I. Name and address of Controller and of Data Protection Officer
The Controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States as well as other data protection
provisions is:
Centres for European Policy Network
Centrum für Europäische Politik
Stiftung Ordnungspolitik
Kaiser-Joseph-Str. 266
79098 Freiburg
Tel. +49 761 38693-220/ -221
Email: presse(at)cep.eu
The Controller’s Data Protection Officer: Christoph Ehlers
II. General information on data processing
1. Extent of the processing of personal data
As a matter of principle, we collect and use the personal data of our users only insofar as this is necessary for the provision of our website, our content and our services. The collection and use of our users‘ personal data generally takes place only with the consent of the user. An exception applies in cases where obtaining prior consent is not possible for practical reasons and processing the data is permitted under legal provisions. We process the following types of data:
– User data (e.g. websites visited, access times)
– Meta data/communication data (e.g. device information, IP addresses)
– Name, e-mail, telephone number and texts of messages that we have received by e-mail, telephone or post.
2. Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for processing operations involving personal data, Article 6 (1) (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.
Art. 6 (1) (b) GDPR provides the legal basis for processing personal data that is necessary for the performance of a contract to which the data subject is a party. This also applies to processing operations that are necessary in order to take steps prior to entering into a contract.
Insofar as processing is necessary for compliance with a legal obligation to which our company is subject, the legal basis for this is Art. 6 (1) (c) GDPR.
Where processing is necessary in order to protect the vital interests of the data subject or of another natural person, the legal basis is Art. 6 (1) (d) GDPR.
Where the processing is necessary to protect a legitimate interest of our company or a third party and this interest is not overridden by the interests and fundamental rights and freedoms of the data subject, Art. 6 (1) (f) GDPR provides the legal basis for the processing.
3. Erasure of data and storage period
The personal data of the data subject will be erased or blocked as soon as the purpose of the storage ceases to apply. Beyond that, storage may take place if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the Controller is subject. The data will also be blocked or erased upon the expiry of a storage period prescribed by the aforementioned provisions, unless continued storage of the data is necessary for the conclusion or fulfilment of a contract.
4. Transfers to third countries
Insofar as we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or this occurs as a result of using third-party services or disclosing or transferring data to third parties, this will only take place where it is necessary in order to fulfil our (pre-)contractual obligations; where it is based on your consent; where it is based on a legal obligation or where it is based on our legitimate interests. Subject to statutory or contractual permissions, we only process data, or allow data to be processed, in a third country if the specific conditions of Art. 44 et seq. GDPR are complied with. This means that the processing is carried out, for example, on the basis of specific guarantees, such as official recognition that there is a level of data protection corresponding to that of the EU (so-called „adequacy decision“) or compliance with specific, officially recognised contractual obligations (so-called „standard contractual clauses“).
III. Provisioning of website and creation of log files
1. Details and scope of data processing
Each time you visit our website, our internet provider IONOS automatically records data and information from the computer system of the visiting computer. The following data is collected and stored for eight weeks. The data is anonymised immediately upon collection:
1. Referrer (previously visited website)
2. Requested website or file
3. Browser type and version
4. Operating system used
5. Device type used
6. Time of access
7. IP address in anonymised form (only used to determine the location of access)
In addition, processing is carried out by WebAnalytics. The data will not be passed on to third parties and there will be no transfer to third countries outside the EU.
The data is stored in our system’s log files. This data is only required to analyse any malfunctions and is deleted after eight weeks. Legal basis for the temporary storage of data and log files is Art. 6 (1) (f) GDPR. Temporary storage of the IP address by the system is necessary in order to enable delivery of the website to the user’s computer. For this, the user’s IP address must be stored for the duration of the session. Storage takes place in log files to ensure the functionality of the website. In addition, we use the data to optimise the website and to ensure the security of our information technology systems. There is no evaluation of the data for marketing purposes in this context and the data cannot be used to identify you personally. These purposes also provide the basis for our legitimate interest in the data processing under Art. 6 (1) (f) GDPR. Collection of data for the purpose of providing the website, and storage of the data in log files, is essential for the operation of the website. The user therefore has no possibility to object.
2. Cookies
We use so-called session or flash cookies on our website and in our applications. Cookies are text files that are stored in or by the internet browser on the user’s computer system. When the user accesses a website, a cookie may be stored on the user’s operating system. This cookie contains a unique character string enabling the browser to be clearly identified the next time it accesses the website. Some functions of our website cannot be provided without the use of cookies. For these, the browser needs to be recognised when it returns to the site. The user data collected by technical cookies is not used to identify the user or create user profiles. The legal basis for the processing of personal data using technical cookies is Art. 6 (1) (f) GDPR.
The cookies are managed by Cookiebot from Usercentrics. For more information about the cookies used, click here.
