A. Responsibility for data processing
The party responsible for the processing of personal data in accordance with the General Data Privacy Regulation (GDPR) is:
SOLIT Management Canada Ltd.
PO Box 158
9941 Greenville Street, St. Peter´s, NS
Phone: +1 902 70 45 200
Fax: +1 902 70 45 201
Office Wiesbaden | Germany:
SOLIT Management GmbH
Otto-von-Guericke Ring 10
Phone:+49 (0) 6122 58 70-70
Fax: +49 (0) 6122 58 70-77
Controller for the retrieval, processing and use of personal data: email@example.com
B. Data processing
In the course of our website operation, we process data.
This also includes disclosure by transmission to third parties and, if applicable, to so-called third countries outside the European Union (“EU”) and the European Economic Area (“EEA”). Insofar as we transfer data outside the EU or the EEA, we have marked this accordingly below.
In the following, please find a list of specifications regarding the types of data, processing purposes, legal basis, recipients and transmissions into third countries:
a) Log files
We register when a data subject calls up our websites. We process the following data: name of the accessed file, the date and time of access to the Internet site, the data volume transmitted, the browser types and versions used, the operating system used by the accessing system, the website from which an accessing system reaches our website (referrer), the Internet protocol address (IP address) and the Internet service provider of the accessing system. We process the data in accordance with our legitimate interest pursuant to Art. 6 (1) (f) GDPR, to ensure security of our online services. The log files will be deleted after seven days, unless they are required to verify or prove an alleged illegal use of the website services, which has become known during the data safekeeping period.
In the context of hosting this website, we store all data processed in connection with its operation. This is necessary to operate this website. All data is processed based on our legitimate interests in accordance with Art. 6 (1) (f) GDPR. To provide our online services, we use the services of web hosting providers, to whom we transfer the aforementioned data.
c) Contacting us
aa) By contacting us via our contact form or by e-mail, your details, surname, first name, e-mail address, possibly your telephone number and your message will be processed exclusively for the purpose of processing and handling your request.
The legal basis for this processing is the fulfillment of our contractual obligations Art. 6. para. 1 b) DSGVO or our legitimate interest in processing and responding to your request according to Art. 6 para. 1 f) DSGVO.
If you submit a legally binding offer (e.g. via our online application entry or a printed application) to conclude a contract for the SOLIT Precious Metal Depot, the SOLIT Value Warehouse, the SOLIT Value Purchase or another offered service, the personal data contained therein will be collected, processed and used by SOLIT Management GmbH through TRESTA Treuhandgesellschaft mbH (“TRESTA”), An der Werft 5, 21680 Stade, for the purpose of executing the contract and fulfilling legal and contractual obligations.
Further information can be found here: https://www.tresta-stade.de.
The data protection guidelines of TRESTA can be found here: https://www.tresta-stade.de/m/de/data_protection.html.
bb) In addition, we process data in order to send you brochures and/or applications ordered by you. This data is processed by us on the basis of your consent pursuant to Art. 6 (1) a) DSGVO or to fulfill our pre-contractual or contractual obligations pursuant to Art. 6 (1) b) DSGVO.
cc) Data transmitted to the service providercom, inc. in connection with contract processing and application processing is secured on Salesforce servers in Germany (Frankfurt am Main). For data backup purposes only, this data is regularly mirrored to Paris.
Further information on data protection can be found at: https://www.salesforce.com/company/privacy/
d) Processing of contracts and applications
If you contact us to send us your application as an employee, e.g. by e-mail or via a contact form, your data (e.g. name, e-mail address, desired location – if specified by you), your message and the application documents submitted will be processed exclusively for the purpose of processing and handling your application request. The legal basis for the data processing is primarily § 26 BDSG. According to this, the processing of data required in connection with the decision on the establishment of an employment relationship is permissible.
Should the data be required for legal prosecution after completion of the application process, data processing may be carried out to safeguard our legitimate interests pursuant to Art. 6 (1) f) DSGVO, namely to assert or defend claims.
In order to provide you with regular information about our company and our offers, we offer a newsletter service. With your registration for the newsletter, we process the data entered by you (e-mail address and other voluntary information). The sending of the newsletter by means of registration is based on your consent in accordance with Art. 6 (1) a) DSGVO.
The registration for the newsletter takes place in the so-called double opt-in procedure. To prevent misuse, we will send you an e-mail after your registration, asking you to confirm your registration. In order to be able to prove the registration process in accordance with the legal requirements, your registration is logged. This concerns the storage of the registration and confirmation time as well as your IP address. To send the newsletter, we use service providers to whom we transmit the above-mentioned data.
