PRIVACY POLICY
I. Name and Address of the Controller
The responsible organization according to the EU General Data Protection Regulation, other national data protection laws of the member states as well as other data protection regulation is:
Delegation of German Industry and Commerce in Ghana (AHK Ghana)
The Octagon Building
Second Floor, Unit B207
Barnes Road, Accra Central
PMB 25 TUC Accra-Ghana
Tel.: +233-(0)-242 438 760
E-Mail: info(at)ghana.ahk.de
Website: www.ghana.ahk.de
II. Name and Address of the Data Protection Office
The data protection officer of the controller is:
Flurina Graf Ackah
The Octagon Building
Second Floor, Unit B207
Barnes Road, Accra Central
PMB 25 TUC Accra-Ghana
Tel.: +233-(0)-242 438 760
E-Mail: flurina.graf(at)ghana.ahk.de
Website: www.ghana.ahk.de
III. Name and Address of the Representative in the EU
DIHK Deutscher Industrie- und Handelskammertag e.V.
Breite Straße 29
D-10178 Berlin
Tel.: +49 (0)30 20308-0
Fax: +49 (0)30 20308-1000
E-Mail: info@dihk.de
Website: www.dihk.de
IV. General Information regarding Data Processing
1. Description and scope of data processing
In principle, we collect and use personal data of our users only to the extent it is required to provide a functioning website as well as for our content and services. The processing of personal data of our users regularly takes place with users consent. An exception applies in cases where it is not possible to obtain prior consent for factual reasons and where the processing of the data is permitted by law.
2. Legal basis for data processing
To the extent that we obtain consent from the data subject for the processing of personal data, Section 6 Subsection 1 lit. a EU General Data Protection Regulation (GDPR) serves as legal basis for the processing of personal data. For the processing of personal data required to execute a contract whose contractual party is the data subject, Section 6 Subsection 1 lit. b GDPR serves as legal basis. This also applies to processing that is required for the execution of pre-contractually measures. If such processing is required to maintain a legitimate interest of our company or a third party, and if the interests, basic rights and fundamental freedoms of the data subject do not outweigh the former interest, Section 6 Subsection 1 lit. f GDPR serves as legal basis for such processing.
3. Duration of storage
Personal data of the data subject will be deleted or blocked as soon as the purpose for storing such data no longer applies. Storage beyond such a period can be effected if such storage is prescribed by the European or national legislative body in provisions pertaining to European Union law or other provisions the data subject is subject to. Blocking or deletion of data is also effected if a storage period expires that is prescribed by the cited standards, unless there is a requirement for further storage of such data to enter into a contract or to execute a contract.
V. Providing the website and creation of logfiles
1. Description and scope of data processing
Any time our web page is visited, our system collects data and information in an automated fashion from the computer system of the accessing computer. The following data is collected in the process:
- Information regarding the browser type and the version used
- The operating system of the user
- The internet service provider of the user
- The IP address of the user
- Date and time of access
- Websites that are accessed by the system of the user via our website
2. Legal basis for the processing of data
Legal basis for the temporary storage of data and the logfiles is Section 6 Subsection 1 lit. f GDPR.
3. Purpose of data processing
The temporary storage of the IP address by the system is necessary to facilitate delivery of the website to the computer of the user. To do so, the IP address of the user must remain stored for the duration of the session. Storing of logfiles is effected to ensure the functionality of the website. In addition, such data helps us to optimize the website and to ensure the security of our information technology systems. An analysis of such data for marketing purposes will not be carried out in this context.
4. Duration of storage
The data will be deleted as soon as they are not needed any more for the purpose that they have been gathered for. When the data is gathered to provide the website, this is the case when the user leaves the website.
When the storage of the data is in logfiles this is the case latest after seven days. A longer storage is possible. In this case the IP-addresses of the user will be deleted or anonymized so that is not possible to assign them to the user anymore.
5. Option for objection and removal
Collection of data for the provisioning of the website and storing of data in logfiles is required for the operation of the web page. Consequently, the user has no possibility to object.