IV. Order processing in third countries
For our website, we use the Gravatar service provided by the order processor Automattic (Aut O’Mattic Ltd.c/o GA, Business Centre, No.1 Lower Mayor Street, International Financial Services Centre, Dublin 1, Ireland). This also involves establishing a connection to the service provider’s servers in the USA, which results in the transmission of your IP address. This takes place on the basis of the EU standard contractual clauses and thus offers sufficient guarantees within the meaning of Art. 46 (1) and Art. 46 (2) (c) GDPR.
Use of the service is based on your consent under Art. 6 (1) (a) GDPR. You can withdraw your consent at any time by sending an e-mail to presse@cep.eu. Any data processing carried out prior to the withdrawal of consent remains unaffected by the withdrawal.
V. Web analysis with Matomo
1. Scope of the processing of personal data
We use the open source software tool Matomo (formerly PIWIK) on our website to analyse the surfing behaviour of our users. This is an open source tool for web analysis. Matomo does not transmit data to servers outside the control of the Stiftung Ordnungspolitik. Matomo does not collect session data without your consent.
Matomo uses cookies. These text files are stored on your computer and enable Stiftung Ordnungspolitik to analyse the use of its website. To this end, the information on usage obtained through the cookie is transmitted to the server of the Stiftung Ordnungspolitik and stored so that usage behaviour can be evaluated. Your IP address is an anonymous identifier for us; we have no technical means of identifying you as a registered user. You remain anonymous as a user.
The Stiftung Ordnungspolitik sees this analysis as part of its internet service. It would like to use it to further improve the website and adapt it even more to the needs of the users.
If you agree to web analysis using Matomo, the following data will be collected when you call up individual pages of our website:
(1) 2 bytes of the IP address of the user’s calling system.
(2) The web page called up
(3) The website from which the user accessed the accessed website (referrer)
(4) The sub-pages called up from the called-up website
(5) The time spent on the website
(6) The frequency with which the website is accessed
The software runs exclusively on the servers of our website. Personal data of the users is only stored there. The data is not passed on to third parties.
You can decide here whether a web analysis cookie may be stored in your browser to enable the Federal Press Office to collect and analyse statistical data.
2. Legal basis for the processing of personal data
The legal basis for the processing of users‘ personal data is Art. 6 (1) a DSGVO.
3. Purpose of the data processing
The processing of the users‘ personal data enables us to analyse the surfing behaviour of our users. By evaluating the data obtained, we are able to compile information on the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness. By anonymising the IP address, the interest of users in the protection of their personal data is adequately taken into account.
4. Duration of storage
The data is deleted as soon as it is no longer required for our recording purposes. The statistics generated and underlying data are not deleted.
5. Possibility of objection and removal
Cookies are stored on the user’s computer and transmitted to our site by the user. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your internet browser, you can deactivate or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all the functions of the website to their full extent.
You can find more information on the privacy settings of the Matomo software under the following link: https://matomo.org/docs/privacy/
VI. Contact
You can contact us by e-mail, telephone or post. The information you provide in your enquiry, including your contact details, will be stored by us solely for the purpose of processing your enquiry and in the event of follow-up questions. In this context, the data will not be passed on to third parties.
Legal basis for the processing of data is Art. 6 (1) (f) GDPR. Our interest in responding to your request overrides your interest; in addition, since you are writing to us, our response is also in your interest and you are aware that we need to process your data to respond to your enquiry.
Where the purpose of the email contact is to conclude a contract, the legal basis for processing it is Art. 6 (1) (b) GDPR.
Data is deleted as soon as it is no longer necessary for achieving the purpose for which it was collected. This is the case once the respective conversation with the user is at an end. The conversation is at an end when the circumstances indicate that the matter has been conclusively dealt with.
VII. Rights of the data subject
If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis à vis the Controller:
1. Right to information
You may require confirmation from the Controller as to whether personal data relating to you is being processed by us.
If such processing is taking place, you may require information from the Controller about the following:
(1) the purposes for which the personal data is being processed;
(2) the categories of personal data which are being processed;
(3) the recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;
(4) the planned duration of the period for which the personal data relating to you will be stored or, if specific information on this is not possible, criteria used to determine the storage period;
(5) the existence of a right to rectify or erase personal data concerning you, a right to the restriction of processing by the Controller or a right to object to such processing;
(6) the existence of a right to lodge a complaint with a supervisory authority;
(7) any available information on the source of the data if the personal data has not been collected from the data subject;
(8) the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for the data subject.
You have the right to receive information on whether personal data concerning you will be transferred to a third country or to an international organisation. In this context, you are entitled to be informed about the appropriate safeguards pursuant to Article 46 GDPR in connection with the transfer.