The data is transmitted to the servers of the following service providers in the USA:
Mailchimp: Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308.
Further information on data protection can be found at: https://mailchimp.com/legal/privacy/
If you participate in a webinar organized by us, we process your participant data for this purpose. We process this data on the basis of your consent pursuant to Art. 6 (1) a) DSGVO or to fulfill our pre-contractual or contractual obligations pursuant to Art. 6 (1) b DSGVO. To provide our online presence, we use services of webinar providers in Germany, to whom we transmit the above data.
g) Lottery participation
In the event of your participation in a sweepstake organized by us, we process the data provided by you: First name, last name, e-mail address, if provided by you: Address, company, telephone number for the purpose of your participation. In addition, we process your data to contact you in the event that you are notified of the prize. If you have been determined as the winner, we will request your surname, first name and address for the purpose of communicating the prize, unless this has already been done as part of your registration. In any case, we will inform you about your prize in advance by e-mail.
For the purpose of transmitting the prize, we will forward your surname, first name and address to the respective supplier. This data processing takes place exclusively for the purpose of sending the prize.
Transmission to third parties: In this context, we also transmit your address data to the company commissioned with the delivery of the prize.
We process your data in the case of sweepstake entries exclusively for the purpose of carrying out the relevant sweepstakes. The processing of the data takes place accordingly on the basis of Art. 6 para. 1 b) DSGVO.
h) Website analysis and marketing
Data subjects can delete all cookies stored on their device and configure commonly used browsers to prevent cookies from being stored. If they do this, they may have to repeat some settings every time they visit this website, and also accept that some functions may be impaired.
aa) Google Analytics
The information generated by the cookie about a data subject’s use of this website (including the IP address) is transferred to a Google server in the USA and stored there. We use this information to analyse his or her use of the website in order to compile reports on the website activity for the website operators and to provide other services associated with use of the website. We process the data obtained in this way on the basis of our overriding interest in optimising the marketing of our services in accordance with Art. 6(1) (f) GDPR. Google will never link data subjects’ IP addresses to other Google data.
We would like to point out that this website uses Google Analytics with the “anonymizeIp()” extension. This ensures that IP addresses are truncated before they are transferred to the server in the USA, which normally makes it impossible to directly identify individuals in connection with the stored data. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there.
Through the use of Google Analytics, the following data is processed:
- 3 bytes of the IP address of the called system of the website visitor (anonymized IP address)
- The website called up
- The website from which the user reached the accessed page of our website (referrer)
- The subpages accessed from the website
- The time spent on the website
- The frequency with which the website is accessed
Google states that it will not associate your IP address with any other data held by Google.
Data subjects can opt out of our data collection at any time with future effect by using the browser add-on for deactivating Google Analytics at https://tools.google.com/dlpage/gaoptout?hl=de.
Please also read the following notes on how Google uses data in its partner network: https://www.google.com/intl/de/policies/privacy/partners/
For additional information regarding data privacy please visit: https://policies.google.com/privacy/partners?hl=de and https://policies.google.com/privacy?gl=de
bb) Google Remarketing/Retargeting
We use so-called tracking cookies from Google on our website. During a visit to our site, information about the visited web pages, the IP address of the visitor, visit duration, other information about the use of the web pages and information about what content the user is interested in is stored in permanent cookies. In the event of a subsequent visit to a partner website, we can have personalized advertising displayed for you on the basis of the articles viewed on our website.
We process the data obtained in this way based on your consent in accordance with Art.6 (1) a) DSGVO. The information generated by the cookie about your use of this website (including your IP address), will be transmitted to and stored by Google on servers in the United States.
The legal basis for any processing of data is your consent in accordance with Art. 6 para. 1 a) DSGVO.
You can revoke your consent at any time with effect for the future by using the following opt-out link: by adjusting your settings in our cookie banner. “Please note that you will have to click the link again if you delete the cookies in your browser in the meantime. Furthermore, you can prevent cookies from being set by adjusting the corresponding settings in your browser.
i) Integration of external content
We use external dynamic content to optimise the appearance and content of our website. When a data subject visits our website, a request is automatically sent to the server of the relevant content provider via API, transferring certain log data (e.g. the data user’s IP address). The dynamic content is then transferred to our website and displayed there. We use external content in connection with the following functionalities:
aa) Integration of YouTube videos
We have integrated videos from the YouTube portal operated by YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066, USA (“YouTube”) into our website. When a data user plays back these videos, log data is transferred to YouTube’s servers in the USA. This data is processed on the basis of our overriding legitimate interest in optimising the marketing of our services in accordance with Art. 6(1) (f) GDPR.
