We are delighted that you are interested in our company. Data protection is a particularly high priority for the management of The Brickworms GbR – Geraldine & Ralf J. Klumb. Use of The Brickworms GbR – Geraldine & Ralf J. Klumb website is possible without any personal data; however, if a data subject wants to use special 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 consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to The Brickworms GbR – Geraldine & Ralf J. Klumb. By means of this privacy policy, our company 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 privacy policy, of the rights to which they are entitled.

As the controller, The Brickworms GbR – Geraldine & Ralf J. Klumb has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, internet-based data transmissions may in principle have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

1. Definitions

The privacy policy of The Brickworms GbR – Geraldine & Ralf J. Klumb is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would firstly like to explain the terminology used. In this privacy policy, we 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

    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 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.
  •  
  • e) profiling

    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) 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 are 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 or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
  •  
  • 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 the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in connection with a particular enquiry under 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

    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.
  •  
  • k) consent

    The data subject’s consent is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the controller

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: The Brickworms GbR – Geraldine & Ralf J. Klumb Würzburger Straße 6 10789 Berlin Germany Phone: +49 (0)30 33939021 E-mail: mail (at) brickworms (dot) eu Website: https://www.brickworms.eu

3. Cookies

The Brickworms GbR – Geraldine & Ralf J. Klumb website uses cookies. Cookies are text files that are stored in a computer system via a web browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which websites and servers can be assigned to the specific web browser in which the cookie was stored. This allows visited websites and servers to differentiate the data subject’s individual browser from other browsers that contain other cookies. A specific web browser can be recognised and identified using the unique cookie ID.

Through the use of cookies, The Brickworms GbR – Geraldine & Ralf J. Klumb can provide the users of this website with more user-friendly services that would not be possible without the storage of cookies.

By means of a cookie, the information and offers on our website can be optimised with the user in mind. Cookies allow us, as previously mentioned, to recognise our website users. The purpose of this recognition is to make it easier for users to utilise our website. The user of a website that uses cookies, e.g. does not have to re-enter their credentials each time the website is accessed, because this is done by the website, and the cookie is thus stored on the user’s computer system. Another example is the shopping basket cookie in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping basket via a cookie.

The data subject may, at any time, prevent the storage of cookies through our website by means of a corresponding setting of the web browser used, and may thus permanently reject the storage of cookies. Furthermore, cookies that are already stored may be deleted at any time via a web browser or other software programs. This is possible in all established web browsers. If the data subject deactivates the storage of cookies in the web browser used, not all functions of our website may be entirely usable.

4. Collection of general data and information

The Brickworms GbR – Geraldine & Ralf J. Klumb website collects a series of general data and information when a data subject or automated system accesses the website. This general data and information are stored in the server log files. The (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 referrers), (4) the subwebsites, (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) any other similar data and information that may be used in the event of attacks on our information technology (IT) systems may be collected.

When using this general data and information, The Brickworms GbR – Geraldine & Ralf J. Klumb 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 as well as advertise it, (3) ensure the long-term viability of our IT systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, The Brickworms GbR – Geraldine & Ralf J. Klumb analyses anonymously collected data and information statistically, with the aim of increasing our company’s data protection and security, 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.

5. Registration on our website

The data subject has the possibility to register on the controller’s website with the indication of personal data. The personal data to be transmitted to the controller is determined by the respective entry form used for registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for the controller’s own purposes. The controller may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the controller’s website, the IP address – assigned by the internet service provider (ISP) and used by the data subject – date and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offences. In this respect, the storage of this data is necessary to safeguard the controller. This data is not disclosed to third parties unless there is a statutory obligation to disclose it, or if the disclosure serves the aim of criminal prosecution.

By voluntarily providing personal data, the data subject’s registration is intended to enable the controller to offer the data subject content or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during registration at any time, or to have it completely deleted from the controller’s database.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees is available to the data subject in this respect as contact persons.