2. Right to rectification
You have a right to obtain rectification and/or completion from the Controller if the personal data concerning you that is being processed is inaccurate or incomplete. The Controller must effect the correction without undue delay.
3. Right to restriction of processing
You may require the restriction of the processing of personal data concerning you under the following conditions:
(1) for a period enabling the controller to verify the accuracy of the personal data where you contest the accuracy of the personal data concerning you;
(2) the processing is unlawful and you oppose the erasure of the personal data and request instead the restriction of the use of the personal data;
(3) the Controller no longer needs the personal data for the purposes of the processing but you require it for the establishment, exercise or defence of legal claims; or
(4) if you have objected to the processing pursuant to Art. 21 (1) GDPR and there has not yet been verification of whether the legitimate grounds of the Controller override your grounds.
Where the processing of personal data concerning you has been restricted, such data may – with the exception of storage – only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
If the restriction of processing has been obtained in accordance with the above conditions, you will be informed by the Controller before the restriction is lifted.
4. Right to erasure
a) Duty to erase
You may require the Controller to erase the personal data concerning you without undue delay and the Controller is obliged to erase this data without delay where one of the following grounds applies:
(1) The personal data concerning you is no longer necessary for the purposes for which it was collected or otherwise processed.
(2) You withdraw your consent on which the processing is based according to Art. 6 (1) (a) or Art. 9 (2) (a) GDPR and there is no other legal basis for the processing.
(3) You object to the processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21 (2) GDPR.
(4) The personal data concerning you has been unlawfully processed.
(5) The erasure of personal data concerning you is necessary for compliance with a legal obligation under Union or Member State law to which the Controller is subject.
(6) The personal data concerning you has been collected in relation to the offer of information society services pursuant to Art. 8 (1) GDPR.
b) Information to third parties
Where the Controller has made the personal data concerning you public and is obliged to erase it pursuant to Article 17 (1) GDPR, the Controller, taking account of the available technology and the cost of implementation, must take reasonable steps, including technical measures, to inform the data controllers processing the personal data that you, as the data subject, have requested the erasure of any links to, or copies or replications of, that personal data.
c) Exemptions
The right to erasure does not apply where processing is necessary
(1) to exercise the right to freedom of expression and information;
(2) for compliance with a legal obligation which requires processing under Union or Member State law to which the Controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
(3) for reasons of public interest in the area of public health in accordance with Art. 9 (2) (h) and (i) and Art. 9 (3) GDPR;
(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89 (1) GDPR, insofar as the rights referred to in Section (a) are likely to render impossible or seriously impair the achievement of the purposes of such processing; or
(5) to establish, exercise or defend legal claims.
5. Right to notification
If you have asserted the right to rectification, erasure or restriction of processing against the Controller, the Controller is obliged to communicate this rectification or erasure of the data or restriction of processing to all recipients to whom the personal data concerning you has been disclosed, unless this proves impossible or involves disproportionate effort.
You have the right to be informed about these recipients by the Controller.
6. Right to data portability
You have the right to receive the personal data concerning you which you have provided to the Controller in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to whom the personal data has been provided, where
(1) the processing is based on consent pursuant to Art. 6 (1) (a) GDPR or Art. 9 (2) (a) GDPR or on a contract pursuant to Art. 6 (1) (b) GDPR and
(2) the processing is carried out by automated means.
In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another, where technically feasible. This must not adversely affect the rights and freedoms of others.
The right to data portability does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.
7. Right to object
You have the right to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you which is based on Article 6 (1) (e) GDPR or on Article 6 (1) (f) GDPR; this also applies to profiling based on those provisions.
The Controller will no longer process your personal data unless he can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if processing serves the establishment, exercise or defence of legal claims.
Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you, for the purpose of such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for such purposes.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.
8. Right to withdraw the declaration of consent under data protection law
You have the right to withdraw your declaration of consent under data protection law at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
9. Automated individual decision-making, including profiling
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or has a similar detrimental effect on you. This does not apply if the decision
(1) is necessary for the conclusion or performance of a contract between you and the Controller,
(2) is permitted under Union or Member State legislation to which the Controller is subject and such legislation contains adequate measures to safeguard your rights and freedoms and your legitimate interests; or
(3) takes place with your explicit consent.
However, such decisions cannot be based on special categories of personal data pursuant to Art. 9 (1) GDPR, unless Art. 9 (2) (a) or (g) applies and appropriate measures have been taken to protect the rights and freedoms and your legitimate interests.
With regard to the cases referred to in paras (1) and (3), the Controller shall take reasonable steps to safeguard your rights and freedoms and your legitimate interests, which at least includes the right to obtain the intervention of a person on behalf of the Controller, the right to express your point of view and the right to contest the decision.
10. Right of complaint to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
The supervisory authority with which the complaint has been lodged will inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Art. 78 GDPR.