We, the Hanns R. Neumann Foundation, Am Sandtorpark 4, 20457 Hamburg, (hereinafter: "the company", "we" or "us") take the protection of your personal data seriously and would like to inform you here about data protection in our company.
As part of our data protection responsibilities, we are subject to certain obligations under applicable data protection laws, in particular the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: "GDPR"), in order to ensure the protection of personal data of the data subject (we also refer to you as data subject hereinafter as "customer", "user", "you" or "data subject").
Insofar as we decide either alone or jointly with others on the purposes and means of data processing, this includes above all the obligation to inform you transparently about the nature, scope, purpose, duration and legal basis of the processing of personal data (cf. Articles 13 and 14 GDPR). With this statement (hereinafter: "Privacy Notice"), we inform you about the manner in which your personal data is processed by us.
Our data protection notices have a modular structure. It consists of a general part for any processing of personal data and processing situations that come into play each time a website is called up (A. General) and a special part, the content of which relates in each case only to the processing situation specified there with the designation of the respective offer or product, in particular the visit to websites as detailed here (B. Visit to websites).
To find the parts that are relevant to you, please refer to the following overview for the breakdown of the privacy notices:
Part - Designation - This part is for you...
Part A - General - ...always relevant.
Part B - Website and social media presences - ...relevant if you use our internet offer including the appearances in social media.
Following the example of Art. 4 of the GDPR, this privacy notice is based on the following definitions:
“Personal data" (Art. 4 No. 1 GDPR) means any information relating to an identified or identifiable natural person ("data subject"). A person is identifiable if he or she can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or by means of information relating to his or her physical, physiological, genetic, mental, economic, cultural or social identity characteristics. The identifiability can also be given by means of a linkage of such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photographs, video or audio recordings may also contain personal data).
“Processing" (Art. 4 No. 2 GDPR) means any operation which involves the handling of personal data, whether or not by automated (i.e. technology-based) means. This includes, in particular, the collection (i.e., acquisition), recording, organization, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction of personal data, as well as the change of a purpose or intended use on which a data processing was originally based.
"Controller" (Art. 4 No. 7 GDPR) 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.
"Third Party" (Art. 4 No. 10 GDPR) means any natural or legal person, public authority, agency or other body other than the Data Subject, the Controller, the Processor and the persons who are authorized to process the Personal Data under the direct responsibility of the Controller or Processor; this also includes other group-affiliated legal entities.
A "processor" (Art. 4 No. 8 GDPR) is a natural or legal person, authority, institution or other body that processes personal data on behalf of the controller, in particular in accordance with the controller's instructions (e.g. IT service provider). In particular, a processor is not a third party in the sense of data protection law.
“Consent" (Art. 4 No. 11 GDPR) means any freely given specific, informed and unambiguous indication of the data subject's 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.
(2) Name and address of the controller
We are the controller for the processing of your personal data within the meaning of Art. 4 No. 7 GDPR:
Hanns R. Neumann Stiftung
Am Sandtorpark 4
For further information on our foundation, please refer to the imprint details on our website: https://www.hrnstiftung.org/imprint
(3) Data protection officer
According to Art. 37 GDPR in conjunction with § 38 BDSG we are not obliged, to appoint a data protection officer. If you have any questions regarding data protection, please contact us using the contact details provided above.
(4) Legal basis for data processing
By law, in principle, any processing of personal data is prohibited and only permitted if the data processing falls under one of the following justifications:
Art. 6 (1) p. 1 lit. a GDPR ("consent"): Where the data subject has voluntarily, in an informed manner and unambiguously indicated by a statement or other unambiguous affirmative act that he or she consents to the processing of personal data relating to him or her for one or more specified purposes;
Art. 6 (1) p. 1 lit. b GDPR: If the processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the request of the data subject;
Art. 6 para. 1 p. 1 lit. c GDPR: If processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a legal obligation to preserve records);
Art. 6 (1) p. 1 lit. d GDPR: If the processing is necessary to protect the vital interests of the data subject or another natural person;
Art. 6 (1) p. 1 lit. e GDPR: Where 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, or
Art. 6 (1) p. 1 lit. f GDPR ("Legitimate Interests"): When processing is necessary to protect the legitimate (in particular legal or economic) interests of the controller or a third party, unless the conflicting interests or rights of the data subject override (in particular if the data subject is a minor).
