Privacy

This data protection policy applies to data processing by

Controller:

COMMEO Rechtsanwälte PartGmbB,
Rechtsanwälte und Notar (hereinafter: Commeo),
Speicherstraße 55,
60327 Frankfurt,
Deutschland,
phone: +49 69 65 9990,
fax: +49 69 65 9990 199

Commeo’s operational data protection officer, Mr Christoph Weinert, is available at the above-mentioned
address or
at dataprotectionofficer@commeo-law.com.

1. Collection and storage of personal data as well as manner and purpose of their use

a) Registration for our newsletter

Given your consent according to Art. 6 para. 1 sentence 1 lit. a) GDPR, we use your e-mail address to
regularly send
you our newsletter.

You can unsubscribe from our newsletter at any time, e.g. by clicking on the link at the end of each
newsletter. You
can alternatively unsubscribe via e-mail to Commeo’s data protection officer
dataprotectionofficer@commeo-law.com.

b) When visiting the website

When visiting our website www.commeo-law.com your browser will automatically send information to our
website’s
server. This information will be stored temporarily in a so-called logfile. The following information is
collected
and stored until it is automatically deleted:

referrer (website visited before)
requested website or file
browser type and version
utilised operating system
utilised device type
time of access
IP address in anonymous form (only used to determine the place of access)

Processing of the aforementioned data is done for the following purposes:

to ensure a smooth connection to our website
to ensure a convenient use of our website
evaluation of the system’s security and stability
further administrative purposes.

The legal basis for such data processing is Art. 6 para. 1 sentence 1 lit. f) GDPR. Our legitimate interest
follows
from the purposes for data processing listed above. The data will under no circumstances be used to induce
any
information regarding your identity.

In addition, we use cookies on our website. Further information on the use of cookies is provided under
Section 3
below.

2. Transfer of Information

There is no transfer of your personal data to third parties other than for the following purposes.

We only transfer your personal data to a third party if:

You expressively agreed to the transfer according to Art. 6 para. 1 sentence 1 lit. a) GDPR,
the transfer is necessary within the meaning of Art. 6 para. 1 sentence 1 lit. f) GDPR for the purpose
of
legitimate interests pursued by the Controller or by a third party and if there is no reason to assume
that
there is an overriding interest not to transfer your data,
there is a legal obligation according to Art. 6 para. 1 sentence 1 lit. c) GDPR to transfer your data,
and
it is permitted by law and necessary in the sense of Art. 6 para. 1 sentence 1 lit. b) GDPR for the
handling of
a contractual relationship with you.

3. Cookies

We use cookies on our website. Cookies are small files automatically generated by your browser and stored by
your
device (laptop, tablet, smartphone or other) when you visit our homepage. Cookies do not damage your
computer in any
way and do not contain any viruses, trojans or any other malware.

Information stored in the cookie is specific to the device used. This does not mean, though, that we get to
know
your identity.

The use of cookies serves to make the use of our website more convenient for you, in particular by using so
called
session cookies, to assess if you have already visited one of our websites. They will be deleted
automatically when
you leave our website.

To enhance user friendliness, we also use cookies that will be stored on your device for a certain
established
period of time. When you revisit our homepage it will be automatically recognized that you have already
visited our
website and which inputs and settings you have made to prevent you from having to make them once again.

In addition, we use cookies in order to statistically assess the use of our website as well as to enhance
our
services for you (see Section 5). These cookies allow us to automatically recognize that you have visited
our
website before and will be deleted automatically after a certain period of time.

The data processed by cookies is required for the above-mentioned purposes of preserving our legitimate
interest as
well as for the legitimate interest of third parties according to Art. 6 para. 1 sentence 1 lit. f) GDPR.

Most browsers automatically accept cookies. You can, however, configure your browser in order to prevent it
from
storing cookies automatically or to require your consent before installing new cookies. However, the entire
deactivation of cookies may have the effect that you do not have access to all features of our website.

3. Plug-ins and Tools

Google Maps

This website uses the mapping service Google Maps. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer. In case Google Maps has been activated, Google has the option to use Google Fonts for the purpose of the uniform depiction of fonts. When you access Google Maps, your browser will load the required web fonts into your browser cache, to correctly display text and fonts.

We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6(1)(f) GDPR. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.

For more information on the handling of user data, please review Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

4. Rights of person affected

You have the right:

to request information according to Art. 15 GDPR about your personal data processed by us. In
particular, you
can request information about the processing purposes, the categories of processed personal data
concerned, the
category of recipients to whom the data have been or will be disclosed, the envisaged storage period,
the
existence of the right to request rectification or erasure of personal data or restriction of processing
of
personal data concerning the data subject or to object to such processing, the origin of your data in
case the
data was collected by us, as well as the existence of an automated decision-making including, if
applicable,
meaningful information about the logic involved;
according to Art. 16 GDPR to immediately request the rectification of inaccurate personal data processed
by us;
according to Art. 17 GDPR to request erasure of your personal data as far as the processing is not
required for
compliance with legal obligations, necessary for the establishment, exercise or defence of legal claims,
or for
reasons in public interest;
according to Art. 18 GDPR to request a restriction of processing of your personal data as far as the
accuracy of
the personal data is contested, the processing is unlawful and you oppose the erasure of the personal
data and
request the restriction of their use instead, or if we no longer need the personal data for the purposes
of the
processing, but they are required by you for the establishment, exercise or defence of legal claims, or
you
appeal against the processing according to Art. 21 GDPR;
according to Art. 20 GDPR to receive the personal data that you have made available to us in a
structured,
commonly used and machine-readable format, or to request us to transmit the personal data to another
controller;
according to Art. 7 para. 3 GDPR to withdraw your consent with regard to processing of your personal
data. As a
consequence, we will not continue the data processing based on that consent; and
according to Art. 77 para. 3 GDPR to lodge a complaint with a supervisory authority. In general you can
address
the supervisory authority of your habitual residence, place of work or place of the alleged infringement
or the
location of our law firm.

5. Right of objection

In case your personal data is processed on the basis of legitimate interests pursuant to Art. 6 para. 1
sentence 1
lit. f) GDPR, you have the right pursuant to Art. 21 GDPR to object to the processing of your personal data
on
grounds relating to your particular situation. If you object to processing for direct marketing purposes, we
will no
longer process your personal data for such purposes.

If you want to make use of your right to objection, it is sufficient to send an email to our data protection
officer
(dataprotectionofficer@commeo-law.com).

6. Data security

The access to our website is encrypted by using SSL protocols (Secure Socket Layer). We offer the highest
security
level supported by your browser. This is usually a 256 Bit encryption.

We use appropriate technical and organizational security measures in order to protect your data from
accidental or
deliberate manipulation, partial or complete loss, destruction or against unauthorized access by any third
person.
Our safety measures will be improved in line with the technological development.

7. Status and changes of this information of data protection

This data protection policy is currently effective as at May 2018.

Due to the development of our website and the provided services or due to a change of legal or regulatory
requirements we may be required to modify this policy. You can download and print the most recent data
protection
policy under https://www.commeo-law.com/en/datenschutz.