Data Protection from Krüger Sicherheit

Preamble

With the following privacy policy, we would like to inform you about the types of personal data (hereinafter also referred to as "data") we process, the purposes for which we process them, and the extent of such processing. This privacy policy applies to all processing of personal data carried out by us, both in the course of providing our services and especially on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online services").

The terms used are not gender-specific.

As of: January 21, 2025

Table of Contents

• Preamble
• Controller
• Overview of Processing
• Relevant Legal Basis
• Security Measures
• Transmission of Personal Data
• General Information on Data Storage and Deletion
• Rights of the Data Subject
• Provision of Online Services and Web Hosting
• Use of Cookies
• Contact and Inquiry Management
• Newsletter and Electronic Notifications
• Presences on Social Networks (Social Media)
• Changes and Updates

Controller

Owner: Andreas Krüger
Krüger Sicherheit+ Service e.K.
Bavariafilmplatz 7
D - 82031 Grünwald

Authorized representatives: Andreas Krüger

Email address: andreas_krueger_2006@yahoo.de

Imprint: https://www.krueger-sicherheit.de/impressum.html

Overview of Processing

The following overview summarizes the types of data processed and the purposes of their processing, referring to the affected individuals.

Types of Processed Data

• Inventory data.
• Contact data.
• Content data.
• Usage data.
• Meta, communication, and procedural data.
• Log data.

Categories of Affected Individuals

• Communication partners.
• Users.

Purposes of Processing

• Communication.
• Security measures.
• Direct marketing.
• Organizational and administrative procedures.
• Feedback.
• Provision of our online services and user-friendliness.
• IT infrastructure.
• Public relations.

Relevant Legal Grounds

Relevant Legal Grounds under the GDPR: Below is an overview of the legal grounds of the GDPR on which we base the processing of personal data. Please note that, in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence or establishment may apply. Furthermore, if more specific legal grounds are applicable in individual cases, we will inform you of these in the privacy policy.

• Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given their consent to the processing of personal data concerning them for one or more specific purposes.
• Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party, or for the performance of pre-contractual measures at the request of the data subject.
• Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - The processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party, provided that the interests, fundamental rights, and freedoms of the data subject, which require protection of personal data, do not override those interests.

National Data Protection Regulations in Germany: In addition to the data protection provisions of the GDPR, national data protection regulations in Germany apply. This includes, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains specific provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes, and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of individual federal states may apply.

Note on the Applicability of the GDPR and Swiss DPA: This privacy notice serves both to inform under the Swiss Data Protection Act (DSG) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that, due to the broader geographical applicability and clarity, the terms used in the GDPR are applied. In particular, instead of the terms "processing" of "personal data", "overriding interest", and "particularly sensitive personal data" used in the Swiss DPA, the terms used in the GDPR such as "processing" of "personal data", "legitimate interest", and "special categories of data" are used. However, the legal meaning of these terms will continue to be determined under the Swiss DPA within its applicability.

Security Measures

In accordance with legal requirements, we take appropriate technical and organizational measures, considering the state of the art, implementation costs, and the nature, scope, circumstances, and purposes of processing, as well as the varying likelihoods and extents of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection commensurate with the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling both physical and electronic access to the data, as well as its input, transmission, storage, availability, and separation. Furthermore, we have established procedures to ensure the exercise of data subject rights, data deletion, and responses to data security risks. Additionally, we consider data protection during the development or selection of hardware, software, and procedures according to the principle of data protection by design and by default.

Securing online connections through TLS/SSL encryption technology (HTTPS): To protect user data transmitted through our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is securely and encryptedly transmitted.

Transmission of Personal Data

As part of our processing of personal data, it may be necessary to transmit or disclose these data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, service providers engaged with IT tasks or providers of services and content integrated into a website. In such cases, we observe the legal requirements and, in particular, enter into appropriate contracts or agreements with the recipients of your data to protect your data.

**Data Transmission within the Organization:** We may transmit personal data to other departments or units within our organization or grant them access to it. If the data transfer is for administrative purposes, it is based on our legitimate business interests or is carried out when required to fulfill our contractual obligations, or if consent from the data subject or legal permission is obtained.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal requirements as soon as the underlying consents are revoked or no further legal grounds for processing exist. This applies in cases where the original purpose of processing no longer applies or the data is no longer needed. Exceptions to this rule apply if legal obligations or special interests require a longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax purposes or whose storage is necessary for legal prosecution or the protection of the rights of other natural or legal persons must be archived accordingly.

Our privacy policy contains additional information on the retention and deletion of data that specifically applies to certain processing activities.

In case of multiple retention periods or deletion deadlines for a particular data, the longest period is applicable.

