Data privacy policy
1 Introduction
With the following information, we would like to give you an overview of the processing of your personal data by Berlin Risk Advisors GmbH and your rights under data protection laws. In principle, it is possible to use our Internet pages without entering personal data. However, if you want to use certain services offered by our company via our website, the processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we will request your consent.
The processing of personal data, such as your name, address, or e-mail address, shall always be in line with the EU’s General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Berlin Risk Advisors GmbH. By means of this privacy policy, we would like to inform you about the scope and purpose of the personal data collected, used and processed by us.
As the controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of any personal data processed through this website. Nevertheless, Internet-based data transmissions can have security gaps, so that full protection cannot be guaranteed. You are therefore also free to transmit personal data to us by alternative means, for example by telephone or by mail.
You can also take simple and easy-to-implement measures to protect yourself against unauthorized access to your data by third parties. Therefore, we would like to provide you with some information on how to securely handle your data at this point:
- Protect your account (login, user or customer account) and your IT system (computer, laptop, tablet or mobile device) with strong passwords.
- Don’t share your passwords with anyone else.
- Make sure you use different passwords for each account (login, user or customer account).
- Do not use one password for numerous websites, applications or online services.
- Especially when using publicly accessible or shared IT systems, be sure to log out each time you log into a website, application, or online service.
Passwords should consist of at least 12 characters and be chosen so that they cannot be easily guessed. Therefore, they should not contain common words from everyday life, your own name or names of relatives. They should include upper and lower case letters as well as numbers and special characters.
2 Responsible party
The responsible party under the DSGVO definition is:
Berlin Risk Advisors GmbH
Am Hamburger Bahnhof 1, 10557 Berlin, Deutschland
The representatives of the responsible party are: Jennifer Hanley Giersch and Vlada Tkach
3 Data protection officer
Contact details for our data protection officer are as follows:
Berlin Risk Datenschutzbeauftragter
c/o Two Towers Consulting GmbH & Co. KG
Hohenzollernring 51
50674 Köln
E-Mail: datenschutz.ext@two-towers.eu
You can contact our data protection officer directly at any time with any questions and / or comments regarding data protection.
4 Übermittlung von Daten an Dritte
We do not transfer your personal data to third parties for purposes other than those listed below.
We only pass on your personal data to third parties if:
1. You have given us your express consent to do so in accordance with Art. 6 Para. 1 lit. a DSGVO,
2. the disclosure is permitted under Art. 6 (1) (f) DSGVO to protect our legitimate interests, and there is no reason to assume that you have an overriding interest worthy of protection thus hindering the non-disclosure of your data,
3. in the event that a legal obligation exists for the disclosure pursuant to Art. 6 (1) c DSGVO, and
4. this is legally permissible, and necessary for the processing of our contractual relationships with you according to Art. 6 para. 1 lit. b DSGVO.
In order to protect your data and to allow us to transfer data to third countries (outside the EU / EEA) if necessary, we have concluded commissioned processing agreements based on the standard contractual clauses as defined by the European Commission. This sometimes does not apply in the case of a data transfer to third countries, for which the European Commission has issued an adequacy decision pursuant to Art. 45 DSGVO.
5 Technology
5.1 SSL/TLS encryption
This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us as the operator. You can recognize an encrypted connection by the fact that there is a “https://” instead of a “http://” in the address line of the browser and by the lock symbol in your browser line.
We use this technology to protect your transmitted data.
5.2 Data collection when visiting the website
BWhen using our website for information purposes only, i.e. when not registering or otherwise transmitting information to us, we only collect data that your browser transmits to our server (in so-called “server log files”). Our website collects general data and information with each call of a page or via an automated system. This general data and information is stored in the server log files.
The following can be recorded
1. browser types and versions used,
2. operating system used by the accessing system,
3. website from which an accessing system is directed to our website (so-called referrer),
4. subpages that are accessed via an accessing system on our website,
5. date and time at which an Internet page was accessed,
6. Internet protocol address (IP address), and
7. Internet service provider of the accessing system.
Bei der Nutzung dieser allgemeinen Daten und Informationen ziehen wir keine RückWhen using this general data and information, we do not draw any conclusions about you as a person. This information is rather required in order to
1. deliver the contents of our website correctly,
2. optimize the content of our website,
3. ensure the long-term functionality of our IT systems and the technology of our website, as well as
4. to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.
Therefore, we will use the collected data and information for statistical purposes only and for the purpose of increasing the data protection and data security of our enterprise, so as to ensure an optimal level of protection for the personal data we process. The data of the server log files are stored separately from any personal data provided by a data subject.
The legal basis for data processing is Art. 6 para. 1 p. 1 lit. f DSGVO. Our legitimate interest is derived from the purposes for data collection as listed above.
6 Cookies
6.1 General information about cookies
We use cookies on our website. These are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone or similar) when you visit our site.
