I am very pleased about your interest in my website. Data protection has a particularly high priority for me. A use of my web pages is basically possible without any indication of personal data. However, if a person concerned wishes to make use of special services via my website, it may be necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, I generally obtain the consent of the person concerned.
The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the basic data protection regulation and in compliance with the country-specific data protection regulations applicable to me. By means of this data protection declaration, I would like to inform the public about the type, scope and purpose of the personal data collected, used and processed by me. Furthermore, this data protection declaration informs the persons concerned about their rights.
As the data controller, I have implemented numerous technical and organisational measures to ensure that the personal data processed via this website is protected as completely as possible. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to me by alternative means, for example by telephone.
My data protection statement is based on the terms used by the European legislator for directives and regulations when the Basic Data Protection Regulation (DS-GVO) was adopted. My data protection declaration should be easy to read and understand for the public as well as for my website visitors and business partners. To ensure this, I would like to explain the terms used in advance.
- (a) personal data: Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as ‘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, on-line identification, 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: any identified or identifiable natural person whose personal data are processed by the controller
- (c) “Processing” shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, organisation, filing, 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 automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular with a view to analysing or predicting aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, conduct, location or movement of that natural person
- (f) Pseudonymisation: Pseudonymisation is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data is not attributed to an identified or identifiable natural person.
- (g) Controller: Controller shall mean 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 national law, provision may be made for the controller or for the specific criteria for his or her designation in accordance with Union or national law.
- (h) Processor: a processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
- (i) Recipient: a natural or legal person, public authority, agency or any other body to whom personal data are disclosed, whether or not that person is a third party However, authorities which may receive personal data in the context of a specific investigation task under Union or national law shall not be considered as recipients.
- (j) Third party means any natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorized to process the personal data.
- (k) ‘consent’ shall mean any informed and unequivocal expression of the data subject’s free will in the specific case, in the form of a statement or any other unequivocal affirmative act by which the data subject signifies his or her consent to the processing of personal data relating to him or her
2. The name and address of the controller
Responsible in the sense of the basic data protection regulation, other data protection laws applicable in the member states of the European Union and other regulations of a data protection nature:
Dr Emmanuel Comte
Senior Research Fellow
Hellenic Foundation for European and Foreign Policy (ELIAMEP)
49, Vasilissis Sofias Avenue
These internet pages only use session cookies, which are deleted directly after the session.
Cookies are text files which are stored on a computer system via an Internet browser.
The person concerned can prevent the setting of cookies by our website at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the person concerned deactivates the setting of cookies in the Internet browser used, it is possible that not all functions of our website can be fully used.
4. Collection of general data and information
My website collects a number of general data and information every time a data subject or automated system accesses the website. This general data and information is stored in the log files of the server. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses my website (so-called referrer), (4) the sub-websites that are accessed via an accessing system to my website, (5) the date and time of an access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) other similar data and information which serve to prevent danger in the event of attacks on my information technology systems.
When using this general data and information, I do not draw any conclusions about the person concerned. This information is rather required to (1) deliver the contents of my website correctly, (2) optimize the contents of my website as well as the advertising for it, (3) to ensure the permanent functionality of my information technology systems and the technology of my website as well as (4) to provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber attack. These anonymously collected data and information are therefore evaluated by me statistically on the one hand and also with the aim of increasing data protection and data security, in order to ultimately ensure an optimum level of protection for the personal data processed by me. The anonymous data of the server log files are stored separately from all personal data provided by an affected person.
5. Routine deletion and blocking of personal data
The controller shall process and store personal data relating to the data subject only for the period of time necessary to achieve the purpose of storage or where provided for by the European legislator or other legislator in laws or regulations to which the controller is subject.
If the purpose of storage ceases to apply or if a storage period prescribed by the European Directives and Regulations or any other competent legislator expires, the personal data will be blocked or deleted as a matter of routine and in accordance with legal requirements.
