We are pleased that you would like to use the Wingfield Tracking System. Since the protection of your personal data is particularly important to us, we will inform you in detail below about the data processing that takes place in connection with the use of our Wingfield mobile app and the Wingfield Box located on the court, which you use as part of the Wingfield Tracking System. As a company under private law, we are subject to the provisions of the European General Data Protection Regulation (GDPR), the German Federal Data Protection Act (BDSG), and the German Act on Data Protection and the Protection of Privacy in Telecommunications and Digital Services (TDDDG). We have taken technical and organizational measures to ensure that the regulations on data protection are observed both by us and by our external service providers. We would like to inform you about our implementation of these requirements below.
1. Definitions
The legislator requires that personal data be processed in a lawful manner, in good faith and in a way that is comprehensible to the data subject ("lawfulness, processing in good faith, transparency"). To ensure this, we will first inform you in this section about the individual legal definitions that are also used in this privacy policy:
1.1. 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.
1.2. Processing
"Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
1.3. Restriction of processing
"Restriction of processing" means the marking of stored personal data with the aim of limiting their future processing.
1.4. Profiling
"Profiling" means any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person's job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
1.5. Pseudonymization
"Pseudonymization" means 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 organizational measures which ensure that the personal data cannot be attributed to an identified or identifiable natural person.
1.6. File system
"File system" means any structured collection of personal data accessible according to specified criteria, whether such collection is maintained on a centralized, decentralized, or functional or geographic basis.
1.7. Controller
"Controller" means a 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 by Union or Member State law.
1.8. Processor
"Processor" means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the Controller.
1.9. Recipient
"Recipient" means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients; the processing of such data by the aforementioned authorities shall be carried out in accordance with the applicable data protection rules in accordance with the purposes of the processing.
1.10. 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 authorized to process the personal data under the direct responsibility of the controller or the processor.
1.11. Consent
A "Consent" of the data subject means any freely given specific, informed and unambiguous indication of his or her 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.
2. Lawfulness of processing
The processing of personal data is only lawful if there is a legal basis for the processing. The legal basis for the processing may be, in accordance with Art. 6 para. 1 sentence 1 letters a) to f) DSGVO, in particular:
The data subject has given his/her consent to the processing of personal data concerning him/her for one or more specific purposes;
the processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the data subject's request;
the processing is necessary for compliance with a legal obligation to which the controller is subject;
the processing is necessary in order to protect the vital interests of the data subject or another natural person;
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;
the processing is necessary for the purposes of the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
3. Wingfield-App
In this section, we inform you about what data we collect from you when you use the Wingfield app.
3.1. App-Stores
You can find our app for Android in the Google Play Store and for iOS in the Apple App Store. When you download the Wingfield app, information is transferred to the App Store on the basis of the agreement concluded with the provider, i.e. in particular the user name, e-mail address and customer number of your account, time of download, payment information and the individual device identification number.
3.2. Log files
When using the Wingfield App, we collect the following data in so-called log files, which are technically necessary for us to offer you the functions of our mobile app and to ensure the stability and security of the app:
IP address
Date and time of the request
Time zone difference from Greenwich Mean Time (GMT)
Content of the request (concrete page)
Access status/HTTP status code
Amount of data transferred in each case
Operating system and its interface
Location data
IMEI = International Mobile Equipment Identity
Name of your mobile device
IMSI = International Mobile Subscriber Identity
MAC address for WLAN use
This data is not merged with other data sources. The server log files are stored for a maximum of 14 days and then automatically deleted. The legal basis for the processing of the log files is Art. 6 para. 1 p. 1 letter f) DSGVO (processing is for the protection of the legitimate interests of the controller). We have a legitimate interest in ensuring the functioning, stability and security of our app by storing log files.