Storing information in the end user's terminal equipment or accessing information already stored in the terminal equipment is only permitted if it is covered by one of the following justifications:
§ 25 para. 1 TTDSG: If the end user has consented on the basis of clear and comprehensive information. The consent has to be given according to Art. 6 para. 1 p. 1 lit. a GDPR;
§ 25 (2) no. 1 TTDSG: If the sole purpose is to carry out the transmission of a message via a public telecommunications network, or
§ 25 para. 2 no. 2 TTDSG: If the storage or access is absolutely necessary so that the provider of a telemedia service can provide a telemedia service expressly requested by the user.
For the processing operations carried out by us, we indicate below the applicable legal basis in each case. A processing operation may also be based on several legal bases.
(5) Data deletion and storage period
For the processing operations carried out by us, we indicate below in each case how long the data will be stored by us and when it will be deleted or blocked. Unless an explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for the storage no longer applies. In principle, your data will only be stored on our servers in the European Union, subject to any transfer that may take place in accordance with the provisions in A.(7) and A.(8).
However, storage may take place beyond the specified time in the event of a (threatened) legal dispute with you or other legal proceedings or if storage is provided for by statutory provisions to which we are subject as the responsible party (e.g. § 257 HGB, § 147 AO). If the storage period prescribed by the legal regulations expires, the personal data will be blocked or deleted unless further storage by us is necessary and there is a legal basis for this.
(6) Data security
We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties (e.g. TSL encryption for our website), taking into account the state of the art, implementation costs and the nature, scope, context and purpose of the processing, as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments.
We will be happy to provide you with more detailed information on request. Please contact us using the details provided above.
(7) Cooperation with processors
In some cases, we use external domestic and foreign service providers to process our business transactions (e.g. for IT, telecommunications and marketing). These service providers only act on our instructions and are contractually obligated to comply with the data protection provisions in accordance with Art. 28 GDPR.
If personal data from you is passed on by us to our subsidiaries or is passed on to us by our subsidiaries (e.g. for advertising purposes), this is done on the basis of existing order processing relationships.
(8) Conditions for the transfer of personal data to third countries
In the course of our business relationships, your personal data may be transferred or disclosed to third party companies. These may also be located outside the European Economic Area (EEA), i.e. in third countries. Such processing takes place exclusively for the fulfillment of contractual and business obligations and to maintain your relationship with us (legal basis is Art. 6 para. 1 lit b or lit. f in each case in conjunction with Art. 44 et seq. GDPR). We will inform you about the respective details of the transfer in the following at the relevant points.
The European Commission certifies that some third countries have a level of data protection comparable to the EEA standard by means of so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be obtained here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). However, in other third countries to which personal data may be transferred, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is adequately guaranteed. This is possible via binding company regulations, standard contractual clauses of the European Commission for the protection of personal data pursuant to Art. 46 para. 1 , 2 lit. c GDPR (the standard contractual clauses of 2021 are available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0915&locale-en), certificates or recognized codes of conduct. Please contact us using the contact details provided above if you would like to receive more information on this.
(9) No automated decision making (including profiling).
We do not intend to use any personal data collected from you for any automated decision making process (including profiling).
(10) No obligation to provide personal data
We do not make the conclusion of contracts with us dependent on you providing us with personal data in advance. In principle, there is also no legal or contractual obligation for you to provide us with your personal data; however, we may only be able to provide certain services to a limited extent or not at all if you do not provide the necessary data. If this should exceptionally be the case, you will be informed separately.
(11) Legal obligation to transmit certain data
We may be subject to a specific legal or statutory obligation to provide the lawfully processed personal data to third parties, in particular public bodies (Art. 6 para. 1 p. 1 lit. c GDPR).
