Privacy Policy

We are very pleased about your interest in our company. Data protection is of particular importance to the management of Atrin Madani. A use of the websites of Atrin Madani is generally possible without providing any personal data. However, if a data subject wishes to use special services of our company via our website, processing of personal data may become necessary. If processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject, is always carried out in line with the General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to Atrin Madani. By means of this privacy policy, our company intends to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed of their rights by means of this privacy policy.

Atrin Madani has implemented numerous technical and organizational measures as the controller responsible for processing to ensure the most complete protection possible 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 transmit personal data to us by alternative means, for example by telephone.

1. Definitions

The privacy policy of Atrin Madani is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.

We use the following terms, among others, in this privacy policy:

a) personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter “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 means any identified or identifiable natural person whose personal data is processed by the controller responsible for processing.

c) processing
Processing means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, 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 means 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 analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

f) pseudonymization
Pseudonymization means 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 organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) controller or controller responsible for processing
Controller or controller responsible for processing means 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 means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

i) recipient
Recipient means 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 the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

j) third party
Third party means 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 authorized to process personal data.

k) consent
Consent means 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 responsible for processing

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union, and other provisions with a data protection character is:

Atrin Madani
Luidpoldstraße 32
10777 Berlin
Germany
Tel.: 017661818193
E-Mail: atrin.madani@gmail.com

Website: atrinmadani.com

3. Cookies

The websites of Atrin Madani use cookies. Cookies are text files that are placed and stored on a computer system via an Internet 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 by which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the visited Internet pages and servers to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID.

By using cookies, Atrin Madani can provide users of this website with more user-friendly services that would not be possible without the setting of cookies.

By means of a cookie, the information and offers on our website can be optimized in the interest of the user. Cookies enable us, as already mentioned, to recognize users of our website. The purpose of this recognition is to make it easier for users to use our website. The user of a website that uses cookies, for example, does not have to enter access data again on each visit to the website because this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping cart via a cookie.

The data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable under certain circumstances.

4. Collection of general data and information

The website of Atrin Madani collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be collected: (1) the 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 referrer), (4) the sub-websites that are accessed via an accessing system on our website, (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) other similar data and information used for security in the event of attacks on our information technology systems.

When using this general data and information, Atrin Madani does not draw any conclusions about the data subject. This information is rather required to (1) deliver the content of our website correctly, (2) optimize the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Therefore, Atrin Madani analyzes this anonymously collected data and information statistically and furthermore with the aim of increasing data protection and data security in our company in order ultimately to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Routine erasure and blocking of personal data

The controller responsible for processing processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or as provided for by the European legislator or another legislator in laws or regulations to which the controller responsible for processing is subject.

If the purpose of storage ceases to apply or a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with the statutory provisions.

6. Rights of the data subject

a) Right of confirmation
Each data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether personal data concerning him or her is being processed. If a data subject wishes to exercise this right of confirmation, he or she may contact an employee of the controller responsible for processing at any time.

b) Right of access
Each data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller free information about the personal data stored concerning him or her and a copy of this information at any time. Furthermore, the European legislator has granted 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 organizations
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 rectification or erasure of personal data concerning him or her, or restriction of processing by the controller, 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) 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

Furthermore, the data subject has the right to obtain information as to whether personal data has been transferred to a third country or to an international organization. Where this is the case, the data subject also has the right to obtain information about the appropriate safeguards relating to the transfer.
If a data subject wishes to exercise this right of access, he or she may contact an employee of the controller responsible for processing at any time.

c) Right to rectification
Each data subject affected by the processing of personal data has the right granted by the European legislator to obtain the rectification without undue delay of inaccurate personal data concerning him or her. Furthermore, the data subject has the right to have incomplete personal data completed, including by means of a supplementary statement, taking into account the purposes of the processing.
If a data subject wishes to exercise this right to rectification, he or she may contact an employee of the controller responsible for processing at any time.

d) Right to erasure (right to be forgotten)
Each data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure without undue delay of personal data concerning him or her where one of the following grounds applies and processing is not necessary:

The personal data were collected or otherwise processed for purposes for which they are no longer necessary.
The data subject withdraws consent on which the processing is based according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
The personal data have been unlawfully processed.
The erasure of personal data is necessary for compliance with a legal obligation under 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 Art. 8(1) GDPR.