3.3. Registration
If you want to use the Wingfield App as a player or coach, you need to create a user account. As part of the registration process, we collect the following personal data from you:
Your email address
Your first and last name
Your date of birth
Your gender
Your country
Your sports
Your playing hand (right, left or both) and the way you play the backhand (one-handed or two-handed)
We process this data in order to distinguish you from other users and to enable you to use our app and the associated products. On a voluntary basis, you can add the following information to your player profile:
The Wingfield Court near you
The club you are a member of
Your trainer
Your highest level of play
Your height
Your weight
Your fitness level
Your playing partner
Your profile picture
establish your connection with the German Tennis Federation
3.4. Wingfield Pro
3.5. On-Demand-Matches
On the Wingfield Courts you can start so-called On-Demand-Matches. An on-demand match is an official match whose result is recognized by the German Tennis Federation ("DTB") and has a corresponding influence on your ranking points. In order to play on-demand matches, you must first verify your data. We will ask you for your DTB ID or your mybigpoint account as part of the verification process. We then transfer the following data to NU Datenautomaten GmbH, Rathausstraße 2, 6900 Bregenz, Austria (hereinafter referred to as "NU"):
Your first and last name
Your date of birth
Your DTB ID
If you have completed an on-demand match, we will transfer the following data to NU:
Your first and last name
Your DTB ID
The location of the match (geographic location and operator association)
NU operates the official ranking database of the DTB and the state tennis associations on behalf of the DTB. The aforementioned data is therefore needed to identify you as a ranked player and to include the match result in your ranking score. NU will not use the data for any other purpose. The legal basis for the collection and disclosure of the data to NU is Art. 6 para. 1 p. 1 letter b) DSGVO (processing for the performance of a contract).
3.6. Linking coach accounts
As a player you have the possibility to link your account with the account of your coach. In this case, your coach will receive the following information about you via the Wingfield app:
Your match stats
Your training statistics
The video data of the recorded matches (full length)
Your profile picture and first name
3.7. Performance class league
Optionally, you have the possibility to play in a performance class league (LK league) by registering in the corresponding league list. As soon as enough players in a similar performance class (+/-4) and age have registered, further steps can be taken to organize the LK matches. The players can network with each other using contact requests. If the contact request is accepted, players can continue to communicate outside of the app as they wish.
In the future, we might offer an app-internal chat function that players can use to communicate with each other.
3.8. Google Analytics for Firebase
The Wingfield App uses the service "Google Analytics for Firebase" an analytics service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). This application uses mobile device identifiers (including Android Advertising ID and Advertising Identifier for iOS, respectively) and cookie-like technologies to run the Google Analytics for Firebase service. Analyzing how our app is used helps us understand which parts of our app are used and how. This enables us to constantly improve our app and its functions and adapt them to changing user behavior.
The information generated by the service about your use of our app is usually transmitted to a Google server in the USA and stored there. However, we use Google Analytics for Firebase with the IP anonymization extension so that your IP address is truncated by Google within member states of the European Union or other states party to the Agreement on the European Economic Area before it is sent to servers in the USA.
However, in exceptional cases, the full IP address may be transmitted to a Google server in the USA and only shortened there. We will also ask for your express consent in this regard. No data collected by cookies will be transferred to the USA without your express consent. You can also opt out of certain Firebase features at any time using the appropriate device settings on mobile devices, such as the advertising settings for mobile devices.
The legal basis for the processing is Art. 6 para. 1 sentence 1 letter a) GDPR (consent) in conjunction with Section 25 para. 1 TDDDG. The transfer of data to the USA is based on the adequacy decision of the European Commission of 10.07.2023. In accordance with Art. 45 GDPR, the European Commission can determine by adequacy decision that a level of data protection equivalent to that of the EU prevails in a country outside the European Union. For the USA, the European Commission has stipulated that companies based there must also be certified under the Trans-Atlantic Data Privacy Framework (“TADPF”). Through certification, the companies concerned undertake to comply with certain regulations stipulated by the TADPF, which ensure an appropriate level of data protection. Google is also certified under the TADPF.
