Privacy Policy

APL Europe GmbH (hereinafter referred to as "APL" or "we") would like to inform you below about how we protect your privacy and how personal data is processed in the context of our service offerings and website presentation. Personal data will be deleted as soon as possible and will never be used or passed on for advertising purposes without explicit permission. If the following information is not sufficient or not comprehensible, please do not hesitate to contact us at the contact address given in section I. Please note that this English translation is for information purpose only and that the German version is prevailing.

I. Name and address of the data controller

The data controller within the meaning of Regulation (EU) 679/2016 on the protection of individuals with regard to the processing of personal data, on the free movement of such data and repealing Directive 95/46/EC (hereinafter "DSGVO") and in accordance with the Federal Data Protection Act (hereinafter "BDSG") and other provisions of data protection law is:

APL Europe GmbH
Sendlinger Straße 4
80331 München
Telephone: +49 89 231 2161 90

II. Contact details of the data protection officer

Warth & Klein Grant Thornton AG Wirtschaftsprüfungsgesellschaft
Wjur. Sebastian Barg
Johannstraße 39
40476 Düsseldorf
Telephone: +49 211 95248548
Mail: sebastian.barg@wkgt.com

III. Definitions / terms

1. Scope of the processing of personal data

We process your personal data as a user of the website only to the extent necessary to provide our web and online services, including a functioning website.

2. Legal basis

Insofar as personal data is processed on the basis of the consent of the data subject, Art. 6 (1) a DSGVO is the legal basis for the processing.

Where personal data is processed for the performance of a contract to which the data subject is a party, the legal basis is Article 6(1)(b) DSGVO; this also applies to processing necessary for the performance of pre-contractual measures.

If processing of personal data is carried out for compliance with a legal obligation to which we are subject, Art. 6 para. 1 lit. c DSGVO is the legal basis.

In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) (d) DSGVO is the legal basis.

If processing is carried out to protect our legitimate interests or those of a third party and the interests, fundamental rights and freedoms of the data subject are not overridden, Article 6(1)(f) of the GDPR is the legal basis for the processing.

3. Possible recipients of personal data

In order to provide our services, we sometimes use service providers who may act on our behalf and according to our instructions (so-called processors). These service providers may receive personal data or come into contact with personal data in the course of providing the service and constitute third parties or recipients within the meaning of the DSGVO.

In such a case, we ensure that our service providers take sufficient security measures, that appropriate technical and organisational measures are in place and that processing operations are carried out in such a way that they comply with the relevant data protection provisions and ensure the protection of the rights of data subjects (cf. Art. 28 DSGVO).

In addition, we process your personal data within various specialist departments involved in the execution of the respective business processes.

4. Processing of personal data in third-party countries

As a matter of principle, your personal data is processed within the European Union (hereinafter "EU") or the European Economic Area (hereinafter "EEA"). Only in exceptional cases may information be transferred to third-party countries. Third-party countries are countries outside the EU and/or EEA in which an adequate level of data protection in accordance with European requirements cannot be assumed without further ado.

If the information transferred also includes personal data and is not transferred pseudonymised or anonymised, we ensure before such a transfer that an adequate level of data protection is guaranteed in the respective third country or at the respective recipient in the third country. This can result from a so-called "adequacy decision" of the European Commission or be ensured by using the so-called "EU standard contractual clauses".

5. Data deletion and storage period

Personal data of the data subjects will be deleted if the data is no longer required for the respective processing purposes. Instead of deletion, the data may be stored under restriction of processing if this is provided for by the European or national legislator in Union regulations, laws or other provisions, in particular e.g.

  1. to comply with statutory retention obligations (e.g. the German Fiscal Code (AO) or the German Commercial Code (HGB), currently between 6 and 10 years), and/or
  2. if there are legitimate interests in storing data (e.g. during the course of limitation periods for the purpose of a possible legal defence (§§ 195 ff. BGB, currently between 3 to 30 years).

The legal basis for this is Art. 6 para. 1 lit. c or letter f DSGVO. The data will be deleted at the latest when a storage period prescribed by the aforementioned standards expires, unless there is a need to continue storing the data for the conclusion of a contract or for other purposes (e.g. legitimate interests according to Art. 6 para. 1 lit. f DSGVO).

6. Categories of data

By visiting our website and / or using our service offers, we usually process master data (for example, first and last name, e-mail address, postal address or telephone number) as well as log and metadata.

7. Data subject rights

The DSGVO grants certain rights to persons affected by the processing of personal data (so-called data subject rights, in particular Art. 12 to 22 DSGVO). If you would like to make use of one or more of these rights listed below, you can contact us at any time. To do so, please use the contact option stated under point I.