**If a period does not explicitly start on a specific date and lasts at least one year, it automatically begins at the end of the calendar year in which the event triggering the period occurred.** In the case of ongoing contractual relationships, during which data is stored, the event triggering the period is the effective date of termination or other end of the legal relationship.

Data that is no longer required for its original purpose but is retained due to legal requirements or other reasons will only be processed for the reasons justifying its retention.

Further Information on Processing Activities, Procedures, and Services:

• Retention and Deletion of Data: The following general periods apply for data retention and archiving under German law:
  • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, and the necessary work instructions and other organizational documents required for understanding them (§ 147 Abs. 1 Nr. 1 in conjunction with Abs. 3 AO, § 14b Abs. 1 UStG, § 257 Abs. 1 Nr. 1 in conjunction with Abs. 4 HGB).
  • 8 years – Booking records, such as invoices and cost receipts (§ 147 Abs. 1 Nr. 4 and 4a in conjunction with Abs. 3 Satz 1 AO, as well as § 257 Abs. 1 Nr. 4 in conjunction with Abs. 4 HGB).
  • 6 years – Other business documents: received trade or business letters, copies of sent trade or business letters, other documents that are relevant for tax purposes, e.g., hourly wage slips, operating accounting sheets, calculation documents, price labels, but also payroll documents, provided they are not already booking records, and cash receipts (§ 147 Abs. 1 Nr. 2, 3, 5 in conjunction with Abs. 3 AO, § 257 Abs. 1 Nr. 2 & 3 in conjunction with Abs. 4 HGB).
  • 3 years – Data necessary to consider potential warranty and compensation claims or similar contractual claims and rights, as well as related inquiries, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of Data Subjects

Rights of data subjects under the GDPR: As data subjects, you have various rights under the GDPR, which are primarily derived from Articles 15 to 21 of the GDPR:

• Right to Object: You have the right to object at any time, for reasons arising from your particular situation, to the processing of your personal data based on Article 6(1)(e) or (f) of the GDPR; this includes profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing purposes; this also applies to profiling, insofar as it is related to such direct marketing.
• Right to Withdraw Consent: You have the right to withdraw any consent you have given at any time.
• Right to Information: You have the right to request confirmation as to whether personal data concerning you is being processed and, if so, to obtain information about these data and further information, including a copy of the data, in accordance with legal requirements.
• Right to Rectification: You have the right to request the completion of incomplete data concerning you or the correction of inaccurate data, in accordance with legal requirements.
• Right to Deletion and Restriction of Processing: You have the right to request the immediate deletion of personal data concerning you, or alternatively, to request the restriction of processing in accordance with legal requirements.
• Right to Data Portability: You have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, or to request its transmission to another data controller, in accordance with legal requirements.
• Complaint to a Supervisory Authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, your place of work, or the place of the alleged infringement, if you believe that the processing of personal data concerning you infringes the GDPR.

Provision of the Online Service and Web Hosting

We process user data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and features of our online services to the user's browser or device.

• Types of Processed Data: Usage data (e.g., page views and time spent, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and features); Meta-, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved parties); Log data (e.g., log files regarding logins, data retrieval, or access times). Content data (e.g., textual or visual messages and posts, as well as related information such as author details or creation time).
• Data Subjects: Users (e.g., website visitors, online service users).
• Purposes of Processing: Provision of our online service and user-friendliness; IT infrastructure (operation and provision of information systems and technical devices such as computers, servers, etc.); Security measures.
• Retention and Deletion: Deletion in accordance with the information provided in the section "General Information on Data Retention and Deletion."
• Legal Grounds: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).

Further Information on Processing Activities, Procedures, and Services:

• Collection of Access Data and Log Files: Access to our online services is logged in the form of "server log files." Server log files may include the address and name of retrieved websites and files, the date and time of the retrieval, transferred data volumes, success messages for the retrieval, the browser type and version, the user's operating system, the referrer URL (the previously visited page), and typically IP addresses and the requesting provider. Server log files can be used for security purposes, e.g., to prevent server overloads (especially in the case of malicious attacks like DDoS attacks), and to ensure the server load and stability; Legal Grounds: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR). Data Deletion: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that is necessary to be retained for evidence purposes will not be deleted until the incident has been fully clarified.
• Email Sending and Hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the email addresses of recipients and senders, as well as additional information related to email transmission (e.g., the involved providers), and the contents of the emails are processed. The aforementioned data may also be processed to detect spam. Please note that emails are generally not encrypted when sent over the internet. Typically, emails are encrypted during transmission, but (unless end-to-end encryption is used) they are not encrypted on the servers from which they are sent and received. We cannot take responsibility for the transmission path of emails between the sender and our server; Legal Grounds: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).
• Checkdomain: Services in the field of information technology infrastructure provision and related services (e.g., storage space and/or computing power); Service Provider: checkdomain GmbH, a dogado group company, Große Burgstraße 27/29, 23552 Lübeck, Germany; Legal Grounds: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR); Website: https://www.checkdomain.de/; Privacy Policy: https://www.checkdomain.de/agb/datenschutz/. Processing Agreement: Provided by the service provider.

