Privacy Policy
We are very pleased about your interest in natureplus. Data protection is of particular importance to the International Association for Sustainable Building and Living (natureplus). The use of natureplus's websites is generally possible without providing any personal data. However, if a data subject wishes to use special services via our website, the processing of personal data may become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the data subject's consent.
The processing of personal data, such as the name, address, email address, or telephone number of a data subject, always takes place in compliance with the General Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to natureplus. Through this privacy policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed about their rights through this privacy policy.
As the controller, natureplus has implemented numerous technical and organizational measures to ensure the most complete protection possible of personal data processed through this website. Nevertheless, internet-based data transmissions can inherently have security vulnerabilities, meaning absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us via alternative means, for example, by telephone.
1. Definitions
The natureplus privacy policy is based on the terminology used by the European legislator when enacting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easily readable and understandable for both the public and our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
Among other terms, we use the following in this privacy policy:
a. Personal data
‘Personal data’ means any information relating to an identified or identifiable natural person (‘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’ means 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’ 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 analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
f. Pseudonymisation
‘Pseudonymisation’ 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
g. Controller
‘Controller’ 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 authorised to process personal data.
k. Consent
Consent 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
The controller in the sense 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:
International Association for Sustainable Building and Living – natureplus e.V.
Dilsberger Straße 2
69151 Neckargemünd
Germany
Phone: +49 (0)6223 – 8660170
Email: office@natureplus.org
Website: www.natureplus.org
3. Cookies
The natureplus websites use cookies. Cookies are text files that are stored and saved on a computer system via an internet browser.
Numerous 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 websites and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited websites 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, natureplus can provide users of this website with more user-friendly services that would not be possible without the setting of cookies.
Cookies allow the information and offers on our website to be optimized for the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, a user of a website that uses cookies does not have to re-enter their access data every time they visit the website, because this is handled by the website and the cookie stored on the user's computer system. Another example is the cookie for a shopping cart in an online shop. The online shop remembers the items 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, already set cookies 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.
4. Collection of General Data and Information
Each time a data subject or an automated system accesses the natureplus website, the website collects a series of general data and information. This general data and information is stored in the server's log files. The data collected may include (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 accessed on our website via an accessing system, (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 prevent danger in the event of attacks on our information technology systems.
When using this general data and information, natureplus does not draw any conclusions about the data subject. Rather, this information is needed to (1) correctly deliver the content of our website, (2) optimize the content of our website and its advertising, (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 necessary information for prosecution in the event of a cyberattack. These anonymously collected data and information are therefore evaluated by natureplus statistically and with the aim of increasing data protection and data security in our company, ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data from 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 shall process and store the 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 other legislators in laws or regulations to which the controller is subject.
If the storage purpose ceases to apply or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or erased in accordance with legal requirements.
6. Rights of the data subject
a. Right of confirmation
Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning them are being processed. If a data subject wishes to exercise this right of confirmation, they may contact an employee of the controller at any time.
b. Right of access
Any person affected by the processing of personal data has the right granted by the European legislator to obtain from the controller at any time, free of charge, information about the personal data stored about them and a copy of this information. 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 right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
- the right to lodge a complaint with a supervisory authority
- where the personal data are not collected from the data subject: any available information as to their source
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in these 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, they may contact an employee of the data controller at any time.
c. Right to rectification
Any person affected by the processing of personal data has the right granted by the European legislator to obtain the immediate rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right to have incomplete personal data completed, including by means of providing a supplementary statement, taking into account the purposes of the processing.
If a data subject wishes to exercise this right of rectification, they may contact an employee of the controller at any time.
d. Right to erasure (right to be forgotten)
Any person affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay, provided that one of the following grounds applies and as long as processing is not necessary:
- 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(1)(a) GDPR or Art. 9(2)(a) GDPR, and 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 personal data have to be erased for compliance with a legal obligation in 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 aforementioned reasons applies and a data subject wishes to request the erasure of personal data stored at natureplus, they may contact an employee of the controller at any time. The natureplus employee will ensure that the request for erasure is complied with immediately.
If natureplus has made personal data public and our company as controller is obliged pursuant to Art. 17(1) GDPR to erase the personal data, natureplus, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The natureplus employee will arrange the necessary measures in each individual case.
e. Right to restriction of processing
Any person 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, 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 processing, but the data subject requires them for the establishment, exercise, or defense of legal claims.
- The data subject has objected to the processing pursuant to Art. 21(1) GDPR, and it is not yet determined 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 at natureplus, they may contact an employee of the controller at any time. The natureplus employee will arrange for the restriction of processing.
f. Right to data portability
Any person affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as 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 that 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 their 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 provided that this does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may contact any employee of natureplus at any time.
g. Right to object
Every person affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.
The International Association for Sustainable Building and Living – natureplus will no longer process the personal data in the event of an 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 establishment, exercise, or defense of legal claims.
