To users of our blog Club115 - updated 02.02.2025
We are updating our Privacy Policy to keep abreast of legal
changes affecting your privacy. We are notifying you of these changes so that
you can understand and stay up to date on how and why your personal information
is collected and processed by us.
Our update today includes a new section for our European users
explaining additional rights they now have to their personal data under the new
General Data Protection Regulation (GDPR) recently enacted by the European Union.
We expect to be making and announcing additional updates to our
Privacy Policy relating to the GDPR in the coming days.
We recognise that protecting your privacy is our duty and
essential to maintaining a lasting relationship with you. Our commitment to you
is to protect personal information you’ve entrusted to us by ensuring that it
is treated and used in a way that guards your privacy while still enabling us
to effectively deliver and enhance our products and services for your benefit.
Thank you for attention!
GDPR Data Protection Policy
Introduction
Club 115 / Horst D. Lindenau as an administrator is committed to
protecting the rights and freedoms of data subjects and safely and securely
processing their data in accordance with all of our legal obligations. We
hold personal data about our employees, clients, suppliers and other
individuals for a variety of business purposes.
Scope
This policy applies to all staff, which must be familiar with this
policy and comply with its terms. This policy supplements our other
policies relating to internet and email use. We may supplement or amend this
policy by additional policies and guidelines from time to time. Any new or
modified policy will be circulated to staff before being adopted.
The principles
Club 115/ Horst D. Lindenau’s blog Club 115 shall comply with the
principles of data protection outlined within the EU General Data Protection
Regulation. We will make every effort possible in everything we do to comply
with these.
Lawful, fair and transparent
Data collection must be fair, and we must be open and transparent as to
how the data will be used. We will communicate to individuals whose data we
capture, what we capture, how it will be used and how we will destroy this upon
their request.
Limited for its purpose
Data can only be collected for a specific purpose, we do not hold
sensitive personal data.
Data minimisation
Any data collected will be necessary and not excessive for its purpose.
Accurate
The data we hold will be accurate and kept up to date.
Retention
We will not store data longer than necessary.
Integrity and confidentiality
The data we hold will be kept safe and secure.
Data security
We will ensure data is kept secure against loss or misuse. Where other
organisations process personal data as a service on our behalf, we will
establish what, if any, additional specific data security arrangements need to
be implemented in contracts with those third party organisations.
Storing data securely
In cases when data is stored on printed paper, it will be kept in a
secure place where unauthorised personnel cannot access it.
Printed data will be shredded when it is no longer needed.
Data stored on a computer should be protected by strong passwords that
are changed regularly.
Data stored on CD's or memory sticks will be encrypted or password
protected and locked away securely when they are not being used.
Data will be regularly backed up in line with the company’s backup
procedures.
All possible technical measures will be put in place to keep data secure
Data retention
We will only retain personal data for as long is necessary. What is
necessary will depend on the circumstances of each case, taking into account
the reasons that the personal data was obtained.
Privacy Notices
We will supply a Privacy Notice when obtaining data from an individual.
Access Request
When access is requested by an individual to their own data we will give
it to them.
Rights of individuals
Individuals have rights to their data which we must respect and comply
with to the best of our ability. We will ensure individuals can exercise their
rights in the following ways:
Right to be informed
Providing privacy notices which are concise, transparent, intelligible
and easily accessible, free of charge, that are written in clear and plain
language, particularly if aimed at children.
Keeping a record of how we use personal data to demonstrate compliance
with the need for accountability and transparency.
Right of access
Enabling individuals to access their personal data and supplementary
information
Allowing individuals to be aware of and verify the lawfulness of the
processing activities
Right to rectification
We will rectify or amend the personal data of the individual if
requested because it is inaccurate or incomplete.
This will be done without delay, and no later than one month.
Right to erasure
We will delete or remove an individual’s data if requested and there is
no compelling reason for its continued processing.
Right to restrict processing
We will comply with any request to restrict, block, or otherwise
suppress the processing of personal data. We will not process this further.
Right to data portability
We will provide individuals with their data so that they can reuse it
for their own purposes or across different services.
We will provide it in a commonly used, machine-readable format.
Right to object
We respect the right of an individual to object to data processing based
on legitimate interest or the performance of a public interest task.
We respect the right of an individual to object to direct marketing,
including profiling.
We respect the right of an individual to object to processing their data
for scientific and historical research and statistics.
Individuals have the right to object to their data being used on grounds
relating to their particular situation.
Rights in relation to automated decision making and profiling
We respect the rights of individuals in relation to automated decision
making and profiling.
Individuals retain their right to object to such automated processing,
have the rationale explained to them, and request human intervention.