You can find more information on data protection in connection with Google Analytics here: https://support.google.com/analytics/answer/6004245?hl =en#zippy=
3.9. Google Sign-In
Our app uses the "Google Sign-In" service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). This service enables our users to use the convenient single sign-on procedure. Users can log in to the Wingfield App using their Google login information without having to register. When you use Google login, we receive the following information from Google:
Your email address
Your first and last name
Your date of birth
In this case, Google receives information about how you use our app. As it cannot be ruled out that personal data will be transferred to Google servers located in the USA, we also ask for your express consent to your personal data being transferred to the USA. The legal basis for the processing is Art. 6 para. 1 sentence 1 letter a) GDPR in conjunction with § 25 para. 1 TDDDG. The transfer of data to the USA is based on the adequacy decision of the European Commission of 10.07.2023. In accordance with Art. 45 GDPR, the European Commission can determine by adequacy decision that a level of data protection equivalent to that of the EU prevails in a country outside the European Union. For the USA, the European Commission has stipulated that companies based there must also be certified under the Trans-Atlantic Data Privacy Framework (“TADPF”). Through certification, the companies concerned undertake to comply with certain regulations stipulated by the TADPF, which ensure an appropriate level of data protection. Google is also certified under the TADPF.. You can remove the link to the Wingfield app at any time in Google's settings. Please note that in this case you will have to register again in the Wingfield App. For more information on data protection at Google, please visit: https://policies.google.com/privacy
3.10. Facebook Connect
Our app also uses the Meta Platforms Inc. 1601 Willow Rd, Menlo Park, CA 94025 („Meta“). . This service enables our users to use the convenient single sign-on procedure. Users can log in to the Wingfield App with their Facebook login data without having to register.
When you use the Facebook login, we receive the following information from Facebook:
Your email address
Your first and last name
Your date of birth
In this case,Meta receives information about how you use our app. This information may also be transferred to servers in the U.S.A. The legal basis for the processing is Art. 6 para. 1 sentence 1 letter a) GDPR in conjunction with Section 25 para. 1 TDDDG. For the USA, there is an adequacy decision of the European Commission pursuant to Art. 49 para. 1 sentence 1 letter a) GDPR, which refers to the US-EU Data Privacy Framework pursuant to Art. 49 para. 1 sentence 1 letter a) GDPR in connection with the US-EU Data Privacy Framework (“TADPF”). Meta is certified under the TADPF. You can revoke this consent at any time by removing the link to the Wingfield App inside your facebook settings. In order to do this navigate to Menu > Settings > Apps & Website. Please note that in this case you will have to register again in the Wingfield app. For more information on data protection at Facebook, please visit: https://www.facebook.com/about/privacy
3.11. Apple Single-Sign-On
Our App continues to use the single sign-on service provided by Apple Inc, Infinite Loop, Cupertino, CA 95014, USA ("Apple"). Users can log in to the Wingfield App using their Apple login details without having to register.
When you use the Apple login, we receive the following information from Apple:
Your email address
Your first and last name
Your date of birth
In this case, Apple receives information about how you use our app. This information may also be transferred to servers in the USA. The legal basis for the processing is Art. 6 para. 1 sentence 1 letter a) GDPR in conjunction with Section 25 para. 1 TDDDG. The transfer of data to the USA is based on the European Commission's adequacy decision of 10.07.2023. According to Art. 45 GDPR, the European Commission can determine by adequacy decision that a level of data protection equivalent to that of the EU prevails in a country outside the European Union. For the USA, the European Commission has stipulated that companies based there must also be certified under the Trans-Atlantic Data Privacy Framework (“TADPF”). Through certification, the companies concerned undertake to comply with certain regulations specified by the TADPF, which ensure an appropriate level of data protection. Apple is also certified under the TADPF. You can remove the link to the Wingfield app at any time in Apple's settings. Please note that in this case you will have to register again in the Wingfield App. For more information on data protection at Apple, please visit: https://www.apple.com/legal/privacy/de-ww/
3.12. YouTube
We use YouTube as a plug-in. We give you the option of using the button to communicate directly with the provider of the Google plug-in so that you are redirected to our YouTube channel. When you click on the plug-in for the first time, a banner appears stating that if you click again, your personal data will be collected by other trackers and transmitted to Google. This is the so-called two-click solution. Only if you click on the marked field again, thereby activating it, will the plug-in provider Google receive the information that you have accessed the corresponding website of our online offering. This data is stored by Google after transmission. The legal basis for the processing is Art. 6 para. 1 sentence 1 letter a) GDPR in conjunction with § 25 para. 1 TTDSG. For the USA, there is an adequacy decision of the European Commission pursuant to Art. 49 para. 1 sentence 1 letter a) GDPR, which refers to the US-EU Data Privacy Framework pursuant to Art. 49 para. 1 sentence 1 letter a) GDPR in connection with the US-EU Data Privacy Framework (“TADPF”). Google LLC is certified under the TADPF.
