Privacy Policy

Thank you for your interest in the services of Text Matters (Petra Hucke and Anja Neudert). In our work, we deal with and read about information security and privacy a lot. We know how important data protection is. Therefore we made sure that you can use our pages without giving away any personal data, and we don’t even use any cookies. If you as a data subject want to use the services we offer, however, we may need to process certain personal data. If such processing of personal data is necessary but there is no statutory basis for such processing, we will ask for your consent first. Please continue reading for more information.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the EU General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to Text Matters. This data privacy policy outlines the nature, scope, and purpose of the personal data we collect, use and process, and informs data subjects about of the rights to which they are entitled.

As controllers, Petra Hucke and Anja Neudert have implemented various technical and organizational measures to ensure that personal data processed through this website are protected as comprehensively as possible. However, data transmission over the internet may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. Definitions

The Text Matters privacy policy is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this privacy policy, we use the following terms, among others:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject means any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller

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 the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. 2However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

j) Third party

Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the controllers

Controllers for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in member states of the European Union and other provisions related to data protection are:

Anja Neudert
Könneritzstr. 29
04229 Leipzig
Germany
Phone: +49 (0) 341 234 268-0
Email: anja.neudert (at) text-matters.de
Website: www.text-matters.de

and

Petra Hucke
Neustätterstr. 2
80636 Munich
Phone: +49 (0) 89 202 44 560
Email: petra.hucke (at) text-matters.de
Website: www.text-matters.de

3. Cookies

The Text Matters web pages do not use any cookies.

4. Collection of general data and information

The Text Matters website collects a number of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files and may include (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used for incident response purposes in the event of attacks on our information technology systems.

When using these general data and information, Text Matters does not draw any conclusions about the data subject. Rather, this information is needed (1) to deliver the content of our website correctly, (2) to optimize the content of our website and support the promotion of our website, (3) to ensure the long-term viability of our information technology systems and website technology, and (4) to provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber attack. Therefore, Text Matters analyzes anonymously collected data and information statistically, with the aim of enhancing data protection and data security, and to ensure a maximum level of protection for the personal data we process. Anonymous data from server log files are stored separately from all personal data provided by a data subject.

5. Contact through the website

The Text Matters website contains information that allow contacting us electronically, including e-mail addresses. If a data subject contacts the controllers by e-mail or through a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data that a data subject transmits to the data controllers voluntarily are stored for the purpose of processing or contacting the data subject. This personal data will not be shared with third parties.

6. Routine deletion and blocking of personal data

The data controllers shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as stipulated by the European legislator or other legislators in laws or regulations to which the controllers are subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

7. Rights of the data subject

a) Right of confirmation

The data subject shall have the right granted by the European legislator to obtain from the controllers the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, they may, at any time, contact the controllers.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controllers free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controllers rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, they may, at any time, contact the controllers.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controllers without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, they may, at any time, contact the controllers.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controllers the erasure of personal data concerning him or her without undue delay, and the controllers shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controllers are subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by Text Matters, they may, at any time, contact the controllers. We shall promptly ensure that the erasure request is complied with immediately.

Where the controllers have made personal data public and pursuant to Article 17(1) are obliged to erase the personal data, the controllers, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. We will arrange the necessary measures in individual cases.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controllers restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controllers 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 instead the restriction of their use instead.
  • The controllers no longer need the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controllers override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by Text Matters, they may at any time contact the controllers. We will promptly arrange the restriction of the processing.

f) Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall 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 point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as 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 his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact the controllers.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

Text Matters shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If Text Matters processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Text Matters to the processing for direct marketing purposes, Text Matters will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Text Matters for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact the controllers. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use their right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controllers are 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 data controller, or (2) it is based on the data subject’s explicit consent, Text Matters shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, they may, at any time, contact the controllers.

i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, they may, at any time, contact the controllers.

8. Legal basis for the processing

Art. 6(1) lit. 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 party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Where we are subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR.
In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our offices and their name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.

Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by us or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. They considered that a legitimate interest could be assumed if the data subject is a client of the controllers (Recital 47 Sentence 2 GDPR).

9. The legitimate interests pursued by the controllers or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR, our legitimate interest is to conduct our business.

10. Period for which the personal data will be stored

The criteria used to determine for how long to store personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

11. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can result from contractual provisions (e.g. information on the contractual partner).

Sometimes, for concluding a contract, it may be necessary for the data subject to provide us with personal data which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when we sign a contract with them. The non-provision of the personal data would have the consequence that the contract with the data subject cannot be concluded.

Before providing personal data, the data subject must contact one of the controllers who then explains to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.

12. Existence of automated decision-making

We do not use automatic decision-making or profiling.

This Privacy Policy has been created with help of the Privacy Policy Generator of the External Data Protection Officers that was developed in cooperation with the Media Law Lawyers from WBS-LAW.