Privacy Policy

We are very pleased about your interest in our company. Data protection is of particularly high importance to the management of Lülf+ Sicherheitsberatung GmbH. Use of the Lülf+ Sicherheitsberatung GmbH website is generally possible without providing any personal data. However, if a data subject wishes to use special services offered by our company via our website, processing of personal data may become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the data subject’s consent.

The processing of personal data, for example the name, address, email address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection provisions applicable to Lülf+ Sicherheitsberatung GmbH. By means of this Privacy Policy, our company would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, this Privacy Policy informs data subjects about the rights to which they are entitled.

In our company, we have appointed a Data Protection Officer, who can be reached at datenschutz[@]luelf-plus.de.

As the controller responsible for processing, Lülf+ Sicherheitsberatung GmbH has implemented numerous technical and organisational measures to ensure the most complete protection possible of personal data processed via this website. Nevertheless, internet-based data transmissions can generally have security gaps, so absolute protection cannot be guaranteed. For this reason, any data subject is free to transmit personal data to us via alternative means, for example by telephone.

1. Definitions
The Privacy Policy of Lülf+ Sicherheitsberatung GmbH is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our Privacy Policy is intended to be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

In this Privacy Policy, we use, among other things, the following terms:

a) Personal data
Personal data is any information relating to an identified or identifiable natural person (hereinafter “data subject”). A natural person is considered identifiable if they 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.

c) Processing
Processing is any operation or set of operations performed on 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 its processing in the future.

e) Profiling
Profiling is 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) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing
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 Union law or the law of the Member States, the controller or the specific criteria for its designation may be provided for by Union law or the law of the Member States.

h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient
Recipient is a natural or legal person, public authority, agency or another body to which personal data is 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 Union law or the law of the Member States shall not be regarded as recipients.

j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent
Consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them.

2. Name and address of the controller responsible for the processing
The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

Lülf+ Sicherheitsberatung GmbH
Bismarckstr. 29
41747 Viersen
Germany
Tel.: 02162 / 43694 – 0
Email: info[@]luelf-plus.de
Website: www.luelf-plus.de

3. Cookies and similar technologies
The websites of Lülf+ Sicherheitsberatung GmbH use cookies and similar technologies (e.g. Web Storage, LocalStorage). Cookies are small text files that are stored on the data subject’s device via the internet browser. They enable us to recognise the device on a subsequent visit and thus provide website functions, make use easier or embed content.
We use both technically necessary cookies and—after your explicit consent—cookies and services that are not strictly necessary for operating the website (e.g. for embedding external content). We process technically necessary cookies on the basis of Art. 6(1)(f) GDPR and Section 25(2) TDDDG. All other cookies and services are used exclusively on the basis of your consent pursuant to Art. 6(1)(a) GDPR in conjunction with Section 25(1) TDDDG.
An overview of all cookies and services we use—including provider, purpose, storage period and, where applicable, transfer to third countries—can be found at any time in our cookie settings (accessible via the “Cookies” link in the footer of our website). There you can also adjust or withdraw your consent at any time with effect for the future.
In addition, you can prevent the setting of cookies in your internet browser settings or delete cookies that have already been set there. Please note that if cookies are completely disabled, not all functions of this website may be fully usable.

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and the related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/de/rcb/datenverarbeitung/

The legal bases for processing personal data in this context are Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we cannot manage your consents.

4. Collection of general data and information
Each time the website of Lülf+ Sicherheitsberatung GmbH is accessed by a data subject or an automated system, the website collects a series of general data and information. This general data and information is stored in the server log files. The following may be recorded: (1) 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 referrer), (4) the subpages accessed on our website via an accessing system, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information used for threat prevention in the event of attacks on our information technology systems.

When using this general data and information, Lülf+ Sicherheitsberatung GmbH does 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 and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. These anonymously collected data and information are therefore evaluated by Lülf+ Sicherheitsberatung GmbH both statistically and with the aim of increasing data protection and data security in our company, in order ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data from the server log files are stored separately from all personal data provided by a data subject.

