Privacy
We are very pleased about your interest in our company. Data protection is of a particularly high priority for the management of the Network Engineering GmbH. Use of the Internet pages of the Network Engineering GmbH is, in principle, without any indication of personal data. If an affected Person wishes to take special Services of our company via our website, but it could be a processing of personal data is required. The processing of personal data is necessary and there is for such processing, there is no legal basis, we get a General consent of the Person concerned.
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 and in Accordance with the Network Engineering GmbH are applicable country-specific data protection provisions. By means of this data protection Declaration, our enterprise would like to inform the Public about the type, scope and purpose of the collected, used and processed personal data. Furthermore, data subjects are informed, by means of this data protection Declaration of the rights that you have.
The Network Engineering GmbH has implemented as a controller, a number of technical and organisational measures in order to ensure complete protection of this website is processed personal data. Nevertheless, Internet transmissions based data security gaps, so absolute protection may not be guaranteed. For this reason, it is open to any interested Person to submit personal data in alternative Ways, for example, by phone, to us.
1. Definitions
The data protection Declaration of the Network Engineering GmbH is based on the terms used by the European directives and legislators when adopting the General data protection regulation (DS – GVO). Our privacy policy is intended to be for the Public as well as our customers and business partners easy-to-read and understandable. To ensure this, we would like to explain in advance the terminology used.
We use in this privacy policy, inter alia, the following terms:
a) personal data
Personal data is any information relating to an identified or identifiable natural Person (hereinafter “data subject”) are. As an identifiable natural Person is considered to be may, directly or indirectly, in particular by means of assignment 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 this natural Person can be identified.
b) data subject
data subject is any identified or identifiable natural Person, whose personal data from the controller to be processed.
c) processing
Processing is any with or without the aid of automated processes executed transaction or any such series in connection with personal data such as collection, organization, Organize, storage, adaptation or alteration, retrieval, consultation, use, disclosure by Transmission, dissemination or any other Form of provision, matching or linking, restriction, Deletion or destruction, Capture,.
d) restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in future is.
e) Profiling
Profiling is any kind of automated processing of personal data, which consists of, these personal data will be used to evaluate certain personal aspects relating to a natural Person, to analyse, in particular, to the aspects relating to work performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location of this natural Person or to predict.
f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be assigned without the involvement of additional information specific to the Person concerned, provided that such additional information is kept separately and technical and organizational measures are subject to ensuring that the personal data are not attributed to an identified or identifiable natural Person.
g) the person responsible or a controller
The person responsible or the controller of 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. The purposes and means of such processing are determined by Union law or the law of the member States, the Controller may or the specific criteria can be provided to his / her designation in accordance with the Union law or the law of the member States.
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) recipient
Recipient is a natural or legal Person, public authority, Agency or other body, of the personal data, regardless of whether a third party or not. Authorities in the framework of a particular Inquiry in accordance with Union law or the law of the member States that personal data may, however are not considered to be recipients.
j) third party
Third party is a natural or legal Person, public authority, Agency or body other than the data subject, the controller, the processor and the persons authorised under the direct responsibility of the controller or the processor of the personal data.
k) consent
Consent is any of the affected Person on a voluntary basis for the specific case in an informed manner, and clearly, as given expression in the Form of a statement or other unambiguous confirmatory act whereby the data subject indicates that the processing of their personal data.
2. The Name and address of the controller
The person responsible within the meaning of the General data protection regulation, other in the member States of the European Union applicable data protection laws and other provisions with data protection character is:
Network Engineering GmbH
Ludwigstraße 4
67346 Speyer,
Germany
Tel.: 06232/60580
E-Mail: info@nwe.de
Website: www.nwe.de
3. Name and address of the data protection officer
The data protection officer of the controller is:
Horst Madloch
management-m
E-Mail: hm@management-m.de
Any interested Person may apply at any time for all questions and suggestions concerning data protection directly to our data protection officer.
4. Cookies
the Internet pages of The Network Engineering GmbH use Cookies. Cookies are text files which are stored on a web browser on a computer system and that are stored.