The Google address is the URL to their privacy policy:
Youtube: Google Inc, 1600 Amphitheater Parkway, Mountainview, California 94043, USA; https://www.google.com/policies/privacy/partners/?hl=de.[PK1].
3.13. LinkedIn
We use LinkedIn as a plug-in. We give you the option of using the button to communicate directly with the provider of the LinkedIn plug-in so that you are redirected to our official LinkedIn page. When you click on the plug-in for the first time, a banner appears with the content that if you click again, your personal data will be collected by other trackers and transmitted to LinkedIn. This is the so-called two-click solution. Only if you click on the highlighted field again, thereby activating it, will the plug-in provider LinkedIn receive the information that you have accessed the corresponding website of our online offering. This data is stored by LinkedIn after transmission. The legal basis for the processing is Art. 6 para. 1 sentence 1 letter a) GDPR in conjunction with § 25 para. 1 TTDSG. For the USA, there is an adequacy decision of the European Commission pursuant to Art. 49 para. 1 sentence 1 letter a) GDPR, which refers to the US-EU Data Privacy Framework pursuant to Art. 49 para. 1 sentence 1 letter a) GDPR in connection with the US-EU Data Privacy Framework (“TADPF”). Google LLC is certified under the TADPF[PK2].
The address of LinkedIn the URL to their privacy policy:
LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland
Privacy policy: https://www.linkedin.com/legal/privacy-policy
Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
3.14. Facebook
We use Facebook as a plug-in. We give you the opportunity to communicate directly with the provider of the Meta plug-in via the button so that you are redirected to our official Facebook page. When you click on the plug-in for the first time, a banner appears stating that if you click again, your personal data will be collected by other trackers and transmitted to Meta. This is the so-called two-click solution. Only if you click on the highlighted field again, thereby activating it, will the plug-in provider Meta receive the information that you have accessed our Facebook page. This data is stored by Meta after transmission. The legal basis for the processing is Art. 6 para. 1 sentence 1 letter a) GDPR in conjunction with § 25 para. 1 TTDSG. For the USA, there is an adequacy decision of the European Commission pursuant to Art. 49 para. 1 sentence 1 letter a) GDPR, which refers to the US-EU Data Privacy Framework pursuant to Art. 49 para. 1 sentence 1 letter a) GDPR in connection with the US-EU Data Privacy Framework (“TADPF”). Meta is certified under the TADPF.
Meta's address is the URL to their privacy policy:
Meta Platforms, Inc, Willow Road 1601 94025 Menlo Park, CA, USA
https://de-de.facebook.com/privacy/policy/
3.15. Storage duration
Information that you provide during registration and other (voluntary) information that you provide us in your account, we will store as long as you maintain your account with us. You can delete your account at any time. Simply send us an e-mail to app@my-wingfield.com. Your personal data will then be deleted within the statutory period.
If you have collected session data (especially video) together with other playing partners registered at Wingfield, please inform us explicitly by e-mail after deleting your account, stating your Wingfield email address, that all videos associated with this account should be deleted. Thus, your playing partners will no longer have access to the video data. Otherwise, the video data will remain accessible to your playing partners.
If you maintain a Pro Account (see Section 3.4), we will store the aforementioned data for at least the term of your Pro Subscription and beyond, as long as you maintain an account with us. If you delete your account, we will thereafter only store certain data regarding which we have legal (in particular tax law) retention obligations.
4. Wingfield-Box
In this section, we inform you about what data we collect when you use the Wingfield Box.
4.1. Video recording
Our product offers you a detailed game analysis using smart cameras. Naturally, video images of the playing persons are recorded.
