is a matter of trust
and your trust is important to us.
Data Privacy Statement
of consenso Consulting GmbH
We are very delighted that you have shown interest in our company. Data protection is of a particularly high priority for the management of consenso Consulting GmbH. In general, the use of the Internet pages of consenso Consulting GmbH is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, e.g. name, address, e-mail address or telephone number of a data subject, is always made in accordance with the General Data Protection Regulation (GDPR) and in compliance with the current country-specific data protection regulations for consenso Consulting GmbH. By means of this data privacy statement, our company would like to inform the public about the nature, extent and purpose of the personal data collected, used and processed by us. Furthermore, data subjects are informed about the rights granted to them by means of this data privacy statement.
As the controller, the consenso Consulting GmbH has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
The data protection declaration of consenso Consulting GmbH is based on the terms used by the European bodies and regulators for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
a) Personal data
Personal data is defined as 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 is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, 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 is the marking of stored personal data with the aim of limiting their processing in the future.
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 analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation is 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g) Controller (or controller responsible for the data processing)
Controller (or controller responsible for the data processing) is 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 European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is 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 context of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients.
j) Third party
Third party is 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 authorised to process personal data.
Consent of the data subject is 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 the data processing)
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
consenso Consulting GmbH
tel +49 (0) 521 260 6 0
3. Name and address of the data protection officer
The data protection officer of the controller is:
consenso Consulting GmbH
tel +49 (0) 521 260 6 0
Any data subject may, at any time, contact our data protection officer directly with all questions and suggestions concerning data protection.
4. General information on data processing
As a general rule, we only collect and use personal data of our users to the extent necessary to provide a functional website as well as our contents and services. The collection and use of personal data of our users shall take place regularly only upon the consent of the user. An exception may be made in such cases, where obtaining prior consent is not possible due to factual reasons and where data processing is permitted by applicable law and regulations.
5. Provision of the website and creation of log files
a) Collection of general data and information
With each call-up by a data subject or an automated system, the website of consenso Consulting GmbH collects a series of general data and information. These general data and information are stored in the server log files. It may collect (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 referrers), (4) the sub-pages of our websites triggered by an accessing system, (5) 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 serving the prevention of dangers in the case of attacks on our information technology systems.
Legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR.
b) Purpose of data processing
When using these general data and information, consenso Consulting GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the contents of our website as well as its advertisement, (3) ensure lasting functionality of our information technology systems and the website technology, and (4) provide prosecution authorities with the necessary information in case of a cyber-attack. Thus, consenso Consulting GmbH evaluates these anonymously collected data and information statistically, with the objective of increasing data protection and data security of our company, and to eventually ensure the best 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.
6. Contact opportunity via the website
Due to legal requirements, the website of consenso Consulting GmbH contains information enabling quick electronic contacting as well as direct communication with our company, also comprising a general mail address for electronic mail (e-mail) as well as contact forms. Once a data subject contacts the controller by e-mail or via one of the provided contact forms, the personal data transmitted by the data subject will be stored automatically. Such personal data, provided on a voluntary basis by a data subject to the controller, are stored for the purpose of processing or contacting the data subject. This personal data will not be disclosed to third parties. The data will be used solely for the processing of the conversation.
Legal basis for the processing of data provided in the course of an e-mail transmission is Art. 6 para. 1 lit. f GDPR. Is the e-mail contact aimed at entering into a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b GDPR.
The processing of personal data from the input mask serves us only to process the contacting. In case of a contact via e-mail, this goes with the necessary legitimate interest of processing the data. The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure security of our information technology systems.
7. Notes regarding our Facebook page
In addition to our website, we also operate the Facebook page https://www.facebook.com/consensoconsulting to represent our company, inform you of our offers and communicate with our customers and interested parties. In doing so, generally, we only process personal data in the event you interact with our Facebook page, e.g. by commenting, clicking a like button or sending us a message. On the one hand, the legal basis for data processing in this context is art. 6 para. 1 item b) GDPR (e.g. when sending us contract-related requests). On the other hand, data processing can also take place based on your consent according to art 6. para. 1 item a) GDPR (e.g. when “liking” one of our posts, commenting or uploading content to our side). You may, at any time, revoke your consent with effect for the future by deleting the comment or the respective content. Any revocation will not affect the legitimate processing based on your consent until the revocation. Furthermore, we analyse the calls and interactions on our Facebook page. For this purpose, Facebook creates usage profiles and only provides us with anonymous data.