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 to the specific Internet browser can be assigned in which the Cookie was stored. This allows visited Internet sites and servers to differentiate the individual Browser of the Person concerned from other Internet browsers that contain other Cookies. A specific Internet browser can be recognized by the unique Cookie ID, and identified.
Due to the use of Cookies, the Network Engineering GmbH can provide the users of this website more user-friendly Services that would not be possible without the Cookie setting possible.
By means of a cookie, the information and offers can be optimized on our website within the meaning of the user. Cookies allow us, as previously mentioned, the users of our website to recognize. The purpose of this recognition is to make it easier for users to use our website. The user of a website that uses Cookies does not have to, for example, enter it each time you visit the website again, his access data, because this is taken over by the website, and the computer system of the user stored Cookie. Another example is the Cookie of a shopping cart in the Online Shop. The Online store remembers the articles that a customer in the virtual shopping cart via a Cookie.
The affected Person can prevent the setting of Cookies through our website at any time by means of a corresponding setting of the Internet browser used, and thus the setting of Cookies permanently. Furthermore, already set Cookies may be at any time via an Internet browser or other software programs deleted. This is in all popular Internet browsers. The data subject deactivates the setting of Cookies in the Internet browser, not all functions of our website to the full extent available.
5. Collection of General data and information
The website of the Network Engineering GmbH recorded for each invocation of the website by an affected Person or an automated System, a series of General data and information. This General data and information are stored in the log files of the server. Captures the (1) browser types and versions, (2) the accessing System’s operating system to be used, (3) the website from which an accessing System reaches our website (so-called referrers), (4) the sub-websites, which are controlled via an accessing System on our website, (5) the date and time of access to the Internet site, (6) an Internet Protocol address (IP address), (7) can be the Internet Service Provider of the accessing system, and (8) any other similar data and information which serve to avert danger in the event of attacks on our information technology systems.
When using these General data and information the Network Engineering GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (to optimize 2) the content of our website as well as the advertising for it, (3) ensure the permanent functionality of our information technology systems and the technology of our website, and (4) to law enforcement authorities in the event of a cyber attack to law enforcement the necessary information. This anonymously collected data and information is evaluated by the Network Engineering GmbH, therefore, on the one hand statistically and further with the aim of increasing the data protection and data security in our company in order ultimately to an optimal protection level for the personal data processed. The anonymous data of the Server log files are separated from all by a data subject to the personal data stored.
6. Subscription to our Newsletters
On the website of the Network Engineering GmbH, users with the opportunity given, the Newsletter of our company is to subscribe to. What personal data will be transmitted when the newsletter is ordered to the controller, is derived from the used for this purpose input mask.
The Network Engineering GmbH informs its customers and business partners at regular intervals by way of a newsletter about offers of the company. The Newsletter of our company can be received by the data subject, in principle, only if (1) the data subject has a valid E-Mail address and (2) the data subject registers for the newsletter shipping. By a data subject for the first time for newsletter shipping, registered E-Mail address will be shipped, for legal reasons, a confirmation e-mail in the Double Opt-In procedure. This confirmation email serves to Check whether the owner of the E-Mail address has authorized the Person concerned to receive the newsletter.
During the registration for the Newsletter, we also store the Internet Service Provider (ISP), IP-address of the concerned Person at the time of the application, used computer system, as well as the date and time of the registration. The collection of this data is necessary in order to understand the(possible) misuse of the E-Mail address of a data subject at a later date and therefore serves as a legal safeguard for the controller.
In the context of a registration for the Newsletter, the personal data collected will only be used to send our newsletter. Furthermore, subscribers to the newsletter by E-Mail, unless this is necessary for the operation of the Newsletter service or a related registration is required, as this could be in the event of Modifications to the newsletter offer, or in the case of a change in technical circumstances of the case. There is no disclosure in the context of the Newsletter service collected personal data on to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which has granted the Person concerned us for the newsletter dispatch, can be revoked at any time. For the purpose of revocation of consent, a corresponding Link is found in each Newsletter. It is also possible at any time directly on the website of the log for the controller from the newsletter shipping, or to inform the controller in any other way is.
