Data protection declaration according to the DSGVO
Company Frank Schneider – cosomex
this data protection declaration exists as of 25.05.2018
1. name and address of the person responsible
The person responsible within the meaning of the Basic Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations:
Frank Schneider – cosomex
Phone: +492601 -912170
2. general information on data processing
2.1 Scope of processing of personal data
We only process personal data of our users if this is necessary to provide a functional website as well as our contents and services. The processing of personal data of our users takes place regularly only after consent of the user. An exception applies in those cases where prior consent cannot be obtained for real reasons and the processing of the data is permitted by law.
2.2 Legal basis for the processing of personal data
Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a EU Data Protection Ordinance (DSGVO) serves as the legal basis.
In the processing of personal data required for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b DSGVO serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.
Insofar as the processing of personal data is required to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c DSGVO serves as the legal basis.
In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) DSGVO serves as the legal basis.
If processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f DSGVO serves as the legal basis for processing.
2.3 Data erasure and storage time
The personal data of the person concerned will be deleted or blocked as soon as the purpose of storage ceases to apply. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other provisions to which the person responsible is subject. The data will also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.
3. provision of the website and creation of log files
3.1 Description and scope of data processing
Every time you visit our website, our system automatically collects data and information from the computer system of the calling computer.
The following data is collected:
1.information about the browser type and version used
2. the user’s operating system
3. the user’s Internet service provider
4. the IP address of the user
5 Date and time of access
6. websites from which the user’s system reaches our website
7. websites accessed by the user’s system via our website
The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.
3.2 Legal basis for data processing
The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f DSGVO.
3.3 Purpose of data processing
The temporary storage of the IP address by the system is necessary to enable the website to be delivered to the user’s computer. For this the IP address of the user must remain stored for the duration of the session.
The data is stored in log files to ensure the functionality of the website. In addition, the data serves us to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.
Our legitimate interest in data processing pursuant to Art. 6 para. 1 lit. f DSGVO also lies in these purposes.
3.4 Duration of storage
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session has ended.
If the data is stored in log files, this is the case after seven days at the latest. Further storage is possible. In this case, the IP addresses of the users are deleted or alienated, so that an assignment of the calling client is no longer possible.
3.5 Possibility of objection and elimination
The collection of data for the provision of the website and the storage of data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.
4.1 Description and scope of data processing
The following data is stored and transmitted in the cookies:
In this way, the following data can be transmitted:
1. entered search terms
2. frequency of page views
3. use of website functions
4.2 Legal basis for data processing
The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f DSGVO.
The legal basis for the processing of personal data using technically necessary cookies is Art. 6 para. 1 lit. f DSGVO.
The legal basis for the processing of personal data using cookies for analytical purposes is Art. 6 para. 1 lit. a DSGVO.
4.3 Purpose of data processing
We need cookies for the following applications:
Acceptance of language settings
The user data collected by technically necessary cookies are not used to create user profiles.
The analysis cookies are used to improve the quality of our website and its content. Through the analysis cookies we learn how the website is used and can thus continuously optimize our offer.
For these purposes, our legitimate interest also lies in the processing of personal data in accordance with Art. 6 para. 1 lit. f DSGVO.
4.4 Duration of storage, possibility of objection and removal
The transmission of Flash cookies cannot be prevented via the browser settings, but by changing the Flash Player settings.
5. contact form and e-mail contact
5.1 Description and scope of data processing
There is a contact form on our website which can be used for electronic contact. If a user takes advantage of this possibility, the data entered in the input mask will be transmitted to us and stored. This data is:
Only your e-mail address is required to contact us. Other data provided by you, such as your name, is voluntary and will also be transmitted.
At the time the message is sent, the following data is also stored:
1.the IP address of the user
2nd date and time of registration
Your consent is obtained for the processing of the data within the scope of the sending process and reference is made to this data protection declaration.
Alternatively, you can contact us via the e-mail address provided. In this case, the user’s personal data transmitted by e-mail will be stored.
In this context, the data will not be passed on to third parties. The data is used exclusively for processing the conversation.
5.2 Legal basis for data processing
The legal basis for the processing of data is Art. 6 para. 1 lit. a DSGVO if the user has given his consent.
The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f DSGVO. If the e-mail contact aims at the conclusion of a contract, then additional legal basis for the processing is Art. 6 exp. 1 lit. b DSGVO.