If one of the above grounds applies and a data subject wishes to arrange the erasure of personal data stored by Atrin Madani, he or she may contact an employee of the controller responsible for processing at any time. The employee of Atrin Madani will arrange for the erasure request to be complied with without undue delay.
If the personal data have been made public by Atrin Madani and our company is obliged as controller pursuant to Art. 17(1) GDPR to erase the personal data, Atrin Madani shall, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested erasure by such controllers of all links to this personal data or of copies or replications of this personal data, as far as processing is not required. The employee of Atrin Madani will arrange what is necessary in individual cases.

e) Right to restriction of processing
Each data subject affected by the processing of personal data has 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 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 defense of legal claims.
The data subject has objected to processing pursuant to Art. 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met and a data subject wishes to request restriction of personal data stored by Atrin Madani, he or she may contact an employee of the controller responsible for processing at any time. The employee of Atrin Madani will arrange restriction of the processing.

f) Right to data portability
Each data subject affected by the processing of personal data has the right granted by the European legislator 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. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out by automated means, provided 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 Art. 20(1) GDPR, the data subject has the right to have the 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. To assert the right to data portability, the data subject may contact an employee of Atrin Madani at any time.

g) Right to object
Each data subject affected by the processing of personal data has 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 Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on those provisions. Atrin Madani shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or the processing serves the establishment, exercise, or defense of legal claims. If Atrin Madani processes personal data for direct marketing purposes, the data subject has the right to object at any time to processing of personal data concerning him or her for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Atrin Madani to the processing for direct marketing purposes, Atrin Madani 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 Atrin Madani for scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) GDPR, unless such processing is necessary for the performance of a task carried out for reasons of public interest. To exercise the right to object, the data subject may contact any employee of Atrin Madani or another employee directly. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling
Each data subject affected by the processing of personal data has 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, unless the decision (1) is necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) is authorized 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 based on the data subject’s explicit consent. If the decision (1) is necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, Atrin Madani shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view, and to contest the decision. If the data subject wishes to assert rights with regard to automated decisions, he or she may contact an employee of the controller responsible for processing at any time.

i) Right to withdraw consent under data protection law
Each data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time. If the data subject wishes to exercise the right to withdraw consent, he or she may contact an employee of the controller responsible for processing at any time.

7. Data protection provisions on the use and application of Facebook

The controller responsible for processing has integrated components of the company Facebook on this website. Facebook is a social network.

A social network is a social meeting place operated on the Internet, an online community that generally enables users to communicate with each other and interact in virtual space. A social network may serve as a platform for exchanging opinions and experiences or enables the Internet community to provide personal or business-related information. Facebook enables users of the social network, among other things, to create private profiles, upload photos, and connect via friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. The controller responsible for the processing of personal data, if a data subject lives outside the USA or Canada, is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time one of the individual pages of this website operated by the controller responsible for processing is accessed and on which a Facebook component (Facebook plug-in) has been integrated, the Internet browser on the information technology system of the data subject is automatically caused by the respective Facebook component to download a display of the corresponding Facebook component from Facebook. An overview of all Facebook plug-ins can be accessed at https://developers.facebook.com/docs/plugins/?locale=de_DE. In the course of this technical procedure, Facebook receives knowledge of which specific subpage of our website is visited by the data subject.

If the data subject is logged into Facebook at the same time, Facebook recognizes with each call-up of our website by the data subject and throughout the entire duration of the respective stay on our website which specific subpage of our website the data subject visits. This information is collected by the Facebook component and assigned by Facebook to the respective Facebook account of the data subject. If the data subject activates one of the Facebook buttons integrated on our website, for example the “Like” button, or submits a comment, Facebook assigns this information to the personal Facebook user account of the data subject and stores this personal data.

Facebook always receives information via the Facebook component that the data subject has visited our website when the data subject is logged into Facebook at the time of the call-up of our website; this occurs regardless of whether the data subject clicks on the Facebook component or not. If such transmission of this information to Facebook is not desired by the data subject, he or she can prevent the transmission by logging out of his or her Facebook account before calling up our website.

The data policy published by Facebook, which can be accessed at https://de-de.facebook.com/about/privacy/, provides information about the collection, processing, and use of personal data by Facebook. It also explains which settings Facebook offers to protect the privacy of the data subject. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by the data subject to suppress data transmission to Facebook.