7. Newsletter-Tracking
The Newsletter of the Network Engineering GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such E-Mails, which are sent in HTML Format to enable log file recording and a log file analysis. This allows a statistical analysis of the success or failure of Online Marketing can be carried out campaigns. Based on the embedded tracking pixel is evident, the Network Engineering GmbH may see if and when an E-Mail was opened by a data subject, and which in the E-Mail Links were accessed by the Person concerned.
Such in the newsletters contained web beacons personal data collected, stored by the controller and evaluated, in order to optimize the sending of the newsletter and the content of future newsletters even better to the interests of the Person concerned to adapt. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate, over the Double-Opt-In procedure given informed consent statement. After a revocation, these personal data from the controller will be deleted. You can unsubscribe from the receipt of the newsletter suggests the Network Engineering GmbH automatically as a revocation.
8. Subscription to comments in the Blog on the website
The Blog of the Network Engineering GmbH comments can, in principle, from the third to be subscribed. In particular, the possibility that a commenter subscribes to the his comment following comments on a particular Blog post is.
If a Person decides for the Option to subscribe to comments sent by the Controller, an automatic confirmation e-mail to check the Double Opt-In procedure as to whether the owner of the specified E-Mail address for this Option to be decided. The Option to subscribe to comments may be terminated at any time.
9. Routine Erasure and blocking of personal data
The Controller processes and stores personal data of the data subject only for the period of time that is required to achieve the storage purpose or if this was provided for by the European Directive and regulation giver or another legislator in laws or regulations to which the controller is subject, the Controller,.
The storage purpose or a by the European Directive and regulation giver or another competent legislator prescribed storage period expires, locked the personal data are routinely and in accordance with the legal provisions, or deleted.
10. Rights of the data subject
a) right of confirmation
Each affected Person has the by the European Directive and regulation giver granted the right to obtain from the controller the confirmation as to whether or not they are being processed personal data relating to him. Want to take a affected Person of this right of Confirmation, you can do so at any time contact an employee of the data controller.
b) right to information
Each of the processing of personal data concerned Person by the European Directive and regulation giver granted the right at any time to obtain from the controller free information about his or her personal data stored and a copy of this information. Furthermore, the European directives and Regulations of the affected Person information, the following information were:
- the purposes of the processing
- , the categories of personal data processed
- the recipients or categories of recipients to whom the personal data are disclosed, have been or will be disclosed, in particular recipients in third countries or international organisations
- , if possible, the planned duration for which the personal data will be stored, or, if this is not possible, the criteria for determining this duration
- the Existence of a Right to rectification or Erasure of the personal data, or restriction of processing by the controller or a right to object against the processing
- , the right to Lodge a Complaint with a Supervisory authority
- if the personal data from the data subject are collected: All the available information about the origin of the data
- the Existence of an automated decision-making including Profiling pursuant to article 22 Para.1 and 4 DS-GMO, and — at least in these cases — meaningful information on the involved logic as well as the significance and the envisaged consequences of such processing for the data subject
Furthermore, a request for information to the concerned Person about whether or not personal data is transferred to a third country or to an international Organisation. If this is the case, the right to the affected Person in the Other, to obtain information about the appropriate guarantees in connection with the Transmission.
An affected Person would like to take this right to information, you can do so at any time contact an employee of the data controller.
c) right to rectification
Each of the processing of personal data concerned Person by the European Directive and regulation giver granted the right to immediate correction request in the subject of inaccurate personal data. Furthermore, the right of the Person concerned, taking into account the purposes of the processing, to request the completion of incomplete personal data — also by means of a supplementary statement.
Want to take a affected Person of this right of Rectification, you can do so at any time contact an employee of the data controller.
d) right to Erasure (right to be Forgotten)
Each of the processing of personal data concerned Person by the European Directive and regulation giver right granted by the person responsible to request that the personal data relating to them be deleted without delay if one of the following reasons applies and insofar as the processing is not necessary:
- The personal data have been collected for such purposes or otherwise processed for which they are necessary.
