PRIVACY POLICY OF KLITSCHKO VENTURES GMBH FOR CUSTOMERS AND BUSINESS PARTNERS

Information in accordance with Article 13 of the General Data Protection Regulation (GDPR)

 


Dear customers, dear business partners, 
the protection of your personal data is very important to us. This privacy policy shall inform about the processing of personal data in the context of a business relationship with us and your rights in connection with this data processing. 
Please also provide this privacy policy to your employees.

 

1. Who is controller for the data processing and who may be contacted?

Company: Klitschko Ventures GmbH
Address: Große Elbstraße 86, 22767 Hamburg
Phone: +49 40 25 499 46 0
E-mail: datenschutz@klitschko-ventures.com

You can reach our data protection officer at:

Company: Klitschko Ventures GmbH
DPO: – To the Data Protection Officer –
Address: Große Elbstraße 86, 22767 Hamburg
E-mail: dpo@klitschko-ventures.com

 

2. Which data do we process and from which sources does it come?

We process personal data that you voluntarily provide us in the context of our business relationship. This includes the following data or categories of data:

  • Basic data (e.g. title, first name, surname, company, position, address, e-mail address, telephone, mobile, fax number)
  • Bank data (e.g. IBAN, BIC)
  • Tax number
  • Business transaction data


3. For which purposes do we process your data and on which legal basis?

We use your data for the initiation, conclusion and performance of the contract as well as for invoicing and administration of payments made or received. For this purpose we require your name, if you are a corporate customer, the name of your company (if different from your name), your address data, your e-mail address and your telephone number. Without this data we cannot conclude the contract with you. We also use other data that you provide us with in relation to the contract, but these data are not required for the conclusion of a contract. Furthermore, we use your data for accounting processes and use the communication data you provide for contract-related communication. The legal basis for this processing is Art. 6 para. 1 lit. b GDPR. In addition to the contractual data, we process the communication data provided by you (names of contact persons, address, telephone number, fax number, e-mail address) in order to be able to contact and communicate with you. Personal data which you provide us with in writing, by e-mail or by telephone will only be processed for correspondence with you or for the purpose for which you have provided us with the data. The basis for the data processing is Art. 6, para. 1, lit. f GDPR, whereby our legitimate interest lies in answering enquiries. In addition, we use your data to inform you about our products/services within the scope of legal admissibility. If we contact you by post, the processing is based on Art. 6 para. 1 lit. f GDPR and serves our legitimate interest in carrying out direct marketing. With your consent, we will inform you by telephone or e-mail on the basis of Art. 6 para. 1 lit. a GDPR. For existing customer advertising, feedback requests, press accreditation, the legal basis in each case is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interests include our advertising interests, organisational interests and our claim to continuously improve our products, range and service. In addition, we process your data in order to fulfil legal obligations (e.g. regulatory requirements, commercial and tax law storage and verification obligations, Art. 6 para. 1 s. 1 lit. c GDPR.

 

4. Who will receive the data?

Your data will be transmitted to the responsible employees within our company for the above-mentioned purposes (Art. 6 para. 1 s. 1 lit. b GDPR). The data will only be transmitted to third parties outside our company if this is necessary for the performance of the contract or invoicing, if you have given your consent or if there is a legal basis or obligation.

Insofar as we use the services of third parties (so-called order processors) to carry out and handle processing operations, the provisions of the GDPR are adhered to. Service providers who support us in providing our services to you are:

  • Hosting providers
  • E-mail service providers
  • IT service providers
  • Service providers for data destruction
  • Service providers for video conferences, online meetings and webinarsWe transmit personal data to the following third parties, who process personal data on their own responsibility (so-called controllers, cf. Art. 4 No. 7 GDPR), within the scope of legal admissibility and necessity:
  • Authorities
  • Tax consultant
  • Lawyers
  • Auditors
  • Insurance
  • Cooperation partners (such as the University of St. Gallen)

5. How long will your data be stored?

We process your personal data only as long as it is necessary to fulfil the respective processing purpose.
In addition, we are subject to various storage and documentation obligations, which among others result from the German Commercial Code (HGB) or the German Fiscal Code (AO).
These can last up to ten full years.
Finally, the storage period is also assessed according to the statutory limitation periods, which for example can be up to thirty years according
to §§ 195 ff. of the German Civil Code (BGB), with the regular limitation period being three years.

 

6. Is data being transferred to a third country or to an international organisation?

We also use companies as order processors which are based in a non-EU country, e.g. Ukraine. Insofar as data is transferred to a third country in this context,
compliance with the EU data protection standard is ensured by means of appropriate contractual clauses in accordance with Art. 46 GDPR.

Any other transfer of data to third countries will only take place with your express consent.

 

7. What are your data protection rights?

Every data subject has the right of access in accordance with Art. 15 GDPR, the right of rectification in accordance with Art. 16 GDPR, the right to erasure in accordance with Art. 17 GDPR, the right to restriction of processing in accordance with Art. 18 GDPR and the right to data portability in accordance with Art. 20 GDPR. In order to exercise the above rights, you may contact the bodies mentioned under section 1.

If you have given us your consent to process your data, you may revoke this consent at any time without any formality, whereby the processing carried out up to that point remains lawful. To do so, you may contact the entitee mentioned in section 1.

In accordance with Art. 21 GDPR, you have the right to object to any processing based on Art. 6 para. 1 s. 1 lit. e or f GDPR. If personal data relating to you is processed by us for the purpose of direct advertising, you have the right to object to this processing in accordance with Art. 21 para. 2 and para. 3 GDPR.

In addition, you have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR).