Data protection

1. Subject of this Privacy Policy

We appreciate your interest in our website and our offers on our websites.

The protection of your personal data (hereinafter referred to as “data”) is a great and very important concern for us. In the following, we would like to inform you in detail about which data was collected during your visit to our website and use of our local offers and how these are processed or used by us in the following, as well as which accompanying protective measures we have also taken in technical and organizational terms.


2. Responsible body / sercice provider

Responsible person according to Art. 4 EU-DSGVO and at the same time a service provider within the meaning of the Telemedia Act (TMG)

DM Dokumenten Management GmbH
Dornierstraße 4
D-82178 Puchheim
Telefon: +49 89 800613-0
Fax: +49 89 800613-99

The responsible persons are represented by the managing directors Mr. Harald Klingelhöller, Mr. Jens Hobbie and Mr. Andreas Hairer at the same time responsible according to § 55 of the Rundfunk-Staatsvertrag.

As Data Protection Officer is responsible

Mr. Ulrich Emmert, Attorney
esb Rechtsanwälte
AG Stuttgart, PR 720600
Schockenriedstr. 8A
D-70565 Stuttgart
Tel.: +49 711 469058-0
Fax: +49 711 469058-99


3. Collection and use of your data

We will collect, process and use all personal data that we receive from you during the use of our web pages only for the stated purpose. In doing so, we note that this only happens within the framework of the applicable legislation or only with your consent.

Please contact or send us your request by mail.

The data will be processed only within the EU and the European Economic Area, as far as not subsequently or directly in the data collection about a transmission in third countries under specification of the respective legal basis is informed and if necessary a consent is requested. The provisions on legal bases for international data transmission and the necessary conditions are available on request.

Automated individual decisions for the processing of personal data are made according to the following criteria: Place of residence, age.

The extent and nature of the collection and use of your data differs depending on whether you visit our website only for the retrieval of information or use services offered by us::


a) Informational use

For the purely informative use of our website, it is generally not necessary for you to provide personal data.

Rather, in this case, we only collect and use those of your data that your internet browser automatically transmits to us, such as:

  • Date and time of retrieval of one of our web pages
  • your browser type
  • the browser settings
  • the operating system used
  • the page you visited last
  • the transferred amount of data and the access status (file transfer, file not found etc.) as well as
  • your IP address.

The data is also stored in the log files of our system. A storage of this data together with other personal data of the user does not take place.

The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f DSGVO.

The temporary storage of the IP address by the system is necessary to allow delivery of the website to the computer of the user. To do this, the user’s IP address must be kept for the duration of the session.

Storage in log files is done to ensure the functionality of the website. In addition, the data is used to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

The data will be deleted as soon as it is no longer necessary to achieve the purpose of its collection. In the case of collecting the data for providing the website, this is the case when the respective session is completed.

In the case of storing the data in log files, this is the case after no more than seven days. An additional storage is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.

The collection of the data for the provision of the website and the storage of the data in log files is essential for the operation of the website. There is consequently no contradiction on the part of the user.

b) Use of offers

Insofar as you wish to make use of the services offered by us on our website or otherwise contacting us, it may be necessary for you to provide additional data. It concerns those data, which are necessary for the respective settlement in accordance with kind. 6 I b) DSGVO, otherwise we can not provide the desired achievement. Other offers may be included in Appendix 2.

Additional information can be provided voluntarily; Input fields with optional information are marked accordingly by us.

The collection or use of your data is for the purpose of providing the service you want. This includes e.g. also a request via our contact form.

If an indication of data is required by law, we will inform you about it.

If necessary, your data will be forwarded to service providers who support us and whom we have of course carefully selected and obliged to observe the EU General Data Protection Regulation.

The transfer of your data to other third parties is otherwise only if this is permitted by law or we have received your explicit consent.


4. Data protection consent

We may require your consent to the processing of your data in accordance with Art. 6 I a GDPR for the processing of your data. We assure that we process and use the data only for the purpose stated in the survey.

You can give your consent separately in connection with the respective data collection. You can subsequently revoke it at any time with effect for the future.

The consent to newsletters is governed by § 5, for cookies or advertising trackers § 6 of this statement below.


5. Newsletter

In order to be able to register for our e-mail newsletter service, in addition to your data protection consent pursuant to Art. 6 I a DSGVO, we need at least your e-mail address to which the newsletter is to be sent. Any other information is optional and will be used to address you personally and personalize the content of the newsletter and to clarify any questions regarding the email address. We use the data exclusively for sending the newsletter.

As a rule, we use the so-called double opt-in procedure for sending out newsletters. H. We will only send you the newsletter if you confirm your registration via a confirmation e-mail sent to you for this purpose using the link contained therein. We want to make sure that only you as the owner of the specified e-mail address can subscribe to the newsletter. Your confirmation in this regard must be made promptly after receipt of the confirmation e-mail, otherwise your newsletter subscription will be automatically deleted from our database.