- The data subject withdraws consent to which the processing in accordance with art. 6, Para. 1 letter a DS-GMO or article 9 Para. 2 letter a DS-GMO based, and there is no other legal basis for processing.
- The Person concerned shall, in accordance with article 21, Para. 1 DS-GMO opposition to the processing, and there are no overriding legitimate reasons for the processing, or the data subject shall, in accordance with article 21, Para. 2 DS-GMO opposition to the processing.
- The personal data have been unlawfully processed.
- The deletion of your personal data, to fulfil a legal obligation under Union law or the law of the member States to which the Controller is subject to.
- The personal data have been Abs in terms of offered services of the information society in accordance with article 8. 1 DS-GMO collected.
If one of the aforementioned reasons applies, and a data subject wishes to leave the Erasure of personal data stored in the Network Engineering GmbH, Vera, you can do so at any time contact an employee of the data controller. The employees of the Network Engineering GmbH will arrange for the deletion request shall be immediately complied with.
The personal data of the Network Engineering GmbH, to the public, and our company is responsible pursuant to article 17 Para. 1 DS-GMO for the deletion of the personal data is required, the Network Engineering GmbH, taking account of available technology and the implementation meets the costs of appropriate measures, also of a technical nature, to set the other data controllers processing the published personal data, inform that the Person concerned has not requested by the other for the data controller the Erasure of all Links to this personal data or of copies or replications of this personal data, as far as processing is not required. The employees of the Network Engineering GmbH, in individual cases, the Necessary measures.
e) right of restriction of processing
Each of the processing of personal data concerned Person by the European Directive and regulation giver right granted by the person responsible for the restriction of the processing of the request, if any of the following conditions is that
- the accuracy of The personal data of the concerned Person is not contested, and for a duration that it allows the accuracy of the personal data to verify.
- The processing is unlawful and the data subject opposes the Erasure of the personal data and requests instead the restriction of the use of personal data.
- The person Responsible needs the personal data for the purposes of the processing no longer, the Person will require, however, for the assertion, exercise or defence of legal claims.
- The affected Person has the gem object to the processing. Article 21 Para. 1 DS-GMO is inserted, and it is not yet certain whether the legitimate reasons of the person responsible outweigh those of the Person concerned.
If any of the above conditions is met and an affected Person wishes to request the restriction of personal data stored in the Network Engineering GmbH can apply for this at any time, an employee of the data controller. The employees of the Network Engineering GmbH is the restriction of the processing of Vera.
f) right to data portability
Each of the processing of personal data concerned Person by the European Directive and regulation giver granted the right to receive the personal data concerning you, which were provided by the affected Person to a controller, in a structured, common and machine-readable Format. You also have the right to transmit this data to another person responsible without hindrance by the person responsible, which provided the personal data, unless the processing on the consent pursuant to art. 6, Para. 1 letter a DS-GMO or article 9 Para. 2 letter a DS-GVO or on a contract pursuant to Art. 6 Para. 1 letter b DS-GMO based and processing through automated procedure is not performed, unless the processing is necessary for the performance of a task is required in the public interest or in the exercise of official authority which has been delegated to the controller.
Furthermore, the Person concerned has, in the exercise of their Right to data portability pursuant to article 20 Para. 1 DS-GVO the right to obtain that the personal data is transmitted directly from one controller to another person responsible, insofar as this is technically feasible and provided that the rights and freedoms of other persons are compromised.
In order to assert the Right to data portability you can contact the data subject at any time, an employee of the Network Engineering GmbH.
g) right to object
Each of the processing of personal data concerned Person by the European Directive and regulation giver granted the right, for reasons arising from your particular Situation, at any time, to the processing of personal data concerning him, on the basis of article 6 Para. 1 letter e or f DS-GMO is to be opposed. This also applies to a rules-based Profiling.