VI. Usage of Cookies
1. Description and Scope of Data Processing
We use cookies to make our website more user-friendly. Some elements of our web page require that the accessing browser can also be identified when the user moves from one page to the next. No personal data is collected in the process.
To do so, the following files are stored and transmitted in the cookies:
- fonts = standard cookie variable used by us to reload the fonts in the browser after a page refresh.
- fullcss = standard cookie variable used by us to reload the CSS file in the browser after a page refresh.
Maximum cookie lifetime: 730 days.
Furthermore, we use cookies on our website which enable the analysis of surfing behavior of the user. This way the following data can be transmitted:
- _ga = one-time identifier of Google Analytics to identify the user (consists of ClientID + time stamp) | standard expiration time 2 years
- _gat = parameter which makes Google Analytics to reduce the polling rate
- _gid = one-time identifier of Google Analytics to identify the user (consists of ClientID + time stamp) | standard expiration time 24 hours
The data that is collected this way is anonymized through technical precautions. Therefore, the data cannot be matched to the user anymore. When opening the website, the user will be informed by an info banner about the usage of cookies for analytical purposes and will be referred to the data protection regulation. In this context there is also the indication how the storage of cookies can be prevented by changing the browser settings. In case you wish to not be tracked, you can deactivate this function in the paragraph Google Analytics in this privacy policy (see below).
2. Legal Basis of Data Processing
Legal basis for the processing of personal data while using technically required cookies is Section 6 Subsection 1 lit. f GDPR. Legal basis for the processing of personal data while using cookies for analytical purposes is Section 6 Subsection 1 lit. a GDPR.
3. Purpose of Data Processing
The purpose of using technically required cookies is the simplification of use of websites for the users. Some functions or our web page cannot be provided without the use of cookies. For such it is necessary that the browser is also recognized when the user moves from one page to the nextWe need cookies for the following features:
- fonts = Standard cookie variable which we use to load the Fonts again after refreshing the browser.
- fullcss = Standard cookie variable which we use to load the CSS file again after refreshing the browser
Maximum lifespan of these cookies: 730 days.
User data collected via technically required cookies is not used to create user profiles.
The purpose of using analytical cookies is to improve the quality of the website and its contents. The analytical cookies tell us how the website is used and thereby we can continuedly improve our offers.
This way the following data can be transmitted:
- _gat = parameter which makes Google Analytics to reduce the polling rate
- _gid = one-time identifier of Google Analytics to identify the user (consists of ClientID + time stamp) | standard expiration time 24 hours
4. Duration of Storage,Option for Objection and Removal.
Cookies are stored by the computer of the user and then are transmitted from this computer to our end. Therefore, you as a user have the full control over the use and processing of cookies. By changing the settings in your internet browser, you can deactivate or limit the transmission of cookies. Cookies that have already been saved can be deleted again at any time. This can also be done automatically. If cookies have be deactivated for our website, it is possible that not all features of our website can be used to their full extent.
VII. Newsletter
1. Description and scope of data processing
On our web page, there is the option to subscribe to a free newsletter. When subscribing for the newsletter, the email address will be transferred to the e-mail marketing software provider commissioned by us (CleverReach GmbH & Co. KG, Mühlenstraße 43, 26180 Rastede, Germany). The following data is gathered:
- E-Mail address
- All other data collected (first name, last name, address, mobile number) is voluntary and will only be used to personalize the newsletter.
Furthermore, the following data is collected upon registration:
- Date and time of registration
For the processing of data, in line with the registration process, we obtain your consent and refer to this privacy policy. In connection with the processing of data for the sending of newsletters, except for the provider of email marketing software (CleverReach GmbH & Co. KG), data is not forwarded to third parties. The data will only be used to send out the newsletter.
2. Legal Basis for the Processing of Data
Legal basis for the processing of data after registration for the newsletter by the user is Section 6 Subsection 1 lit. a GDPR if the consent of the user is on hand. To the extent this pertains to the sending of a newsletter in line with membership to registered data of our database, legal basis is Section 6 Subsection 1 lit. b GDPR.
