1. Name and address of the controller
The controller in the sense of the GDPR and other national data protection laws of the member states as well as other data protection regulations is:
Digital Insurance Group B.V.
Oudezijds Voorburgwal 282 G
Tel.: +31 (0) 20 233 82 30
E-Mail: [email protected]
2. Data protection officer
The contact details of the data protection officer are:
datenschutz [at symbol] digitalinsurance [dot] io (email address is broken down into letters for security reasons)
Data Protection Officer
Digital Insurance Group B.V.
Oudezijds Voorburgwal 282 G
3. General information on processing
3.1 Scope of the processing of personal data
The use of our website is usually possible without providing personal data. Any personal data collected on our website (such as name, address or email address), is given on a voluntary basis. The collection and use of personal data of our website users is being done regularly only with the user’s consent. An exception applies in those cases where prior consent cannot be obtained for real reasons and the processing of the data is permitted by law.
We point out that data transmission via the Internet (e.g., communication by email) always comes with a security risk. A seamless protection of data against unauthorised access by third parties is not possible and is not guaranteed.
Due to disclosure obligations, contact details are published in the imprint (“Impressum”) of our website. The use of this contact details by third parties for the transmission of unsolicited advertisements and information material is herewith specifically prohibited. The site operators reserve the right to take legal action in case of unsolicited sending of advertising information in any form (such as spam emails).
3.2 Legal basis for the processing of personal data
Whenever we obtain the consent of the data subject for the processing of personal data, Article 6 (1) (a) GDPR serves as the legal basis for the processing of personal data. In the processing of personal data required for the performance of a contract to which the data subject is a party, Article 6 (1) (b) GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.
Insofar as the processing of personal data is required to fulfil a legal obligation to which our company is subject, Article 6 (1) (c) GDPR serves as the legal basis.
In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 para. 1 d GDPR serves as the legal basis.
If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Article 6 (1) (f) GDPR serves as the legal basis for processing.
The personal data of the person concerned will be erased or processing will be restricted as soon as the purpose of processing no longer applies. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the controller is subject. The data will also be erased or restricted in processing if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.
4. Provision of the website and creation of log files
4.1 Description and scope of processing
Each time our website is visited, our system automatically collects data and information from the computer system of the calling computer.
- Date and time of access
- IP-Address (masked)
- Visited site
- Browser and version
- Size of requested document
The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.
4.2 Legal basis for processing
The legal basis for the temporary storage of data and log files is Article 6 (1) (f) GDPR.
4.3 Purpose of the processing
The temporary storage of the IP-address by the system is necessary to enable the website to be delivered to the user’s computer. For this the IP-address of the user must remain stored for the duration of the session.
The data is stored in log files to ensure the functionality of the website. In addition, the data serves us to optimise the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
In these purposes also lies our legitimate interest in the processing according to Article 6 (1) (f) GDPR.
4.4 Duration of data storage
The data will be erased as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended. If the data is stored in log files, this is the case after 7 days. Further storage is possible. In this case, the IP-addresses of the users are erased or alienated, so that an assignment of the calling client is no longer possible.
4.5 Objection and removal
The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, the user has no possibility of objection.
5.1 Description and scope of processing
The following data is stored and transmitted in the cookies:
- Time of your web page visit
- Place of your web page visit
- Number of visits to your website
- As well as other data collected by Google Analytics
All user data collected in this way are pseudonymised by technical precautions apart from Disqus to which you have to log in. Therefore, it is no longer possible to assign the data to the calling user. The data will not be stored together with other personal data of the users.
5.2 Legal basis for processing
The legal basis for the processing of personal data using cookies is Article 6 (1) (f) GDPR.
5.3 Purpose of the processing
The following applications require cookies:
We don’t use the technically necessary cookies and the user data collected to create user profiles.
Analysis cookies are used to improve the quality of our website and its content. Through the analysis cookies we learn how the website is used and thus continuously optimise our offer.
We use the following applications:
Our website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on the user’s computer, to help the website analyse how users use the site.