(12) Your rights
You can assert your rights as a data subject regarding your processed personal data at any time by contacting us using the contact details provided above. You have the right as a data subject:
In accordance with Art. 15 GDPR, you may request information about your data processed by us. In particular, you can request information about the processing purposes, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data, if it was not collected by us, as well as the existence of automated decision-making, including profiling and, if applicable, meaningful information about its details;
In accordance with Art. 16 GDPR, you have the right to demand the correction of incorrect data or the completion of your data stored by us without delay;
In accordance with Art. 17 GDPR, you have the right to request the deletion of your data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the assertion, exercise or defense of legal claims;
In accordance with Art. 18 GDPR, you have the right to demand the restriction of the processing of your data, insofar as the correctness of the data is disputed by you or the processing is unlawful;
According to Art. 20 GDPR to receive your data that you have provided to us in a structured, common and machine-readable format or to request the transfer to another controller ("data portability");
You have the right to object to processing in accordance with Article 21 of the GDPR, provided that the processing is based on Article 6 (1) sentence 1 lit. e or lit. f of the GDPR. This is particularly the case if the processing is not necessary for the performance of a contract with you. Unless it is an objection to direct marketing, when exercising such an objection, we ask you to explain the reasons why we should not process your data as we have done. In the event of your justified objection, we will review the merits of the case and either discontinue or adapt the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing;
According to Art. 7 (3) GDPR your consent given once (if applicable also before the validity of the GDPR, i.e. before May 25, 2018) - i.e. your voluntary will made understandable in an informed manner and unambiguously by a declaration or other clear confirming action that you agree to the processing of the personal data in question for one or more specific purposes - to be revoked towards us at any time, if you have given such consent. This has the consequence that we may no longer continue the data processing, which was based on this consent, for the future and
In accordance with Art. 77 GDPR, you have the right to complain to a data protection supervisory authority about the processing of your personal data in our company, such as the data protection supervisory authority responsible for us: The Hamburg Data Protection and Freedom of Information Commissioner, Ludwig-Erhard-Strasse 22, 20459 Hamburg, phone: 040 42854 4040, fax: 040 428 54 - 4000, e-mail firstname.lastname@example.org.
(13) Changes to the data protection notice
In the context of the further development of data protection law and technological or organizational changes, our data protection information is regularly reviewed to determine whether it needs to be adapted or supplemented. You will be informed of any changes in particular on our website at https://www.hrnstiftung.org/privacy-policy. This data protection notice is current as of February 2023.
B. Visiting websites
(1) Explanation of the function
You can obtain information about our foundation and the services we offer in particular at https://www.hrnstiftung.org/ together with the associated sub-pages (hereinafter collectively referred to as "websites"). When you visit our websites, personal data may be processed.
(2) Personal data processed
During the informative use of the websites, the following categories of personal data are collected, stored and processed by us:
"Log data": When you visit our websites, a so-called log data record (so-called server log files) is stored temporarily and anonymously on our web server. This consists of:
- the page from which the page was requested (so-called referrer URL).
- the name and URL of the requested page
- the date and time of the call
- the description of the type, language and version of the web browser used.
- the IP address of the requesting computer, which is shortened in such a way that a personal reference can no longer be established.
- the amount of data transferred
- the operating system
- the message whether the call was successful (access status/http status code).
- the GMT time zone difference
"Contact form data": When contact forms are used, the data transmitted through them are processed (e.g. surname and first name, address, company, e-mail address and the time of transmission).
In addition to the purely informational use of our website, we offer the subscription to our newsletter. If you subscribe to our newsletter, the following "newsletter data" will be collected, stored and processed by us:
- the page from which the page was requested (so-called referrer URL).
- the date and time of the call
- the description of the type of the used web browser
- the IP address of the requesting computer, which is shortened in such a way that a personal reference can no longer be established.
- the e-mail address
- the date and time of registration and confirmation
We would like to 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 that are stored on our website. For the evaluations, we link the aforementioned data and the web beacons with your e-mail address and an individual ID. Links contained in the newsletter also contain this 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.
We use the Brevo (formerly SendinBlue) service for sending newsletters. The provider in Germany is SendinBlue GmbH, Köpenicker Straße 126, 10179 Berlin, a subsidiary of the French parent company SendinBlue SAS, 55 rue d'Amsterdam, 75008 Paris, France. Brevo is a service with which the newsletter dispatch can be organised and analysed. The data you enter for the purpose of receiving newsletters (e.g. e-mail address) is stored on SendinBlue's servers.
