Data protection is of great importance to us. Generally speaking, you can use our website without
providing personal data. If a data subject wishes to use special services of our company through our
website, however, it might be necessary to process personal data. If the processing of personal data is
necessary and there are no legal grounds on which to process such data, we will seek the consent of the
and understandable for the public as well as our customers and business partners. In order to ensure
this, we would like to take this opportunity to provide definitions for the terminology used herein.
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
The data subject is an identified or identifiable natural person whose personal data are processed
by the controller.
Processing means 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’ means the marking of stored personal data with the aim of limiting their
processing in the future.
‘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.
‘Controller means the natural or legal person, public authority, agency or other body which, alone
or jointly with others, determines the purposes and means of the processing of personal data. 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
‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
‘Recipient’ means a natural or legal person, public authority, agency or another 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 are not regarded as recipients.
i) Third party
‘Third party’ means 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.
‘Consent’ of the data subject means 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.
2. Name and address of the controller
The controller in the sense of the GDPR, other data protection acts in the Member States of the EU
and other data protection regulations is:
If he/she has any questions or suggestions concerning data protection, the data subject can contact
our office at any time under www.ctlsoftware.eu
identifier for the cookie. It consists of a sequence of characters which allow websites and servers
to be associated with the specific browser in which the cookie was stored. This makes it possible
for the visited websites and servers to differentiate between the individual browser of the data
subject and other browsers that contain cookies. A certain browser can be recognised and identified
by its unique cookie ID.
Using cookies, we can provide visitors to this website with more user-friendly services that would
not be possible without a cookie.
With a cookie, the information, products and services on our website can be optimised based on the
interests of the user. Cookies enable us to recognise each user of our website. The purpose of this
recognition is to make it easier for users to use our website. For example, the user of a website
website because the details are stored by the website and the cookie on the user’s computer. Another
example is the cookie for a basket in an online shop. Using a cookie, the online shop takes note of
the items that a customer places in his or her virtual basket.
The data subject can prevent our website from using cookies by changing the settings of his or her
browser and in doing so, deactivate cookies permanently. Furthermore, cookies that are already on
the computer can be erased at any time through a browser or other software. This feature is provided
by all standard Internet browsers. If the user deactivates cookies in his or her browser, the user
might not be able to use all of the features of our website to their full extent.
We use performance and tracking cookies internally to enable us to provide you with a better user
experience. Information supplied by these cookies helps us understand how our visitors behave on
this website, track unique visitors or time spent on the site, and on different web pages so that we
can improve how we present content to you.
5. Contact through the website
In accordance with the statutory regulations, our website contains information (including an email
address) that enables you to contact our company electronically and communicate with us directly. If
a data subject contacts the controller by email or through a contact form, the personal data
transmitted by the data subject are stored automatically. Personal data that have been provided to
the controller voluntarily by a data subject are used for the purposes of processing enquiries or
contacting the data subject. These personal data are not shared with third parties
6. Routine erasure and blocking of personal data
The controller only processes and stores personal data relating to the data subject for the period
that is necessary in order to fulfil the purpose for which the data are being stored or for the
period prescribed by the European Commission or other legislators in laws or regulations to which
the controller is subject.
When the purpose for which the data are being stored no longer applies or if a storage period
prescribed by the European Commission or another legislator expires, the personal data will be
blocked or erased routinely and in line with the statutory regulations.
7. Rights of the data subject
a) Right to confirmation
The European Commission grants the data subject the right to obtain from the controller confirmation
as to whether or not personal data concerning him or her are being processed. If a data subject
wishes to exercise this right to confirmation, he or she can contact an employee of the controller
at any time.
b) Right of access
The European Commission grants the data subject the right to obtain from the controller, at any
time, free information about the personal data concerning him or her that it has stored, and to
receive a copy of the information. Furthermore, the European Commission grants the data subject the
right to access the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipient 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 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 individual decision-making, including profiling, in the sense of
Article 22, paragraphs 1 and 4, of the GDPR and at least in these cases – meaningful
information about the logic involved, as well as the significance and the envisaged
consequences of such processing for the data subject. Furthermore, the data subject has the
right to be informed if personal data have been transferred to a third country or to an
international organisation. Where this is the case, the data subject has the right to be
informed of the appropriate safeguards relating to the transfer. If a data subject wishes to
exercise this right of access, he or she can contact an employee of the controller at any
c) Right to rectification
The European Commission grants the data subject the right 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 has 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 can contact an employee
of the controller at any time.
d) Right to erasure
The European Commission grants the data subject the right 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 and
where the processing of the data 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 on which the processing is based according to point (a)
of Article 6, paragraph 1, of the GDPR, or point (a) of Article 9, paragraph 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, paragraph 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, paragraph 2, of the GDPR;
the personal data have been unlawfully processed;
the personal data have to 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, paragraph 1, of the GDPR.
If any of the criteria above are met and the data subject wishes to have us erase the personal data
that we are storing, the data subject can contact an employee of the controller at any time. The
employee will ensure that the request for erasure is fulfilled without undue delay.
Where we have made the personal data public and are, as the controller, obliged pursuant to Article
17, paragraph 1, of the GDPR to erase the personal data, we, 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 the data subject has requested the erasure
by such controllers of any links to, or copies or replications of, those personal data. On an
individual basis, our employee will initiate the necessary measures.
e) Right to restriction of processing
The European Commission grants the data subject the right 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 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
the data subject has objected to processing pursuant to Article 21, paragraph 1, of the GDPR
pending the verification whether the legitimate grounds of the controller override those of
the data subject.
If any of the criteria above are met and the data subject wishes to request the restriction of
personal data that we are storing, the data subject can contact an employee of the controller at any
time. Our employee will have the processing of the data restricted.
f) Right to data portability
The European Commission grants the data subject the right to receive the personal data concerning
him or her, which he or she has provided to a controller, in a structured, commonly used and
machine-readable format The data subject also has the right to transmit those data to another
controller without hindrance from the controller to which the personal data have been provided,
where the processing is based on consent pursuant to point (a) of Article 6, paragraph 1, of the
GDPR or point (a) of Article 9, paragraph 2, of the GDPR or on a contract pursuant to point (b) of
Article 6, paragraph 1, of the GDPR, and the processing is carried out by automated means; this
right does not apply to processing 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, paragraph 1,
of the GDPR, the data subject has the right to have the personal data transmitted directly from one
controller to another, where technically feasible, provided that this does not adversely affect the
rights and freedoms of others.
The data subject can contact one of our employees at any time in order to exercise this right to
g) Right to object
The European Commission grants the data subject the right 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, paragraph 1, of the GDPR, including profiling based on those
We shall no longer process the personal data unless we 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.
Where personal data are processed for direct marketing purposes, the data subject has the right to
object at any time to processing of personal data concerning him or her for such marketing, which
includes profiling to the extent that it is related to such direct marketing. Where the data subject
objects to processing for direct marketing purposes, the personal data shall no longer be processed
for such purposes.
Where personal data are processed for scientific or historical research purposes or statistical
purposes pursuant to Article 89, paragraph 1, of the GDPR, the data subject, on grounds relating to
his or her particular situation, has the right to object to processing of personal data concerning
him or her, unless the processing is necessary for the performance of a task carried out for reasons
of public interest.
The data subject can contact one of our employees at any time in order to exercise this right to
object. In the context of the use of information society services, and Directive 2002/58/EC
notwithstanding, the data subject may also exercise his or her right to object by automated means
using technical specifications.
h) Automated individual decision-making, including profiling
The European Commission grants the data subject the right 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, unless the decision (1) is necessary for entering
into, or performance of, a contract between the data subject and a data controller, or (2) is
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 based on the data subject’s explicit consent.
If the decision is (1) necessary for entering into, or performance of, a contract between the data
subject and the data controller, or (2) based on the data subject’s explicit consent, we 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 to contest the decision.
If a data subject wishes to exercise rights in connection with automated decision-making, he or she
can contact an employee of the controller at any time.
i) Right to withdraw consent
The European Commission grants the data subject the right to withdraw consent to the processing of
personal data at any time.
If a data subject wishes to exercise his or her right to withdraw consent, he or she can contact an
employee of the controller at any time.
The controller has integrated the component Google Analytics (with anonymisation active) into this
website. Google Analytics is a web analytics service. Web analytics is the collection and evaluation
of data relating to the usage habits of website users. For example, a web analytics service collects
data relating to the website the data subject was visiting prior to the current website (the
referrer), what pages of the website are accessed or how often or for how long a page is viewed. A
web analytics service is primarily used to optimise a website and to analyse the cost-effectiveness
of Internet advertising.
Google Analytics is operated by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351,
The controller uses the tag ‘_gat._anonymizeIp’ in Google Analytics. When this tag is active, the IP
address of the data subject is shortened and anonymised by Google if our website is accessed from a
Member State of the EU or from another signatory to the Agreement on the European Economic Area.
The purpose of Google Analytics is to analyse visits to our website. For example, Google uses the
data and information it obtains in this way to evaluate the use of our website, compile online
reports on website activity and provide us with other services in connection with the use of our
Google Analytics installs a cookie on the computer of the data subject. Cookies are defined above.
