Privacy Policy

Last updated: 19 May 2024

Name and Address of the Controller

The controller in terms of the GDPR and the new Federal Data Protection Act (BDSG) is

Sentry Eagle
Stefan Kühnel
Schachenmeierstraße 23
80636 München

Telephone: +49 (0)89 41 55 45 28
E-Mail: privacy@sentryeagle.com

I. Name and address of the data privacy officer

Stefan Kühnel
Schachenmeierstraße 23
80636 München

Telephone: +49 (0)89 41 55 45 28
E-Mail: privacy@sentryeagle.com

II. General information on data processing

1. Scope of processing personal data

We process personal data of our users only to the extent necessary for the presentation and optimisation of a functional website as well as our content and services.

The processing of personal data of our users normally takes place only with their consent. An exception applies in those cases where the data processing is permitted by law.

2. Legal basis for processing personal data

This website presented by Sentry Eagle and its individual components are part of the public relations work of Sentry Eagle. The legal basis for processing personal data within the framework of this public relations work is Article 6 (1) point (e) of the EU General Data Protection Regulation (GDPR) in conjunction with Section 3 of the BDSG. Where we obtain consent to process personal data, the legal basis is provided by Article 6 (1) point (a) of the GDPR.

The legal basis for processing personal data which is required for the performance of a contract to which you are a party (e.g. ordering publications and newsletters) is Article 6 (1) point (b) of the GDPR. This also applies to pre-contractual measures.

3. Data erasure and storage duration

Your personal data will be erased or blocked, as soon as the purpose for which it was stored no longer applies.

III. Presentation of the website and creation of log files

1. Description and scope of data processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the computer accessing it. The following data is logged:

• information about the browser type and version used
• the user's operating system
• the user's IP address – this data is stored on the delivery servers for 90 days, to secure operations and protect against attacks (e.g. DDOS).
• date and time of access including the URL accessed, HTTP method used and status code returned, along with the amount of data transmitted
• HTTP origin request header sent by the client
• websites from which the user's system accesses our website (saved as referrer)

2. Legal basis for data processing

The legal basis for the temporary storage of data and log files is Art. 6(1)(e) GDPR in conjunction with Section 3 BDSG (new).

3. Purpose of data processing

Temporary storage of the IP address by the system is necessary for the website to be delivered to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.

The IP is stored on the delivery servers for 90 days, serving to secure operations and provide protection against attacks (e.g. DDOS).

4. Duration of storage

The log files are stored centrally and deleted after 90 days.

5. Right to object and deletion

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. For this reason, it is not possible for users to object.

IV. Use of cookies

a) Description and scope of data processing

Technically necessary cookies are required to provide you with the basic functions of the website and, therefore, cannot be deactivated.

In detail, these cookies are as follows:

• cookie-reject-optional – A cookie to save the setting "Reject optional cookies". Standard setting on visiting the website.
• cookie-accept-all – A cookie to save the setting "Accept all cookies".

b) Legal basis for data processing

The legal basis for processing personal data using cookies is Article 6 (1) point (e) of the GDPR in conjunction with Section 3 of the new BDSG and/or Article 6 (1) point (a) of the GDPR for cookies which require consent.

c) Purpose of data processing

Necessary cookies are required to provide you with the basic functions of the website

The user data collected by technically necessary cookies will not be used to create user profiles.

d) Duration of storage and rights to objection and deletion

Cookies are stored on the user's computer and transmitted to our site from there. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transfer of cookies. Previously stored cookies can be deleted at any time. This can also be done automatically.

V. Contact form, e-mail contact and postal contact

1. Description and scope of data processing

There is a contact form on our website which can be used for contacting us online. If you make use of this opportunity, the data entered in the input form is sent to us and stored. This data is:

• subject
• your message
• title, first name and surname, e-mail address, street and house number, postal code, city.

At the time of sending the message, the following additional data is stored:

1. the IP address of the user
2. the date and time of registration.

During the sending process, your consent is obtained for processing the data for this purpose, and you are referred to this privacy policy statement.

Alternatively, you can contact us via the e-mail address provided, or by post. In this case, the user's personal data transmitted together with the e-mail or letter is stored.

In this regard, there is no disclosure of data to third parties. The data is used solely for processing the conversation.