  1. Right to information according to Art. 15 DSGVO
    You may request confirmation from the controller as to whether personal data concerning you is being processed.
  2. Right of rectification according to Art. 16 DSGVO
    You have a right of rectification and/or completion vis-à-vis the controller if the personal data processed concerning you are inaccurate or incomplete. The controller shall carry out the rectification without undue delay.
  3. Right to erasure according to Art. 17 DSGVO
    You may request the controller to erase the personal data concerning you without undue delay and the controller is obliged to erase this data without undue delay, unless one of the exceptions regulated in the DSGVO applies or other legal retention obligations oblige us to retain the data in question.
  4. Right to data portability according to Art. 20 DSGVO
    You have the right to receive the personal data concerning you, which you have provided to the controller and the processing of which is based on consent or on a contract with you, in a structured, common and machine-readable format. You also have the right, under the conditions laid down in the DSGVO, to transmit this data to another controller without hindrance from the controller to whom the personal data was provided. In exercising this right, you also have the right to have the personal data relating to you transferred directly from one controller to another controller, where this is technically feasible. The freedom and rights of other persons must not be affected by this.
  5. Right of objection according to Art. 21 DSGVO
    You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling insofar as it is related to such direct marketing. In the event of an objection, the personal data concerning you will no longer be processed for these purposes.
  6. Right to revoke consent pursuant to Art. 7 (3) DSGVO
    You have the right to revoke your declaration of consent under data protection law at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation. This also applies to the revocation of declarations of consent given to us prior to the application of the GDPR, i.e. prior to 25 May 2018. All personal data stored on the basis of the consent given in each case will be deleted in this case, unless there is another legal basis for further storage according to the law. If you wish to revoke your consent, please contact us using the contact details provided in section I. or II.
  7. Right of complaint pursuant to Art. 77 DSGVO
    In the event of violations of data protection regulations, data subjects have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged violation. The right of appeal is without prejudice to other administrative or judicial remedies.

    Our competent data protection supervisory authority is:

    Bayerisches Landesamt für Datenschutzaufsicht
    Promenade 18
    91522 Ansbach
    Telefon: +49 (0) 981 180093-0
    Telefax: +49 (0) 981 180093-800
    Mail: poststelle@lda.bayern.de

    The contact details of other data protection supervisory authorities can be found under the following link:https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

IV. Data processing through website use

1. Description and scope of data processing

Each time the website is called up, the system automatically generates data and information from the computer system of the calling computer. The following log files are processed:

  1. browser type and browser version
  2. operating system used
  3. referrer URL
  4. host name of the accessing computer
  5. time of the server request
  6. IP address

This data will not be merged with other data sources.

2. Purpose and legal basis of data processing

The temporary storage of the IP address and possibly other log files by the system are necessary to enable the website to be provided to your computer. This is required for addressing the communication traffic between the user and our service offer. The legal basis for this data processing - i.e. for the duration of your website visit - is Art. 6 para. 1 letter b or f DSGVO and § 96 TKG and § 25 Abs. 2 Nr. 2 TTDSG.

Any processing and storage of the IP address and log files that goes beyond the communication process is carried out for the purpose of ensuring the functionality, for the purpose of optimising these offers and for ensuring the security of our information technology systems. The legal basis for storing the IP address for these purposes beyond the communication process is Art. 6 para. 1 letter f DSGVO and § 25 Abs. 2 Nr. 2 TTDSG.

3. Duration of storage

The data is stored for as long as it is required to achieve legitimate purposes. In the case of the collection of data for the provision of the website, this is the case when the respective session - i.e. the website visit - has ended. Log files, including the IP address, are stored for a maximum of seven days from the end of the page access by the user for the purpose of system security and optimisation of our web and online services.

4. Possibility of objection

The collection of log files for the provision of our website, including their storage within the aforementioned limits, is absolutely necessary for the operation of the website and the individual functions stored there. Therefore, there is no possibility of objection on the part of the user of the website. This does not apply to the processing of log files for analysis purposes. Here, the possibility of objection - depending on the web analysis tools used and the type of data analysis (personal / anonymous / pseudonymous) - is governed by section III. 7. f of this data protection declaration.

V. Data processing for the purpose of advertising and marketing

Personal data will only be used for the purpose of advertising and/or marketing measures (hereinafter referred to as "marketing") if you have given your consent or if there is another legal basis which allows this even without consent.

Your personal data will only be used for the purpose of advertising and/or marketing approaches as well as for conducting customer satisfaction surveys if you have given your consent or if there is another legal basis which permits an advertising and/or marketing approach even without consent. As far as legally permissible, we reserve the right to address customers for advertising purposes also on the basis of publicly accessible data and/or address data of third parties, which they extract from publicly accessible sources (e.g. data from directory media, the Internet, company homepages, public registers or similar).

