 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 (e.g., processing required for the delivery of goods or services), the processing is based on Art. 6(1)(b) GDPR. The same applies to processing operations necessary to carry out pre-contractual measures, such as inquiries about our products or services. If our company is subject to a legal obligation requiring the processing of personal data (e.g., tax obligations), the processing is based on Art. 6(1)(c) GDPR. In rare cases, processing might be necessary to protect the vital interests of the data subject or another natural person (e.g., if a visitor is injured and personal data must be passed on to medical personnel). Then, processing would be based on Art. 6(1)(d) GDPR. Finally, processing could be based on Art. 6(1)(f) GDPR if it is necessary for the purposes of a legitimate interest pursued by our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject do not override such interests. The European legislator has considered that a legitimate interest may exist if the data subject is a customer of the controller (Recital 47 sentence 2 GDPR).
8. Legitimate Interests Pursued by the Controller or a Third Party
If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the performance of our business activities in favor of the well-being of all our employees and shareholders.
9. 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 expiration of that period, the relevant data are routinely deleted, provided they are no longer required for contract fulfillment or contract initiation.
10. Statutory or Contractual Requirements to Provide the 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 inform you that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual obligations (e.g., information about the contractual partner). Sometimes it may be necessary to provide us with personal data to conclude a contract, which we must then process. For example, the data subject is obligated to provide us with personal data when our company concludes a contract with them. Failure to provide the personal data would mean that the contract could not be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will clarify on a case-by-case basis whether the provision of the personal data is legally or contractually required, or necessary for the conclusion of the contract, and whether there is an obligation to provide the personal data and what the consequences of non-provision would be.
11. Existence of Automated Decision-Making
As a responsible company, we do not use automatic decision-making or profiling.
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