Last update: May 2019
MEMORATIO is controller within the meaning of the General Data Protection Regulation (“GDPR”) with regard to the personal data collected and processed as described in the following:
If you have any questions or concerns regarding privacy issues and your personal data or would like to exercise your privacy rights, please email us with the subject line “Data Privacy” at firstname.lastname@example.org
1.3 Subject-matter of Data Protection
The subject matter of data protection is personal data. Pursuant to Art. 4(1) GDPR, this includes all information relating to an identified or identifiable natural person, e.g., name or email address.
1.3.1 Automated Data Collection
When accessing our Website, your end device automatically transmits data for technical reasons. The following data is stored separately from other data that you may transmit to us, for example: IP address, date and time of access, browser type/version, operating system used, URL of the previously visited website and amount of data sent. We might collect this information in order to monitor our website's functionality.
1.3.2 Contacting us
If you contact us per email, we will retain your email address and further data you submit with the email in order to process your inquiry/request. We collect and process such data in order to answer your inquiry/request, Article 6(1)(b) GDPR. Please note that we may need further data in order to answer your inquiry/request (e.g. your name or invoice address), if it is impossible to do so without such data.
1.4 Transfer of your personal data
MEMORATIO may transfer your personal data to third parties if this is required for performance of the contract or for legal reasons (Art. 6(1)(b) GDPR). Further, we may transfer your personal data to third parties if you explicitly consent to such transfer (Art. 6(1)(a) GDPR). In addition, we may transfer your personal data if this is necessary for compliance with a legal obligation to which Memoratio is subject. Any data transfer will take place in accordance with applicable data protection laws.
We use the following data processors:
• service providers in the areas of web design and hosting which are located in Germany; and
• the service providers as specified in Sec. 1.6, 1.7, 1.8 and Sec. 1.9 below.
The transfer of personal data to data processors is based on Art. 28(1) DSGVO, or alternatively on our legitimate interest in the economic and technical advantages associated with the use of specialized data processors, and the fact that your rights and interests in protecting your personal data do not predominate, Art. 6(1)(f) GDPR.
We also process data in countries outside the European Union ("EU") if there is an adequate level of data protection. In a decision of 12 July 2016, the European Commission decided for the USA that an adequate level of data protection exists under the provisions of the EU-U.S. Privacy Shield (Adequacy Decision, Art. 45 GDPR). We use the following service provider, which is certified according to the EU-U.S. Privacy Shield: Google (Google Inc., 1600 Amphitheater Parkway Mountain View, CA 94043, USA). For further information contact us by e-mail at email@example.com
This website uses the following types of cookies, whose scope and way of functioning will be explained in the following:
transient cookies and persistent cookies.
Transient cookies are automatically deleted when you close the browser. Session cookies are a type of transient cookie. They store a so-called session ID, which allows us to recognise your computer again when you return to our Website. Session cookies are deleted when you log out or close the browser. Persistent cookies are automatically deleted after a predetermined period of time that varies depending on the cookie. You can delete cookies in the security settings of your web browser at any time.
You can configure your web browser settings just as you like and, for example, reject all third-party cookies or all cookies. We would like to inform you that if you restrict cookies, you may not be able to use all of the features of this website.
1.6 Google Analytics
Memoratio uses features of the web analytics service Google Analytics, operated by Google Inc., 1600 Amphitheater Parkway Mountain View, CA 94043, USA (“Google”). Google Analytics uses so-called „cookies“. These are text files that are stored on your computer and allow to analyse your use of the Website.
The information generated by the cookie about your use of this Website is usually transferred to a Google server in the US and stored there. On this website Google Analytics has been expanded to the code "gat._anonymizeIp ();" to ensure an anonymous collection of IP addresses (so called IP-masking). As IP anonymization is activitated on this Website, your IP address will be previously abbreviated within Member States of the European Union or other parties to the Agreement on the European Economic Area. Only in exceptional cases the full IP address is transferred to a Google server in the USA and is abbreviated there. The IP address transmitted by your browser within the context of Google Analytics will not be combined with any other data held by Google. On behalf of the operator of this Website Google will use this information to evaluate your usage of the Website, to create reports on website activities and to provide other services related to Website and internet usage to the Website operator.
We use Google Analytics due to our legitimate interest to offer the best possible website functions, to evaluate the statistics of use and to better advertise our Website, Art. 6(1)(f) GDPR.
For statistical evaluation of visitor access, data is collected, processed and stored with technologies of Hotjar Ltd. for marketing purposes and for the recognition of web visitors. So-called cookies may be used for this purpose. Cookies are small text files that are stored on your computer and enable an analysis of your use of the website. The data collected by Hotjar may also contain personal data. Hotjar Ltd. may use information left behind by visits to the websites to create anonymous user profiles. If IP addresses are collected, they will be made anonymous immediately after collection by deleting the last number block. The data collection and storage by Hotjar Ltd for this Website can be objected to at any time with effect for the future at https://www.hotjar.com/legal/compliance/opt-out
We use Hotjar due to our legitimate interest to offer the best possible website functions and to evaluate the statistics of use and to better advertise our Website, and the fact that your rights and interests in protecting your personal data do not predominate, Art. 6(1)(f) GDPR.
1.8 Integration of Google Maps
We use the offerings of Google Maps on our Website. This allows us to display interactive maps for you on the Website and facilitates the convenient use of the map feature.