Regarding data processing via our Facebook page, you have the possibility to assert your rights of the persons affected (see following chapter “Your rights”) also against Facebook. For further information please refer to Facebook’s privacy statement.
8. Routine deletion and blocking of personal data
The controller shall process and store the personal data of the data subject only for the period necessary to achieve the storage purpose, or to the extent granted by the European bodies and regulators or other legislators in laws or regulations to which the controller is subject to.
Should the storage purpose cease to exist, or should a period prescribed by the European bodies and regulators or another competent legislator expire, the personal data will be routinely blocked or deleted according to the applicable legal regulations.
9. Rights of the data subject
Where personal data of an individual is processed, this person is concerned within the meaning of GDPR and he or she is entitled to the following rights towards the controller:
a) Right of confirmation
Each data subject is entitled to the right conferred by the European bodies and regulators to demand a confirmation of the controller, if any relevant personal data is being processed. If a data subject wishes to make use of this right of confirmation, he or she may contact our data protection officer or any other employee of the controller at any time.
b) Right of access
Each data subject concerned by the processing of personal data is entitled to the right conferred by the European bodies and regulators to obtain, at any time, free information by the controller about the stored personal data concerning him/her including a copy of this information. Furthermore, the European bodies and regulators have granted the data subject access to the following information:
- processing purposes
- categories of personal data to be processed
- recipients or categories of recipients to whom the personal data might have been or might be disclosed, especially where recipients in third countries or in international organisations are involved
- if possible, the planned period for the data storage or, if this is not possible, the criteria for the determination of this period
- existence of a right to correct or delete the personal data concerning him/her or to restrict the processing by the controller or to object to such processing
- existence of a right to lodge a complaint with a supervisory authority
- if the personal data are not collected from the data subject: any available information regarding the origin of the data
- existence of automated decision-making, including profiling, according to Art. 22 para. 1 and 4 GDPR and – at least in these cases – meaningful information on the logic involved as well as the significance and envisaged consequences of such processing for the data subject
Furthermore, the data subject is entitled to the right to obtain information as to whether personal data are transmitted to a third country or an international organisation. Where this is the case, as a matter of fact, the data subject shall have the right to obtain information on the suitable guaranties according to Art. 46 GDPR in connection with the transmission.
Should a data subject wish to make use of this right of information, he or she may contact our data protection officer or any other employee of the controller at any time.
c) Right of correction
Each data subject concerned by the processing of personal data is entitled to the right conferred by the European bodies and regulators to demand immediate correction of inaccurate personal data concerning him or her. Furthermore, considering the processing purposes, the data subject is entitled to the right to demand completion of incomplete personal data – also by means of providing a complementary declaration.
If a data subject wishes to exercise this right of correction, he or she may contact our data protection officer or any other employee of the controller at any time.
d) Right of deletion (right to be forgotten)
Every data subject concerned by the processing of personal data is entitled to the right conferred by the European bodies and regulators to demand immediate deletion of the relevant personal data concerning him or her, if one of the following reasons applies, and as long as the processing is not required:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent on which the processing is based according to Art. 6 para. 1 lit. a GDPR or Art 9. para. 2 lit a GDPR, and there is no other legal basis for the processing.
- The data subject enters an objection against the processing according to Art. 21 para. 1 DGPR, and there are no primary legitimate reasons for the processing, or the data subject enters an objection against the processing according to Art. 21 para. 2 GDPR.
- The personal data have been unlawfully processed.
- Deletion of the personal data is required as to comply with a legal obligation according to European Union law or the law of the Member States to which the controller is subject.
- The personal data have been collected in the course of offered services of the information society according to Art. 8 para. 1 GDPR.
If one of the above-mentioned reasons applies and a data subject wishes to request deletion of personal data stored by consenso Consulting GmbH, he or she may contact our data protection officer or any other employee of the controller at any time. The data protection officer of consenso Consulting GmbH or any other employee shall promptly ensure that the erasure request is complied with immediately.