The information generated by the cookie about the use of this website is, for example, the time and place as well as the number of visits to your website.
6. Email contact
6.1 Description and scope of processing
You can contact us via the email address provided. In this case, the user’s personal data transmitted by e-mail will be stored.
In this context, we do not disclose data to third parties. The data is used exclusively for processing the conversation.
6.2 Legal basis for processing
The legal basis for the processing of data is Article 6 (1) (a) GDPR if the user has given his consent. The legal basis for the processing of data transmitted in the course of sending an e-mail is Article 6 (1) (f) GDPR. If the email contact aims at the conclusion of a contract, then additional legal basis for the processing is Article 6 (1) (b) GDPR.
6.3 Purpose of the processing
The processing of the personal data from the contact form serves us only to execute the contact request. If you contact us per email, this execution is our required legitimate interest in the processing of your data. The additional personal data processed during the sending process serves to prevent misuse of the contact form and to ensure the security of our information technology systems.
6.4 Duration of data storage
The data will be erased as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the contact form and those sent by email, this is the case when the respective conversation with the user is finished. The conversation is terminated when it can be inferred from the circumstances that the facts in question have been finally clarified.
The additional personal data collected during the sending process will be erased after a period of sixty days at the latest.
6.5 Objections and removal
The user has the possibility to withdraw his consent to the processing of personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued. If you wish to change or delete your data, please inform us informally at the above contact address. All personal data stored in the course of contacting us will be erased in this case.
7. Rights of the data subject
If your personal data are being processed, you are a „data subject” within the meaning of the GDPR and you are entitled to assert the following rights against the controller:
7.1. Right of access
You can ask the controller for a confirmation whether personal data concerning you are being processed by us.
If such processing has taken place, you can request the following information from the controller:
- the purposes for which the personal data are processed;
- the categories of personal data being processed;
- the recipients or categories of recipients to whom the personal data concerning you have been or are still being disclosed;
- planned duration of data storage of personal data concerning or, if specific information on this is not possible, criteria for determining the storage period;
- the existence of a right to have your personal data concerning you corrected or erased, a right to have processing restricted by the controller or a right to object to such processing;
- the existence of a right to lodge a complaint with a supervisory authority;
- any available information on the source of the data if the personal data are not collected from the data subject;
- the existence of automated decision-making, including profiling in accordance with Article 22 (1) and (4) GDPR and – at least in these cases – meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate guarantees in accordance with Article 46 GDPR in connection with the transmission.
7.2 Right to rectification
You have a right to assert rectification and/or completion against the controller if the personal data processed concerning you are incorrect or incomplete. The controller shall make the correction without delay.
7.3 Right to restriction of processing
Under the following conditions, you may request that the processing of personal data concerning you be restricted:
- if you dispute the accuracy of the personal data concerning you for a period of time that enables the controller to verify the accuracy of the personal data;
- if the processing is unlawful and you refuse to delete the personal data and instead request that the use of the personal data be restricted;
- if the controller no longer needs the personal data for the purposes of the processing, but you need them to assert, exercise or defend legal claims;
- if you have filed an objection to the processing pursuant to Article 21 (1) GDPR and it has not yet been determined whether the legitimate reasons of the controller outweigh your reasons.
If the processing of personal data concerning you has been restricted, such data may only be processed – apart from being stored – with your consent or for the purpose of asserting, exercising or defending rights or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or a Member State.
If the processing restriction has been restricted in accordance with the above conditions, you will be informed by the person responsible before the restriction is lifted.
7.4 Right to erasure
You may request the controller to erase the personal data relating to you without delay and the controller is obliged to erase this data without delay if one of the following reasons applies:
a) Obligation to erase
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
The data subject withdraws consent on which the processing is based according to point (a) of Article 6.1, or point (a) of Article 9.1, and where there is no other legal ground for the processing;
The data subject objects to the processing pursuant to Article 21 (1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (2);
The personal data have been unlawfully processed;
The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
The personal data have been collected in relation to the offer of information society services referred to in Article 8.1.
b) Information to Third Parties
Where the controller has made the personal data public and is obliged pursuant to Article 17 (1) GDPR 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 controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
The right to erasure shall not apply to the extent that processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation which requires processing by 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 area of public health in accordance with points (h) and (i) of Article 9 (2) as well as Article 9 (3) GDPR;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) GDPR in so far as the right referred to in Article 89 (1) GDPR is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
- for the establishment, exercise or defence of legal claims.