6. Rights of the data subject
- (a) Right to confirmation: Every data subject has the right granted by the European Directive and Regulation to obtain confirmation from the controller as to whether personal data relating to him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may contact me at any time.
- (b) Right of access: every person concerned by the processing of personal data has the right to obtain at any time from the controller, free of charge, information on personal data relating to him/her and a copy thereof. Furthermore, the European Directive and Regulation Giver has granted the data subject the right of access to the following information:Furthermore, the data subject has the right of access to information on whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject also has the right to be informed about the appropriate safeguards in relation to the transfer and, if he or she wishes to exercise this right, he or she may contact me at any time.
- the processing purposes
- the categories of personal data processed
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular to recipients in third countries or international organisations
- if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
- the existence of a right of rectification or erasure of personal data concerning him or her or of a restriction on processing by the controller or a right to object to such processing
- the existence of a right of appeal to a supervisory authority
- if the personal data are not collected from the data subject: All available information on the origin of the data
- the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the DPA and, at least in these cases, meaningful information about the logic involved and the scope and intended impact of such processing on the data subject
- (c) Right of rectification: Any person concerned by the processing of personal data shall have the right to obtain the rectification without delay of inaccurate personal data relating to him/her, as granted by the European legislator. Furthermore, the data subject shall have the right to request the completion of incomplete personal data, including by means of a supplementary declaration, having regard to the purposes of the processing operation. If a data subject wishes to exercise this right of rectification, he may contact me at any time.
- (d) Right to erasure (right to be forgotten) Any person affected by the processing of personal data has the right, granted by the European Directives and Regulations, to obtain from the controller the immediate erasure of personal data relating to him/her, if one of the following reasons applies and if the processing is not necessary:If one of the above reasons applies and a data subject wishes to have personal data held by me erased, he/she may contact me at any time. If the personal data have been made public by me and I am responsible according to Art. 17 para. 1 of the DS-GVO, I shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data controllers who process the published personal data that the data subject has requested these other data controllers to delete all links to these personal data or copies or replications of these personal data, unless the processing is necessary. I will arrange for the necessary in individual cases.
- The personal data has been collected or otherwise processed for purposes for which it is no longer necessary.
- The data subject withdraws the consent on which the processing was based in accordance with Article 6(1)(a) DPA or Article 9(2)(a) DPA and there is no other legal basis for the processing.
- The data subject lodges an objection to the processing pursuant to Article 21(1) DPA and there are no overriding legitimate reasons for the processing, or the data subject lodges an objection to the processing pursuant to Article 21(2) DPA.
- The personal data were processed unlawfully.
- The deletion of personal data is necessary to comply with a legal obligation under Union or national law to which the controller is subject.
- The personal data were collected in relation to information society services offered, in accordance with Article 8(1) of the DS-GVO.
- (e) Right to limit processingAny person affected by the processing of personal data has the right, granted by the European Directive and Regulation, to request the controller to limit the processing if one of the following conditions is met:If one of the above conditions is met and a data subject wishes to request the limitation of personal data held by me, he may contact me at any time to do so. I will arrange for the restriction of the processing.
- The accuracy of the personal data is contested by the data subject, for a period of time that allows the controller to verify the accuracy of the personal data.
- The processing is unlawful, the data subject refuses the deletion of the personal data and instead requests the restriction of the use of the personal data.
- The controller no longer needs the personal data for the purposes of the processing, but the data subject needs them in order to assert, exercise or defend legal claims.
- The data subject has lodged an objection to the processing pursuant to Art. 21 (1) DPA and it is not yet clear whether the legitimate reasons of the controller outweigh those of the data subject.