6. Subscription to our newsletters

On The Brickworms GbR – Geraldine & Ralf J. Klumb website, users are given the opportunity to subscribe to our company newsletter. The entry form used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

The Brickworms GbR – Geraldine & Ralf J. Klumb informs its customers and business partners regularly by means of a newsletter about company offers. The company newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for delivery of the newsletter. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for delivery of the newsletter, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorised to receive the newsletter.

During registration for the newsletter, we also store the IP address of the computer system assigned by the internet service provider (ISP) and used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to understand the (possible) misuse of a data subject’s e-mail at a later date, and it therefore serves to legally protect the controller.

The personal data collected as part of registering for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be notified by e-mail if this is necessary for the operation of the newsletter service or registration, as may be the case in the event of changes to the newsletter offer or technical changes. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for sending the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the controller’s website, or to communicate this to the controller in a different way.

7. Newsletter tracking

The Brickworms GbR – Geraldine & Ralf J. Klumb newsletter contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, The Brickworms GbR – Geraldine & Ralf J. Klumb may see if and when an e-mail was opened by a data subject, and which links in the e-mail were accessed by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analysed by the controller in order to optimise the sending of the newsletter, as well as to better adapt the content of future newsletters to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure at any time. After revocation, these personal data will be deleted by the controller. The Brickworms GbR – Geraldine & Ralf J. Klumb automatically regards a withdrawal from the receipt of the newsletter as a revocation.

8. Getting in contact via the website

The Brickworms GbR – Geraldine & Ralf J. Klumb website contains information that enables quick electronic contact with our company, as well as direct communication with us, which also includes a general address of so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

9. Routine erasure and blocking of personal data

The data controller shall process and store the data subject’s personal data 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.

10. Rights of the data subject

  • a) Right of confirmation

    Each data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself or herself of this right of confirmation, he or she may, at any time, contact any of the controller’s employees.
  •  
  • b) Right of access

    Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her 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 from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
    • the existence of the right to lodge a complaint with a supervisory authority;
    • where the personal data are not collected from the data subject, 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 the data subject.
    Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself or herself of this right of access, he or she may, at any time, contact any of the controller’s employees.
  •  
  • c) Right to rectification

    Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right 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, he or she may, at any time, contact any of the controller’s employees.
  •  
  • d) Right to erasure (right to be forgotten)

    Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
    • 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 to 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.
    • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects 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 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) of the GDPR.
    If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by The Brickworms GbR – Geraldine & Ralf J. Klumb, he or she may, at any time, contact any of the controller’s employees. An employee of The Brickworms GbR – Geraldine & Ralf J. Klumb shall promptly ensure that the erasure request is complied with immediately. 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 the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of The Brickworms GbR – Geraldine & Ralf J. Klumb will arrange the necessary measures in individual cases.
  •  
  • e) Right of restriction of processing

    Each data subject shall have 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 instead the restriction of their use instead.
    • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
    • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending verification as to whether the legitimate grounds of the controller override those of the data subject.
    If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by The Brickworms GbR – Geraldine & Ralf J. Klumb, he or she may at any time contact any of the controller’s employees. The employee of The Brickworms GbR – Geraldine & Ralf J. Klumb will arrange restriction of the processing.
  •  
  • f) Right to data portability

    Each data subject shall have the right granted by the European legislator to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, 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 his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where 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, the data subject may at any time contact any employee of The Brickworms GbR – Geraldine & Ralf J. Klumb.
  •  
  • g) Right to object

    Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
  • The Brickworms GbR – Geraldine & Ralf J. Klumb shall no longer process the personal data in the event of objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
  • If The Brickworms GbR – Geraldine & Ralf J. Klumb processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to The Brickworms GbR – Geraldine & Ralf J. Klumb to processing for direct marketing purposes, The Brickworms GbR – Geraldine & Ralf J. Klumb will no longer process the personal data for these purposes.
  • In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by The Brickworms GbR – Geraldine & Ralf J. Klumb 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, the data subject may contact any employee of The Brickworms GbR – Geraldine & Ralf J. Klumb. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
  •  
  • h) Automated individual decision-making, including profiling

    Each data subject shall 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 him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject, and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
  • If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, The Brickworms GbR – Geraldine & Ralf J. Klumb shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human interv