Privacy policy of 4 Solutions Team GmbH
The data controller within the meaning of data protection laws is Justinas Urbonas
With this privacy notice, we inform you (hereinafter also referred to as “user” or “data subject”) in general about data processing in our company and in particular about data processing when you visit our website, contact us via our website contact form, contact us by email or telephone, and register to receive our newsletter. Furthermore, we inform you about our online presence on social media and about your rights regarding the processing of your data. The term “data processing” always refers to the processing of personal data.
1. General information on data processing
1.1 Categories of personal data
We process the following categories of personal data:
• Inventory data (e.g. names, addresses, functions, organizational affiliation, etc.);
• Contact details (e.g. email, telephone/fax numbers etc.);
• Content data (e.g., text entries, image files, videos, etc.);
• Usage data (e.g., access data);
• Metadata/communication data (e.g. IP addresses).
1.2 Recipients or categories of recipients of personal data
If, in the course of our processing, we disclose data to other persons and companies such as web hosts, processors or third parties, transmit it to them or otherwise grant them access to the data, this is done on the basis of a legal permission (e.g. if the transfer of data to third parties is necessary for the performance of a contract pursuant to Art. 6 para. 1 subpara. 1 lit. b GDPR), if the data subjects have given their consent or if a legal obligation provides for this.
1.3 Duration of storage of personal data
The criterion for the duration of storage of personal data is the respective statutory retention period. After this period expires, the corresponding data will be deleted unless it is still required for the purpose of fulfilling the contract, performing the contract, or initiating a contract.
1.4 Transfers to third countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if this occurs in the context of using third-party services or disclosing or transferring data to third parties, this will only be done if it is necessary for the performance of our (pre-)contractual obligations, based on your consent, due to a legal obligation, or based on our legitimate interests. Subject to legal or contractual permissions, we will only process or have data processed in a third country if the special requirements of Articles 44 et seq. of the GDPR are met, i.e., processing will take place, for example, on the basis of special safeguards, such as the officially recognized finding of a level of data protection equivalent to that of the EU or compliance with officially recognized specific contractual obligations (so-called “standard contractual clauses”).
2. Data processing in connection with visiting our website
2.1 Log files
Whenever a data subject accesses our website, general data and information are stored in the log files of our system:
• Date and time of retrieval (timestamp);
• Request details and target address (protocol version, HTTP method, referrer, user agent string);
• Name of the retrieved file and amount of data transferred (requested URL including query string, size in bytes);
• Message indicating whether the retrieval was successful (HTTP status code).
When using this general data and information, we do not draw any conclusions about the data subject. No personal data analysis or marketing profiling takes place. The IP address is not stored in this context.
The legal basis for the temporary storage of data is Article 6(1)(f) GDPR. The collection of data for the provision of the website and the storage of data in log files is essential for the secure operation of our website. Consequently, there is no right to object for the data subject.
2.2 Malware detection and log data analysis
We collect log data generated during the operation of communication technology within our company and evaluate it automatically, insofar as this is necessary to detect, limit or eliminate malfunctions or errors in the communication technology or to defend against attacks on our information technology or to detect and defend against malware.
The legal basis for the temporary storage and analysis of the data is Article 6(1)(f) GDPR. The storage and analysis of the data are essential for providing the website and ensuring its secure operation. Therefore, the data subject has no right to object.
2.3 Cookies
Our website uses cookies. Cookies are small text files that are exchanged between your web browser and our hosting server. Cookies are stored on your computer and transmitted from there to our site. You can restrict or completely prevent the use of cookies in your web browser settings. You can also delete cookies that have already been stored at any time. If you disable cookies for our website, this may result in the website not being displayed or used in its entirety.
The legal basis for the processing of personal data using cookies is Article 6(1)(f) GDPR.
2.4 Hosting
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services, and technical maintenance services, which we use for the purpose of operating our website.
In this process, we or our processors process inventory data, contact data, content data, contract data, usage data, as well as meta and communication data of users of our website on the basis of our legitimate interests in the efficient and secure provision of this online service pursuant to Art. 6 para. 1 subpara. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a contract for commissioned data processing).
3. Data processing in the context of contacting us
3.1 Contact via email
You can contact our company via email using the email addresses published on our website.
If you use this contact method, the data you provide (e.g., name, address), or at least your email address and the information contained in the email, along with any personal data you submit, will be stored for the purpose of contacting you and processing your request. In addition, the following data will be collected by our system:
• IP address of the requesting computer;
• Date and time of the email.
The legal basis for the processing of personal data in connection with emails transmitted to us is Art. 6 para. 1 subpara. 1 lit. b or lit. f GDPR.
3.2 Contact via website contact form
If you use the contact form provided on our website to communicate with us, you are required to provide your first and last name as well as your email address. Without this information, we cannot process your request submitted via the contact form. Providing your postal address is optional and allows us to process your request by mail, if you so wish.
In addition, the following data is collected by our system:
• IP address of the requesting computer;
• Date and time of registration.
The legal basis for the processing of personal data within the framework of contact forms submitted to us is Art. 6 para. 1 subpara. 1 lit. b or lit. f GDPR.
3.3 Contact by letter and fax
If you send us a letter or fax, the data you provide (e.g., name, first name, address) and the information contained in the letter or fax, along with the personal data you provide, will be stored for the purpose of contacting you and processing your request.
The legal basis for the processing of personal data in connection with letters and faxes sent to us is Art. 6 para. 1 subpara. 1 lit. b or lit. f GDPR.
