Privacy policy

We are very pleased about your interest in our company. Data protection has a particularly high priority for the management of medienprojekt p2 GmbH. Using the internet pages of medienprojekt p2 GmbH is possible without any indication of personal data. However, if a data subject (person concerned) 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 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 shall always be in line with the country-specific data protection regulations applicable to medienprojekt p2 GmbH. By means of this privacy policy, our company would like 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.

As the controller, medienprojekt p2 GmbH has implemented numerous technical and organisational measures to ensure the fullest protection of personal data processed through this website. Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to submit personal data to us by alternative means, for example by telephone.

  1. Definitions

The privacy policy of medienprojekt p2 GmbH is based on the terms used by the European Directive and Ordinance Maker when issuing the General Data Protection Regulation (GDPR). Our privacy policy should 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 terms 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 are processed by the controller.

  • c) Processing

Processing is any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction.

  • (d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.

  • e) Profiling

Profiling is any form of automated processing of personal data, which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.

  • f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a way 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 which ensure that the personal data are not attributed to an identified or identifiable natural person.

  • (g) Controller or person responsible for processing

The controller or person responsible for 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 Union or Member State law, the controller or the specific criteria for its designation may be provided for under Union or Member State law.

  • (h) Processors

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 other body to whom personal data is disclosed, whether or not a third party. However, authorities that may receive personal data in the context of a specific investigation mandate under Union or Member State law shall not be considered as recipients.

  • j) Third party

Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorised to process the personal data under the direct responsibility of the controller or the processor.

  • k) Consent

Consent shall mean any freely given specific and informed indication of the data subject’s wishes in the form of a statement or other unambiguous affirmative act by which the data subject signifies his or her agreement to the processing of personal data relating to him or her.

  1. Name and address of the controller responsible for processing

The responsible party 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 of a data protection nature is:

medienprojekt p2 GmbH

Mettinger Street 31

70327 Stuttgart

Germany

Tel: +49 711 601 87 46-0

E-mail: info@medienprojektp2.de

Website: www.medienprojektp2.de

  1. Cookies

The internet pages of medienprojekt p2 GmbH use cookies. Cookies are text files that are 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 string of characters by which internet pages and servers can be assigned to the specific internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognised and identified via the unique cookie ID.

Through the use of cookies, medienprojekt p2 GmbH can provide the users of this website with more user-friendly services that would not be possible without any cookies being set.

By means of a cookie, the information and offers on our website can be optimised in the interests of the user. Cookies enable us, as already mentioned, to recognise the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter his or her access data each time he or she visits the website because this is done by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping basket in the online shop. The online shop remembers the items that a customer has placed in the virtual shopping basket via a cookie.

The data subject can prevent the setting of cookies by our website at any time by means of an appropriate 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 programmes. 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.

  1. Collection of general data and information

The website of medienprojekt p2 GmbH collects a series of general data and information every time a data subject or automated system calls up the website. This general data and information is stored in the server’s log files. The following data 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 accesses our website (so-called referrer), (4) the sub-websites which 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 that serve to avert danger in the event of attacks on our information technology systems.

When using these general data and information, medienprojekt p2 GmbH does not draw any conclusions about the data subject. This information is required in order to (1) correctly deliver the contents of our website, (2) optimise the contents of our website as well as the advertising for these, (3) ensure the permanent functionality of our information technology systems and the technology of our website as well as (4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Therefore, medienprojekt p2 GmbH analyses anonymously collected data and information on the one hand for statistical purposes and on the other for the purpose of increasing the data protection and data security of our enterprise, so as to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.

  1. Routine deletion and blocking of personal data

The controller shall process and store personal data of the data subject only for the time necessary to achieve the purpose of storage or where provided for by the European Directive and Regulation or other legislator in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies or if a storage period prescribed by the European Directive and Regulation or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

  1. Rights of the data subject
  • a) Right to confirmation

Every data subject shall have the right, granted by the European Directive and the Regulation, to obtain confirmation from the controller as to whether personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact any employee of the controller.