Use of Cookies

The term "cookies" refers to features that store and read information on the user's devices. Cookies can be used for various purposes, such as ensuring the functionality, security, and comfort of online services, as well as for generating analyses of visitor traffic. We use cookies in accordance with legal regulations. Where required, we obtain the user's consent in advance. If consent is not necessary, we rely on our legitimate interests. This applies when storing and reading information is essential to provide explicitly requested content and features, such as saving settings and ensuring the functionality and security of our online service. Consent can be revoked at any time. We clearly inform about the scope and which cookies are used.

Notes on Data Protection Legal Grounds: Whether we process personal data using cookies depends on obtaining consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the relevant services and procedures.

Retention Period: The following types of cookies are distinguished based on their retention period:

• Temporary Cookies (also: Session or Session Cookies): Temporary cookies are deleted as soon as a user leaves an online service and closes their device (e.g., browser or mobile app).
• Permanent Cookies: Permanent cookies remain stored even after the device is closed. For example, they can store the login status and display preferred content when the user revisits a website. Additionally, user data collected via cookies may be used for measuring reach. If we do not provide explicit information on the type and retention period of cookies (e.g., when obtaining consent), users should assume that they are permanent and the retention period can last up to two years.

General Notes on Withdrawal and Objection (Opt-out): Users can revoke their consents at any time and also lodge an objection to processing in accordance with legal regulations, including through the privacy settings of their browser.

• Processed Data Types: Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved parties).
• Data Subjects: Users (e.g., website visitors, online service users).
• Legal Grounds: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR). Consent (Art. 6(1) sentence 1 lit. a) GDPR).

Further Information on Processing Activities, Procedures, and Services:

• Processing of Cookie Data Based on Consent: We use a consent management solution where the user's consent for the use of cookies or the procedures and providers mentioned within the consent management solution is obtained. This procedure serves the purpose of collecting, recording, managing, and revoking consents, particularly concerning the use of cookies and similar technologies that store, read, and process information on the user's devices. As part of this process, user consents for the use of cookies and related information processing are obtained, including the specific processes and providers mentioned in the consent management procedure. Users also have the option to manage and revoke their consents. Consent statements are stored to avoid repeated queries and to provide proof of consent according to legal requirements. The data is stored server-side and/or in a cookie (the so-called opt-in cookie) or using similar technologies to associate the consent with a specific user or device. If no specific information on the providers of consent management services is available, the following general information applies: The consent storage duration is up to two years. A pseudonymous user identifier is created and stored along with the consent time, details of the consent scope (e.g., categories of cookies and/or service providers), and information about the browser, system, and device used; Legal Grounds: Consent (Art. 6(1) sentence 1 lit. a) GDPR).

Contact and Inquiry Management

When contacting us (e.g., by post, contact form, email, phone, or via social media) and in the context of existing user and business relationships, the information provided by the inquiring parties will be processed as necessary to respond to contact inquiries and any requested actions.

• Processed Data Types: Master data (e.g., full name, home address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers); Content data (e.g., textual or visual messages and posts, including information such as authorship or creation time); Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved parties).
• Data Subjects: Communication partners.
• Purposes of Processing: Communication; Organizational and administrative procedures; Feedback (e.g., collecting feedback via online forms); Provision of our online services and user-friendliness.
• Retention and Deletion: Deletion in accordance with the details in the section "General Information on Data Retention and Deletion".
• Legal Grounds: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR); Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b) GDPR).

Further Information on Processing Activities, Procedures, and Services:

• Contact Form: When contacting us via our contact form, email, or other communication methods, we process the personal data provided to us to answer and process the respective request. This typically includes information such as name, contact details, and any other information provided to us that is necessary for the appropriate handling of the request. We use this data exclusively for the stated purpose of communication and contact; Legal Grounds: Performance of a contract and pre-contractual inquiries (Art. 6(1) sentence 1 lit. b) GDPR), Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).

Newsletter and Electronic Notifications

We send newsletters, emails, and other electronic notifications (hereafter referred to as "newsletters") exclusively with the consent of the recipients or based on a legal basis. If the contents of the newsletter are specified during registration, those contents are essential for obtaining the user's consent. Usually, providing your email address is sufficient to register for our newsletter. However, to offer you a personalized service, we may request your name for a personal greeting in the newsletter or additional information if required for the purpose of the newsletter.