If the International Association for Sustainable Building and Living – natureplus processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data 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 natureplus to the processing for direct marketing purposes, natureplus will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to their particular situation, to object to the processing of personal data concerning them at natureplus 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 natureplus 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 their right to object by automated means using technical specifications.
h. Automated individual decision-making, including profiling
Every person 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 them or similarly significantly affects them, unless the decision (1) is necessary for entering into, or the 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 the performance of, a contract between the data subject and the controller, or (2) it is made with the data subject's explicit consent, natureplus 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 their point of view, and to contest the decision.
If the data subject wishes to exercise their rights concerning automated decisions, they may contact an employee of the controller at any time.
i. Right to withdraw data protection consent
Every person 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 their right to withdraw consent, they may contact an employee of the controller at any time.
7. Legal basis for processing
Art. 6(1)(a) GDPR serves as the legal basis for our company for processing operations where 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 necessary for the delivery of goods or the provision of any other 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, such as in cases of inquiries regarding our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as 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 another natural person. This would be the case, for example, if a visitor were injured in our facility and their name, age, health insurance data, or other vital information had to be passed on to a doctor, hospital, or other third party. In that case, the processing would be based on Art. 6(1)(d) GDPR.
Finally, processing operations could be based on Art. 6(1)(f) GDPR. This legal basis is used for processing operations that are not covered by any of the aforementioned legal bases, if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights, and fundamental freedoms of the data subject do not override these. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. The legislator took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, sentence 2, GDPR).
8. Legitimate interests in the processing pursued by the controller or by a third party
If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and our shareholders.
9. Period for which the personal data will be stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After the expiration of this period, the corresponding data is routinely deleted, provided it is no longer required for the fulfillment or initiation of a contract.
10. Statutory or contractual provisions for the provision of personal data; necessity for the conclusion of a contract; obligation of the data subject to provide the 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 result from contractual provisions (e.g., information about the contractual partner).
In some cases, it may be necessary for the conclusion of a contract that a data subject provides us with personal data, which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data when our company enters into a contract with them. Failure to provide the personal data would result in the contract with the data subject not being concluded.
Before providing personal data, the data subject must contact one of our employees. Our employee will clarify on a case-by-case basis whether the provision of 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 not providing the personal data would be.
11. Webflow
This website is hosted via the Content Delivery Network (CDN) of Webflow. This is a service provided by Webflow Inc., 398 11th Street, 2nd Floor, San Francisco, California, 94103. The Webflow CDN provides duplicates of website data on various Webflow servers distributed globally. This results in faster website loading times, higher reliability, protection against brute-force attacks, and increased protection against data loss. A large portion of the elements and the source code of this website are retrieved from the Webflow CDN when the page is accessed. During this retrieval, your IP address is anonymized and transmitted to Webflow servers outside the EU, where it is stored for 24 hours. This anonymized 24-hour storage serves as protection against brute-force attacks. No tracking or other further processing of this data takes place. The use of the Webflow CDN is in the interest of higher website reliability, increased protection against data loss, protection against brute-force attacks, and improved loading speeds for this website. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR.
Webflow Inc., based in the USA, is certified under the EU-U.S. Privacy Shield framework, which ensures compliance with the level of data protection applicable in the EU.
To ensure data-compliant processing, we have concluded a contract with our hoster in accordance with the EU Standard Contractual Clauses for data processing.
The current Webflow privacy policy can be found at: https://webflow.com/legal/eu-privacy-policy
12. Weglot
Functions of the translation service Weglot are integrated into this website. The provider is Weglot SAS, 138, rue Pierre Joigneaux, 92270 Bois-Colombes, France. Weglot is loaded when the website is accessed, allowing you to change the language to something other than German via the language icon in the website header. As a result, a direct connection between your browser and the Weglot server may be established when visiting this website. Weglot thereby receives the information that you have visited this website with your IP address. The storage and analysis of the data are based on Art. 6(1)(f) GDPR. Corresponding consent is requested via the website's cookie and privacy settings. Processing then takes place exclusively on the basis of Art. 6(1)(a) GDPR; consent can be revoked at any time via the privacy settings at the bottom of each subpage. Further information on this can be found in Weglot's privacy policy: https://weglot.com/privacy/.
13. Google Search Console
For the purpose of continuously optimizing the Google ranking of our websites, we use the web analysis service "Google Search Console." This Google Search Console allows for search analyses that provide us with information on how often the website appears in Google search results. This enables us to monitor and manage our websites in the search index. No personal user or tracking data is processed or transmitted to Google as part of the use of Google Search Console.
11. Twitter
The controller has integrated Twitter components on this website. Twitter is a multilingual, publicly accessible microblogging service on which users can publish and distribute so-called tweets, which are short messages limited to 280 characters. These short messages are accessible to everyone, including those not registered with Twitter. However, the tweets are also displayed to the respective user's so-called followers. Followers are other Twitter users who follow a user's tweets. Furthermore, Twitter allows for reaching a broad audience via hashtags, links, or retweets.