8. Data protection provisions on the use and application of Instagram

The controller responsible for processing has integrated components of the Instagram service on this website. Instagram is a service that qualifies as an audiovisual platform and enables users to share photos and videos and also to redistribute such data in other social networks.

The operating company of the Instagram services is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland.

Each time one of the individual pages of this website operated by the controller responsible for processing is accessed and on which an Instagram component (Insta button) has been integrated, the Internet browser on the information technology system of the data subject is automatically caused by the respective Instagram component to download a display of the corresponding component from Instagram. In the course of this technical procedure, Instagram receives knowledge of which specific subpage of our website is visited by the data subject.

If the data subject is logged into Instagram at the same time, Instagram recognizes with each call-up of our website by the data subject and throughout the entire duration of the respective stay on our website which specific subpage the data subject visits. This information is collected by the Instagram component and assigned by Instagram to the respective Instagram account of the data subject. If the data subject activates one of the Instagram buttons integrated on our website, the data and information transmitted in this way are assigned to the personal Instagram user account of the data subject and stored and processed by Instagram.

Instagram always receives information via the Instagram component that the data subject has visited our website when the data subject is logged into Instagram at the time of the call-up of our website; this occurs regardless of whether the data subject clicks on the Instagram component or not. If such transmission of this information to Instagram is not desired by the data subject, he or she can prevent the transmission by logging out of his or her Instagram account before calling up our website.

Further information and the applicable data protection provisions of Instagram can be accessed at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

9. Data protection provisions on the use and application of YouTube

The controller responsible for processing has integrated components of YouTube on this website. YouTube is an Internet video portal that enables video publishers to set video clips free of charge and other users to view, rate, and comment on them likewise free of charge. YouTube allows the publication of all kinds of videos, which is why complete films and television shows as well as music videos, trailers, or videos made by users themselves can be accessed via the Internet portal.

The operating company of YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

Each time one of the individual pages of this website operated by the controller responsible for processing is accessed and on which a YouTube component (YouTube video) has been integrated, the Internet browser on the information technology system of the data subject is automatically caused by the respective YouTube component to download a display of the corresponding YouTube component from YouTube. Further information about YouTube can be accessed at https://www.youtube.com/yt/about/de/. In the course of this technical procedure, YouTube and Google receive knowledge of which specific subpage of our website is visited by the data subject.

If the data subject is logged into YouTube at the same time, YouTube recognizes when a subpage containing a YouTube video is accessed which specific subpage of our website the data subject visits. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google always receive information via the YouTube component that the data subject has visited our website when the data subject is logged into YouTube at the time of the call-up of our website; this occurs regardless of whether the data subject clicks on a YouTube video or not. If such transmission of this information to YouTube and Google is not desired by the data subject, he or she can prevent the transmission by logging out of his or her YouTube account before calling up our website.

The privacy provisions published by YouTube, which can be accessed at https://www.google.de/intl/de/policies/privacy/, provide information about the collection, processing, and use of personal data by YouTube and Google.

10. Legal basis for processing

Art. 6(1)(a) GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries concerning our products or services. If our company is subject to a legal obligation by which the processing of personal data is required, for example for the fulfillment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data might be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our premises and his or her name, age, health insurance data, or other vital information had to be passed on to a doctor, hospital, or other third parties. Then processing would be based on Art. 6(1)(d) GDPR. Finally, processing operations could be based on Art. 6(1)(f) GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 Sentence 2 GDPR).

12. Legitimate interests in the processing pursued by the controller or a third party

If the processing of personal data is based on Art. 6(1)(f) GDPR, our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and our shareholders.

13. Period for which the personal data will be stored

The criterion for the duration of storage of personal data is the respective statutory retention period. After expiry of that period, the corresponding data are routinely deleted, unless they are no longer required for contract fulfillment or contract initiation.

14. Statutory or contractual provisions on the provision of personal data; necessity for the conclusion of a contract; obligation of the data subject to provide personal data; possible consequences of failure to provide

We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information about the contractual partner). Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data that must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data are provided by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of a contract, whether there is an obligation to provide the personal data, and what the consequences of failure to provide the personal data would be.

14. Existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

Developed by the
LegalTech
specialists at Willing & Able, who also developed the system for
GDPR processing records
. The texts of the privacy policy generator were created and published by
Prof. Dr. h.c. Heiko Jonny Maniero
and attorney
Christian Solmecke
.