- (f) Right to data transfer: Any person concerned by the processing of personal data has the right, granted by the European Directive and Regulation, to receive the personal data concerning him/her which have been made available to a controller by the data subject in a structured, common and machine-readable format. He or she also has the right to have this data communicated to another controller without hindrance by the controller to whom the personal data has been made available, provided that the processing is based on the consent pursuant to Article 6 paragraph 1 letter a DPA or Article 9 paragraph 2 letter a DPA or on a contract pursuant to Article 6 paragraph 1 letter b DPA and that the processing is carried out by means of automated procedures, unless the processing is 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, when exercising their right to data transferability pursuant to Art. 20 Paragraph 1 of the DPA, the data subject has the right to request that personal data be transferred directly from one controller to another controller, insofar as this is technically feasible and provided that this does not adversely affect the rights and freedoms of other persons.
- (g) Right of objection: every data subject has the right, granted by the European legislator, to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her carried out pursuant to Article 6(1)(e) or (f) of the DPA. This also applies to profiling based on these provisions.I shall no longer process personal data in the event of an objection, unless I can demonstrate compelling legitimate reasons for processing which are overridden by the interests, rights and freedoms of the data subject or if the processing is carried out for the purpose of asserting, exercising or defending legal claims.If I process personal data for the purpose of direct marketing, the data subject shall have the right to object at any time to the processing of personal data for the purpose of such marketing. This also applies to profiling, insofar as it is related to such direct marketing. If the data subject objects to me being processed for the purposes of direct marketing, I will no longer process the personal data for those purposes. Furthermore, the data subject has the right to object, for reasons arising from his or her particular situation, to the processing of personal data relating to him or her which is carried out by me for the purposes of scientific or historical research or for statistical purposes in accordance with Article 89 (1) of the DPA, unless such processing is necessary for the performance of a task carried out in the public interest. To exercise the right of objection, the data subject may contact me directly. The data subject is also free to exercise his right of objection in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures involving technical specifications.
- (h) Automated case-by-case decisions including profiling: Any person concerned by the processing of personal data has the right granted by the European Directive and Regulation Giver not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects him or her in a similar way, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorised by Union or national legislation to which the controller is subject and such legislation provides for adequate measures to safeguard the rights and freedoms and legitimate interests of the data subject, or (3) is made with the explicit consent of the data subject.Where the decision is (1) necessary for the conclusion or performance of a contract between the data subject and the controller or (2) with the express consent of the data subject, I shall take appropriate measures to safeguard the rights and freedoms and the legitimate interests of the data subject, including at least the right to obtain the intervention of the controller, to put forward his point of view and to challenge the decision.
- (i) Right to revoke a data protection consent: Every person affected by the processing of personal data has the right granted by the European Directive and Regulation Giver to revoke his or her consent to the processing of personal data at any time.
7. The legal basis of the processing
Art. 6 I lit. a DS-GVO serves me as a legal basis for processing operations for which I 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, with processing operations necessary for the supply of goods or provision of another service or consideration, the processing is based on Article 6 I lit. b of the DPA. The same applies to such processing operations which are necessary to carry out pre-contractual measures, for example in cases of enquiries about my services. If my activity is subject to a legal obligation which makes the processing of personal data necessary, for example to fulfil tax obligations, the processing is based on Art. 6 I lit. c DS-GVO. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on my premises and his name, age, health insurance details or other vital information were subsequently to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6 I lit. d DS-GVO. Finally, processing operations could be based on Art. 6 I lit. f DS-GVO. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of mine or of a third party, provided that the interests, fundamental rights and freedoms of the data subject do not prevail. I am permitted such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 of the DS-GVO).
8. Legitimate interests in the processing pursued by the controller or a third party
If the processing of personal data is based on Article 6 I lit. f DS-GVO, my legitimate interest is to carry out my business activities for the benefit of my well-being.
9. The duration for which the personal data are stored
The criterion for the duration of storage of personal data is the respective legal retention period. After expiry of the period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfilment or initiation of the contract.
10. Legal or contractual provisions making the personal data available; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-supply
I would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded that a data subject provides me with personal data which I must subsequently process. For example, the data subject is obliged to provide me with personal data if I conclude a contract with him/her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before the data subject provides personal data, the data subject must contact me. I will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided.
11. Existence of automated decision making
As a responsible freelancer I abstain from automatic decision making or profiling.