The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.
Each time one of the individual pages of this website, which is operated by the controller and on which a Twitter component (Twitter button) has been integrated, is accessed, the internet browser on the data subject's information technology system is automatically prompted by the respective Twitter component to download a display of the corresponding Twitter component from Twitter. Further information about the Twitter buttons can be found at about.twitter.com/resources/buttons. As part of this technical process, Twitter receives information about which specific subpage of our website is being visited by the data subject. The purpose of integrating the Twitter component is to enable our users to redistribute the content of this website, to promote this website in the digital world, and to increase our visitor numbers.
If the data subject is logged into Twitter at the same time, Twitter recognizes which specific subpage of our website the data subject is visiting each time they access our website and for the entire duration of their stay on our website. This information is collected by the Twitter component and assigned by Twitter to the data subject's respective Twitter account. If the data subject clicks on one of the Twitter buttons integrated into our website, the data and information transmitted thereby are assigned to the data subject's personal Twitter user account and stored and processed by Twitter.
Twitter receives information via the Twitter component that the data subject has visited our website whenever the data subject is logged into Twitter at the time they access our website; this occurs regardless of whether the data subject clicks on the Twitter component or not. If the data subject does not wish for this information to be transmitted to Twitter, they can prevent the transmission by logging out of their Twitter account before accessing our website.
The applicable privacy policy of Twitter can be accessed at twitter.com/privacy.
12. YouTube
The controller has integrated YouTube components on this website. YouTube is an internet video portal that allows video publishers to post video clips for free and other users to view, rate, and comment on them, also free of charge. YouTube allows the publication of all types of videos, which is why complete film and television programs, as well as music videos, trailers, or videos created by users themselves, can be accessed via the internet portal.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
Each time one of the individual pages of this website, which is operated by the controller and on which a YouTube component (YouTube video) has been integrated, is accessed, the internet browser on the data subject's information technology system is automatically prompted by the respective YouTube component to download a display of the corresponding YouTube component from YouTube. Further information about YouTube can be found at www.youtube.com/yt/about/. As part of this technical process, YouTube and Google receive information about which specific subpage of our website is being visited by the data subject.
If the data subject is logged into YouTube at the same time, YouTube recognizes which specific subpage of our website the data subject is visiting whenever they access a subpage containing a YouTube video. This information is collected by YouTube and Google and assigned to the data subject's respective YouTube account.
YouTube and Google receive information via the YouTube component that the data subject has visited our website whenever the data subject is logged into YouTube at the time they access our website; this occurs regardless of whether the data subject clicks on a YouTube video or not. If the data subject does not wish for this information to be transmitted to YouTube and Google, they can prevent the transmission by logging out of their YouTube account before accessing our website.
The privacy policy published by YouTube, which is available at www.google.de/intl/de/policies/privacy/, provides information about the collection, processing, and use of personal data by YouTube and Google.
13. Cloudflare
On our website, we use a "Content Delivery Network" (CDN) from the technology service provider Cloudflare Inc., 101 Townsend St. San Francisco, CA 94107, USA ("Cloudflare"). A Content Delivery Network is an online service that helps deliver large media files (such as graphics, page content, or scripts) through a network of regionally distributed servers connected via the Internet. The use of the Cloudflare Content Delivery Network helps us optimize the loading speeds of our website.
Processing is carried out in accordance with Art. 6(1)(f) GDPR based on our legitimate interest in the secure and efficient provision, as well as the improvement of the stability and functionality, of our website.
We have concluded a data processing agreement with Cloudflare (Data Processing Addendum, available at https://www.cloudflare.com/media/pdf/cloudflare-customer-dpa.pdf), which obligates Cloudflare to protect the data of our site visitors and not to pass it on to third parties. For the transfer of data from the EU to the USA, Cloudflare relies on the European Commission's standard contractual clauses, which are intended to ensure compliance with the European level of data protection in the USA.
Further information can be found in the Cloudflare privacy policy at: https://www.cloudflare.com/privacypolicy/
14. jsDelivr CDN
This site uses a "Content Delivery Network" (CDN) from jsDelivr.
A CDN is a service used to deliver content from our online services, particularly large media files such as graphics or scripts, more quickly via a network of regionally distributed servers connected via the Internet. User data is processed solely for the aforementioned purposes and to maintain the security and functionality of the CDN.
For this purpose, the browser you use must connect to the CDN's servers. This informs the CDN that our website has been accessed via your IP address. This usage is based on our legitimate interests, i.e., our interest in the secure and efficient provision, analysis, and optimization of our online services in accordance with Art. 6(1)(f) GDPR. Further information can be found in the jsDelivr privacy policy: https://www.jsdelivr.com/privacy-policy-jsdelivr-net/
15. Existence of automated decision-making
As a responsible company, we do not use automated decision-making or profiling.
This privacy policy was created using the privacy policy generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as an External Data Protection Officer in Erlangen, in cooperation with IT and data protection attorney Christian Solmecke.