(3) Purpose and legal basis of data processing
We process the personal data described in more detail above in accordance with the provisions of the GDPR, the other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Art. 6 (1) p. 1 lit. f GDPR, the aforementioned purposes also represent our legitimate interests.
The processing of the log data serves statistical purposes and the improvement of the quality of our website, in particular the stability and security of the connection (legal basis is Art. 6 para. 1 p. 1 lit. a or lit. f GDPR).
Contact form data is processed for the purpose of handling customer inquiries (legal basis is Art. 6 para. 1 p. 1 lit. b or lit. f GDPR).
The newsletter data is processed for the purpose of sending the newsletter. When registering for our newsletter, you consent to the processing of your personal data (legal basis is Art. 6 para. 1 lit. a GDPR). 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 specified e-mail address in which we ask you to confirm that you wish to receive the newsletter. 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. 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 email@example.com or by sending a message to the contact details provided in the imprint.
If the processing of data requires the storage of information in your terminal equipment or access to information already stored in the terminal equipment, Section 25 (1), (2) TTDSG is the legal basis for this.
(4) Duration of data processing
Third parties engaged by us will store your data on their systems for as long as is necessary in connection with the provision of services for us in accordance with the respective order.
(5) Transfer of personal data to third parties; basis for justification
The following categories of recipients, which are usually processors (see A.(7)), may receive access to your personal data:
service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data center services, payment processing, IT security). The legal basis for the transfer is then Art. 6 para. 1 p. 1 lit. b or lit. f GDPR, insofar as it does not involve order processors;
State agencies/authorities, insofar as this is necessary for the fulfillment of a legal obligation. The legal basis for the disclosure is then Art. 6 para. 1 p. 1 lit. c GDPR;
Persons appointed to carry out our foundation operations (e.g. auditors, banks, insurance companies, legal advisors or supervisory authorities). The legal basis for the disclosure is then Art. 6 para. 1 p. 1 lit. b or lit. f GDPR.
For the guarantees of an adequate level of data protection in the event of a transfer of the data to third countries, see A.(8).
In addition, we will only disclose your personal data to third parties if you have given your express consent to do so in accordance with Art. 6 (1) p. 1 lit. a GDPR.
Cookies can contain data that makes it possible to recognize the device used. In some cases, however, cookies only contain information about certain settings that are not personally identifiable. However, cookies cannot directly identify a user.
A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. With regard to their function, a distinction is made between cookies:
Technical cookies: these are mandatory to move around the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes, nor do they store which web pages you have visited;
Performance Cookies: these collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect information that could identify you - all information collected is anonymous and is only used to improve our website and find out what interests our users;
Advertising cookies, targeting cookies: These are used to offer the website user tailored advertising on the website or offers from third parties and to measure the effectiveness of these offers;
Sharing cookies: These are used to improve the interactivity of our website with other services (e.g. social networks).
We use the open source software tool Matomo (formerly PIWIK) on our website to analyze the surfing behavior of our users. This is an open source tool for web analysis. Matomo does not transmit data to servers located outside the European Union. Matomo does not collect session data without your consent.
We see this analysis as part of our internet service. We would like to use it to further improve our website and adapt it even more to the needs of our users.
If you agree to web analysis using Matomo, the following data will be collected when you call up individual pages of our website:
(1) 2 bytes of the IP address of the user's calling system.
(2) The web page called up
(3) The website from which the user accessed the accessed website (referrer)
(4) The sub-pages called up from the called-up website
(5) The time spent on the website
(6) The frequency with which the web page is accessed
The software runs exclusively on the servers of our website. Personal data of the users is only stored there. The data is not passed on to third parties.
You can decide here whether a web analysis cookie may be stored in your browser to enable us to collect and analyze statistical data.
The data processing is based on Art. 6 para. 1 lit. a GDPR (consent).
The processing of users' personal data enables us to analyze the surfing behavior of our users. By evaluating the data obtained, we are able to compile information on the use of the individual components of our website. This helps us to continuously improve our website and its user-friendliness. By anonymizing the IP address, the interest of users in the protection of their personal data is adequately taken into account.
The data is deleted as soon as it is no longer required for our recording purposes. The statistics generated and underlying data are not deleted.
You can find more information on the privacy settings of the Matomo software at the following link: https://matomo.org/docs/privacy/.