The installation of the cookie enables Google to analyse how our website is used. Whenever the data
subject visits one of the pages of the website of the controller on which Google Analytics is
active, Google Analytics has the browser on the IT system of the data subject automatically transmit
data to Google for online analysis. Through this technical process, Google gains access to personal
data such as the IP address of the data subject which enable Google to track the origins of visitors
and clicks and then calculate commission.
The cookie stores personal information such as the date and time of the visit, the location from
which the website is being visited and the frequency of visits to our website by the data subject.
Whenever the data subject visits our website, these personal data, including the IP address of the
data subject, are transmitted to Google in the USA. Google stores these personal data in the USA.
Under certain circumstances, Google shares these personal data with third parties.
The data subject can prevent our website from using cookies as described above by changing the
settings of his or her browser and in doing so, deactivate cookies permanently. Changing browser
settings in this way would also prevent Google from installing a cookie on the IT system of the data
subject. Additionally, cookies that have already been installed by Google Analytics can be erased at
any time through the browser or using other software.
Furthermore, the data subject can object to and prevent the collection and processing of the data
generated by Google Analytics relating to the use of this website. To do so, the data subject must
download and install a browser add-on from https://tools.google.com/dlpage/gaoptout. Through
of website may be transmitted to Google Analytics. Google views the installation of the browser
add-on as an objection. If, at a later date, the IT system of the data subject is erased, formatted
or reinstalled, the data subject must re-install the browser add-on in order to deactivate Google
Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person
in the sphere of control of the data subject, the browser add-on can be reinstalled or reactivated.
https://www.google.de/intl/us/policies/privacy/ and http://www.google.com/analytics/terms/us.html.
For more details about Google Analytics, see https://www.google.com/intl/us/analytics/.
9. Legal grounds for processing
Point (a) of Article 6, paragraph 1, of the GDPR serves as the legal grounds if we obtain your
to process your data for a specific purpose. Point (b) of Article 6, paragraph 1, of the GDPR serves
the legal grounds if the processing of personal data is necessary in order to perform a contract to
which the data subject is party, as is the case with the processing necessary for the delivery of
or the performance of another service or consideration. The same applies to processing that is
to take steps prior to entering into a contract, e.g. queries regarding our products or services.
(c) of Article 6, paragraph 1, of the GDPR serves as the legal grounds if the processing of personal
data is necessary in order for our company to comply with a legal obligation, e.g. the fulfilment of
duties under tax law. In rare cases, it might be necessary to process personal data in order to
the vital interests of the data subject or the vital interests of another natural person. This would
the case, for example, if a visitor to our company were injured and his or her name, age, health
insurance data or other vital information had to be disclosed to a doctor, hospital or other third
party. The processing would then be based on point (d) of Article 6, paragraph 1, of the GDPR.
processing might be based on point (f) of Article 6, paragraph 1, of the GDPR. Point (f) of Article
paragraph 1, of the GDPR serves as legal grounds where processing is necessary for the purposes of
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. Therefore, such
processing is admissible because it has been mentioned by European legislators. In this context, the
European Commission is of the opinion that a legitimate interest could be assumed if the data
a customer of the controller (Recital 47, line 2, of the GDPR).
10. Legitimate interests in processing pursued by the controller or a third party
If personal data are being processed on the basis of point (f) of Article 6, paragraph 1, of the
our legitimate interest is the performance of our business activities for the well-being of all of
employees and shareholders.
11. Duration for which personal data may be stored
The relevant statutory storage period determines the period of time for which personal data may be
stored. Upon expiry of this deadline, the data in question are routinely erased unless they are
necessary for the performance or initiation of a contract.
12. Legal or contractual regulations on the provision of personal data; necessity for the
conclusion of a contract; obligation of the data subject to provide personal data; potential
consequences of refusal to provide personal data
Please be aware that the provision of personal data is legally mandatory to a certain extent (e.g.
regulations) or might be required by contractual provisions (e.g. information about a contractual
partner). Occasionally, for the purposes of concluding a contract, it might be necessary for a data
subject to provide us with personal data that we will then have to process. For example, the data
subject is obliged to provide us with personal data if our company enters into a contract with him
her. A refusal to provide personal data will make it impossible to conclude the contract with the
subject. Before the data subject provides personal data, he or she must contact one of our
Our employee will then notify the data subject of whether the provision of personal data is legally
contractually mandatory, whether it is necessary for the conclusion of a contract, whether the data
subject is obliged to provide the personal data and what consequences a refusal to provide personal
13. Existence of automated decision-making
As a conscientious company, we do not use automated decision-making or profiling.