  1. The legal basis for advertising and/or marketing measures based on explicit consent is Art. 6 para. 1 letter a DSGVO; the explanations on consent under section III. 7 g apply accordingly.
  2. The legal basis for the use of personal data for the purpose of direct advertising by letter is Art. 6 (1) (f) DSGVO (legitimate interests); the legitimate interest here is to address potential customers for the purpose of direct advertising for our products and services.
  3. The legal basis for advertising and/or marketing measures via telephone calls is Section 7 (2) No. 2 UWG; this requires express consent in the case of consumers, and at least presumed consent in the case of other market participants; for the requirement of express consent, see above as well as Section III. 7 g.
  4. For advertising and/or marketing measures via e-mail for the purpose of direct advertising for our own similar goods or services, the legal basis is Section 7 (3) UWG, provided that (i) we have received your e-mail address in connection with the provision of a service, (ii) you have not objected to the use of your e-mail address for the purpose of direct advertising and (iii) when collecting the e-mail address and each time it is used, we clearly inform you that you can object to such use of your e-mail at any time (for the right to object, see Section III. 7 f).

Personal data will be stored and used for advertising purposes for an indefinite period of time, depending on the respective legal basis for the advertising measure (consent or legitimate interests), until you have objected to the use of your data for advertising purposes or you have revoked your corresponding consent.

You can revoke your consent to the processing of personal data at any time with effect for the future. You can object to processing on the basis of legitimate interests at any time; a right of objection exists in particular in the case of profiling in accordance with Art. 21 DSGVO. If a revocation and/or an objection is made, the personal data will no longer be processed for the respective purposes concerned; this does not apply in any case to the processing of data that is still required for the purpose of fulfilling the contract (Art. 6 (1) (b) DSGVO), including statutory retention obligations, and/or if the data is still required in the context of legitimate interests (Art. 6 (1) (f) DSGVO) (e.g. in the case of an advertising objection, the processing of data in a so-called blacklist, in order to prevent future advertising approaches).

We will be happy to provide you with further information on our handling of data in the area of marketing and/or the sources of our data upon request; please contact our data protection officer, whose contact details can be found in section II.

VI. E-mail contact / contacting us

1. Description and scope of data processing

To contact us, you can use the contact details provided. If you make use of these options, personal data will be processed and stored by us for the purpose of responding to your enquiry. In this context, we may process the personal data you provide to us; this may be, for example, your first name, last name and e-mail address. We do not pass on this data without your consent.

2. Purpose and legal basis of data processing

The processing of this data is based on your consent pursuant to Art. 6(1)(a) DSGVO and / or on our legitimate interests (Art. 6(1)(f) DSGVO), as we have a legitimate interest in the effective processing of requests addressed to us.

3. Duration of storage

Data is generally deleted as soon as it is no longer required to achieve the purpose for which it was collected. In addition, data stored on the basis of your consent will be stored on this basis until your consent is revoked.
Insofar as data is no longer required for the fulfilment of contractual or legal obligations, including commercial and tax law retention obligations, as well as for the pursuit of justified interests, i.e. for the preservation of evidence within the framework of the legal statute of limitations, it is regularly deleted.

VII. Links to third parties

We have provided links to third parties on our website. Please note that we are not the provider of these services or websites. Furthermore, we have no knowledge of the content of the transmitted data or its use by the respective provider. You will find more detailed information on the handling of your data in the respective data protection notices of the providers.

a) Immobilienscout24

On our website we have linked the real estate broker platform Immobilienscout24, Immobilien Scout GmbH, Invalidenstraße 65, 10557 Berlin. If you activate the button to Immobilienscout24, a direct connection between your browser and the server of Immobilienscout24 is established via the button. This provides Immobilienscout24 with information about your visit to the website. You can find more information on this in Immobilienscout24's data protection declaration at https://www.immobilienscout24.de/agb/datenschutz.html.

b) Google Maps

On our website we have linked to the map display service of Google, Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA. If you activate the button to Google Maps, a direct connection between your browser and Google's server is established via the button. This provides Google with information about your visit to the website. Further information on this can be found in Google's privacy policy at https://www.google.de/intl/de/policies/privacy.

VIII. Other

Should any provision of the data protection declaration be or become invalid or unenforceable in whole or in part, this shall not affect the validity of the remaining provisions of the data protection declaration. The same shall apply if and to the extent that a loophole should become apparent in the data protection declaration. In place of the invalid or unenforceable provision or to fill the gap, an appropriate provision shall apply which, as far as legally possible, comes as close as possible to what would have been intended according to the meaning and purpose of the data protection declaration.

IX. More Information

Your trust is important to us. Therefore, we would like to be available to you at any time to answer any questions you may have regarding the processing of your personal data. If you have any questions that are not answered by this data protection declaration or if you would like more detailed information on a particular point, please contact us at any time.

We reserve the right to change the data protection declaration at irregular intervals and will inform you of any significant changes that have an impact on the use of your personal data.

This privacy poilicy is dated February 2022.

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