5. Registration on our website / booking a seminar
The data subject has the option to register on the website of the controller by providing personal data. Which personal data is transmitted to the controller is determined by the respective input form used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for its own purposes.
Excluded from this is the booking of seminars, which is carried out via moreapp (https://moreapp.com/assets/MoreApp-LA-EULA-DPA.pdf).
The controller may arrange for the transfer to one or more processors, for example a parcel service provider, which also uses the personal data exclusively for internal use attributable to the controller.

By registering on the website of the controller, the IP address assigned by the data subject’s internet service provider (ISP), the date and the time of registration are also stored. This data is stored because only in this way can misuse of our services be prevented, and because this data can, if necessary, make it possible to investigate criminal offences. In this respect, the storage of this data is necessary to safeguard the controller.

The registration of the data subject with the voluntary provision of personal data serves the controller to offer the data subject content or services that, due to their nature, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely deleted from the controller’s database.

The controller shall provide any data subject, at any time upon request, with information about which personal data concerning the data subject is stored. Furthermore, the controller shall rectify or erase personal data at the request or indication of the data subject, insofar as this does not conflict with statutory retention obligations. All employees of the controller are available to the data subject as contact persons in this context.

6. Contact option via the website
Due to legal requirements, the website of Lülf+ Sicherheitsberatung GmbH contains information that enables quick electronic contact with our company and direct communication with us, which also includes a general address for so-called electronic mail (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted voluntarily by a data subject to the controller is stored for the purpose of processing or contacting the data subject. This personal data is not passed on to third parties.

7. Routine erasure and blocking of personal data
The controller processes and stores the data subject’s personal data only for the period necessary to achieve the purpose of storage, or insofar as this has been provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies or a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or erased in accordance with statutory provisions.

8. Rights of the data subject
a) Right to confirmation
Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right of confirmation, they may contact an employee of the controller at any time.

b) Right of access
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller, at any time and free of charge, information about the personal data stored about them and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:

the purposes of the processing
the categories of personal data being processed
the recipients or categories of recipients to whom the personal data has been disclosed 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 rectification or erasure of personal data concerning them, or restriction of processing by the controller, or the right to object to such processing
the existence of the right to lodge a complaint with a supervisory authority
where the personal data is not collected from the data subject: any available information as to its source
the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) GDPR and—at least in those cases—meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject
Furthermore, the data subject has the right to be informed whether personal data has been transferred to a third country or to an international organisation. Where this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, they may contact an employee of the controller at any time.

c) Right to rectification
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right, taking into account the purposes of the processing, to have incomplete personal data completed—including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, they may contact an employee of the controller at any time.

d) Right to erasure (right to be forgotten)
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, where one of the following grounds applies and insofar as the processing is not necessary:

The personal data has been collected or otherwise processed for purposes for which it is no longer necessary.
The data subject withdraws consent on which the processing was based pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
The personal data has been processed unlawfully.
The erasure of the personal data is necessary for compliance with a legal obligation under Union law or the law of the Member States to which the controller is subject.
The personal data has been collected in relation to the offer of information society services pursuant to Art. 8(1) GDPR.
If one of the above grounds applies and a data subject wishes to request the erasure of personal data stored by Lülf+ Sicherheitsberatung GmbH, they may contact an employee of the controller at any time. The employee of Lülf+ Sicherheitsberatung GmbH will ensure that the erasure request is complied with without undue delay.

If Lülf+ Sicherheitsberatung GmbH has made the personal data public and our company, as the controller, is obliged pursuant to Art. 17(1) GDPR to erase the personal data, Lülf+ Sicherheitsberatung GmbH shall, taking account of available technology and the cost of implementation, take reasonable measures, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure by such controllers of any links to, or copies or replications of, that personal data, insofar as processing is not required. The employee of Lülf+ Sicherheitsberatung GmbH will arrange the necessary measures in individual cases.

e) Right to restriction of processing
Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead.
The controller no longer needs the personal data for the purposes of the processing, but the data subject requires it for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Art. 21(1) GDPR and it has not yet been determined whether the legitimate grounds of the controller override those of the data subject.
If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Lülf+ Sicherheitsberatung GmbH, they may contact an employee of the controller at any time. The employee of Lülf+ Sicherheitsberatung GmbH will arrange the restriction of processing.

f) Right to data portability
Every data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which has been provided by the data subject to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data has been provided, where the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out by automated means, provided that 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 their right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may contact an employee of Lülf+ Sicherheitsberatung GmbH at any time.

g) Right to object
Every data subject affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.