  • b) Right to information

Any data subject by the processing of personal data shall have the right granted by the European Directive and the Regulation to obtain at any time from the controller, free of charge, access to and a copy of the personal data relating to him or her which have been stored. Furthermore, the European Directive and Regulation has granted the data subject access to the following information:

    • the processing purposes
    • the categories of personal data that are processed
    • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organisations
    • if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration
    • the existence of a right to obtain the rectification or deletion of personal data concerning them or to obtain the restriction of processing by the controller or a right to object to such processing
    • the existence of a right of appeal to a supervisory authority
    • if the personal data is not collected from the data subject: all available information on the origin of the data
    • the existence of automated decision-making, including profiling, pursuant to Article 22(1) and (4) of the GDPR and, at least in these cases, meaningful information about the logic involved and the scope and intended effects of such processing for the data subject

Furthermore, the data subject has the right to be informed whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in connection with the transfer.

If a data subject wishes to exercise this right of access, he or she may, at any time, contact any employee of the controller.

  • c) Right of rectification

Any person affected by the processing of personal data has the right granted by the European Directive and Regulation to request the rectification without delay of inaccurate personal data concerning him or her. Furthermore, the data subject shall have the right, taking into account the purposes of the processing, to request the completion of incomplete personal data, including by means of a supplementary declaration.

If a data subject wishes to exercise this right of access, he or she may, at any time, contact any employee of the controller.

  • d) Right to deletion (right to be forgotten)

Any data subject by the processing of personal data shall have the right, granted by the European Directive and the Regulation, to obtain from the controller the deletion without delay of personal data concerning him or her, where one of the following grounds applies and insofar as the processing is not necessary:

    • the personal data were collected or otherwise processed for purposes for which they are no longer necessary.
    • the data subject revokes the consent on which the processing was based pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR and there is no other legal basis for the processing.
    • the data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
    • the personal data have been processed unlawfully.
    • the deletion of the 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 was collected in relation to information society services offered pursuant to Art. 8(1) GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to arrange for the deletion of personal data stored by medienprojekt p2 GmbH, he or she may, at any time, contact any employee of the controller. The employee of medienprojekt p2 GmbH will arrange for the deletion request to be complied with immediately.

If the personal data has been made public by medienprojekt p2 GmbH and our company as the responsible party is obliged to delete the personal data pursuant to Art. 17 Para. 1 GDPR, medienprojekt p2 GmbH shall implement reasonable measures, including technical measures, to compensate other data controllers for processing the personal data published, taking into account the available technology and the cost of implementation, in order to inform the data subject that he or she has requested from those other data controllers to delete all links to the personal data or copies or replications of the personal data, unless the processing is necessary. The employee of medienprojekt p2 GmbH will arrange for the necessary action to be taken in individual cases.

  • e) Right to restriction of processing

Any data subject by the processing of personal data has the right, granted by the European Directive and the Regulation, to obtain from the controller the restriction of processing where one of the following conditions is met:

    • 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 objects to the deletion of the personal data and requests instead the restriction of the use of the personal data.
    • the controller no longer needs the personal data for the purposes of processing, but the data subject needs it for the establishment, exercise or defence of legal claims.
    • the data subject has objected to the processing pursuant to Article 21(1) of the GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of personal data stored by medienprojekt p2 GmbH, he or she may, at any time, contact any employee of the controller. The employee of medienprojekt p2 GmbH will arrange the restriction of the processing.

  • f) Right to data portability

Any person concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, to receive the personal data concerning him or her, which have been provided by the data subject to a controller, in a structured, commonly used and machine-readable format. He/she shall also have the right to transmit such data to another controller without hindrance from the controller to whom the personal data have been provided, provided that the processing is based on consent pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR or on a contract pursuant to Article 6(1)(b) of the GDPR and the processing is carried out by automated means, unless the processing is 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, when exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to obtain that the personal data be transferred directly from one controller to another controller, to the extent that this is technically feasible and provided that this does not adversely affect the rights and freedoms of other individuals.