Deletion and Restriction of Processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to be able to prove previously given consent. The processing of these data will be limited to the purpose of potentially defending against claims. A specific deletion request is possible at any time, provided that the prior existence of consent is confirmed. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blacklist (so-called "blocklist").

Logging the registration process is based on our legitimate interests for the purpose of proving its proper procedure. If we appoint a service provider for the sending of emails, this will be based on our legitimate interests in an efficient and secure email delivery system.

Contents:

Information about us, our services, promotions, and offers.

• Processed Data Types: Master data (e.g., full name, home address, contact information, customer number, etc.); Contact data (e.g., postal and email addresses or phone numbers); Meta-, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved parties). Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
• Data Subjects: Communication partners.
• Purposes of Processing: Direct marketing (e.g., via email or post).
• Legal Grounds: Consent (Art. 6(1) sentence 1 lit. a) GDPR).
• Right to Object (Opt-Out): You can unsubscribe from our newsletter at any time, i.e., withdraw your consent or object to further receipt. A link to unsubscribe from the newsletter can be found at the end of each newsletter or you can use one of the contact methods above, preferably email, to do so.

Further Information on Processing Activities, Procedures, and Services:

• Measurement of Open and Click Rates: The newsletters contain a so-called "web beacon," i.e., a pixel-sized file that is retrieved from our server (or the server of a mailing service provider, if we use one) when the newsletter is opened. During this retrieval, technical information such as details about the browser and your system, as well as your IP address and the time of retrieval, are collected. This information is used to technically improve our newsletters based on the technical data or the audience and their reading behavior, determined from their retrieval locations (which can be identified by the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deletion. The evaluations are used to recognize the reading habits of our users and adapt our content to them or send different content based on the users' interests. The measurement of open and click rates, as well as the storage of the measurement results in user profiles, - This section must be unlocked with a premium license. - premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext premiumtext ; Legal Grounds: Consent (Art. 6(1) sentence 1 lit. a) GDPR).

Presences on Social Media

We maintain online presences within social networks and process user data in this context to communicate with active users or provide information about us.

We would like to point out that user data may be processed outside the European Union. This may pose risks to users, as enforcing user rights could be more difficult.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, usage behavior and resulting user interests can be used to create user profiles. These profiles may be used to display advertisements within and outside the networks that are presumed to match the users' interests. Cookies are usually stored on users' devices to store usage behavior and user interests. Additionally, data may be stored in the user profiles, regardless of the devices used by the users (especially if they are members of the respective platforms and are logged in there).

For a detailed presentation of the respective processing forms and options for objection (opt-out), please refer to the privacy policies and statements of the operators of the respective networks.

In case of information requests and the assertion of rights of data subjects, we would like to point out that these can most effectively be made to the providers. Only they have access to the user data and can take direct actions and provide information. However, if you need assistance, you can contact us.

• Processed Data Types: Contact data (e.g., postal and email addresses or phone numbers); Content data (e.g., textual or visual messages and posts, and information related to them, such as authorship or creation time). Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
• Affected Persons: Users (e.g., website visitors, online service users).
• Purposes of Processing: Communication; Feedback (e.g., collecting feedback via online form). Public relations.
• Retention and Deletion: Deletion according to the details in the section "General Information on Data Retention and Deletion."
• Legal Grounds: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR).

Further Information on Processing Activities, Procedures, and Services:

• LinkedIn: Social network - We, together with LinkedIn Ireland Unlimited Company, are responsible for the collection (but not further processing) of data from visitors, which is used to create "Page Insights" (statistics) for our LinkedIn profiles. This data includes information about the types of content users view or interact with, as well as actions they take. Additionally, details about the devices used are collected, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job function, country, industry, hierarchy level, company size, and employment status. Privacy information regarding the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy
  We have entered into a specific agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum," https://legal.linkedin.com/pages-joint-controller-addendum), which particularly regulates the security measures LinkedIn must follow and LinkedIn's agreement to fulfill the rights of data subjects (e.g., users can directly submit access or deletion requests to LinkedIn). Users' rights (especially the right to access, deletion, objection, and complaints to the relevant supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of data is the sole responsibility of LinkedIn Ireland Unlimited Company, particularly with regard to the transmission of data to LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal Grounds: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF). Right to Object (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal Grounds: Legitimate interests (Art. 6(1) sentence 1 lit. f) GDPR); Website: https://www.xing.com/. Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

Changes and Updates

We ask that you regularly inform yourself about the contents of our privacy policy. We will update the privacy policy as soon as changes in the data processing we carry out make it necessary. We will notify you if any changes require your participation (e.g., consent) or another individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that these addresses may change over time, and we ask you to check the details before contacting them.

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