Should personal data have been made public by consenso Consulting GmbH, and should our company be obliged to delete the personal data according to Art. 17 para. 1 GDPR, consenso Consulting GmbH – considering available technology and implementation costs – shall take appropriate measures, including those of a technical nature, to inform other controllers processing the published personal data, that the data subject has demanded of such controllers to delete all links to or copies and replications of these personal data, as far as processing is not required. The data protection officer of consenso Consulting GmbH or any other employee will arrange for the necessary steps in each individual case.
The right of deletion does not exist, if processing is required due to
- the exercise of freedom of expression and information;
- the compliance with a legal obligation demanding the processing according to the Union law or the law of the Member States that the controller is subject to, or the performance of a task carried out in the public interest, or in the exercise of public authority vested in the controller;
- reasons of public interest in the field of public health according to Art. 9 para. 2 lit. h and i as well as Art. 9 para. 3 GDPR;
- archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to Art. 89 para. 1 GDPR, if the right mentioned under section a) is likely to prevent or seriously affect the realisation of the goals of the processing, or;
- assertion, exercise or defence of legal claims.
e) Right of restriction of processing
Each data subject concerned by the processing of personal data is entitled to the right conferred by the European bodies and regulators to demand restriction of the processing by the controller, if one of the following conditions 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, the data subject refuses deletion of the personal data and instead demands restriction of the use of the personal data.
- The controller does no longer require the personal data for processing purposes, but the data subject still needs them for the assertion, exercise or defence of legal claims.
- The data subject has entered an objection against the processing according to Art. 21 para. 1 GDPR, and it has not been decided whether the legitimate reasons of the controller outweigh the ones of the data subject.
If one of the above-mentioned conditions applies, and a data subject demands restriction of the personal data stored by consenso Consulting GmbH, he or she may contact our data protection officer or any other employee of the controller at any time. The data protection officer of consenso Consulting GmbH or any other employee will arrange the restriction to be carried out.
f) Right of data portability
Each data subject concerned by the processing of personal data is entitled to the right conferred by the European bodies and regulators to receive the personal data concerning him/her, which he or she has made available to a controller, in a structured, commonly used and machine-readable format. Furthermore, he or she has the right to transmit these data to another controller without hindrance from the controller to whom the personal data have been provided, as long as the processing is based on the consent according to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, or on a contract according to Art. 6 para. 1 lit. b GDPR, and the data are processed with the help of automated procedures, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the controller.
Furthermore, when it comes to exercising his/her right of data portability and according to Art. 20 para. 1 GDPR, the data subject is entitled to the right to have his/her personal data transmitted directly from one controller to another, if this is technically feasible and does not affect the rights and freedoms of other persons.
To exercise the right of portability, the data subject may contact our data protection officer or any other employee of the controller at any time.
g) Right of appeal / right to object
Each data subject concerned by the processing of personal data is entitled to the right conferred by the European bodies and regulators to enter an objection, at any time, due to reasons arising from his or her particular situation, against the processing of personal data concerning him/her based on Art. 6 para. 1 lit. e or f GDPR. This also applies for any profiling based on these regulations.
In the event of an objection, consenso Consulting GmbH shall no longer process personal data, unless we can provide compelling and legitimate reasons for the processing, overweighing the interests, rights and freedoms of the data subject, or the processing serves the assertion, exercise or defence of legal claims.
Should consenso Consulting GmbH process personal data for direct advertising purposes, the data subject shall be entitled to the right to enter an objection against the processing of personal data, at any time, for the purpose of such advertising. In case the data subject objects to the processing for direct advertising purposes by consenso Consulting GmbH, consenso Consulting GmbH will no longer process the personal data for such purposes.
Furthermore, the data subject is entitled to the right, due to reasons arising from his or her particular situation, to object to the processing of personal data concerning him/her by consenso Consulting GmbH for scientific or historical research purposes or statistical purposes according to Art. 89 para. 1 GDPR, unless such processing is necessary to carry out a task in the public interest.
