RFRERE
DEEN

Privacy Policy

I. Name and Contact Details of the Data Controller

Roel Frère Lindenstrasse 15 06686 Lützen Email: info@rfrere.com Tel: +49 34444909066

II. Hosting

The content of our website is hosted by the following provider:

Hostinger, UAB Švitrigailos g. 34 LT-03230 Vilnius Lithuania

The servers used for hosting are located in the Netherlands.

III. General Information on Data Processing

1. Scope of Processing Personal Data

We generally process our users' personal data only to the extent necessary for providing a functional website and our content and services. The processing of our users' personal data is regularly carried out only with the user's consent. An exception applies in cases where obtaining prior consent is not possible for practical reasons and the processing of the data is permitted by law.

2. Legal Basis for the Processing of Personal Data

Where we obtain the data subject's consent for the processing of personal data, Article 6.1 (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

When processing personal data that is necessary for the performance of a contract to which the data subject is a party, Article 6.1 (b) GDPR serves as the legal basis. This also applies to processing operations that are necessary for carrying out pre-contractual measures.

Where processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Article 6.1 (c) GDPR serves as the legal basis.

In the event that processing of personal data is necessary to protect the vital interests of the data subject or of another natural person, Article 6.1 (d) GDPR serves as the legal basis.

If processing is necessary for the purposes of the legitimate interests pursued by our company or a third party, and the interests or fundamental rights and freedoms of the data subject do not override those interests, then Article 6.1 (f) GDPR serves as the legal basis for the processing.

3. Data Deletion and Storage Period

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also take place if this has been provided for by European or national legislation in EU regulations, laws, or other provisions to which the controller is subject. Data will also be blocked or deleted when a storage period prescribed by the aforementioned regulations expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

IV. Provision of the Website and Creation of Log Files

1. Description and Scope of Data Processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer. This information is temporarily stored in a server log file until it is automatically deleted.

The following data is collected:

  • Browser type and version of your PC
  • User's operating system
  • Hostname of the accessing computer
  • IP address of the requesting computer
  • Date and time of access
  • URL from which you accessed our website
  • Websites accessed by the user's system via our website

2. Legal basis for data processing

The legal basis for the temporary storage of data and log files is Article 6.1 (f) GDPR.

3. Purpose of data processing

The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user's computer. For this purpose, the user's IP address must be stored for the duration of the session.

Storage in log files is carried out to ensure the functionality of the website. The data also helps us to technically optimize the website and to ensure the security of our IT systems. The data will not be used for marketing purposes.

Our legitimate interest in processing the data pursuant to Art. 6.1 (f) GDPR lies in these purposes.

4. Storage Period

The data will be deleted as soon as it is no longer required for the purpose for which it was collected. In the case of data collected to provide the website, this is the case when the respective session ends.

In the case of data stored in log files, this is the case after a maximum of seven days. Further storage is possible. In this case, the users' IP addresses will be deleted or anonymized so that they cannot be associated with a specific individual.

5. Right to Object and Erasure

The collection of data for the provision of the website and the storage of data in log files is essential for the operation of the website. Therefore, users have no right to object.

V. Use of Cookies

1. Description and Scope of Data Processing

Our website uses cookies. Cookies are text files that are stored in the internet browser or by the internet browser on the user's computer system. When a user accesses a website, a cookie can be stored on the user's operating system. This cookie contains a characteristic string that enables the browser to be uniquely identified when the website is accessed again.

We use cookies to ensure the functionality of our website. Some elements of our website require that the accessing browser can be identified even after a page change.

Cookies are not capable of executing programs or transmitting viruses, Trojans, or other malware to your computer system.

The cookie stores information that relates to the specific device being used.

2. Legal Basis for Data Processing

The legal basis for processing personal data using technically necessary cookies pursuant to Section §25.2 of the German Telecommunications and Telemedia Data Protection Act (TTDSG) is Article 6.1(f) of the GDPR.

3. Purpose of Data Processing

The purpose of using technically necessary cookies is to enable users to use websites. Some functions of our website cannot be offered without the use of cookies. For these functions, it is necessary that the browser is recognized even after a page change.