Information is stored in the cookie. The information stored depends on the context of the specific end-device used. This does not however mean, that we thereby gain direct knowledge of your identity.
The use of cookies serves to make the use of our offer more attractive. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site.
In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your terminal device for a certain fixed period of time. If you visit our site again to use our services, it is automatically recognized that you have already been with us and which entries and settings you have made so that you do not have to enter them again.
On the other hand, we may use cookies to statistically record the use of our website and to evaluate our offering for the purpose of optimization. These cookies enable us to automatically recognize that you have already visited our website when you visit it again. The cookies set in this way are automatically deleted after a defined period of time. The respective storage period of the cookies can be found in the settings of the consent tool used.
6.2 Legal basis for the use of cookies
The data processed by the cookies, which are required for the proper functioning of the website, are thus necessary in order to protect our legitimate interests as well as those of third parties, in accordance with Art. 6 (1) lit. f DSGVO.
For all other cookies, you have to provide your consent via our opt-in cookie banner as defined under Art. 6 (1) lit. a DSGVO.
6.3 Consent with Borlabs
Our website uses Borlabs Cookie Consent technology to obtain your consent to store certain cookies in your browser or to use certain technologies, and to document this consent in accordance with relevant data protection laws.
The provider of this technology is Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg (hereinafter Borlabs). When you access our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the revocation of these consents are stored. This data is not shared with the company Borlabs.
The collected data will be stored until you request us to delete it, or until you delete the Borlabs cookie yourself or until the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected. Details of the data processing of Borlabs Cookie can be found under https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.
Borlabs Cookie Consent Technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c DSGVO.
7 Contents of our website
7.1 Contacting / Contact form
Personal data is collected when contacting us (e.g. via the contact form or e-mail). The data collected thereby can be seen in the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. The legal basis for processing the data is our legitimate interest in responding to your request pursuant to Art. 6 (1) lit. f DSGVO. If your contact aims at signing a contract, the additional legal basis for processing is Art. 6 para. 1 lit. b DSGVO. Your data will be deleted after having completed the processing of your request. This is the case if it can be inferred from the circumstances, that the matter concerned, has been conclusively clarified and the deletion is not contrary to any statutory retention obligations.
7.2 Application management
We collect and process personal data of applicants for the purpose of managing the application process. The processing may also take place electronically. This is in particular the case if an applicant sends us their application documents electronically, for example by e-mail. If we sign an employment or service contract with applicants, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If we do not sign an employment or service contract with the applicant, the application documents will automatically be deleted two months after notification of the rejection decision, provided that no other legitimate interests on our part prevent deletion. Another legitimate interest in this sense is, for example, is a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG). In addition, we store application data for a maximum period of two years, insofar as we have been given appropriate consent to do so.
The legal basis for processing your data is Art. 88 DSGVO in conjunction with. § Section 26 (1) BDSG.
8 Our activities in social networks
We have social media pages through which we communicate and inform about our services.
We are not the original provider of these pages, but only use them within the scope of the possibilities offered to us by the respective providers.
As a precaution, we therefore point out that your data may be processed outside the European Union or the European Economic Area. Thus the use of these social media platforms may therefore bear data protection risks for you. Safeguarding your rights, e.g. to information, deletion, objection, etc., could be more difficult. In addition, processing in the social networks often takes place directly for advertising purposes or for analysis of usage behavior by the providers. Such activities are beyond our sphere of influence. If usage profiles are created by the provider, this often involves the use of cookies or the assignment of usage behavior to your own member profile hosted on the social network.
The described processing operations of personal data are carried out in accordance with Art. 6 Para. 1 lit. f DSGVO on the basis of our legitimate interest and the legitimate interest of the respective provider, in order to be able to communicate with you in a timely manner, or to inform you about our services. If you do have to give your consent to data processing as a user with such respective providers, the legal basis is Art. 6 para. 1 lit. a DSGVO in conjunction with. Art. 7 DSGVO.
Since we do not have access to the providers’ databases, we would like to point out that it is best to assert your rights (e.g. to information, correction, deletion, etc.) directly with the respective provider. Further information on the processing of your data in social networks, and the possibility of exercising your right of objection or revocation (so-called opt-out), we have listed the respective providers of social networks used by us:
8.1 LinkedIn
(Co-) Controller for data processing in Europe:
LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Irland
Privacy Policy:
https://www.linkedin.com/legal/privacy-policy
9 Web analysis
9.1 Matomo
This website has integrated Matomo, provided by InnoCraft Ltd, 150 Willis St, 6011 Wellington, New Zealand. Matomo is a software tool for web analysis purposes, i.e. for collecting, collating and evaluating data on the behavior of visitors to websites. Among other things, data about the website is collected. This includes data about the location from which the subject has accessed our website (so-called referrer), which subpages of the website have been accessed or how often and for how long a subpage has been viewed. This is used to optimize the website and for cost-benefit analysis of Internet advertising.