Through your visit to the website, Google will be informed that you pulled up the corresponding subpage of our website. The data mentioned under Sec. 3.1 is also transmitted. This will occur regardless of whether Google makes a user account available through which you are logged in or if there is no user account at all. If you are logged into Google, your data will be directly assigned to your account. If you don’t want the information assigned directly to your profile with Google, you will have to log out before activating the button. Google stores your data as a usage profile and uses it for advertising, market research, and/or user-friendly configuration of its website. Such usage serves particularly (also for users who are not logged in) the purpose of providing customised needs-based advertising and in order to inform other users of the social network of your activities on our Website. You have the right to deny permission for such a user profile to be formed, but in order to assert this right you must contact Google.
We integrate Google Maps due to our legitimate interest to offer the best website functions, and the fact that your rights and interests in protecting your personal data do not predominate, Art. 6(1)(f) GDPR.
For further information on the purpose and scope of data collection and its processing by the plug-in provider, see the data protection declaration of the provider. There you will also receive further information on your rights within this context and setting options for protecting your privacy: http://www.google.de/intl/de/policies/privacy. Google also processes your personal data in the United States and has agreed to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
1.9 Integration of YouTube videos
Memoratio uses the YouTube video platform operated by YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066 USA (“YouTube”). We have integrated YouTube videos into our online offerings that are stored on http://www.YouTube.com and can be played directly from our Website. These are all integrated in “Extended Data Protection Mode”, meaning that no data about you as a user is transmitted to YouTube if you do not play the videos. Only when you play the videos will the data described in Section 3.1 be transmitted. We have no influence on this data transmission.
Through your visit to the website, YouTube will be informed that you pulled up the corresponding subpage of our website. The data mentioned above is also transmitted. This will occur regardless of whether YouTube makes a user account available through which you are logged in or if there is no user account at all. If you are logged into Google, your data will be directly assigned to your account. If you don’t want the information assigned directly to your profile with YouTube, you will have to log out before activating the button. YouTube stores your data as a usage profile and uses it for advertising, market research, and/or user-friendly configuration of its website. Such usage serves particularly (also for users who are not logged in) the purpose of providing customised needs-based advertising and in order to inform other users of the social network of your activities on our website. You have the right to deny permission for such a user profile to be formed, but in order to assert this right you must contact YouTube.
We integrate YouTube videos due to our legitimate interest to offer the best website functions, and the fact that your rights and interests in protecting your personal data do not predominate, Art. 6(1)(f) GDPR.
Further information on the purpose and scope of data collection and its processing through YouTube can be found in the data protection declaration. There you will also receive further information on your rights and setting options for protecting your privacy: https://www.google.de/intl/de/policies/privacy. Google also processes your personal data in the United States and has agreed to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
1.10 External Links
This Website may contain links to third-party websites operated by providers that are not associated with Memoratio. Any behaviour of these third parties is beyond our control. Memoratio is not responsible for the processing of personal data by third parties.
1.11 Deletion of Personal Data
We will delete or anonymize your personal data as soon as it is no longer required for the purposes for which we have collected or used it in accordance with the above paragraphs. For more details on our data retention concept, you can contact us by e-mail at firstname.lastname@example.org
1.12 Your privacy rights
You are entitled to the following rights with regard to your personal data:
1.12.1 Right to access (Art.15 GDPR)
You always have the right to request confirmation as to whether we process your personal data and, where that is the case, to request access to the personal data we hold about you.
1.12.2 Right to rectification (Art. 16 GDPR)
You have the right to request prompt correction of your inaccurate personal data.
1.12.3 Right to erasure (Art. 17 GDPR)
You have the right to request erasure of personal data without undue delay under certain circumstances. Such circumstances may be e.g. if your personal data is no longer necessary for the purposes for which it was collected or if you withdraw consent on which our processing is based according to Article 6(1)(a) GDPR and where there is no other legal ground for processing.
1.12.4 Right to restriction of processing (Art. 18 GDPR)
You have the right to obtain a restriction of processing under certain circumstances. Such circumstances may be e.g. when you think that your personal data is not accurate or if we do not need the personal data for the original purpose of the processing but you need us to keep them for the establishment, exercise or defence of legal claims.
1.12.5 Right to data portability (Art. 20 GDPR)
Under certain circumstances, you have the right to receive your personal data you have provided us with, in a structured, commonly used and machine-readable format and you have the right to transmit that information to another controller without hindrance or ask us to do so.
1.12.6 Right to object to processing (Art. 21 GDPR)
You have the right to object to the processing of your personal data under certain circumstances, in particular if we process your personal data on the legal basis of Art. 6(1)(e) and Art. 6(1)(f) GDPR or if we use your personal data for marketing purposes in accordance with Art. 21 DSGVO. We will stop the processing of your personal data unless we can prove compelling reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
1.12.7 Right to withdraw the consent
If you gave us your consent to collection and processing of your personal data within the meaning of Art. 6(1)(a) GDPR, you have the right to withdraw such consent at any time.
1.12.8 How to exercise your rights
You have a right to file a complaint with a supervisory authority, also in the member state of your habitual residence.
The supervisory authority competent for us is:
Bayerisches Landesamt für Datenschutzaufsicht
Promenade 27 (Schloss)
Tel. +49 981 53 1300
Fax +49 981 53 98 1300
If you think that you might need to contact another supervisory authority, please, contact us using contact information given in Section 1.2 – we will be happy to assist you with the search.
1.13 Policy changes