3. Purpose of Data Processing
Collection of the email address of the user is done to deliver the newsletter.
4. Duration of Storage
Data is deleted as soon as it is no longer required to fulfill the purpose of its collection. The email address of the user is therefore stored for as long as the newsletter subscription is active.
5. Newsletter-Tracking
To optimize our newsletter, we use personalized newsletter tracking. In this context, besides the email address, we also collect activities connected to the newsletters (click behavior). We gather this data to analyze your preferences so that we can further improve the content of our newsletter for you. The data will not be used for anything else and will not be given to any third party except CleverReach GmbH & Co. KG. The Newsletter tracking is an automated process carried out by CleverReach GmbH & Co. KG. The user can oppose the tracking at any time. However, we then will not be able to send you the newsletter anymore. Hence, your data will be deleted fully.
The data will be deleted as soon as they are not needed any more for the purpose for which they have been gathered. This means that the data of the user will be saved for the duration of the newsletter subscription.
The following data is stored:
• Open rates – who has opened the e-mail
• Click rates – which external links have been clicked on in the newsletter
• Unsubscribes – how many people have unsubscribed
• Bounces – which e-mails could not be delivered
• Geo- and email client analysis – which device (phone, tablet, …) was used to open the newsletter and distribution of openings worldwide
The user has the right at any time to be informed about the data that is stored about him and/or to request that his data is deleted. The subscription will cease once your data is deleted.
6. Option for Objection and Removal:
A newsletter subscription may be cancelled by the respective user at any time. A special link is provided in every newsletter for this purpose. Alternatively, you may also send an email to flurina.graf(at)ghana.ahk.de
VIII. Event Pre-Registration or Registration
1. Description and Scope of Data Processing
On our website is a contact form available, which can be used for electronic contact. If a user accepted this option, the data entered in the input mask will be transmitted to us and saved.
At the time of sending the message, the following data is also stored:
- Date and time of registration
- Browser used
- Operating system
For the processing of the data in the context of the sending process your consent is obtained and referred to this privacy statement.
Alternatively, contact via the provided e-mail address is possible. In this case, the user’s personal data transmitted by e-mail will be stored.
In this context, there is no disclosure of the data to third parties. The data is used exclusively for processing the conversation.
Please be advised that photographs will be taken at the event for use on our website, marketing material and in other online and social media. By entering our event, you consent to us photographing and using your image and likeness.
2. Legal Basis of Data Processing
Legal basis for the processing of data is Section 6 Subsection 1 lit. a GDPR if the consent of the user is on hand. If the registration serves the execution of a contract whose contractual party is the user, or the execution of pre-contractual measures, the additional legal basis for the processing of data is Section 6 Subsection 1 lit. b GDPR.
3. Purpose of Data Processing
A registration of the user is required for the execution of a contract with the user, or for the execution of pre-contractual measures.
4. Duration of Storage
Data is deleted as soon as it is no longer required to fulfill the purpose of its collection. This is the case for data collected during the registration process for the execution of a contract or for the execution of pre-contractual measures if such data is no longer required for the execution of the contract. Even after having entered into a contract, the requirement to store personal data of the contractual partner may remain in existence to fulfill contractual or statutory requirements.
5. Option for Objection and Removal
As user, you have at any time the option to cancel the registration. Your stored personal data can be amended at any time. To amend or delete your data, please contact flurina.graf(at)ghana.ahk.de.
If the data is required for the execution of a contract or the execution of pre-contractual measures, a premature deletion of such data is only possible to the extent that contractual or statutory requirements do not preclude deletion.
IX. Premier Partner Registration
1. Description and scope of data processing
Registration for premier partner membership is done by contact via email. In this case, the user’s personal data transmitted by e-mail will be stored. Data will not be shared with any third parties. The data is used exclusively for processing the conversation.