Additional information are available at: https://policies.google.com/privacy?hl=de&gl=de
bb) Google Maps and Google Fonts
We use the map service “Google Maps” of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”) to provide you with an interactive map. When displaying the map, data including your IP address and your location are transmitted to Google servers in the USA and stored there. This processing takes place on the basis of our overriding legitimate interest in optimal marketing of our offer in accordance with Art. 6 (1) f) DSGVO.
In addition, we use Google Fonts for the uniform display of fonts on our websites. These are loaded from Google servers when you visit the site. Google does not store any cookies in your browser. According to our information, however, the IP address of the user’s terminal device is transmitted to Google and stored. This processing takes place on the basis of our overriding legitimate interest in optimal marketing of our offer in accordance with Art. 6 (1) f) DSGVO.
Google is responsible for further data processing.
Further information on data protection can be found at: https://policies.google.com/privacy?hl=de&gl=de
j) Google reCAPTCHA
In order to protect the comments section and the input forms of our websites from spam and abuse, we use the external service reCAPTCHA, a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). reCAPTCHA makes it possible to distinguish between input of human origin and input that is misused by automated software (also known as “bots”).
When using the service, the following data is transferred to Google’s servers in the USA:
- Referrer URL
- IP address of the user
- The user’s input behavior as well as mouse movements in the area of the “reCAPTCHA” checkboxes
- Google account: If the user is logged in to his Google account at the same time, this is recognized and assigned
- Information about the browser used, browser size, browser resolution, browser plug-ins, language settings, date
- Mouse and touch events within the page
- Scripts and display instructions of the website
The processing of personal data by us is based on our overriding legitimate interest in the security of our website in accordance with Art. 6 (1) f) DSGVO.
Responsibility of Google: In all other respects, the processing of personal data is carried out under the full responsibility of Google. We have no influence on how Google will use the data.
Further information on data protection can be found at: https://policies.google.com/privacy?hl=de&gl=de
k) Use of photographs and videos of events
In the course of events and functions, photographs and, if necessary, videos are taken in order to provide pictorial documentation of the events. These photographs and video recordings are published by us on our website for follow-up reporting. The data processing is carried out on the basis of our legitimate interests according to Art. 6 (1) f) DSGVO, in order to document and promote the event in question.
In all other cases, processing takes place solely on the basis of your prior consent pursuant to Art. 6 (1) a) DSGVO.
C. Duration of data storage
We store personal data only for as long as is necessary for the purposes for which it is being processed or until a data subject withdraws his or her consent. Insofar as statutory retention requirements need to be complied with, the retention period for certain data can be up to 10 years, regardless of the purposes for which it is being processed.
D. Rights of the data subject
a) Right of information
At any time, data subjects are entitled to request free information about all the personal data we stored about them.
b) Rectification, erasure, restriction of processing (blocking), opting out
If a data subject no longer agrees to his or her personal data being stored or if his or her personal data is no longer correct, we will, upon receipt of a corresponding instruction from the data subject, have his or her data erased or blocked or make the necessary corrections (to the extent possible under applicable law). The same applies if a data subject requests us to restrict the processing of his or her data in the future.
c) Data portability
On request we will provide data subjects their data in a commonly-used, structured and machine-readable format, so that they can transfer it to another controller if they wish.
d) Right of complaint
Data users have the right to lodge a complaint with the responsible supervisory authority: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html
e) Right to withdraw consent with future effect
Data subjects are entitled to withdraw their consent at any time with future effect. This will not affect the legality of the processing prior to their withdrawal.
The above rights do not apply to data where we are not able to identify the data subject, for example if the data has been anonymised for analysis purposes. It may be possible for data subjects to exercise their rights to information/access, erasure, blocking, rectification, or transfer to another organisation in relation to these data, if they provide us with additional information that enables us to identify them.
g) Exercising the rights of data subjects
If data subjects have any questions about the processing of their personal data, or if they wish to exercise their rights to access/information, rectification, blocking, opt-out or erasure of data, or if they wish their data to be transferred to another organisation, they may contact firstname.lastname@example.org