The software is operated on the coontroller’s server, and the log files, which are sensitive under data protection law, are stored exclusively on this server.
Matomo installs a cookie on your IT system. As a result, we are enabled to analyze the use of our website. Each time one of the individual pages of this website is called up, the Internet browser on your IT system is automatically prompted by the Matomo component to transmit data to our server for the purpose of online analysis. As part of this technical procedure, we obtain knowledge of personal data, such as the IP address of the person concerned, which we then use, among other things, to trace the origin of visitors and clicks.
By means of the cookie, personal information, for example the access time, the location from which an access originated, and the frequency of visits to our website are stored. Each time you visit our website, this personal data, including the IP address of the Internet connection you are using, is transmitted to our server. This personal data is stored by us. We do not pass this personal data onto third parties.
You can prevent the setting of cookies by our website at any time by adapting the settings of the Internet browser used and thus permanently objecting to the setting of cookies. Such a setting would also prevent Matomo from installing a cookie on your IT system. In addition, a cookie already set by Matomo can be deleted at any time via your Internet browser or other software programs.
Furthermore, you have the option to object to the collection of data generated by Matomo and related to the use of this website, via the consent management tool on our website. If your IT system is deleted, formatted or reinstalled at a later date, the data subject must set an opt-out cookie again. We would like to point out that these measures might restrict the functionality of our website.
You can prevent Matomo from tracking you on our website by clicking on this link:
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 Para. 1 lit. a DSGVO.
Matomo’s privacy policy can be found at https://matomo.org/privacy/.
10 Your rights as a data subject
10.1 Confirmation
You have the right to request confirmation from us as to whether your personal data is being processed.
10.2 Information Art. 15 DSGVO
You have the right to obtain information, about the personal data stored about you, as well as a copy of this data in accordance with the legal provisions, at any time and free of charge.
10.3 Rectification Art. 16 DSGVO
You have the right to demand that incorrect personal data concerning you, be corrected. Furthermore, you have the right to request the completion of incomplete personal data, taking into account the purposes of the processing.
10.4 Deletion Art. 17 DSGVO
You have the right to demand that we delete any personal data concerning you without undue delay, provided that one of the reasons provided for by law applies, and insofar as the processing or storage is not necessary.
10.5 Restriction of processing Art. 18 DSGVO
You have the right to demand that we restrict processing if one of the legal requirements applies.
10.6 Data portability Art. 20 DSGVO
You have the right to receive the personal data concerning you, which has been provided to us by you, in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from us to whom the personal data has been provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) DSGVO or Art. 9(2)(a) DSGVO or on a contract pursuant to Art. 6(1)(b) DSGVO, and the processing is carried out with the aid of automated procedures, unless the processing is necessary for the performance of a task which is carried out in the public interest or on behalf of an official authority.
Furthermore, when exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to request that personal data be transferred directly from one controller to another controller, to the extent that this is technically feasible and provided that this does not adversely affect the rights and freedoms of other individuals.
10.7 Objection Art. 21 DSGVO
You have the right to object to the processing of personal data relating to you which is carried out on the basis of Art. 6(1)(e) (data processing in the public interest) or (f) (data processing on the basis of a balance of interests) DSGVO at any time, on grounds relating to your particular situation.
This also applies to profiling based on these provisions within the meaning of Art. 4 No. 4 DSGVO.
If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms, or insofar as the processing serves the assertion, exercise or defense of legal claims.
In individual cases, we process personal data to conduct direct marketing. You may object to the processing of personal data for the purpose of such advertising at any time. This also applies to profiling, insofar as it is related to such direct advertising. If you object to us processing your personal data for direct marketing purposes, we will refrain from processing your personal data for these purposes.
In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you, which is carried out by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) DSGVO, unless such processing is necessary for the performance of a task carried out in the public interest.
You are free to exercise your right to object in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures using technical specifications.
10.8 Revocation of consent under data protection law
You have the right to revoke consent for the future processing of personal data at any time.
10.9 Complaint to a supervisory authority
You have the right to complain about our processing of personal data to a supervisory authority which is responsible for data protection.
11 Routine storage, deletion and blocking of personal data
We only process and store your personal data for the period of time required to achieve the purpose of storage, or insofar as this has been provided due to legal provisions to which our company is subject.
If the purpose of storage no longer applies or if a prescribed storage period expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
12 Duration of the storage of personal data
The criterion for the duration of storage of personal data is the respective statutory retention period. Following the expiry period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfillment or initiation of the contract.
13 Topicality and change of the data protection declaration
This data protection declaration is currently valid and is dated: May 2022.
Due to the further development of our internet pages and our offerings, or due to changed legal or official requirements, it may become necessary to change this data protection declaration.