We require cookies for the following applications:

  • Saving language settings

The user data collected by technically necessary cookies is not used to create user profiles.

Our legitimate interest in the subsequent processing of personal data pursuant to Article 6.(f) of the GDPR also lies in these purposes.

4. Storage Period, Right to Object and Erasure

Cookies are stored on the user's computer and transmitted from there to our website. Therefore, as a user, you have full control over the use of cookies. You can disable or restrict the storage of cookies by changing the settings in your internet browser. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, you may not be able to use all of the website's functions to their full extent.

5. Communication via WhatsApp

For communication with our customers and other third parties, we use, among other things, the instant messaging service WhatsApp. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Communication takes place via end-to-end encryption (peer-to-peer), which prevents WhatsApp or other third parties from accessing the content of the communication. However, WhatsApp does receive access to metadata generated during the communication process (e.g., sender, recipient, and time). We would also like to point out that, according to WhatsApp, it shares its users' personal data with its US-based parent company, Meta. Further details on data processing can be found in WhatsApp's privacy policy at: https://www.whatsapp.com/legal/#privacy-policy.

The use of WhatsApp is based on our legitimate interest in communicating with customers, prospective customers, and other business and contractual partners as quickly and effectively as possible (Art. 6.1 (f) GDPR). If corresponding consent has been requested, data processing is carried out exclusively on the basis of this consent; this consent can be revoked at any time with effect for the future.

The communication content exchanged between you and us on WhatsApp remains with us until you request its deletion, revoke your consent to its storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions – in particular, retention periods – remain unaffected.

The company is certified under the EU-US Data Privacy Framework (DPF). The DPF is an agreement between the European Union and the USA that aims to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to complying with these data protection standards.

Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/7735.

VI. Contact Form and Email Contact

1. Description and Scope of Data Processing

Our website includes a contact form that can be used for electronic communication. If a user chooses to use this form, the data entered in the input fields will be transmitted to us and stored. This data includes:

  • Name
  • Email address
  • Message
  • Consent for data processing

The following data is also stored at the time the message is sent:

  • The user's IP address
  • Date and time of transmission

Your consent for the processing of this data is obtained during the submission process, and you are referred to this privacy policy.

Alternatively, you can contact us via the provided email address. In this case, the user's personal data transmitted with the email will be stored.

In this context, the data will not be shared with third parties. The data will be used exclusively for processing the communication.

2. Legal Basis for Data Processing

The legal basis for processing the data, if the user has given their consent, is Article 6.1 (a) GDPR.

The legal basis for processing data transmitted via email is Article 6.1 (f) GDPR. If the email contact aims at concluding a contract, the additional legal basis for processing is Article 6.1 (b) GDPR.

3. Purpose of Data Processing

We process the personal data from the input form solely for the purpose of handling your inquiry. In the case of contact via email, this also constitutes the necessary legitimate interest in processing the data.

The other personal data processed during the sending process serves to prevent misuse of the contact form and to ensure the security of our IT systems.

4. Storage Period

The data will be deleted as soon as it is no longer necessary for the purpose for which it was collected. For personal data from the contact form and those transmitted via email, this is the case when the respective conversation with the user has ended. The conversation ends when it is clear from the circumstances that the matter in question has been resolved.

Any additional personal data collected during the sending process will be deleted no later than seven days after collection.

5. Right to Object and Erasure

The user has the right to withdraw their consent to the processing of their personal data at any time. If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.

If you wish to exercise your right to withdraw consent or object, simply send an email to the email address provided in the legal notice.

All personal data stored in connection with the contact will be deleted in this case.

VII. Web Analytics using Umami

1. Handling of Personal Data

We use the privacy-focused web analytics service Umami (Umami Software, Inc.), hosted in the EU on Umami's EU cloud infrastructure.

Umami does not use cookies and does not collect any personal data. No individual visitor is identified or tracked across sessions or devices. The service only records anonymised, aggregated statistics.

When individual pages of our website are accessed, the following anonymised data may be recorded:

  • The accessed web page
  • The website from which the user accessed the current web page (referrer)
  • Approximate visitor location (country/region, derived without storing the IP address)
  • Browser, operating system and device type
  • The duration of the visit to the web page

2. Legal basis for the processing of personal data

Because Umami collects no personal data and does not use cookies, no consent under the TTDSG is required. Insofar as any indirectly identifiable data is processed, the legal basis is our legitimate interest under Article 6.1 (f) GDPR in understanding how our website is used.