4.1.1 Registered users
When you register, we will ask for your consent to record video of you for match analysis with Wingfield Tracking System. The recording starts only when a match is started at the Wingfield box. The recording ends as soon as the match is finished by a player or automatically after five hours at the latest. The raw video data is only manually reviewed by us to improve our product and for troubleshooting. The creation of your game statistics is fully automated. If you have completed an on-demand match (see section 3.5), we will manually review the raw video data once to ensure that the match was held according to the rules and that the result is valid. If we discover irregularities or have doubts about the compliance of the match, we will create a match report and send it together with the video raw data to the German Tennis Federation e.V., Hallerstr. 89, 20149 Hamburg ("DTB"), so that the DTB can finally decide whether the match will be evaluated. The legal basis for the data processing is Art. 6 para. 1 sentence 1 letter a) DSGVO (consent of the data subject) in conjunction with Section 25 (1) TDDDG and Art. 6 para. 1 sentence 1 letter b) DSGVO (processing for the performance of a contract).
4.1.2 Alignment of the cameras
The cameras are oriented so that only the court itself and the area immediately behind it are filmed. The area behind the court is so far away from the cameras that people in this area are usually not identifiable. The courts where our product is used are marked accordingly with signs, so it is your free decision whether to enter the recording area or not.
4.2. Analysis data
When you use the Wingfield Box in conjunction with the Wingfield App, we regularly process the following personal data: Statistics of your games (e.g., number of aces, service errors, double faults, forehand and backhand winners or faults, and break points won) and account data (username and email address). We store this data for as long as you maintain an account with us. The legal basis for the data processing is Art. 6 para. 1 p. 1 letter b) DSGVO (processing for the performance of a contract).
4.3. Storage duration
We store the recorded videos and the analysis data generated from the analysis of this video data about your game for as long as you maintain your account with us. In addition, we only keep raw video data if you played an on-demand match in the last six months before closing your account, as we are obliged by the DTB to keep this data for six months for security reasons. You can delete your account at any time by sending us your deletion request by e-mail to app@my-wingfield.com.
4.4. Live broadcasting of matches
We offer the option of broadcasting matches live on YouTube via our Wingfield boxes. Participating court operators can create a streaming key using our internal software solution. This streaming key is necessary so that the live stream can be established on YouTube via the Wingfield box. After entering this key in the Wingfield box, the live stream can take place on the court operator's YouTube channel. The legal basis for data processing is Art. 6 para. 1 sentence 1 letter a) GDPR (consent of the data subject) in conjunction with § 25 para. 1 TDDDG and Art. 6 para. 1 sentence 1 letter b) GDPR (processing for the performance of a contract). The relevant agreements and consents are obtained from the participating courts. They will also provide you with further information on the processing of your data in the course of the specific use of Wingfield Box.
5. General inquiries
If you contact us by mail, e-mail, contact form, telephone or fax, your request including all resulting personal data will be stored and processed by us for the purpose of processing your request.
The processing of this data is based on Art. 6 para. 1 p. 1 letter b) DSGVO, if your request is related to the performance of a contract concluded with us or is necessary for the implementation of pre-contractual measures. Otherwise, the processing is based on Art. 6 para. 1 p. 1 lit. f) DSGVO, as we have a legitimate interest in the effective processing of requests addressed to us. In addition, we may also be entitled under Art. 6 para. 1 p. 1 lit. c) DSGVO, as we are legally obliged to enable fast electronic contact and direct communication with us. Of course, your data will initially be used strictly for the purpose of processing and responding to your inquiry, will not be disclosed to third parties without your consent, and will be deleted after final processing unless we are under a legal obligation to retain data.
6. Processor
As a matter of principle, we do not pass on your data to third parties without your express consent. However, we work - like any modern company - with processors to provide you with an uninterrupted and best possible service. When we work together with external service providers, order processing regularly takes place on the basis of Art. 28 DSGVO. For this purpose, we conclude appropriate agreements with our partners to ensure the protection of your data. We use only carefully selected processors for the processing of your data. They are bound by our instructions and are regularly monitored by us. We only use external service providers who have ensured that all data processing operations are carried out in accordance with data protection regulations. When we work with external service providers, commissioned processing regularly takes place on the basis of Art. 28 DSGVO. For this purpose, we conclude appropriate agreements with our partners to ensure the protection of your data. We use only carefully selected processors for the processing of your data. They are bound by our instructions and are regularly monitored by us. We only use external service providers who have ensured that all data processing operations are carried out in accordance with data protection regulations.
