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Inhaltlich Verantwortlicher gemäß §6 MDstV /Responsible content according $6 MDstV
Dr. Axel Brandt
 

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 Privacy Policy
 

We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the Sino German Executive Search. The use of the Internet pages of the Sino German Executive Search is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
 

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 General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the Sino German Executive Search. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, the Sino German Executive Search has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions 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 data protection declaration of the Sino German Executive Search is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration 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 data protection declaration, we use, inter alia, the following terms:

• 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 is any identified or identifiable natural person,      whose personal data is processed by the controller responsible for the      processing.
• c)    Processing
• Processing is 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 is 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 is 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 or controller responsible for the      processing
• Controller or controller responsible for the processing 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 is a natural or legal person, public authority, agency or      other body which processes personal data on behalf of the controller.
• i)      RecipientRecipient is a natural or      legal person, public authority, agency or another body, to which the      personal data are disclosed, whether a third party or not. However, public      authorities which may receive personal data in the framework of a      particular inquiry 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 is 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 controller

Controller 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 is:
 

3. Cookies

The Internet pages of the Sino German Executive Search use cookies. Cookies are text files that are stored in a computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the dats subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
Through the use of cookies, the Sino German Executive Search can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
 

4. Collection of general data and information

The website of the Sino German Executive Search collects a series 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. Collected may be (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 Internet site, (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 in the event of attacks on our information technology systems.
When using these general data and information, the Sino German Executive Search does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the Sino German Executive Search analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
 

5. Contact possibility

 Via the websiteThe website of the Sino German Executive Search contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
 

6. Routine erasure and blocking of personal data

The data controller 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 this is granted by the European legislator or other legislators in laws or regulations to which the controller is 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
• Each data subject shall have the right granted by the European      legislator to obtain from the controller the confirmation as to whether or      not personal data concerning him or her are being processed. If a data      subject wishes to avail himself of this right of confirmation, he or she      may, at any time, contact our Data Protection Officer or another employee      of the controller.
• b) Right of access
• Each data subject shall have the right granted by the European      legislator to obtain from the controller 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 controller       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 avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.

• c) Right to rectification
• Each data subject shall have the right granted by the European      legislator to obtain from the controller 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, he or she may, at any time, contact our Data      Protection Officer or another employee of the controller.
• d) Right to erasure (Right to be forgotten)
• Each data subject shall have the right granted by the European      legislator to obtain from the controller the erasure of personal data      concerning him or her without undue delay, and the controller 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 controller is       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 the Sino German Executive Search, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of the Sino German Executive Search or another employee shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, 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. The Data Protection Officer of the Sino German Executive Search or another employee 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 controller 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 controller to verify the accuracy of       the personal data.
  • The processing is unlawful and the data subject opposes the       erasure of the personal data and requests instead the restriction of       their use instead.
  • The controller no longer needs 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 controller 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 the Sino German Executive Search, he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of the Sino German Executive Search or another employee will 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 Data Protection      Officer designated by the Sino German Executive Search or another      employee.
• 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.
  The Sino German Executive Search 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 the Sino German Executive Search      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 the Sino German Executive Search to the processing for direct      marketing purposes, the Sino German Executive Search 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 the Sino German      Executive Search 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 directly contact the Data Protection Officer of the      Sino German Executive Search or another employee. 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 his or her 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      authorised by Union or Member State law to which the controller is subject      and which also lays down suitable measures to safeguard the data subject's      rights and freedoms and legitimate interests, or (3) is not based on the      data subject's explicit consent.
  If the decision (1) is necessary for      entering into, or the performance of, a contract between the data subject      and a data controller, or (2) it is based on the data subject's explicit      consent, the Sino German Executive Search 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, he or she may at      any time directly contact our Data Protection Officer of the Sino German      Executive Search or another employee of the controller.
• 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.
  f the data subject wishes to exercise the      right to withdraw the consent, he or she may at any time directly contact      our Data Protection Officer of the Sino German Executive Search or another      employee of the controller.

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. Is our company 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 company and his 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 abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by 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. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
 

9. The legitimate interests pursued by the controller 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 carry out our business in favor of the well-being of all our employees and the shareholders.
 

10. Period for which the personal data will be stored

The criteria used to determine the period of storage of 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 dataWe clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides 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 our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies 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

As a responsible company, we do not use automatic decision-making or profiling.