The Network Engineering GmbH will no longer process the personal data in the event of the objection, unless we can compelling protection worthy grounds for the processing, to prove that outweigh the interests, Rights and freedoms of the Person concerned, or the processing serves the assertion, exercise or defence of legal claims.
The Network Engineering GmbH processes personal data to carry out direct advertising, the Person concerned shall have the right to at any time object to the processing of personal data for the purposes of such advertising appeal. This also applies to Profiling, insofar as it relates to such direct advertising. Contrary to the affected Person as against to the Network Engineering GmbH to the processing for direct marketing purposes, the Network Engineering GmbH will no longer process the personal data for these purposes.
In addition, the data subject has the right, for reasons arising from their particular Situation, against the processing of personal data, which the Network Engineering GmbH for scientific or historical research purposes or for statistical purposes pursuant to article 89 Para. 1 DS-GMO are made to appeal, unless such processing for the performance of a public interest task required.
To exercise the Right to object, the data subject directly to each employee of the Network Engineering GmbH or another employee. The Person concerned is free, it is also, in connection with the use of information society services, and notwithstanding Directive 2002/58/EC, your right of objection by means of automated procedures to exercise, in which technical specifications are used.
h) Automated decisions in individual cases including Profiling
Each of the processing of personal data concerned Person by the European Directive and regulation giver right granted, not exclusively on automated processing — including Profiling — to be based decision subject to the deployed against legal effect or similarly significantly not affected, as long as the decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller or (2) due to the laws of the Union or of the member States to which the Controller is subject, is admissible and that legislation appropriate measures to safeguard the rights and freedoms and the legitimate interests of the data subject or (3) with the Express consent of the affected Person.
The decision (1) is necessary for the conclusion or performance of a contract between the data subject and the controller is required, or (2) takes place with the Express consent of the Person concerned, the Network Engineering GmbH appropriate measures to safeguard the rights and freedoms and the legitimate interests of the Person concerned, including at least the right to obtain the intervention of a Person on the part of those responsible, to a statement of his own position and to contest the decision.
The affected Person wishes to make rights with respect to automated decisions, you can do so at any time contact an employee of the data controller.
i) right to revoke a data protection consent
Each of the processing of personal data concerned Person by the European Directive and regulation giver right granted your consent to the processing of personal data at any time, to revoke it.
The affected Person wishes to exercise their right to withdrawal of consent, a claim, you can do so at any time contact an employee of the data controller.
11. Data protection for applications and the application procedures
The Controller collects and processes the personal data of applicants for the purpose of processing of the application procedure. The processing may also be carried out electronically. This is particularly the case if an applicant documents appropriate application by electronic means, for example, by E-Mail or via a website owned web form, to the controller transmitted. The saved person Responsible for processing an employment contract with an applicant, the submitted data for the purpose of processing the employment relationship in compliance with legal regulations. Is closed by the controller is not a contract of employment with the applicant, the documents will be deleted two months after notification of the refusal decision automatically, if deletion is no other legitimate interests of the controller. Other legitimate interest in this sense is, for example, a burden of proof in a procedure under the General equal treatment act (AGG).
12. Data protection provisions for the application and use of Matomo
The Controller has integrated on this website the component Matomo. Matomo is an Open Source software tool for Web analysis. Web analysis is the survey, collection and analysis of data about the behavior of visitors from Internet sites. A Web analysis Tool collects, among other things, data about from which website a Person concerned is a website come (the so-called Referrer), which was accessed pages of the website, or how often and for which length of stay a subpage considered. A Web analysis is mainly Use for the optimization of a website and for cost-benefit analysis of Internet advertising used.
The Software is operated on the Server of the controller, the data protection legally sensitive log files are stored exclusively on this Server.
The purpose of the Matomo component is the analysis of the visitor flows on our website. The Controller uses the obtained data and information, inter alia, the use of this website, compiling Online Reports, which show the activities on our Internet pages, to compile.