In order to assert the right to data portability, the data subject may at any time contact any employee of medienprojekt p2 GmbH.

  • g) Right to object

Any person affected by the processing of personal data shall have the right granted by the European Directive and Regulation to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.

medienprojekt p2 GmbH 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 for the assertion, exercise or defence of legal claims.

If medienprojekt p2 GmbH processes personal data for the purpose of direct marketing, the data subject shall have the right to object at any time to processing of personal data processed for such marketing. This also applies to profiling, insofar as it is connected with such direct advertising. If the data subject objects to medienprojekt p2 GmbH to the processing for direct marketing purposes, medienprojekt p2 GmbH 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 which is carried out by medienprojekt p2 GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the General Data Protection Regulation, unless such processing is necessary for the performance of a task carried out in the public interest.

In order to exercise the right to object, the data subject may directly contact any employee of the medienprojekt p2 GmbH or another employee. The data subject shall also be free to exercise his or her right to object by means of automated procedures using technical specifications in the context of the use of information society services, notwithstanding Directive 2002/58/EC.

  • h) Automated decisions in individual cases including profiling

Any person concerned by the processing of personal data shall have the right, granted by the European Directive and the Regulation, 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, provided that the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and that such law lays down appropriate measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is made with the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the data controller, or (2) it is made with the data subject’s explicit consent, medienprojekt p2 GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, which include at least the right to obtain the data subject’s involvement 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 decisions, he or she may, at any time, contact any employee of the controller.

  • i) Right to revoke consent under data protection law

Any person affected by the processing of personal data has the right granted by the European Directive and Regulation 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, at any time, contact any employee of the controller.

  1. Data protection in applications and the application process

The controller collects and processes the personal data of applicants for the purpose of managing the application procedure. The processing may also be carried out electronically. This is particularly the case if an applicant sends the relevant application documents to the controller electronically, for example by e-mail or via a web form on the website. If the data controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application files shall be automatically deleted two months after the notification of the rejection decision, unless otherwise justified by the controller. Other legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).

  1. Privacy policy on the use and application of Google Analytics (with anonymisation function)

The controller has integrated the Google Analytics component (with anonymisation function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, collation and evaluation of data on the behaviour of visitors to websites. A web analysis service collects, among other things, data about the website from which a data subject has accessed a website (so-called referrer), which sub-pages of the website have been accessed or how often and for how long a sub-page has been viewed. A web analysis is mainly used to optimise a website and to analyse the cost-benefit of internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

The controller uses the addition “_gat._anonymizeIp” for web analysis via Google Analytics. By means of this addition, the IP address of the internet connection of the data subject is shortened and anonymised by Google if access to our internet pages is made from a member state of the European Union or from another state party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse the flow of visitors to our website. Google will use the data and information collected for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity.

Google Analytics sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyse the use of our website. Each time a data subject accesses one of the individual pages of this website operated by the data controller on which a Google Analytics component has been integrated, the internet browser on the data subject’s information technology system is automatically triggered by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. As part of this technical procedure, Google obtains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission calculations.

By means of the cookie, personal information, for example the access time, the place from which an access originated and the frequency of visits to our website by the data subject, is stored. Each time you visit our website, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data collected through the technical process with third parties.

The data subject can prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Google from setting a cookie on the information technology system of the data subject. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the option to object to the collection of data generated by Google Analytics and related to the use of this website as well as to the processing of this data by Google and to prevent such processing. For this purpose, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout. This browser add-on tells Google Analytics via JavaScript that no data and information about visits to internet pages may be transmitted to Google Analytics. The installation of the browser add-on is considered by Google as an objection. If the information technology system of the data subject is deleted, formatted or reinstalled at a later point in time, the data subject must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within his or her control, it is possible to reinstall or reactivate the browser add-on.