5.3 Purpose of data processing
The processing of the personal data from the input mask serves us only for the treatment of the establishment of contact. In the event of contact by e-mail, this also constitutes the necessary legitimate interest in the processing of the data.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
5.4 Duration of storage
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the contact form and those that were sent by e-mail, this is the case when the respective conversation with the user is finished. The conversation is terminated when it can be inferred from the circumstances that the facts in question have been finally clarified.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
5.5 Possibility of objection and elimination
The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case, the conversation cannot be continued.
Simply send us an e-mail with your request to oppose or delete the data to: email@example.com
All personal data stored in the course of contacting us will be deleted in this case.
6. Use of Unity in apps published by us
6.1 Description and scope of data processing
Applications developed and published by us, as well as the game “Socca”, published in Google Playstore, and Apple Appstore use Unity. Unity is a range of services including Unity Ads and Unity Analytics. Unity’s services enable developers to integrate advertising into their applications and publish free applications.
Unity collects data from users of the applications in order to provide appropriate and relevant advertising for the respective user and thus improve the user experience. Users are offered an option (Data Privacy Option) with which they can object to the use of data for each application individually. By contradicting the use of data in the privacy settings, users will continue to receive advertising in the future, but this is done randomly without an analysis of the relevance of the advertising placed.
By using Unity Services, the following data is stored and transmitted:
1. type of terminal device
3. language settings
4. playing behavior and in-app purchases
5. IP address
6. IDFA (Apple’s Advertising Identifier)
7. Google Play advertising ID
6.2 Legal basis for data processing
The legal basis for the processing of personal data using Unity is Art. 6 para. 1 lit. f DSGVO.
The legal basis for the processing of personal data using Unity for analytical purposes is Art. 6 para. 1 lit. a DSGVO.
6.3 Purpose of data processing
The purpose of using Unity is to integrate advertising content in the application for users. Unity requires the analysis of personal data for the following applications:
Improvement of the user experience through relevant advertising
We use Unity’s services to analyze the services they are particularly interested in, so that we can continuously optimize our applications and only display advertising content relevant to them-
For these purposes, our legitimate interest also lies in the processing of personal data in accordance with Art. 6 para. 1 lit. f DSGVO.
6.4 Duration of storage, possibility of objection and removal
Unity has introduced the opt-out option to allow players to exercise this right and other data rights contained in the GDPR. We offer the possibility to exercise these rights via the Unity Ads SDK and the Unity Data Privacy Plug-In. Exercising the rights is an easy way for players to authenticate their identity, access the data stored in the app, request Unity to stop processing (targeting) the data and request the deletion of the data.
7. rights of the data subject
The following list includes all rights of the persons concerned according to the DSGVO. Rights that are not relevant for the own website need not be mentioned. In this respect, the list can be shortened.
If personal data are processed by you, you are affected within the meaning of the DSGVO and you have the following rights vis-à-vis the person responsible:
7.1 Right to information
You can ask the person in charge to confirm whether personal data concerning you will be processed by us.
If such processing has taken place, you can request the following information from the person responsible:
(1) the purposes for which the personal data are processed;
(2) the categories of personal data being processed;
(3) the recipients or categories of recipients to whom the personal data concerning you have been or are still being disclosed;
(4) the planned duration of the storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;
(5) the existence of a right to rectification or deletion of personal data concerning you, a right to limitation of processing by the controller or a right to object to such processing;
(6) the existence of a right of appeal to a supervisory authority;
(7) any available information on the origin of the data if the personal data are not collected from the data subject;
(8) the existence of automated decision-making including profiling in accordance with Art. 22 para. 1 and 4 DSGVO and – at least in these cases – meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.
You have the right to request information as to whether the personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 DSGVO in connection with the transmission.
7.2 Right to correction
You have a right of rectification and/or completion vis-à-vis the data controller if the personal data processed concerning you are incorrect or incomplete. The person responsible shall make the correction without delay.
7.3 Right to limitation of processing
Under the following conditions, you may request that the processing of personal data concerning you be restricted:
(1) if you dispute the accuracy of the personal data concerning you for a period that enables the data controller to verify the accuracy of the personal data;
(2) the processing is unlawful and you refuse to delete the personal data and instead request that the use of the personal data be restricted;
(3) the data controller no longer needs the personal data for the purposes of the processing, but you do need them to assert, exercise or defend legal claims, or
(4) if you have filed an objection to the processing pursuant to Art. 21 para. 1 DSGVO and it has not yet been determined whether the legitimate reasons of the person responsible outweigh your reasons.