2. Legal Basis of Data Processing
Legal basis for the processing of data is Section 6 Subsection 1 lit. b GDPR since data processing serves the execution of a contract whose contractual party is the user, or the execution of pre-contractual measures.
3. Purpose of Data Processing
A registration of the user is required for the execution of a contract with the user, or for the execution of pre-contractual measures. The stored data will be used for managing our member database, for our own marketing, for sending our newsletter, for invitations to events and other membership services. Limited data of premier partners are published on our website. Stored data will not be shared with third parties.
4. Duration of storage
Data is deleted as soon as it is no longer required to fulfill the purpose of its collection. This is the case for data collected during the registration process for the execution of a contract or for the execution of pre-contractual measures if such data is no longer required for the execution of the contract. Even after having entered into a contract, the requirement to store personal data of the contractual partner may remain in existence to fulfill contractual or statutory requirements.
5. Option for objection and removal
As user, you have at any time the option to cancel the registration. Your stored personal data can be amended at any time. To amend or delete your data, please contact flurina.graf(at)ghana.ahk.de.
If the data is required for the execution of a contract or the execution of pre-contractual measures, a premature deletion of such data is only possible to the extent that contractual or statutory requirements do not preclude deletion.
X. Email Contact
1. Description and extent of data processing
On our website is a contact form available, which can be used for electronic contact. If a user accepted this option, the data entered in the input mask will be transmitted to us and saved.
At the time of sending the message, the following data is also stored:
- Date and time of registration
- Browser used
- Operating system
For the processing of the data in the context of the sending process your consent is obtained and referred to this privacy policy. Alternatively, contact via the provided e-mail address is possible. In this case, the user’s personal data transmitted by e-mail will be stored. Data will not be shared with any third parties. The data is used exclusively for processing the conversation.
2. Legal basis of data processing
Legal basis for the processing of the data is in the presence of the consent of the user Article 6 (1) lit. a of the GDPR. The legal basis for the processing of the data transmitted while sending an e-mail is Article 6 (1) lit. f of the GDPR. If the e-mail contact aims to conclude a contract, then additional legal basis for the processing is Article 6 (1) lit. b of the GDPR.
3. Purpose of data processing
If contact is established via email, our required legitimate interest is also in the processing of such data. Other personal data processed during the sending process only serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
4. Duration of storage
Data is deleted as soon as it is no longer required to fulfill the purpose of its collection. This is the case for personal data sent via email if the respective conversation with the user is finished. The conversation is finished if it can be deduced from the circumstances that the respective matter is clarified in a concluding fashion.
5. Option for objection and removal
The user has the option to revoke his consent for the processing of personal data. If the user contacts us via email, he may object at any time to the storing of his personal data. In such a case, the conversation cannot be continued. You may send your revocation of consent and objection to storage in writing via email to flurina.graf(at)ghana.ahk.de. All personal data stored in the process of establishing contact will be deleted in such a case.
XI. Transfer of personal data to third parties
1. Website Operators
In line with processing, personal data is forwarded to the agency commissioned to run the website as well as to the technical service provider. The processing of personal data is governed by a separate agreement with the service provider.
2. Newsletter
In line with processing, personal data is forwarded to the email marketing software provider CleverReach GmbH & Co. KG. The processing of personal data is governed by a separate agreement with the service provider
3. Event Pre-registration or Registration
Data is not forwarded to third parties. If an event is organized together with other organizers, data will be shared with the other organizers only if stated explicitly on the registration form.
4. Social Media Sharing Button
- General Note
Social media plugins usually cause every visitor of a page to be immediately tracked by these services with their IP address and their other browsing behavior logged. This can be done even if you do not press the button. To prevent this, we use the Shariff method. In doing so, the direct contact between the social network and you will not be established by our social media buttons until you click on the respective share button. If you are already logged in to a social network, this will be done on Facebook and Google+ without another window. On Twitter, a pop-up window appears where you can still edit the tweets text. You can publish our content on social networks without them being able to create complete surf profiles.