7.5 Right to be informed
If you have exercised your right to have the controller correct, erase or restrict the processing, he is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this correction or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
You have the right to be informed of such recipients by the controller.
7.6 Right to data portability
You have the right to receive the personal data concerning you, which you have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
the processing is based on consent pursuant to point (a) of Article 6 (1) or point (a) of Article 9 (2) or on a contract pursuant to point (b) of Article 6 (1); and
the processing is carried out by automated means.
In exercising your right to data portability pursuant to Article 20 (1) you shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
The exercise of the right referred to in Article 20 (1) shall be without prejudice to Article 17. That right shall 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.
7.7 Right to object
You have the right to object at any time, for reasons arising from your particular situation, to the processing of your personal data based on Article 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions.
The controller no longer processes the personal data concerning you, unless he can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
If personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing.
If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility to exercise your right of objection in connection with the use of Information Society services by means of automated procedures using technical specifications, notwithstanding Directive 2002/58/EC.
7.8 Right to withdraw data protection declaration of consent
You have the right to withdraw your declaration of consent any time. The withdrawal of consent shall not affect the legality of the processing carried out on the basis of the consent until withdrawal.
7.9 Automated decision in individual cases including profiling
You have the right not to be subject to a decision based exclusively on automated processing – including profiling – that has legal effect against you or significantly impairs you in a similar manner. This does not apply if the decision
- is necessary to enter into or perform a contract between you and the controller;
- tis admissible under Union or Member State legislation to which the controller is subject and where such legislation contains appropriate measures to safeguard your rights, freedoms and legitimate interests or
- is based on your express consent.
However, these decisions may not be based on special categories of personal data pursuant to Article 9 (1) GDPR, unless Article 9 (2) (a) or (g) applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.
In the cases referred to in (1) and (3), the controller shall take reasonable measures to safeguard your rights, freedoms and legitimate interests, including at least the right to obtain the intervention of a person by the controller, to state his own position and to challenge the decision.
7.10 Right to complain to the supervisory authorities
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint to a supervisory authority, in particular in the Member State of your place of residence, employment or suspected infringement, if you believe that the processing of personal data concerning you is contrary to the GDPR.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Article 78 GDPR.
8. Press contacts
8.1 Scope and description of processing of personal data
Public relations as well as networking with the press are vital task for us a startup company in order to create medial impact. The DIG-team for press and publications processes personal data of media professionals, such as contact data and main areas of activity.
The following data may be processed:
- email address
- phone number
- media and address data of the media
- industry / thematic focus
The data is either collected directly from the data subject in person, i.e. if a media professional gets in contact with us, or indirectly using journalist / media databases or publicly accessible sources.
8.2 Legal basis for the processing of personal data
If the processing of the personal data serves the fulfilment of a contract or the implementation of pre-contractual measures, the legal basis for the processing of the data is Article 6 (1) (b) GDPR. Otherwise the legal basis for the processing of data is Article 6 (1) (f) GDPR.
8.3 Purpose of the processing
As a growing startup business we are dependent on press contacts for media coverage as part of our marketing. For this reason, we use the standard communication channels that can connect us with such professionals. Our legitimate interest according to Art. 6 (1) (f) GDPR here is to make those contacts as part of our marketing to ensure growth and future business.
8.4 Storage period
The data will be erased or processing will be restricted as soon as they are no longer necessary to achieve the purpose for which they were collected or if the data subject has objected against the processing.
8.5 Objections and erasure
An objection against being contacted by DIG can be made at any time, informally and with effect into the future.