We use the automation software Zapier for our website. The service provider is Zapier Inc, 548 Market Street 6241, San Francisco, CA 94104, USA. The data processing is based on Art. 6 para. 1 lit. a GDPR (consent).
Zapier may process your data in the USA. For the transfer of data to the USA, please refer to A.(8). We have agreed data processing conditions with Zapier that comply with the standard contractual clauses within the meaning of Art. 46 GDPR. For more information, please visit https://help.zapier.com/hc/en-us/articles/8496244423053.
The data is deleted as soon as it is no longer required for the recording purposes.
For more information about data processing by Zapier, please visit https://zapier.com/privacy?tid=134485516.
We use the landing page service Unbounce. This service is provided by Unbounce Marketing Solutions Inc, 400 - 401 West Georgia Street, Vancouver, BC V6B 5A1, Canada ("Unbounce").
Some of our websites are hosted by Unbounce and the website user's browser communicates directly with Unbounce so that your IP address is transmitted and cookies can be set. Any data you enter on these pages is also processed and stored by Unbounce. We are then provided with an anonymous evaluation of the activities.
The data processing is based on Art. 6 para. 1 lit. a GDPR (consent).
For more information about data processing by Unbouce, please visit https://unbounce.com/product/security/gdpr/.
In order to show you YouTube videos, we may have integrated YouTube into our website. The data processing is based on Art. 6 para. 1 lit. a GDPR (consent).
The information generated by the cookie about your use of our website is usually transmitted to a Google server in the USA and stored there. However, since we have activated IP anonymization on our website, your IP address will be shortened by Google beforehand within member states of the European Union. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and only shortened there (for more information on the purpose and scope of data collection, see e.g. https://policies.google.com/privacy). We have also concluded an order processing agreement with Google LLC (USA) in accordance with Art. 28 GDPR. Accordingly, Google will use all information strictly for the purpose of evaluating the use of our websites for us and compiling reports on website activity.
Google sets the following cookies when you visit our website and consent to the use of YouTube:
Name Purpose Leakage
NID Used to unblock YouTube content 6 months
You can revoke your consent once given at any time. Please use one of the following options for this purpose:
You inform us that you wish to withdraw your consent.
You can also prevent the collection of data generated by the cookie and related to your use of our websites (including your IP address) to Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link (https://tools.google.com/dlpage/gaoptout?hl).
f) The Giving Block
We use the cryptocurrency donation platform The Giving Block on our website. The service provider is The Giving Block Holdings LLC (“The Giving Block”), 78 SW 7th St Suite 500, Miami, FL 33130. The data processing is based on Art. 6 para. 1 lit. a GDPR (consent).
The Giving Block may process your data in the USA. For the transfer of data to the USA, please refer to A.(8). For more information, please visit https://thegivingblock.com/about/privacy-policy/.
The data is deleted as soon as it is no longer required for its purposes.
g) Social Media Plugins
We currently use the following social media plug-ins: Facebook, Instagram, Twitter LinkedIn. The integration of social media plug-ins into this site and our social media pages on the Facebook, Instagram, Twitter and LinkedIn platforms serve the purpose of direct and active communication with you. We provide information about our offers there.
We use the so-called two-click solution. This means that when you visit our site, no personal data is initially passed on to the providers of the plug-ins. You can recognize the provider of the plug-in by the marking on the box above its initial letter or logo. Only when you click on the marked box and thereby activate it, does the plug-in provider receive the information that you have accessed the corresponding website of our online offer. In addition, the data mentioned under B.(2) of this data protection information is transmitted. Facebook states that the IP address is anonymized immediately after collection in the EEA. The legal basis is your consent according to Art. 6 para. 1 lit. a GDPR. You can revoke your 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.
Further information on the purpose and scope of the data collection and its processing by the plug-in provider can be found in the data protection declarations of these providers communicated below. There you will also receive further information on your rights in this regard and setting options for protecting your privacy:
Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland; http://www.facebook.com/policy.php; further information on data collection: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-onother#applications as well as http://www.facebook.com/about/privacy/your-info#everyoneinfo.
As far as Instagram is concerned:
Twitter, Inc, 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy.
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; https://www.linkedin.com/legal/privacy-policy.
h) Cookie Settings