PRIVACY POLICY 

Last updated March 2022

INTRODUCTION

Welcome to our Internet Site. In this Privacy Policy, you can read about our practice concerning your privacy when visiting it, including any other media form or channel-related or connected to it.  With our Privacy Policy, we fulfill our obligation to inform you about the type, scope, purpose, duration, and legal basis of our processing of your personal data. Please read this privacy policy carefully to be aware of how we protect your personal data.  If you do not agree with its terms, please do not access the Site. 

We reserve the right to make changes to this Privacy Policy at any time and for any reason. Updating the “Last Updated” date of this Privacy Policy will make the last version effective, immediately upon posting the updated Privacy Policy on the Site. Every time you use our website, we understand that you are accepting the updated version of our Privacy Policy. 

PROCESSING AND COLLECTING OF YOUR INFORMATION

In this Privacy Policy:

“Personal Data” means any information related to a natural person (data subject), such as name, identification number, location data, an online identifier or physical, physiological, genetic, mental, economic, cultural, or social aspects of this natural person. 

“Processing” is any operation in which personal data is handled, whether with or without the help of automated (i.e., technology-supported) processes. In particular, this includes collecting, recording, organizing, arranging, storing, adapting or changing, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning, combining, restricting, deleting, or destroying personal data as well as the change of an objective or purpose on which data processing was originally based.

“Controller” 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. 

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

“Recipient” means a natural or legal person, public authority, agency, or other body, to which the personal data are disclosed, whether a third party or not. processes personal data on behalf of the controller. 

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

Controller responsible for the processing of your personal data within the meaning of Art. 4 No. 7 DS-GVO and Art. 4 No. 7 GDPR is:

Marcia Zeitoune Janzen, LL.M.

C/o: Clayston Rechtsanwälte

Lehmweg 17, 20251 Hamburg

+49 (0)170 4601546 (mobile)

+49 (0) 40-480 639 92 (fax)

marcia@zjlegal.com

For more information about our law firm, please refer to the Imprint information on this website. 

According to the law, processing is only lawful if and to the extent that at least one of the following applies: 

1. the data subject has given consent to the processing for specific purpose(s);
2. processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject, prior to entering into a contract;
3. processing is necessary for compliance with a legal obligation to which the controller is subject;
4. processing is necessary in order to protect vital interests of the data subject or of another natural person;
5. processing is necessary in the public interest;
6. processing is required due to legitimate interests pursued by the controller or by a third party, except when such interests are overridden by the interests, fundamental rights and freedom of the data subject. 

We neither search nor actively collect information about the users of our Site. As a law firm we are contacted by people searching for our services, who may give us voluntarily, in an individual conversation or through written contact, private information like name, address, e-mail and telephone number, identity number, etc. Further personally identifiable information such as age, gender, etc. may be disclosed in the frame of the reason why these people searched for our services. Using the contact form included in this Site you will also inform your name and e-mail address, so that we can return to you. This does not mean that we are using your information for any other aim than our interaction in the frame of our professional services. 

Nevertheless, the use of this Site may imply in a derivative collection of your information by our servers when you access the Site. For the informational use of our website, the following categories of personal data are collected from us, stored and further processed:

• “Protocol data”: When you visit our websites, a so-called protocol data set (so-called server logfiles) is temporarily stored and anonymized on our web server. This consists of:

o the page from which the page was requested (so-called referrer URL)

o the name and URL of the required page

o the date and time of the call

o the description of the type, language, and version of the web browser used

o the IP address of the requesting computer, which is shortened so that a personal transfer is no longer recoverable

o the transmitted data set

o the operating system

o the message whether the call was successful (access status / http status code)

o the GMT time zone difference

If you are using our Site through a mobile device, this information may also include your device ID, model, and manufacturer, and information about the location of your device.

PROCESSING AND DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed if we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others. In such case, we may share your information as permitted or required by any applicable law, rule, or regulation. We may share your information with third parties that perform services for us or on our behalf, including hosting services, website analytics, event organizers, correspondent lawyers, accountants, auditors, insurances, etc., who are also obligated to follow privacy protection laws and regulations.  In addition to that, we will only pass on your personal data to third parties if you have given us express consent or request to do so.

Insofar as no express storage period is stated, your personal data will be deleted or blocked as soon as the purpose or legal basis for the storage ceases.

TRACKING TECHNOLOGIES

Cookies and Web Beacons

We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Site to help customize the Site and improve your experience. Cookies cannot run programs or transmit viruses to your computer and therefore do no harm. They serve to make the Internet offer overall more user-friendly and effective, thus making it more enjoyable for you.

Cookies may contain data that enables a recognition of the device used. However, some cookies also contain random information about certain settings that are not personally accessible. In any case, cookies cannot directly identify a user.

When you access the Site, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Site. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

Website Analytics 

We may partner with selected third-party vendors to allow tracking technologies and remarketing services on the Site through the use of first-party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

THIRD-PARTY WEBSITES

The Site may contain links to third-party websites of interest, which may include advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third-party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services, or applications that may be linked to or from the Site.

SECURITY OF YOUR INFORMATION

Storage of your data basically only takes place on servers in Holland. 

We use administrative, technical, and physical security measures to help protect your personal information against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access of third parties, taking into account the state of the art, the nature of the technology, the purpose of processing your data as well as the existing risks of a data breach (including their impact) for the people concerned. Please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.  Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

YOUR RIGHTS

You may exercise your rights with respect to your processed personal data at any time under the Controller’s contact details given above. As a data subject, you have the right:

• to obtain from the Controller confirmation as to whether or not your personal data are being processed, and, if the case may be, access to the personal data, the purposes of the processing, the categories of the personal data concerned, the recipients of the data, the storage period, the existence of the right of rectification, or restriction of processing or erasure of personal data, as well as the existence of automated decision-making including profiling; 
• to obtain from the Controller without delay the rectification of inaccurate personal data or its completion; 
• to obtain from the Controller the erasure of personal data without delay, unless the processing is necessary for the exercise of the right to freedom of expression and information, for the fulfillment of a legal obligation, for reasons of public interest or for the enforcement, exercise or defense of legal claim;
• to obtain from the Controller the restriction of your data processing, insofar as the accuracy of your data is disputed or the processing is unlawful; 
• to receive the personal data provided to the Controller and to transmit those data to another controller without hindrance from the Controller. 
• object the processing of the data, insofar as the processing can be considered unlawful. This is especially the case if the processing is not required to fulfill a contract with you. Insofar as it is not an objection against direct advertising, we ask you, when exercising such objection, to present the reasons why your data should not be processed by us. In the event of your reasoned objection, we will check the case and will either stop the data processing or adapt or show you our mandatory grounds for protection, on the basis of which we continue the processing.
• to withdraw your consent at any time, whereby the withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.
• to complain before a supervisory authority. The data protection supervisory authority responsible for us is the Hamburg Commissioner for Data Protection and Freedom of Information (Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit), Ludwig Erhard -Str. 22, 20459 Hamburg. 

CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

Marcia Zeitoune Janzen, LL.M.

Lehmweg 17 (c/o: Clayston Lawyers)

20251 Hamburg

+49 (0)170 4601546 (mobile)

+49 (0) 40-480 639 92 (fax)

marcia@zjlegal.com