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Privacy Policy

Name and contact of the responsible person according to Article 4(7) DSGVO

Lothar Kahl & Partner
2150 Moravia La Guaria
San Jose
Costa Rica
Email: info@kahl-partner.com

Security and protection of your personal data

We consider it our primary responsibility to maintain the confidentiality of the personal information you provide to us and to protect it from unauthorized access. Therefore, we use extreme care and state-of-the-art security standards to ensure maximum protection of your personal data.

As a company under private law, we are subject to the provisions of the European General Data Protection Regulation (DSGVO) and the regulations of the German Federal Data Protection Act (BDSG). We have taken technical and organizational measures to ensure that the regulations on data protection are observed by us as well as by our external service providers.

Definitions

The legislator requires that personal data be processed in a lawful manner, in good faith and in a way that is comprehensible to the data subject (“lawfulness, processing in good faith, transparency”). To ensure this, we inform you about the individual legal definitions, which are also used in this privacy policy:

  1. Personal Data

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “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.

  1. Processing

“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

  1. Restriction of processing

“Restriction of processing” is the marking of stored personal data with the aim of limiting their future processing.

  1. Profiling

“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.

  1. Pseudonymization

“Pseudonymization” means 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 such additional information is kept separately and is subject to technical and organizational measures which ensure that the personal data cannot be attributed to an identified or identifiable natural person.

  1. File system

“File system” means any structured collection of personal data accessible according to specified criteria, whether that collection is maintained in a centralized, decentralized, or functional or geographic manner.

  1. Responsible

“Controller” means a 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 law or Member State law, the controller or the specific criteria for its designation may be provided for by Union law or Member State law.

  1. order processor
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“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

  1. Receiver

“Recipient” means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients; the processing of such data by the aforementioned authorities shall be carried out in accordance with the applicable data protection rules, in accordance with the purposes of the processing.

  1. Third

“Third party” means a natural or legal person, public authority, agency or other body, other than the data subject, the controller, the processor and the persons who, under the direct responsibility of the controller or the processor, are authorized to process the personal data.

  1. Consent

A “consent” of the data subject is any freely given specific, informed and unambiguous indication of his or her wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

Legality of processing

The processing of personal data is lawful only if there is a legal basis for the processing. According to Article 6 (1) lit. a – f DSGVO, the legal basis for processing may be in particular:

  1. The data subject has given consent to the processing of personal data concerning him or her for one or more specific purposes;
  2. processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the data subject’s request;
  3. processing is necessary for compliance with a legal obligation to which the controller is subject;
  4. processing is necessary in order to protect the vital interests of the data subject or of another natural person;
  5. 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;
  6. processing is necessary for the purposes of protecting the legitimate interests of the controller or of 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, in particular where the data subject is a child.

Information about the collection of personal data

(1) In the following, we inform about the collection of personal data when using our website. Personal data are, for example, name, address, e-mail addresses, user behavior.

(2) If you contact us by e-mail or via a contact form, the data you provide (your e-mail address, your name, if applicable, and your telephone number) will be stored by us in order to answer your questions. We delete the data accruing in this context after the storage is no longer necessary, or the processing is restricted if there are legal obligations to retain data.

Collection of personal data when visiting our website

When you use the website for informational purposes only, i.e., when you do not register or otherwise submit information to us, we collect only the personal data that your browser sends to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure stability and security (legal basis is Art. 6 para. 1 p. 1 lit. f DSGVO):

  • IP address
  • Date and time of the request
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of the request (specific page)
  • Access status/HTTP status code
  • Any transmitted data volume
  • Website from which the request comes
  • Browser
  • Operating system and its interface
  • Language and version of the browser software.

Use of cookies

(1) In addition to the previously mentioned data, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive associated with the browser you are using and through which certain information flows to the entity that sets the cookie. Cookies cannot execute programs or transfer viruses to your computer. They serve to make the Internet offer more user-friendly and effective overall

(2) This website uses the following types of cookies, the scope and functionality of which are explained below:

  • Transient cookies (to this a.)
  • Persistent cookies (to this b.).
  1. Transient cookies are automatically deleted when you close the browser. These include, in particular, session cookies. These store a so-called session ID, with which various requests of your browser can be assigned to the common session. This allows your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close the browser.
  2. Persistent cookies are deleted automatically after a specified period of time, which may differ depending on the cookie. You can delete the cookies in the security settings of your browser at any time.
  3. You can configure your browser setting according to your preferences and
    B. refuse to accept third-party cookies or all cookies. So-called “third party cookies” are cookies set by a third party, consequently not by the actual website you are on. Please note that by disabling cookies you may not be able to use all the features of this website.
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Other features and offers of our website

(1) In addition to the purely informational use of our website, we offer various services that you can use if you are interested. For this purpose, you will generally have to provide further personal data, which we use to provide the respective service and to which the aforementioned data processing principles apply.