In order to exercise the right of appeal, the data subject may directly contact our data protection officer or any other employee of the controller at any time. Furthermore, the data subject shall be free to exercise his/her right of appeal via automated procedures using technical specifications in the context of the use of services of the information society, notwithstanding directive 2002/58/EG.
h) Automated decisions in individual cases including profiling
Each data subject concerned by the processing of personal data is entitled to the right conferred by the European bodies and regulators not to be subject to a decision solely made upon automated processing – including profiling – that produces legal effects with respect to him/her or significantly affects him/her in a similar way, unless the decision (1) is necessary for the entering into or performance of a contract between the data subject and the controller, or (2) is permitted according to the regulations of the European Union or the Member States to which the controller is subject and these regulations comprise appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, or (3) is made with the explicit consent of the data subject.
If the decision (1) is required for entering into, or the performance of, a contract between the data subject and the controller, or (2) it is made with the explicit consent of the data subject, consenso Consulting GmbH will take appropriate measures to safeguard the rights and freedoms as well as the legitimate interest of the data subject, including 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 exercise the rights concerning automated individual decision-making, he or she may, at any time, may contact our data protection officer or any other employee of the controller.
i) Right of withdrawal from a data protection consent
Each data subject concerned by the processing of personal data is entitled to the right conferred by the European bodies and regulators to withdraw his/her consent to the processing of his/her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact our data protection officer or any other employee of the controller.
j) Right of information
If a data subject has asserted the right of correction, deletion or restriction of the processing against the controller, the controller shall be obliged to inform all recipients, to whom the relevant personal data concerning this individual might have been disclosed, about this correction or deletion of the data or restriction of the processing, unless this proves impossible or involves a disproportionate effort.
The data subject is entitled to the right against the controller to be informed about these recipients.
k) Right of complaint to a supervisory authority
Irrespective of any other administrative or judicial procedures, each data subject has the right to file a complaint with a supervisory authority, especially in the Member State of his/her residence, place of work or location of the supposed infringement, if he or she believes that the processing of the personal data concerning him/her violates GDPR.
The supervisory authority to which the complaint was made shall inform the complainant about the status and results of the complaint including the possibility of appeal according to Art. 78 GDPR.
10. Data protection for applications and application processes
The controller collects and processes the personal data of applicants for the purpose of handling the application procedure. Processing may also be carried out by electronic means. This applies, in particular, if an applicant submits appropriate application documents to the controller e.g. via e-mail or a web form on our website. If the controller enters into an employment contract with an applicant, the provided data will be stored for the purpose of handling the employment relationship in compliance with the legal requirements. If no employment contract is concluded between the controller and the applicant, the application documents will be deleted automatically two months after notification of the refusal decision, unless barred by any other legitimate interest of the controller. Other legitimate interest in this sense can be e.g. the burden of proof relating to a proceeding under the German General Equal Treatment Act (AGG).
11. Data protection provisions about the application and use of Google Analytics (with anonymisation function)
On this website, the controller has integrated the component Google Analytics (with anonymisation function). Google Analytics is a web analytics service. Web analytics is the collection, gathering and analysis of data about the behaviour of visitors to websites. A web analytics service collects, inter alia, data about the website from which a data subject has come to a website (so-called referrers), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. It exists a contract data processing agreement.
For the web analytics through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyse the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/.
You may also prevent the collection of data by Google Analytics by clicking on the following link. This will set an opt-out cookie preventing the future collection of your data while visiting this website: Deactivate Google Analytics
12. Legal basis for the processing
Art. 6 I lit. 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, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6 I lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services.
Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may 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 company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d GDPR.
Finally, processing operations could be based on Article 6 I lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the above-mentioned legal grounds, 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 which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
13. Legitimate interest in the processing, pursued by the controller or by a third party
Where the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.
14. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.
15. Provision of personal data as statutory or contractual requirement; requirement necessary to enter into a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him/her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, he or she must contact our data protection officer. The data protection officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
16. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
17. Up-to-dateness and change of these data protection notices
These data protection notices as of 28. November 2019 are currently applicable.
It may become necessary to change these data protection notices due to the further development of our website and the respective offers or due to amended legal or official requirements. You may always call up and print out the latest version of our data privacy statement under http://www.consenso.de/en/data-protection.html