If you purchase goods or services from us or use them free of charge and deposit your e-mail address here, this can subsequently be used by us for sending a newsletter. In such a case, the newsletter will only send direct mail for your own similar goods or services. The legal basis for sending the newsletter as a result of the sale of goods or services is § 7 Abs.3 UWG.

You can unsubscribe any newsletter you have ordered. You can either send us an informal e-mail to or cancel it using the link at the bottom of the newsletter.


6. Use of cookies

For our website we use the technology of cookies. Cookies are small text files that are sent from our web server to your browser as part of your visit to our website and are held by this on your computer for later retrieval. The purpose of using technically necessary cookies (session cookies) is to simplify the use of websites for users. Some features of our website can not be offered without the use of cookies.

The use of analysis cookies or web beacons (small graphics for log analysis) is for the purpose of improving the quality of our website and its contents as well as recognizing visitors. Through the analysis cookies we learn how the website is used and so we can constantly optimize our offer.

This information can be passed on to advertisers under the above conditions. The transferred data can not be merged with other data you have stored.

This information can also be passed on by advertising partners to their contractual partners under the above-mentioned conditions. The transferred data can not be merged with other data you have stored.

The advertising partners or the companies to which the advertising information is forwarded may also be located in countries outside the European Union and the European Economic Area (observing the DSGVO data transmission requirements under Articles 44-47, EU standard contractual clauses and / or the case of USA the EU US Privacy Shield).

Whether cookies can be set and retrieved can be determined by the settings in your browser. For example, you may disable your cookie altogether, restrict it to certain websites, or configure your browser to automatically notify you when a cookie is about to be placed and ask for your feedback. You can also delete cookies in your browser at any time. For technical reasons, however, it is necessary for the full functionality of our website to allow the aforementioned session cookies.

When using a login area on the home page, the account name is logged as far as the correctness of the password input is logged and the user is sent a session cookie that is deleted when the maximum session life (within a few hours) is logged out or expired.

If we allow a login service via a third-party provider to log in to a protected area, this is displayed to the user. In this case, the information specified by the provider by default or in the settings of the login provider is transmitted to us by the user, but at least the name, e-mail address and date of birth to fulfill the obligations stipulated in Art. 8 and 32 DSGVO.

In accordance with Art. 13 of the EU Data Protection Regulation, we will first obtain your consent for the use of cookies pursuant to Art. 6 I a DSGVO


7. Right to object

In accordance with Art. 21 EU-GDPR you can object to the processing of your data in the cases mentioned there. This applies in particular to the cases of processing which takes place on the basis of Art. 6 I e or Art. 6 I f or in the form of direct mail advertising or profiling.


8. Data security

We also use technical and organizational security measures to protect personal data arising or collected, in particular against accidental or intentional manipulation, loss, destruction or against the attack of unauthorized persons. Our security measures are continuously improved in line with technological developments.

We provide you with various online forms and services that you can use to send us personally identifiable information. These forms are protected against third party access through the use of TLS encryption. The data you enter or submit to us as a file may be stored by us and processed by agreement. If the use and processing requires the consent of the user or third parties, the consent can be withdrawn at any time without giving reasons. In this case, however, the contract performance may be affected by us.

Depending on the service, you may be asked to provide various inputs to identify or prevent abuse:

a) For the identification of the delivery of data, the entry of a user-defined identifier or other appropriate authentication may be required. The data shall be protected by SFTP or HTTPS against the knowledge of third parties in accordance with Art. 32 I a and b DSGVO, provided that the user uses the methods of data transmission recommended by us.

b) To prevent the use of machines, so-called CAPTCHAS can be used according to Art. 32 I b DSGVO, which contain images or tasks that can not be processed by computer scripts.


9. Deletion periods

We store personal data only as long as the purpose of data storage is eliminated. This does not apply if the user has voluntarily consented to a longer processing of the data or legal storage periods or the possible prosecution of legal claims within unexpired limitation periods against the deletion (in the case of conflicting retention or limitation periods, it may be necessary that the Processing of data according to Art. 18 EU-GDPR).


10. Affected rights

Under applicable law, you have various rights to your personal information. If you would like to assert these rights, please send your request by e-mail or by post with a clear identification of your person to the address specified in section 2.

Below is an overview of your rights.

a) Right to confirmation and information

You have the right at any time to obtain confirmation from us as to whether personal data relating to you are being processed. If this is the case, you have the right to obtain free information from us about the personal data you have stored together with a copy of this data. Furthermore, there is a right to the following information:

1.     the processing purposes;

2.     the categories of personal data being processed;

3.     the recipients or categories of recipients to whom the personal data have been or are being disclosed, in particular in the case of beneficiaries in third countries or international organizations;

4.     if possible, the planned duration for which the personal data are stored or, if this is not possible, the criteria for determining that duration;

5.     the existence of a right to rectification or erasure of personal data concerning you or to restriction of processing by the controller or a right to object to such processing;

6.     the existence of a right of appeal to a supervisory authority;

7.     if the personal information is not collected from you, all available information about the source of the data;

  1. The existence of automated decision-making, including profiling, in accordance with Article 22 (1) and (4) GDPR and, at least in these cases, meaningful information about the logic involved and the implications and consequences of such processing for you..