From the then possible collection and use of your data by Facebook, we have no knowledge and no influence. For more information, please refer to the privacy policy of Facebook http: //de-de.facebook.com/policy.php. In addition, we refer you to the general handling and deactivation of cookies on our general presentation in this data protection regulation.
- YouTube Videos
We have occasionally included YouTube videos on our website, which are stored on the servers of the provider YouTube and are playable from our website via an embedding. Embedding the videos is done with the advanced privacy option enabled. When you play these videos, your computer will store YouTube cookies and DoubleClick cookies and may transfer data to YouTube Inc., Amphitheater Parkway, Mountain View, CA 94043, as the YouTube operator.
When playing videos stored on YouTube, at least the following information will be transmitted to Google Inc. as the YouTube operator and operator of the DoubleClick network as of today: IP address and cookie ID, the specific address of the page we visited, system date and time the call, identifier of your browser.
Whether you have a Google Account on which you are logged in or whether you do not have a user account, the transfer of this information occurs. If you are signed in, Google may directly associate this information with your account. If you do not want to be assigned to your profile, you must log out before activating the play button for the video.
YouTube or Google Inc. store these data as usage profiles and may use them for purposes of advertising, market research and/or custom design of their websites. Such an evaluation is done (even for non-registered users) to provide needs-based advertising and to inform other users about your activities on our website. You have a right to object to the formation of these user profiles, and you must be directed to Google as the operator of YouTube to exercise it.
- Google Maps
This website uses the Google Maps software provided by Google Inc. By using this site, you consent to the collection, processing and use by Google and its agents of any automated data collected (https://www.google.com/help/terms_maps/). Further information on the purpose and extent of the data collection and its processing by Google can be found on [maps.google.com].
- Website Analysis with Google Analytics
This website uses the “Google Analytics” service provided by Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA) to analyze users’ website usage. The service uses “cookies” – text files stored on your device. The information collected by the cookies is usually sent to a Google server in the US and stored there.
On this website IP anonymization is undertaken. The IP address of users is shortened within the member states of the EU and the European Economic Area. This reduction eliminates the personal reference of your IP address. Under the terms of the agreement, which website operators have entered into with Google Inc., they use the information collected to compile an evaluation of website activity and site activity and provide Internet-related services.
You have the option to prevent the storage of cookies on your device by making the appropriate settings in your browser. There is no guarantee that you will be able to access all features of this website without restriction if your browser does not allow cookies.
Furthermore, you can use a browser plug-in to prevent the information collected by cookies (including your IP address) from being sent to Google Inc. and used by Google Inc. View the plugin [www.analytics.google.com] You can prevent the collection by Google Analytics by clicking on the following link. An opt-out cookie will be set which prevents the future collection of your data when visiting this website:
More information on Google Inc’s data usage can be found here: [www.analytics.google.com/]
XII. Rights of the Data Subject
Under the EU Data Protection Regulation, you have the following rights:
- If your personal data are processed, you have the right to obtain information about the data stored about you (Article 15 GDPR).
- If incorrect personal data are processed, you are entitled to a correction (Article 16 GDPR).
- If the legal prerequisites exist, you can request the deletion or limitation of the processing and appeal against the processing (Articles 17, 18 and 21 GDPR).
- If you have consented to the data processing or a data-processing contract and the data processing is carried out using automated procedures, you may be entitled to data transferability (Article 20 GDPR).
- If you make use of your rights mentioned above, the Delegation of the German Industry and Commerce in Ghana will check whether the legal requirements are fulfilled.
For data protection complaints, you can contact the responsible supervisory authority:
- Data Protection Commission, Pawpaw Street, East Legon, P.O.Box CT 7195, Accra, Ghana, Tel. +233 302 222 929, info(at)dataprotection.org.gh.
- Berliner Beauftragte für Datenschutz und Informationsfreiheit, Friedrichstr. 219, 10969 Berlin, Germany, Tel. +49 30 13889 0, mailbox@datenschutz-berlin.de.