2. Legal basis for data processing

The legal basis for processing data in the course of sending an e-mail is Article 6 (1) point (e) of the GDPR. If the aim of the e-mail contact is the conclusion of a contractual relationship, then Article 6 (1) point (b) of the GDPR also applies to the data processing.

3. Purpose of data processing

The processing of personal data from the input form is used solely for us to handle the contact request. The other personal data processed during the sending process is intended to prevent misuse of the contact form, and to ensure the security of our information technology systems.

4. Duration of storage

The data is deleted as soon as the purpose for which it was stored no longer applies. There is a retention period of up to three years for the personal data entered into the contact form, and the data sent by e-mail or post.

The other personal data collected as part of the sending process is deleted after a maximum period of seven days.

5. Right to objection and deletion

The user has the right to withdraw their consent to the processing of personal data at any time. If the user contacts us by e-mail, among other options, they can object to the storage of their personal data at any time. In such cases, the conversation cannot be continued.

In this event, all personal data that has been stored in the course of the contact will be deleted.

VI. Information on your rights

If your personal data is processed, you are a data subject under the provisions of the GDPR and have the following rights that you can demand from your controller:

1. Right of access by the data subject – Art. 15 GDPR

The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her is being processed.

Where this is the case the data subject is entitled to obtain the following information from the controller:

• the purposes of the processing of personal data;
• the categories of personal data concerned;
• the recipients or categories of recipient to whom the personal data has been or will be disclosed;
• the envisaged period for which the personal data will be stored, or, if no specific information can be given, 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 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) 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.

The data subject is entitled to information on whether pertinent personal data is transferred to a third country or international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer. Please also see the Right to data portability, pursuant to Article 20 GDPR.

2. Right to rectification – Art. 16 GDPR

The data subject shall have the right to obtain from the controller the rectification and/or completion of incorrect or incomplete personal data concerning him or her. The controller shall make the corrections without undue delay.

3. Right to restriction of processing – Art. 18 GDPR

The data subject shall have the right 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 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) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

A data subject who has obtained restriction of processing on the basis of the above preconditions shall be informed by the controller before the restriction of processing is lifted.

4. Right to erasure – Art. 17 GDPR

a) Right to be forgotten

The data subject shall have the right 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:

• the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
• the data subject withdraws the consent on which the processing is based according to point (a) of Article 6 (1), or point (a) of Article 9 (2) GDPR, and where there is no other legal ground for the processing;
• the data subject objects to the processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (2) GDPR;
• the personal data has been unlawfully processed;
• the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
• the personal data has been collected in relation to the offer of information society services referred to in Article 8 (1) GDPR.

b) Information to third parties

Where the controller has made the personal data public and is obliged pursuant to Article 17 (1) GDPR 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 controllers processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, that personal data.

c) Exceptions

The right to be forgotten shall not apply to the extent that processing is necessary:

• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
• for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9 (2) as well as Article 9 (3) GDPR;
• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) GDPR in so far as the right referred to in paragraph a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
• for the establishment, exercise or defence of legal claims.

5. Notification obligation – Art. 19 GDPR

Should the data subject have made use of the right to rectification or erasure of data or restriction of processing vis à vis the controller, the latter is obliged to communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort.

The data subject is entitled to be informed by the controller about those recipients.

The right to data portability does not apply to processing personal data which is required for performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

6. Right to data portability – Art. 20 GDPR

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to haven the data transmitted to another controller, where:

1. the processing is based on consent pursuant to point (a) of Article 6 (1) or point (a) of Article 9 (2) GDPR or on a contract pursuant to point (b) of Article 6 (1) GDPR; and
2. the processing is carried out by automated means.

In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

7. Right to object – Art. 21 GDPR

The data subject shall have the right 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) of Article 6 (1) GDPR.

The controller shall no longer process the personal data unless the controller demonstrates 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.

8. Right to withdraw consent – Art. 7 (3) GDPR

The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

9. Right to lodge a complaint with a supervisory authority – Art. 77 GDPR

Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, if the data subject considers that the processing of personal data relating to him or her infringes the provisions of GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 GDPR.

Responsible supervisory authority:

Bayerisches Landesamt für Datenschutzaufsicht

Promenade 18
91522 Ansbach
Deutschland

Telephone: +49 (0) 981 180093-0
Fax: +49 (0) 981 180093-800
E-Mail: poststelle@lda.bayern.de