The use of the cliveruggles.com internet pages is possible without any indication of personal data; however, if you wish to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain your consent.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject will always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the data controller. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
We have implemented various technical and organisational measures to ensure the most complete protection of personal data processed through our website. However, internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, you are free to transfer personal data to us via alternative means.
The following data protection declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). In this data protection declaration, we therefore use, inter alia, the following terms:
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (“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.
b) Data subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, 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.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
f) Controller or controller responsible for the processing
The controller or controller responsible for the processing is 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 European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law.
The processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
A recipient is a natural or legal person, public authority, agency or another body to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
j) Third party
A third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
The consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes whereby s/he, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him- or herself.
The controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in member states of the European Union and other provisions related to data protection is Clive Ruggles Ltd, Fargate House, Main Street, Tur Langton, Leicester LE8 0PJ, United Kingdom (company registration number 05863445). The controller can be contacted by mail at this address.
3. Collection of general data and information
The cliveruggles.com website collects a series of general data and information when a data subject or automated system calls up the website. These general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, we may analyse anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
4. Routine erasure and blocking of personal data
The controller will process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
5. Your rights as data subject
a) Right of confirmation
You have the right granted by the European legislator to obtain from the data controller a confirmation as to whether or not personal data concerning yourself are being processed. If you wish to avail yourself of this right of confirmation, you may contact the data controller at any time.
b) Right of access
You have the right granted by the European legislator to obtain from the data controller free information about your personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request rectification or erasure of personal data concerning yourself, or restriction of processing of personal data concerning yourself, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data were not collected from you, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for yourself [however, see §14 below].
Furthermore, you have a right to obtain information as to whether personal data relating to yourself are transferred to a third country or to an international organisation. Where this is the case, you have the right to be informed of the appropriate safeguards relating to the transfer. If you wish to avail yourself of this right of access, you may contact the controller at any time.
c) Right to rectification
You have the right granted by the European legislator to obtain from the data controller, without undue delay, the rectification of inaccurate personal data concerning yourself. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If you wish to exercise this right to rectification, you may contact the data controller at any time.
d) Right to erasure (Right to be forgotten)
You have the right granted by the European legislator to obtain from the data controller, without undue delay the erasure of personal data concerning yourself. The controller also has the obligation to erase personal data without undue delay where one of the following grounds applies, as long as processing is not necessary:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw the consent upon which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there are no other legal grounds for the processing;
- you object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR;
- the personal data have been unlawfully processed;
- the personal data must be erased for compliance with a legal obligation in European Union or Member State law to which the controller is subject; or
- the personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and you wish to request the erasure of personal data stored by the data controller, you may contact the controller at any time. The controller will ensure that the erasure request is complied with promptly. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that you, the data subject, have requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The controller will arrange the necessary measures in individual cases.
e) Right of restriction of processing
You have the right granted by the European legislator to obtain from the data controller restriction of processing where one of the following applies:
- you contest the accuracy of the personal data, for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful but you oppose the erasure of the personal data and request instead the restriction of their use;
- the controller no longer needs the personal data for the purposes of processing, but they are required by you for the establishment, exercise or defence of legal claims; or
- you have objected to processing pursuant to Article 21(1) of the GDPR pending the verification of whether the legitimate grounds of the controller override those of you as the data subject.
If one of the aforementioned conditions is met, and you wish to request the restriction of the processing of personal data stored by the controller, you may contact the controller at any time. The controller will arrange the restriction of the processing.
f) Right to data portability
You have the right granted by the European legislator to receive the personal data concerning yourself that was provided to the controller in a structured, commonly used and machine-readable format. You have the right to transmit those data to another controller without hindrance from the controller, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not 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, in exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to have personal data transmitted directly from one controller to another, where it is technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, you may contact the controller at any time.
g) Right to object
You have the right granted by the European legislator to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning yourself which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions [however, see §14 below]. The controller will no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
If the controller processes personal data for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning yourself for such marketing. This applies to profiling to the extent that it is related to such direct marketing [however, see §14 below]. If you object to the controller to the processing for direct marketing purposes, we will no longer process the personal data for these purposes.
In addition, you have the right, on grounds relating to your particular situation, to object to the processing of personal data concerning yourself by the controller for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, you may contact the controller at any time. You are also free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use your right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
You have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning yourself, or similarly significantly affects yourself, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between you and a data controller, or (2) is not authorised by European Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (3) is not based on your explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between you and the data controller, or (2) it is based on your explicit consent, the controller willl implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller to express your point of view and contest the decision.
If you wish to exercise your rights concerning automated individual decision-making, you may contact the controller at any time.
j) Right to withdraw data protection consent
You have the right granted by the European legislator to withdraw your consent to the processing of your personal data at any time. If you wish to exercise your right to withdraw the consent, you may contact the controller at any time.
6. Data protection for applications and the application procedures
The data controller may collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).
7. Data protection provisions about the application and use of Google Analytics (with anonymization function)
On this website, the controller has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
For the web analytics through Google Analytics the controller uses the application "_gat. _anonymizeIp". By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
8. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we 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 (not in this case a donor) is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations as are necessary for carrying out pre-contractual measures, for example in the case of enquiries concerning our products or services. If our company is subject to a legal obligation by which the processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary in order to protect the vital interests of a data subject or those of someone else (another “natural person”). This would be the case, for example, if a visitor were injured and their name, age, health insurance data or other vital information needed to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by 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. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
9. Legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our stakeholders.
10. Period for which the personal data will be stored
The criterion used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data are routinely deleted, as long as it they are longer necessary for the fulfilment of the contract or the initiation of a contract.
11. Provision of personal data as statutory or contractual requirement; requirement necessary to enter into a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
The provision of personal data could be partly required by law (e.g. tax regulations) or could result from contractual provisions (e.g. information on the contractual partner). In some circumstances it could be necessary, in order to conclude a contract, for such a partner to provide us with personal data which would subsequently need to be processed by us. A data subject might, for example, be obliged to provide us with personal data when our company signs a contract with them. The non-provision of the personal data would have the consequence that the contract could not be concluded. Before personal data is provided by a data subject, the controller will clarify with them whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.
12. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.