3. Purpose of data processing

The aggregated statistics allow us to understand how visitors use our website, such as the number of visits and the most popular pages, so we can continuously improve the website and its user-friendliness.

4. Storage Period

Aggregated visit statistics are retained for up to six months.

5. Right to Object

Since Umami does not use cookies or store personal data, there is no individual tracking to object to. If you have any questions about our use of Umami, you can contact us at the email address provided in the legal notice.

VIII. Rights of the Data Subject

1. Right of Access

You have the right to obtain from the controller confirmation as to whether or not personal data concerning you are being processed.

If such processing is taking place, you have the right to obtain from the controller the following information:

  1. the purposes of the processing;
  2. the categories of personal data concerned;
  3. the recipients or categories of recipients to whom the personal data have been or will be disclosed;
  4. the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  5. the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
  6. the right to lodge a complaint with a supervisory authority;
  7. where the personal data are not collected from the data subject, any available information as to their source;
  8. the existence of automated decision-making, including profiling, pursuant to Article 22.1 and 22.4 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 request information as to whether the personal data concerning you are transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.

2. Right to correction

You have the right to correction and/or completion vis-à-vis the controller if the processed personal data concerning you are inaccurate or incomplete. The controller must carry out the rectification without undue delay.

3. Right to Restriction of Processing

Under the following conditions, you may request the restriction of processing of your personal data:

  1. if you contest the accuracy of your personal data for a period enabling the controller to verify its accuracy;
  2. if the processing is unlawful and you oppose the deletion of the personal data and request the restriction of its use instead;
  3. if the controller no longer needs the personal data for the purposes of the processing, but you require it for the establishment, exercise, or defense of legal claims; or
  4. if you have objected to processing pursuant to Article 21.1 GDPR pending the verification of whether the legitimate grounds of the controller override your grounds.

If the processing of your personal data has been restricted, this data may – apart from being stored – only be processed with your consent or for the establishment, exercise, or defense 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 imposed under the aforementioned conditions, you will be informed by the controller before the restriction is lifted.

4. Right to Deletion

a) Obligation to Deletion

You have the right to request that the controller erase your personal data without undue delay, and the controller is obligated to erase such data without undue delay where one of the following grounds applies:

  1. The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  2. You withdraw your consent on which the processing is based according Article 6-1 (a) or Article 9.2 (a) GDPR, and there is no other legal ground 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 have been unlawfully processed.
  5. The erasure of your personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
  6. Your personal data was collected in relation to the offer of information society services referred to in Article 8.1 of the GDPR.

b) Information to third parties

Where the controller has made your personal data public and is obliged pursuant to Article 17.1 of the GDPR to delete it, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you, as the data subject, have requested the erasure by such controllers of any links to, or copies or replications of, those personal data.

c) Exceptions

The right to deletion does not apply to the extent that processing is necessary

  1. for exercising the right of freedom of expression and information;
  2. for compliance with a legal obligation to which the controller is subject under Union or Member State law, 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 Article 9.2 (h) and (i) and Article 9.3 of the GDPR;
  4. for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89.1 of the GDPR, insofar as the right referred to in point (a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  5. for the establishment, exercise, or defense of legal claims.

5. Right to Information

If you have asserted your right to correction, deletion, or restriction of processing against the controller, the controller is obligated to inform all recipients to whom your personal data has been disclosed of this correction, deletion, or restriction of processing, unless this proves impossible or involves disproportionate effort.

You have the right to be informed by the controller about these recipients.

6. Right to Data Transfer

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 was provided, where:

  1. the processing is based on consent pursuant to Article 6.1 (a) GDPR or Article 9.2 (a) GDPR or on a contract pursuant to Article 6.1 (b) GDPR;
  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. The rights and freedoms of other persons must not be adversely affected by this. 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) or (f) of the GDPR, including profiling based on those provisions.

The controller will no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of establishing, exercising or defending legal claims.

Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.