If the processing of personal data concerning you has been restricted, such data may only be processed – apart from being stored – with your consent or for the purpose of asserting, exercising or defending rights or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or a Member State.
If the processing restriction has been restricted according to the above conditions, you will be informed by the person responsible before the restriction is lifted.
7.4 Right to cancellation
a.Duty to delete
You may request the data controller to delete the personal data relating to you without delay and the controller is obliged to delete this data without delay if one of the following reasons applies:
(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.
(2) You revoke your consent, on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a DSGVO, and there is no other legal basis for the processing.
(3) You file an objection against the processing pursuant to Art. 21 para. 1 DSGVO and there are no overriding legitimate reasons for the processing, or you file an objection against the processing pursuant to Art. 21 para. 2 DSGVO.
(4) The personal data concerning you have been processed unlawfully.
(5) The deletion of personal data relating to you is necessary to fulfil a legal obligation under Union law or the law of the Member States to which the data controller is subject.
(6) The personal data concerning you were collected in relation to information society services offered pursuant to Art. 8 para. 1 DSGVO.
b.Information to third parties
If the data controller has made the personal data concerning you public and is obliged to delete it pursuant to Art. 17 para. 1 DSGVO, he shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform data processors who process the personal data that you as the data subject have requested the deletion of all links to this personal data or of copies or replications of this personal data.
The right to cancellation does not exist insofar as the processing is necessary
(1) to exercise freedom of expression and information;
(2) for the performance of a legal obligation required for processing under the law of the Union or of the Member States to which the controller is subject or for the performance of a task in the public interest or in the exercise of official authority conferred on the controller;
(3) for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 DSGVO;
(4) for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes pursuant to Art. 89 para. 1 DSGVO, insofar as the law referred to under a) is likely to make it impossible or seriously impair the attainment of the objectives of such processing, or
(5) to assert, exercise or defend legal claims.
7.5 Right to information
If you have exercised your right to have the data controller correct, delete or limit the processing, he/she is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction on processing, unless this proves impossible or involves a disproportionate effort.
The person responsible shall have the right to be informed of such recipients.
7.6 Right to Data Transferability
You have the right to receive the personal data concerning you that you have provided to the person responsible in a structured, common and machine-readable format. In addition, you have the right to pass this data on to another person in charge without obstruction by the person in charge to whom the personal data was provided, provided that
(1) processing is based on consent pursuant to Art. 6 para. 1 lit. a DSGVO or Art. 9 para. 2 lit. a DSGVO or on a contract pursuant to Art. 6 para. 1 lit. b DSGVO and
(2) processing is carried out by means of automated methods.
In exercising this right, you also have the right to request that the personal data concerning you be transferred directly from one data controller to another data controller, insofar as this is technically feasible. The freedoms and rights of other persons must not be affected by this.
The right to transferability shall not apply to the processing of personal data necessary for the performance of a task in the public interest or in the exercise of official authority conferred on the controller.
7.7 Right of objection
You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you under Article 6(1)(e) or (f) of the DSBER; this also applies to profiling based on these provisions.
The data controller no longer processes the personal data concerning you, unless he can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct marketing.
If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.
You have the possibility to exercise your right of objection in connection with the use of Information Society services by means of automated procedures using technical specifications, notwithstanding Directive 2002/58/EC.
7.8 Right to revoke the data protection declaration of consent
You have the right to revoke your data protection declaration of consent at any time. The revocation of consent shall not affect the legality of the processing carried out on the basis of the consent until revocation.
7.9 Automated decision in individual cases including profiling
You have the right not to be subject to a decision based exclusively on automated processing – including profiling – that has legal effect against you or significantly impairs you in a similar manner. This does not apply if the decision
(1) is necessary for the conclusion or performance of a contract between you and the person responsible,
(2) the legislation of the Union or of the Member States to which the person responsible is subject is admissible and that legislation contains appropriate measures to safeguard your rights, freedoms and legitimate interests; or
(3) with your express consent.
However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 DSGVO, unless Art. 9 para. 2 lit. a or g DSGVO applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.
In the cases referred to in (1) and (3), the person responsible shall take reasonable measures to safeguard your rights, freedoms and legitimate interests, including at least the right to obtain the intervention of a person by the person responsible, to state his own position and to challenge the decision.
7.10 Right of appeal to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right of appeal to a supervisory authority, in particular in the Member State where you reside, work or suspect of infringement, if you believe that the processing of personal data concerning you is contrary to the DSGVO.
The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy under Article 78 DSGVO.