Imprint

Address
SecCommerce Informationssysteme GmbH
Hindenburgstraße 49
22297 Hamburg – Germany

Support
Support for notary software is exclusively provided by NotarNet GmbH:    info[at]notarnet.de.

For the free use of SecSigner and SecCardAdmin please address all support requests to: info[at]seccommerce.com
Customers with maintenance contracts should please address all support requests to the address mentioned in the contract.

E-mail
info[at]seccommerce.com

Fax
Fax: +49 – 40 – 53 052 – 100

Trade register
SecCommerce Informationssysteme GmbH
Amtsgericht (Local Court) Hamburg
HRB 69920
Value added tax identification number: DE 201628902
CEO: Falk Goossens, André Damm-Goossens
Authorized signatory: Tilo Kienitz

Privacy Policy

This privacy policy informs you about the type, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and the associated websites, features, and content as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offering”). Regarding the terms used, such as “processing” or “controller,” we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Categories of Data Subjects

Visitors and users of the online offering (hereinafter collectively referred to as “users”).

Purpose of Processing

– Provision of the online offering, its features, and content.
– Responding to contact requests and communication with users.
– Security measures.
– Reach measurement/marketing

Definitions of Terms

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “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 (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data.

“Pseudonymization” means the processing of personal data in such a way 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 organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“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 analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

“Controller” means 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.

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

Relevant Legal Basis

In accordance with Article 13 GDPR, we inform you of the legal basis of our data processing activities. Unless the legal basis is specifically mentioned in this privacy policy, the following applies: The legal basis for obtaining consent is Article 6(1)(a) and Article 7 GDPR; the legal basis for processing for the performance of our services and implementation of contractual measures, as well as responding to inquiries, is Article 6(1)(b) GDPR; the legal basis for processing to fulfill our legal obligations is Article 6(1)(c) GDPR; and the legal basis for processing to safeguard our legitimate interests is Article 6(1)(f) GDPR. In cases where vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.

Security Measures

We take appropriate technical and organizational measures in accordance with Article 32 GDPR, taking into account the state of the art, implementation costs, and the nature, scope, context, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

The measures include, in particular, securing the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access, input, transmission, securing availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and response to data threats. We also take the protection of personal data into account already during the development or selection of hardware, software, and procedures, in accordance with the principle of data protection by design and by default (Article 25 GDPR).

Cooperation with Processors and Third Parties

If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them, or otherwise grant them access to the data, this is done only on the basis of a legal permission (e.g., if a transmission of data to third parties, such as payment service providers, is necessary for contract fulfillment pursuant to Article 6(1)(b) GDPR), you have consented, a legal obligation provides for this, or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called “processing contract,” this is done on the basis of Article 28 GDPR.

Transfers to Third Countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this happens in the context of the use of third-party services or disclosure, or transfer of data to third parties, this only happens if it is to fulfill our (pre-)contractual obligations, based on your consent, due to a legal obligation, or based on our legitimate interests. Subject to legal or contractual permissions, we process or let the data be processed in a third country only under the special conditions of Article 44 ff. GDPR. This means the processing takes place, for example, on the basis of specific guarantees, such as the officially recognized establishment of a data protection level equivalent to that of the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

Rights of Data Subjects

You have the right to request confirmation as to whether data concerning you is being processed and to request information about this data, as well as further information and a copy of the data in accordance with Article 15 GDPR.

In accordance with Article 16 GDPR, you have the right to request the correction of inaccurate data concerning you or the completion of incomplete data concerning you.

In accordance with Article 17 GDPR, you have the right to request that data concerning you be deleted immediately, or alternatively, in accordance with Article 18 GDPR, to request a restriction of the processing of the data.

In accordance with Article 20 GDPR, you have the right to receive the data concerning you that you have provided to us and to request its transmission to other controllers.

Furthermore, in accordance with Article 77 GDPR, you have the right to file a complaint with the competent supervisory authority.

Right to Withdraw Consent

You have the right to withdraw consents granted in accordance with Article 7(3) GDPR with effect for the future.

Right to Object

You may object to the future processing of data concerning you at any time in accordance with Article 21 GDPR. The objection can specifically be made against processing for direct marketing purposes.

Cookies and Right to Object to Direct Advertising

Cookies are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie serves primarily to store information about a user (or the device on which the cookie is stored) during or after their visit within an online offering. As temporary cookies, or “session cookies” or “transient cookies,” cookies are called that are deleted after a user leaves an online offering and closes their browser. In such a cookie, for example, the contents of a shopping cart in an online shop or a login status can be stored. As “permanent” or “persistent,” cookies are called that remain stored even after the browser is closed. For example, the login status can be stored if the users visit the site after several days. Likewise, user interests can be stored in such a cookie, which are used for reach measurement or marketing purposes. As “third-party cookie,” cookies are called that are offered by providers other than the controller who operates the online offering (otherwise, if it is only their cookies, they are called “first-party cookies”).

We can use temporary and permanent cookies and clarify this within the framework of our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offering.

A general objection to the use of cookies used for online marketing purposes can be declared on a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by turning them off in the settings of the browser. Please note that not all features of this online offering may be used then.

Deletion of Data

The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. That is, the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.

In accordance with legal requirements in Germany, the storage is particularly carried out for 10 years in accordance with §§ 147(1) AO, 257(1) No. 1 and 4, Para. 4 HGB (books, records, management reports, accounting records, commercial books, documents relevant to taxation, etc.) and 6 years in accordance with § 257(1) No. 2 and 3, Para. 4 HGB (commercial letters).

