We are very delighted that you have shown interest in
our enterprise. Data protection is of a particularly high priority for the management of Rolke
Search Ltd. The use of the Internet pages of Rolke Search Ltd. 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 Rolke Search Ltd. 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, Rolke Search Ltd. 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.
Definitions
The data protection declaration of Rolke Search Ltd. 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
The Controller or the controller responsible for
the processing is the natural or legal person, public authority, agency or any 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
The Processor is a natural or legal person, public
authority, agency or any other body which processes personal data on behalf of the
controller.
i) Recipient
The Recipient is a natural or legal person, public authority,
agency or any other 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
The 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.
Name and Address of the controller
The 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:
Rolke Search
Ltd.
12a Tilton Street
SW6 7LP London
United Kingdonm
Phone: 0044 20
7386 3984
Email: christian@rolkesearch.com
Website:
rolkesearch.com
Cookies
The Internet pages of Rolke Search Ltd. 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 data 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, Rolke Search Ltd. 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.
Collection of general data and information
The website of Rolke
Search Ltd. 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, Rolke Search Ltd. 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, Rolke Search Ltd. analyses 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.
Contact possibility via the website
The website of Rolke Search Ltd. 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.
Comments function in the blog on the website
Rolke Search Ltd.
offers users the possibility to leave individual comments on individual blog contributions on a
blog, which is on the website of the controller. A blog is a web-based, publicly-accessible
portal, through which one or more people called bloggers or web-bloggers may post articles or
write down thoughts in so-called blogposts. Blogposts may usually be commented by third
parties.
If a data subject leaves a comment on the blog published on this website, the
comments made by the data subject are also stored and published, as well as information on the
date of the commentary and on the user’s (pseudonym) chosen by the data subject. In addition,
the IP address assigned by the Internet service provider (ISP) to the data subject is also
logged. This storage of the IP address takes place for security reasons, and in case the data
subject violates the rights of third parties or posts illegal content through a given comment.
The storage of these personal data is, therefore, in the own interest of the data controller, so
that he can exculpate in the event of an infringement. This collected personal data will not be
passed to third parties, unless such a transfer is required by law or serves the aim of the
defence of the data controller.
Subscription to comments in the blog on the
website
The comments made in the blog of Rolke Search Ltd. may be subscribed to by third
parties. In particular, there is the possibility that a commentator subscribes to the comments
following his comments on a particular blog post.
If a data subject decides to subscribe
to the option, the controller will send an automatic confirmation e-mail to check the double
opt-in procedure as to whether the owner of the specified e-mail address decided in favour of
this option. The option to subscribe to comments may be terminated at any time.
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.
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 any 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 any 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
any 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
Rolke Search Ltd., he or she may, at any time, contact any employee of the controller. An
employee of Rolke Search Ltd. 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. An employees of Rolke Search Ltd. 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 Rolke Search Ltd., he or
she may at any time contact any employee of the controller. The employee of Rolke Search Ltd.
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 any employee of Rolke Search Ltd.
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.
Rolke Search Ltd. 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 Rolke Search Ltd. 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 Rolke Search Ltd. to the processing for direct marketing purposes, Rolke Search Ltd.
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 Rolke Search Ltd. 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
any employee of Rolke Search Ltd. 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, Rolke
Search Ltd. 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, contact any employee of Rolke Search Ltd.
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, he or she
may, at any time, contact any employee of Rolke Search Ltd.
Data protection for
applications and the application procedures
The data controller shall collect and process the
personal data of applicants for the purpose of the processing of the application procedure. The
processing may also be carried out electronically. This is the case, in particular, if an
applicant submits corresponding application documents by e-mail or by means of a web form on the
website to the controller. If the data controller concludes an employment contract with an
applicant, the submitted data will be stored for the purpose of processing the employment
relationship in compliance with legal requirements. If no employment contract is concluded with
the applicant by the controller, the application documents shall be automatically erased two
months after notification of the refusal decision, provided that no other legitimate interests
of the controller are opposed to the erasure. Other legitimate interest in this relation is,
e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).
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 fulfilment 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. It considered that a legitimate interest
could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2
GDPR).
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 favour of the well-being of all our employees and the
shareholders.
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 fulfilment of the contract or the initiation of a
contract.
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 also result from
contractual provisions (e.g. information on the contractual partner). Sometimes it may be
necessary for the conclusion of 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 one of our employees. The employee clarifies with 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.
Existence of automated decision-making
As a
responsible company, we do not use automatic decision-making or profiling.
This Privacy
Policy has been generated by the Privacy Policy Generator of the DGD – Your External DPO that
was developed in cooperation with German Lawyers from WILDE BEUGER SOLMECKE, Cologne.