Further information and Google’s applicable privacy policy can be found at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail under this link https://www.google.com/intl/de_de/analytics/.

  1. Privacy policy on the use and application of Jetpack for WordPress

The controller has integrated Jetpack on this website. Jetpack is a WordPress plug-in that offers additional functions to the operator of a website built on WordPress. Jetpack allows the website operator, among other things, an overview of the visitors to the page. Furthermore, the display of related articles and publications or the possibility to share content on the page can increase the number of visitors. In addition, security features are built into Jetpack so that a website using Jetpack is better protected against brute force attacks. Jetpack also optimises and speeds up the loading of the images integrated on the website.

The operating company of the Jetpack plug-in for WordPress is Automattic Inc, 132 Hawthorne Street, San Francisco, CA 94107, USA. The operating company uses the tracking technology of Quantcast Inc, 201 Third Street, San Francisco, CA 94103, USA.

Jetpack sets a cookie on the information technology system of the data subject. What cookies are has already been explained above. Each time a data subject accesses one of the individual pages of this website operated by the data controller on which a Jetpack component has been integrated, the internet browser on the data subject’s information technology system is automatically triggered by the respective Jetpack component to transmit data to Automattic for analysis purposes. As part of this technical process, Automattic obtains knowledge of data that is subsequently used to create an overview of website visits. The data obtained in this way is used to analyse the behaviour of the data subject who has accessed the website of the controller and is evaluated with the aim of optimising the website. The data collected via the Jetpack component will not be used to identify the data subject without first obtaining the separate express consent of the data subject. The data will also be made available to Quantcast. Quantcast uses the data for the same purposes as Automattic.

The data subject can prevent the setting of cookies by our website, as already described above, at any time by means of an appropriate setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting of the internet browser used would also prevent Automattic/Quantcast from setting a cookie on the information technology system of the data subject. In addition, cookies already set by Automattic can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the possibility to object to and prevent the collection of data generated by the Jetpack cookie and related to a use of this website as well as the processing of such data by Automattic/Quantcast. To do this, the data subject must press the opt-out button under the link https://www.quantcast.com/opt-out/, which sets an opt-out cookie. The opt-out cookie set with the objection is stored on the information technology system used by the data subject. If the cookies on the data subject’s system are deleted after an objection, the data subject must access the link again and set a new opt-out cookie.

However, with the setting of the opt-out cookie, there is the possibility that the internet pages of the controller are no longer fully usable for the data subject.

Automattic’s applicable privacy policy is available at https://automattic.com/privacy/. Quantcast’s applicable privacy policy is available at https://www.quantcast.com/privacy/.

  1. Legal basis of processing

Art. 6 I lit. a GDPR serves our company as the legal basis for processing operations in 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 a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Article 6 I lit. b GDPR. The same applies to processing operations that are necessary for the implementation of pre-contractual measures, for example in the case of enquiries about our products or services. If our company is subject to a legal obligation by which the processing of personal data becomes necessary, 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 might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result their name, age, health insurance details or other vital information needed 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.
Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, he took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47, second sentence of the GDPR).

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

If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the performance of our business activities for the benefit of the well-being of all our employees and our shareholders.

  1. Duration for which the personal data are stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of the deadline, the corresponding data is routinely deleted if it is no longer required for the fulfilment or initiation of the contract.

  1. Legal or contractual requirements to provide the personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner).
Sometimes, in order to conclude a contract, it may be necessary for a data subject to provide us with personal data which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if 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 providing personal data 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 the contract, whether there is an obligation to provide the personal data and what the consequences of not providing the personal data would be.

  1. Existence of automated decision making

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

This data protection declaration was created by the data protection declaration generator of DGD Deutsche Gesellschaft für Datenschutz GmbH (German Authority for Data Protection), which acts as the External data protection commissioner Düsseldorf in cooperation with the Cologne data protection lawyer Christian Solmecke created.