In accordance with legal requirements in Austria, the retention is particularly for 7 years in accordance with § 132(1) BAO (accounting documents, receipts/invoices, accounts, documents, business papers, records of income and expenses, etc.), for 22 years in connection with properties, and for 10 years for documents related to electronically provided services, telecommunications, broadcasting, and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

Business-Related Processing

Additionally, we process
– Contract data (e.g., contract object, term, customer category).
– Payment data (e.g., bank details, payment history)
from our customers, prospects, and business partners for the purpose of providing contractual services, customer service, marketing, advertising, and market research.

Agency Services

We process our clients’ data within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/advice or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services, and training services.

Here, we process inventory data (e.g., customer master data such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text input, photographs, videos), contract data (e.g., contract object, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., within the context of evaluating and measuring the success of marketing measures). We do not generally process special categories of personal data, unless they are part of a commissioned processing. The data subjects include our customers, prospects, and their customers, users, website visitors, or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing, and customer service. The legal bases of the processing result from Article 6(1)(b) GDPR (contractual services), Article 6(1)(f) GDPR (analysis, statistics, optimization, security measures). We process data that is necessary for the justification and fulfillment of contractual services and indicate the necessity of providing it. A disclosure to external parties only takes place if it is necessary within the framework of an order. When processing the data entrusted to us within the scope of an order, we act in accordance with the instructions of the principals as well as the legal requirements of a commissioned data processing according to Article 28 GDPR and do not process the data for any other purposes than those specified in the order.

We delete the data after the expiration of statutory warranty and comparable obligations. The necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiration (6 years in accordance with § 257(1) HGB, 10 years in accordance with § 147(1) AO). In the case of data disclosed to us by the principal in the context of an order, we delete the data according to the specifications of the order, generally after the end of the order.

Administration, Financial Accounting, Office Organization, Contact Management

We process data within the scope of administrative tasks as well as organization of our business, financial accounting, and compliance with legal obligations, such as archiving. Here, we process the same data that we process within the scope of providing our contractual services. The processing bases are Article 6(1)(c) GDPR, Article 6(1)(f) GDPR. Customers, prospects, business partners, and website visitors are affected by the processing. The purpose and our interest in the processing lie in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of our business activities, performance of our tasks, and provision of our services. The deletion of data in terms of contractual services and contractual communication corresponds to the information provided in these processing activities.

We disclose or transmit data to the financial administration, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, we store information on suppliers, event organizers, and other business partners on the basis of our business interests, e.g., for the purpose of later contact. These majority company-related data are generally stored permanently.

Contact

When contacting us (e.g., via contact form, e-mail, telephone, or via social media), the user’s details are processed for handling the contact request and its processing in accordance with Article 6(1)(b) GDPR. The user’s details may be stored in a Customer-Relationship-Management System (“CRM System”) or comparable inquiry organization.

We delete the inquiries if they are no longer necessary. We review the necessity every two years; in addition, the statutory archiving obligations apply.

Hosting and E-Mail Delivery

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail delivery, security services, and technical maintenance services that we use for the purpose of operating this online offering.

In this context, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects, and visitors of this online offering based on our legitimate interests in an efficient and secure provision of this online offering pursuant to Article 6(1)(f) GDPR in conjunction with Article 28 GDPR (conclusion of processing contract).

Collection of Access Data and Log Files

We or our hosting provider, collect data on the basis of our legitimate interests pursuant to Article 6(1)(f) GDPR on every access to the server on which this service is located (so-called server log files). The access data include the name of the accessed website, file, date and time of access, data volume transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address, and the requesting provider.

Log file information is stored for security reasons (e.g., to investigate misuse or fraud) for a maximum period of 7 days and then deleted. Data that must be kept for evidentiary purposes are excluded from deletion until the respective incident is finally clarified.

Google Analytics

Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering in the sense of Article 6(1)(f) GDPR), we use Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offering by users is usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering, and to provide us with further services associated with the use of this online offering and the internet. Pseudonymous usage profiles of users can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the IP address of users is truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

The IP address transmitted by the user’s browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offering by Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information on data use by Google, settings, and objection options can be found in Google’s privacy policy (https://policies.google.com/technologies/ads) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

The personal data of users will be deleted or anonymized after 14 months.

Online Presence in Social Media

We maintain online presences within social networks and platforms to communicate with customers, prospects, and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.

Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g., write posts on our online presences or send us messages.

Integration of Third-Party Services and Content

Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering in the sense of Article 6(1)(f) GDPR), we use content or service offers from third-party providers to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).

This always requires that the third-party providers of this content perceive the IP address of the users, as they could not send the content to their browser without the IP address. The IP address is therefore necessary for the display of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information, such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, as well as be linked to such information from other sources.

YouTube

We integrate the videos of the platform “YouTube” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google Fonts

We integrate the fonts (“Google Fonts”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google Maps

We integrate the maps of the service “Google Maps” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include IP addresses and location data of the users, which, however, are not collected without their consent (usually as part of the settings of their mobile devices). The data can be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Changes to Our Privacy Policy

We reserve the right to adapt this privacy policy to ensure it always complies with current legal requirements or to implement changes to our services in the privacy policy, e.g., when introducing new services. The new privacy policy will then apply to your next visit.

Questions for the Data Protection Officer

If you have any questions about data protection, please write to us at the above-mentioned address.