(2) In some cases, we use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions and are regularly monitored.

(3) Furthermore, we may pass on your personal data to third parties if promotional participations, competitions, contract conclusions or similar services are offered by us together with partners. You will receive more information about this when you provide your personal data or below in the description of the offer.

(4) Insofar as our service providers or partners have their registered office in a state outside the European Economic Area (EEA), we will inform you of the consequences of this circumstance in the description of the offer.

Newsletter

(1) With your consent, you can subscribe to our newsletter, with which we will inform you about our current interesting offers. The goods and services advertised are named in the consent form.

(2) For the registration to our newsletter, we use the so-called double opt-in procedure. This means that after your registration, we will send you an e-mail to the e-mail address you have provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month. In addition, we store your respective IP addresses used and times of registration and confirmation. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.

(3) Mandatory information for sending the newsletter is only your e-mail address. The provision of further, separately marked data is voluntary and will be used to address you personally. After your confirmation, we store your e-mail address for the purpose of sending the newsletter. Legal basis is Art. 6 Para. 1 S. 1 lit. a DSGVO.

(4) You can revoke your consent to the sending of the newsletter at any time and unsubscribe from the newsletter. You can declare the revocation by clicking on the link provided in each newsletter e-mail, by e-mail to info@kahl-partner.com or by sending a message to the contact details provided in the imprint.

(5) We point out that we evaluate your user behavior when sending the newsletter. For this evaluation, the emails sent contain so-called web beacons or tracking pixels, which are single-pixel image files stored on our website. For the evaluations, we link the above-mentioned data and the web beacons with your e-mail address and an individual ID. The data is collected exclusively pseudonymously, i.e. the IDs are not linked to your other personal data, a direct personal reference is excluded. You can object to this tracking at any time by clicking on the separate link provided in each e-mail or by informing us via another contact channel. The information is stored for as long as you are subscribed to the newsletter. After unsubscribing, we store the data purely statistically and anonymously.

children

Our services are generally directed to adults. Persons under the age of 18 should not submit any personal information to us without the consent of their parents or guardians.

Rights of the data subject

(1) Withdrawal of consent

If the processing of personal data is based on a granted consent, you have the right to revoke the consent at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

For the exercise of the right of withdrawal, you can contact us at any time.

(2) Right of confirmation

You have the right to request confirmation from the controller as to whether we are processing personal data relating to you. You can request the confirmation at any time using the contact details above.

(3) Right to information

If personal data are processed, you can request information about these personal data and about the following information at any time:

  1. the purposes of the processing;
  2. the categories of personal data processed;
  3. the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations;
  4. 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;
  5. the existence of a right to rectification or erasure of the personal data concerning you or to restriction of processing by the controller or a right to object to such processing;
  6. the existence of a right of appeal to a supervisory authority;
  7. if the personal data are not collected from the data subject, any available information about the origin of the data;
  8. the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject.

If personal data are transferred to a third country or to an international organization, you have the right to be informed about the appropriate safeguards pursuant to Article 46 GDPR in connection with the transfer. We will provide a copy of the personal data that is the subject of the processing. For any additional copies you request person, we may charge a reasonable fee based on the administrative costs. If you make the request electronically, the information shall be provided in a commonly used electronic format, unless it specifies otherwise. The right to receive a copy under paragraph 3 shall not interfere with the rights and freedoms of other persons.

(4) Right of rectification  

You have the right to request that we correct any inaccurate personal data relating to you without undue delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary declaration.

(5) Right to erasure (“right to be forgotten”)

You have the right to request that the controller delete personal data concerning you without undue delay, and we are obliged to delete personal data without undue delay, if one of the following reasons applies:

  1. The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
  2. The data subject revokes the consent on which the processing was based pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR and there is no other legal basis for the processing.
  3. 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.
  4. The personal data have been processed unlawfully.
  5. The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
  6. The personal data have been collected in relation to information society services offered pursuant to Article 8(1) DSGVO.
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If the controller has made the personal data public and is obliged to erase it pursuant to paragraph 1, it shall take reasonable steps, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers which process the personal data that a data subject has requested that they erase all links to, or copies or replications of, such personal data.

The right to erasure (“right to be forgotten”) does not exist insofar as the processing is necessary:

  • to exercise the right to freedom of expression and information;
  • to comply with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • for reasons of public interest in the field of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the GDPR;
  • for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) of the GDPR, insofar as the right referred to in paragraph 1 is likely to make impossible or seriously prejudice the achievement of the purposes of such processing; or
  • for the establishment, exercise or defense of legal claims.

(6)  Right to restrict processing

You have the right to request us to restrict the processing of your personal data if one of the following conditions is met:

  1. 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,
  2. the processing is unlawful and the data subject objects to the erasure of the personal data and requests instead the restriction of the use of the personal data;
  3. the controller no longer needs the personal data for the purposes of the processing, but the data subject needs it for the establishment, exercise or defense of legal claims; or
  4. the data subject has objected to the processing pursuant to Article 21(1) of the GDPR for as long as it is not yet clear whether the legitimate grounds of the controller override those of the data subject.