Matomo sets a Cookie on the information technology System of the data subject. What Cookies are has already been explained above. With the setting of the Cookies allows us to analyse the use of our website. Through each call to one of the individual pages of this Internet site, the Internet browser on the information technology System of the Person concerned is automatically through the Matomo component prompted to submit data for the purpose of Online analysis to our Server In the framework of this technical procedure, we obtain knowledge about personal information, such as the IP address of the data subject, which serves, among other things, the origin of visitors and clicks, to understand.
By means of the cookie, personal information will be assumed, such as the access time, the location from which the access, and the frequency of visits of our website is stored. With each visit of our Internet pages, these personal data will be transferred, including the IP address used by the Person concerned Internet connection to our Server. These personal data will be stored by us. We do not share this personal data to third parties.
The affected Person can prevent the setting of Cookies by our website, as stated above, at any time, by means of a corresponding setting of the Internet browser used, and thus the setting of Cookies permanently. Such an adjustment to the used Internet browser would also prevent Matomo sets a Cookie on the information technology System of the data subject. In addition, a Matomo already set cookies can be deleted at any time via an Internet browser or other software programs.
Furthermore, the possibility of an acquisition by the Matomo generated, to speak to a use of this website-related data and to prevent the such is for the affected Person. For this purpose, the data subject must set your Browser to “Do Not Track”.
With the setting of the Opt-Out-Cookies for the possibility that the websites are of the controller for the affected Person to the full extent usable, however.
Further information and the applicable data protection provisions of Matomo may https://matomo.org/privacy/ be retrieved.
13. The legal basis for the processing
Article 6 I lit. a DS-GMO serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. The processing of personal data to fulfil a contract whose contractual party is the data subject is required, as is for example, when processing operations are required for delivery of Goods or the provision of any other service or consideration, the processing is based on article 6 I lit. b DS-GMO. The same applies to such processing operations for the implementation of pre-contractual measures are required, for example in cases of enquiries to our products or services. Subject to our company with a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on article 6 I lit. c DS-GMO. In rare cases, the processing of personal data could become 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 would be injured in our company and his Name, his age, his health insurance would have to be passed data or other vital information to a doctor, hospital or other third parties. Then, the processing is article 6 I lit would. d DS-GMO are based. Ultimately, processing operations on article 6 I lit could. f DS-GMOs are based. On this legal basis, processing operations which are not covered by any of the aforementioned legal bases are based, when the processing to protect a legitimate interest of our company or a third party is not required, provided that the interests, fundamental rights and freedoms of the data subject. Such processing operations are permitted, in particular, because they were mentioned by the European legislator, especially. He represented to the extent of the view that a legitimate interest could be assumed if the data subject is a client of the controller (recital 47 sentence 2 DS-GMO).
14. The legitimate interests of processing by the controller or by a third party will be pursued
Based on the processing of personal data, article 6 I lit. f DS-GMO is our legitimate interest to carry out our business in favor of the well-being of all our employees and our shareholders.
15. Duration for which the personal data will be stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After the expiry of the deadline, the corresponding data is erased if they are to fulfil the contract or to initiate a Contract is required.
16. Legal or contractual provisions for the provision of the personal data; necessity for the conclusion of a contract; obligation of the data subject to provide the personal data; possible consequences of non-provision
We clarify also, that the provision of personal data is required for part required by law (e.g. tax regulations) or from contractual provisions (e.g. information on the contractual partner) result. Sometimes it can be a conclusion of the contract required that an affected Person provides us with personal data which must be processed by us. The data subject is, for example, obliged to provide us with personal data if our company concludes a contract. A non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before providing personal data by the person Concerned must contact the Affected person to one of our employees. Our staff will advise the Affected individual cases based on whether the provision of personal data is required by law or contract or for the conclusion of the contract is required, whether there is an obligation to provide the personal data to provide, and what are the consequences of non-provision of the personal data would have.
17. Existence of an automated decision-making
As a responsible company we refrain from automatic decision-making or Profiling.
Source: This privacy statement has been prepared in part by the data protection Declaration Generator of the DGD Deutsche Gesellschaft for privacy GmbH, as an External data protection officer in Munich, in cooperation with the data protection lawyer Christian Solmecke created.