4. Data processing when subscribing to our newsletter
When you subscribe to our newsletter mailing list, your email address and the newsletter you have selected will be stored by us on a server.
In addition, the following data is collected by the system during registration:
• IP address of the requesting computer;
• Date and time of registration.
Your consent for data processing will be obtained during the registration process, and you will be referred to this privacy policy. Data processing is based on your consent pursuant to Art. 6 para. 1 subpara. 1 lit. a GDPR and on the basis of legitimate interest pursuant to Art. 6 para. 1 subpara. 1 lit. f GDPR.
We use this data exclusively for sending the newsletter. We do not share your data with third parties or use it for any other purposes. When you register, your data is stored on our servers. A message containing a link to confirm your registration is then sent to the email address you provided (so-called double opt-in procedure). If you do not confirm your registration via the link in this email, your data will be deleted after 24 hours. Only after you confirm the link in the email will your data be stored for newsletter distribution for the duration of your subscription. This ensures that the newsletter was requested by you and not by a third party.
If you no longer consent to the storage of your data for this purpose and therefore no longer wish to use our services, you can unsubscribe from our newsletter at any time. A corresponding link can be found in every newsletter for this purpose. The personal data you provided for newsletter subscription will then be deleted.
5. Online presence on social media
We maintain an online presence on social networks to inform users active there about our services and to communicate with them via these platforms if they are interested. Our social media channels can only be accessed via an external link. As soon as you access our social media profile on the respective network, the terms and conditions and data processing policies of the respective operators apply.
We have no influence on the collection of data and its further use by social networks. We have no knowledge of the extent, location, and duration of data storage, the degree to which the networks comply with existing deletion obligations, what analyses and links are performed with the data, and to whom the data is disclosed.
We therefore expressly point out that your data (e.g. personal information, IP address) will be stored and used for business purposes by the network operators in accordance with their data usage policies.
We process data relating to our social media presence insofar as comments or direct messages are sent to us via these platforms. The legal basis for processing this data after obtaining the user’s consent is Article 6(1)(a) of the GDPR.
6. Your rights
As a data subject, you have the following rights in connection with the processing of your personal data:
6.1 Right of access pursuant to Art. 15 GDPR
(1) The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
a) the purposes of processing;
b) the categories of personal data that are processed;
c) 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 organisations;
d) where possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria used to determine that duration;
e) the existence of a right to rectification or erasure of personal data concerning them or to restriction of processing by the controller or a right to object to such processing;
f) the existence of a right to lodge a complaint with a supervisory authority;
g) where the personal data are not collected from the data subject, any available information on the source of the data;
h) the existence of automated decision-making, including profiling, pursuant to 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.
(2) Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer.
6.2 Right to rectification pursuant to Art. 16 GDPR
The data subject has the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement.
6.3 Right to erasure pursuant to Art. 17 GDPR
(1) The data subject shall have the right to request 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:
a) The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
b) The data subject withdraws their consent on which the processing was based according to Art. 6 para. 1 lit. a) or Art. 9 para. 2 lit. a) GDPR, and there is no other legal basis for the processing.
c) 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.
d) The personal data were processed unlawfully.
e) 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.
f) The personal data were collected in relation to information society services offered, in accordance with Article 8(1) of the GDPR.
(2) Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase them, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copies or replications of, those personal data.
(3) Paragraphs 1 and 2 shall not apply insofar as processing is necessary
a) to exercise the right to freedom of expression and information;
b) for compliance with a legal obligation which requires processing under 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;
c) for reasons of public interest in the area of public health pursuant to Art. 9 para. 2 lit. h) and i) and Art. 9 para. 3 GDPR;
d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1), insofar as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
e) for the establishment, exercise or defense of legal claims.
6.4 Right to restriction of processing pursuant to Art. 18 GDPR
(1) The data subject shall have the right to request from the controller the restriction of processing where one of the following applies:
a) 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,
b) the processing is unlawful and the data subject objects to the erasure of the personal data and requests the restriction of their use instead;
c) the controller no longer needs the personal data for the purposes of the processing, but the data subject requires them for the establishment, exercise or defence of legal claims, or
d) the data subject has objected to the processing pursuant to Article 21(1) GDPR pending the verification of whether the legitimate grounds of the controller override those of the data subject.
(2) Where processing has been restricted pursuant to paragraph 1, such personal data shall, with the exception of storage, only be processed with the consent of the data subject 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.
6.5 Right to data portability pursuant to Art. 20 GDPR
(1) 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 shall have the right to transmit those data to another controller without hindrance from the controller to whom the personal data have been provided, where
a) the processing is based on consent pursuant to Art. 6 para. 1 lit. a) or Art. 9 para. 2 lit. a) GDPR or on a contract pursuant to Art. 6 para. 1 lit. b) GDPR and
b) processing is carried out using automated procedures.
(2) When 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.
The right under paragraph 1 shall not infringe upon the rights and freedoms of other persons.
This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
6.6 Right to object pursuant to Art. 21 GDPR
The data subject has 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) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. 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.
In connection with the use of information society services, the data subject may, notwithstanding Directive 2002/58/EC, exercise his or her right to object by automated means using technical specifications.
6.7 Right of withdrawal pursuant to Art. 7 para. 3 GDPR
The data subject has the right to withdraw their consent to data processing at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
6.8 Right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR
Without prejudice to any other administrative or judicial remedy, every data subject has the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement, if the data subject considers that the processing of personal data relating to them infringes this Regulation.
Žilvinas Gecevičius CEO
Justinas Urbonas Head of Engineering Network Projects / HDD