Where processing has been restricted in accordance with the above conditions, such personal data shall be processed, apart from being stored, only with the consent of the data subject 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 substantial public interest of the Union or of a Member State.

To exercise the right to restrict processing, the data subject may contact us at any time using the contact details provided above.

(7) Right to data portability

You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, and you have the right to transfer that data to another controller without hindrance from the controller to whom the personal data was provided, provided that:

  1. the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b) of the GDPR and
  2. the processing is carried out by automated means.
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When exercising the right to data portability pursuant to paragraph 1, you have the right to obtain that the personal data be transferred directly from one controller to another controller, where technically feasible. The exercise of the right to data portability does not affect the right to erasure (“right to be forgotten”). 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.

(8) Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the DSGVO; this also applies to profiling based on these provisions. The controller shall no longer process the personal data unless it 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 defense of legal claims.

If personal data are processed for the purpose of direct marketing, you have the right to object at any time to processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing. If you object to processing for direct marketing purposes, the personal data will no longer be processed for these purposes.

In connection with the use of information society services, notwithstanding Directive 2002/58/EC, you may exercise your right to object by means of automated procedures using technical specifications.

You have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1), unless the processing is necessary for the performance of a task carried out in the public interest.

You may exercise the right to object at any time by contacting the respective controller.

(9) Automated decisions in individual cases, including profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision:

  1. is necessary for entering into, or the performance of, a contract between the data subject and the controller,
  2. is permitted by Union or Member State law to which the controller is subject, and that law contains suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or
  3. with the data subject’s explicit consent.
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The controller shall take reasonable steps to safeguard the data subject’s rights and freedoms and legitimate interests, which include at least the right to obtain the intervention of a data subject on the part of the controller, to express his or her point of view and to contest the decision.

The data subject may exercise this right at any time by contacting the relevant controller.

(10) Right to lodge a complaint with a supervisory authority

They shall also have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular in the Member State of their residence, their place of work or the place of the alleged infringement, if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

(11) Right to effective judicial remedy

You have the right to an effective judicial remedy, including the right to lodge a complaint with a supervisory authority pursuant to Article 77 GDPR, without prejudice to any available administrative or non-judicial remedy, if it considers that   your rights under this Regulation have been infringed as a result of the processing of your personal data not carried out in accordance with this Regulation.

Use of Google Analytics

(1) This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. In the event that IP anonymization is activated on this website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.

(2) The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.

(3) You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

(4) This website uses Google Analytics with the extension “_anonymizeIp()”. This means that IP addresses are processed in a shortened form, which means that it is not possible to relate them to a specific person. Insofar as the data collected about you a personal reference, this is therefore immediately excluded and the personal data is thus immediately deleted.

(5) We use Google Analytics to analyze and regularly improve the use of our website. Through the statistics obtained, we can improve our offer and make it more interesting for you as a user. The data is transferred to a Google server in the USA and stored there. The personal data is transmitted on the basis of Art. 46 and/or Art. 49 para. 1 lit. a) DSGVO. The legal basis for the use of Google Analytics is Art. 6 para. 1 p. 1 lit. f DSGVO.

(6) Third Party Provider Information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. User Terms:

http://www.google.com/analytics/terms/de.html, Privacy Policy Overview: http://www.google.com/intl/de/analytics/learn/privacy.html, and Privacy Policy: http://www.google.de/intl/de/policies/privacy.

(7) This website also uses Google Analytics for cross-device analysis of visitor flows, which is performed via a user ID. You can disable cross-device analysis of your usage in your customer account under “My Data”, “Personal Data”

Integration of Google Maps

(1) On this website we use the offer of Google Maps. This allows us to show you interactive maps directly in the website and enables you to use the map function conveniently.

(2) By visiting the website, Google receives the information that you have accessed the corresponding sub-page of our website. In addition, the data collected during the visit to our website is transmitted. This occurs regardless of whether Google provides a user account through which you are logged in or whether there is no user account. If you are logged in to Google, your data will be directly assigned to your account. If you do not want the assignment with your profile at Google, you must log out before activating the button. Google stores your data as usage profiles and uses them for the purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have a right to object to the creation of these user profiles, whereby you must contact Google to exercise this.

(3) Further information on the purpose and scope of the data collection and its processing by the plug-in provider can be found in the provider’s privacy policy. There you will also find further information on your rights in this regard and setting options for protecting your privacy: http://www.google.de/intl/de/policies/privacy. The data is transferred to a Google server in the USA and stored there. The personal data is transmitted on the basis of Art. 46 and/or Art. 49 para. 1 lit. a) DSGVO.