If personal data are transmitted to a third country or to an international organization, you have the right to be informed about the appropriate safeguards under Article 46 of the GDPR in connection with the transfer.

b) Right to rectification

You have the right to demand immediate correction of incorrect personal data concerning you. Taking into account the purposes, you have the right to request the completion of incomplete personal data, including by means of a supplementary statement.

c) Right to be deleted („Right to be forgotten“)

You have the right to ask us to delete your personal information without delay and we are required to delete your personal information immediately if any of the following is true:

  1. Personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
  2. They withdraw their consent, on which the processing was based on Article 6 (1) GDPR (a) or Article 9 (2) (a) GDPR, and lack any other legal basis for the processing.
  3. It object to the processing in accordance with Article 21 (1) of the GDPR and there are no high-level legitimate grounds for processing, or you object to the processing in accordance with Article 21 (2) GDPR.
  4. The personal data were processed unlawfully.
  5. The deletion of personal data is required to fulfill a legal obligation under Union or national law to which we are subject.
  6. The personal data were collected in relation to information society services offered pursuant to Article 8 (1) of the GDPR.

The right to erasure does not exist if the processing is necessary

  1. to exercise the right to freedom of expression and information;
  2. to fulfill a legal obligation required by the law of the Union or of the Member States to which the controller is subject, or to carry out a task which is in the public interest or in the exercise of official authority delegated to the controller;
  3. For reasons of public interest in the field of public health pursuant to Art. 9 (2) lit. h and i and Art. 9 (3) GDPR;
  4. for archival purposes in the public interest, scientific or historical research purposes or for statistical purposes acc. Article 89 (1) GDPR, to the extent that the law referred to in subparagraph (a) is likely to render impossible or seriously affect the achievement of the objectives of that processing, or
  5. to assert, exercise or defend legal claims.

If we have made the personal data public and if we are obliged to delete it in accordance with Art. 17 GDPR, we take appropriate measures, including technical ones, to inform data controllers who process the personal data, taking into account the available technology and implementation costs. to inform you that you have requested that you delete any links to such personal information or copies or replications of such personal information.

d) Right to restriction of processing

You have the right to ask us to restrict processing if one of the following conditions is met:

  1. The accuracy of your personal information is contested by you for a period of time that enables us to verify the accuracy of your personal information,
  2. the processing is unlawful and you refuse to delete the personal data and instead request the restriction of the use of the personal data;
  3. We no longer need personal information for the purposes of processing, but you need the information to assert, exercise or defend your rights, or
  4. If you have objected to the processing in accordance with Article 21 (1) GDPR, as long as it is not certain that the legitimate reasons of our company outweigh yours.

If the processing of personal data concerning you has been restricted, this data may only be used with your consent or for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person or for reasons of important public interest Union or a Member State.

e) Right to data portability

You have the right to receive the personal information you have provided to us in a structured, common and machine-readable format, and you have the right to transfer that information to another person without hindrance, provided that

  1. the processing is based on a consent pursuant to Article 6 (1) (a) GDPR or Article 9 (2) (a) GDPR or a contract pursuant to Article 6 (1) (b) GDPR; and
  2. the processing is done using automated procedures.

In exercising your right to data portability in accordance with paragraph 1, you have the right to obtain that the personal data are transmitted directly by us to another party, as far as technically feasible.

The right to data portability does not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority delegated to the controller.

f) Right of objection

You have the right, for reasons of your own particular situation, to object at any time to the processing of personal data relating to you pursuant to Article 6 (1) (e) or (f) of the GDPR; this also applies to profiling based on these provisions. We no longer process personal information unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing is for the purposes of asserting, exercising or defending legal claims.

If personal data are processed by us in order to operate direct mail, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct mail.

You have the right, for reasons of your own particular situation, to object to the processing of personal data concerning you for scientific or historical research purposes or for statistical purposes under Article 89 (1) of the GDPR, unless: , processing is necessary to fulfill a public interest task.

g) Automated decisions including profiling

You have the right not to be subjected to a decision based solely on automated processing – including profiling – that will have legal effect or similarly affect you in a similar manner.

h) Right to revoke a data protection consent

You have the right to revoke your consent to the processing of personal data at any time.

i) Right to complain to a supervisory authority

You have the right to complain to a supervisory authority, in particular in your Member State of residence, employment or the place of alleged infringement, that you believe that the processing of your personal data is unlawful.

j) Right to information

If you have the right of rectification, erasure or restriction of the processing to the controller, he / she is obliged to notify all recipients to whom the personal data concerning you have been corrected or deleted or processing restricted, unless: this proves to be impossible or involves a disproportionate effort.

You have the right to be informed about these recipients.



Copyright 2018, DM Dokumenten Management GmbH