Lülf+ Sicherheitsberatung GmbH will no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims.

If Lülf+ Sicherheitsberatung GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for such marketing. This also applies to profiling insofar as it is related to such direct marketing. If the data subject objects to Lülf+ Sicherheitsberatung GmbH to the processing for direct marketing purposes, Lülf+ Sicherheitsberatung GmbH will no longer process the personal data for these purposes.

In addition, the data subject has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them by Lülf+ Sicherheitsberatung GmbH for scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) GDPR, unless such processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may contact any employee of Lülf+ Sicherheitsberatung GmbH directly. The data subject is also free to exercise their right to object in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by automated means using technical specifications.

h) Automated decisions in individual cases, including profiling
Every data subject affected by the processing of personal data has 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 them or similarly significantly affects them, provided that the decision (1) is not necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and that law lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, Lülf+ Sicherheitsberatung GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.

If the data subject wishes to assert rights relating to automated decisions, they may contact an employee of the controller at any time.

i) Right to withdraw a data protection consent
Every data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise their right to withdraw consent, they may contact an employee of the controller at any time.

j) Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR (Art. 77 GDPR).

The supervisory authority responsible for us is:

State Commissioner for Data Protection and Freedom of Information North Rhine‑Westphalia (LDI NRW) Kavalleriestraße 2–4 40213 Düsseldorf Phone: 0211 / 38424‑0 Email: poststelle@ldi.nrw.de Web: https://www.ldi.nrw.de

9. Data protection for applications and in the application process
The controller collects and processes applicants’ personal data for the purpose of handling the application process. Processing may also take place electronically. This is particularly the case if an applicant submits corresponding application documents to the controller electronically, for example by email or via a web form on the website. If the controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of handling the employment relationship in compliance with statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller oppose deletion. Other legitimate interests in this sense include, for example, an obligation to provide evidence in proceedings under the General Equal Treatment Act (AGG).

10. Legal basis of processing
Art. 6(1)(a) GDPR serves our company 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 is a party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, for example to fulfil tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and their name, age, health insurance data or other vital information had to be passed on to a doctor, a hospital or other third parties. In that case, the processing would be based on Art. 6(1)(d) GDPR. Finally, processing operations may be based on Art. 6(1)(f) GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not override those interests. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 GDPR).

11. Legitimate interests in the processing pursued by the controller or a third party
If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and our shareholders.

12. Period for which the personal data is stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of the period, the corresponding data is routinely erased, provided that it is no longer required for contract performance or contract initiation.

13. Statutory or contractual provisions for the provision of personal data; necessity for the conclusion of a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide
We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual arrangements (e.g. information on the contracting party). In some cases, it may be necessary for the conclusion of a contract that a data subject provides us with personal data which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will clarify on a case-by-case basis whether the provision of personal data is required by law or contract or necessary for the conclusion of a contract, whether there is an obligation to provide the personal data, and what the consequences of failure to provide the personal data would be.

14. Automated decision-making
As a responsible company, we do not use automated decision-making or profiling.

15. Hosting
We host our website with Strato AG, Otto‑Ostrowski‑Straße 7, 10249 Berlin (hereinafter “Strato”). When you visit our website, Strato collects various technical data, including your IP address, requests, meta and communication data, device information, and the date and time of access. Processing takes place exclusively on servers within the Federal Republic of Germany; data is not transferred to a third country.

The use of Strato is based on Art. 6(1)(f) GDPR. We have a legitimate interest in presenting our website as reliably, securely and efficiently as possible. Where corresponding consent has been requested, processing is additionally based on Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as this includes the storage of cookies or access to information on the user’s end device. Consent can be revoked at any time.

We have concluded a data processing agreement with Strato in accordance with Art. 28 GDPR, which ensures the protection of your personal data and permits processing only in accordance with our instructions.

Further information on data protection at Strato can be found at https://www.strato.de/datenschutz/.