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
the Sandig Software Productions GmbH.
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, the Sandig Software Productions GmbH 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 — excluded from that are
orders of products offered on our website, because the product itself as well as the invoice is
always delivered online via Internet.
1. Definitions
The data protection declaration of the Sandig Software Productions GmbH 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
Controller or controller responsible for the processing is the natural or legal person,
public authority, agency or other body which, alone or jointly with others, determines the
purposes and means of the processing of personal data; 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
Processor is a natural or legal person, public authority, agency or other body which
processes personal data on behalf of the controller.
i) Recipient
Recipient is a natural or legal person, public authority, agency or 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 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
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.
2. Name and Address of the controller
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:
Sandig Software Productions GmbH
Schleifmühle 12
91320 Ebermannstadt
Germany
Tel.: +49 (0)9194 7946 55
E-Mail: sandig.com
Website: https://www.sandig.com
3. Cookies
The Internet pages of the Sandig Software Productions GmbH 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, the Sandig Software Productions GmbH 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.
4. Collection of general data and information
The website of the Sandig Software Productions GmbH 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, the Sandig Software Productions GmbH 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, the Sandig Software Productions
GmbH analyzes 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.
5. Registration on our website
The data subject has the possibility to register on the website of the controller with the indication of
personal data. Which personal data are transmitted to the controller is determined by the respective input
mask used for the registration. The personal data entered by the data subject are collected and stored
exclusively for internal use by the controller, and for his own purposes. The controller may request
transfer to one or more processors (e.g. a parcel service) that also uses personal data for an
internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the Internet service
provider (ISP) and used by the data subject—date, and time of the registration are also stored.
The storage of this data takes place against the background that this is the only way to prevent the
misuse of our services, and, if necessary, to make it possible to investigate committed offenses.
Insofar, the storage of this data is necessary to secure the controller. This data is not passed on
to third parties unless there is a statutory obligation to pass on the data, or if the transfer
serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended
to enable the controller to offer the data subject contents or services that may only be offered
to registered users due to the nature of the matter in question. Registered persons are free to
change the personal data specified during the registration at any time, or to have them completely
deleted from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to
what personal data are stored about the data subject. In addition, the data controller shall correct
or erase personal data at the request or indication of the data subject, insofar as there are no
statutory storage obligations. The entirety of the controller’s employees are available to the data
subject in this respect as contact persons.
6. Contact possibility via the website
The website of the Sandig Software Productions GmbH 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.
7. 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.
8. 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 the Sandig Software Productions GmbH, he or she may,
at any time, contact any employee of the controller. An employee of Sandig Software
Productions GmbH 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 the Sandig Software Productions GmbH 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 the Sandig Software
Productions GmbH, he or she may at any time contact any employee of the controller.
The employee of the Sandig Software Productions GmbH 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 the Sandig Software Productions GmbH.
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.
The Sandig Software Productions GmbH 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 the Sandig Software Productions GmbH 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
the Sandig Software Productions GmbH to the processing for direct marketing purposes,
the Sandig Software Productions GmbH 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 the
Sandig Software Productions GmbH 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
the Sandig Software Productions GmbH. 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,
the Sandig Software Productions GmbH 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 the Sandig Software Productions GmbH.
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 the Sandig Software Productions GmbH.
9. Social Networks
Sandig Software Productions GmbH has integrated a button for "sharing" visited pages on "Facebook".
This is a simple link that only contacts the social network when clicked.
Simply loading a page does not lead to immediate transmission of data to the social network.
10. 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 fulfillment 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. He considered that a legitimate interest could be assumed if the data
subject is a client of the controller (Recital 47 Sentence 2 GDPR).
11. 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 favor of the well-being of all our employees and the shareholders.
12. 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 fulfillment of the contract or the initiation of a contract.
13. 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
to conclude 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
any employee. The employee clarifies to 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.
14. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
This Privacy Policy has been created based on the text generated by the Privacy Policy Generator
of the German Association for Data Protection that was developed in cooperation with RC GmbH,
which sells used IT and the filesharing Lawyers from WBS-LAW.