Marketing service provider
Cloud & Hosting Service Provider
Database service provider
Mailing service provider
7. Kids & Teens
Our offer is generally directed at adults. Persons under the age of 18 may not transmit any personal data to us without the consent of their parents or legal guardians.
8. Provisioning obligation and profiling
There is no legal obligation to provide us with personal data. Automated decision-making in the sense of Art. 22 DSGVO does not take place.
9. Your rights
In this section, we inform you about your rights regarding your personal data.
9.1. Revocation of consent
If the processing of personal data is based on a granted consent, you have the right to revoke the consent at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of consent until revocation.
9.2. Right to confirmation
You have the right to request confirmation from us as to whether we are processing personal data relating to you. You can request confirmation at any time using the contact details above.
9.3. Right to information
If personal data is processed, you can request information about this personal data and about the following information at any time:
If personal data is transferred to a third country or to an international organization, you have the right to be informed about the appropriate safeguards pursuant to Art. 46 DSGVO in connection with the transfer. We will provide a copy of the personal data that is the subject of the processing. For any additional copies you request, we may charge a reasonable fee based on administrative costs. If you make the request electronically, the information shall be provided in a commonly used electronic format unless you specify otherwise. The right to receive a copy under subsection 3 may not interfere with the rights and freedoms of others.
9.4. Right to rectification
You have the right to request that we correct any inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data - also by means of a supplementary declaration.
9.5. Right to deletion („Right to be forgotten“)
You have the right to request that we delete personal data concerning you without undue delay, and we are obliged to delete personal data without undue delay if one of the following reasons applies:
The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
You revoke your consent on which the processing is based pursuant to Art. 6(1)(a) or Art. 9(2)(a) DSGVO and there is no other legal basis for the processing.
You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the You object 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 we are subject.
The personal data was collected in relation to information society services offered pursuant to Art. 8 (1) DSGVO.
If we have made personal data public and we are obliged to erase it on one of the above grounds, we are obliged, taking into account the available technology and the costs of implementation, to take reasonable steps, including technical measures, to inform data controllers that process the personal data that a data subject has requested that they erase all links to or copies or replications of that personal data. The right to erasure ("right to be forgotten") does not exist to the extent that the processing is necessary:
to exercise the right to freedom of expression and information
for compliance with a legal obligation which requires processing under Union or Member State law to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
for reasons of public interest in the area of public health pursuant to Article 9(2)(h) and (i) and Article 9(3) of the GDPR;
for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, insofar as the right referred to in paragraph 1 is likely to render impossible or seriously prejudice the achievement of the purposes of such processing, or
for the assertion, exercise or defense of legal claims.
9.6. Right to restriction of processing
You have the right to request that we restrict the processing of your personal data if one of the following conditions is met:
the accuracy of the personal data is disputed by you for a period of time that allows us to verify the accuracy of the personal data,
the processing is unlawful and you refuse the erasure of the personal data and request the restriction of the use of the personal data instead;
we no longer need the personal data for the purposes of processing, but you need it for the assertion, exercise or defense of legal claims, or
you have objected to the processing pursuant to Art. 21 (1) DSGVO, as long as it has not yet been determined whether the legitimate grounds on which we rely outweigh your legitimate interests.
Where processing has been restricted in accordance with the above conditions, such personal data shall - apart from being stored - only be processed with the consent of the data subject or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of substantial public interest of the Union or a Member State.
9.7. Right to data portability
You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, and you have the right to transfer this data to another controller without hindrance from the controller to whom the personal data was provided, provided that:
the processing is based on consent pursuant to Art. 6(1)(a) or Art. 9(2)(a) or on a contract pursuant to Art. 6(1)(b) DSGVO and
the processing is carried out with the help of automated procedures.
When exercising the right to data portability pursuant to paragraph 1, you have the right to have the personal data transferred directly from one controller to another controller insofar as this is technically feasible. The exercise of the right to data portability does not affect the right to erasure ("right to be forgotten"). This right does not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
9.8. Right of objection
Pursuant to Art. 21 DSGVO, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you, which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. We will no longer process the personal data unless we can demonstrate compelling, legitimate grounds for the processing that override your interests, rights, and freedoms or the processing serves the purpose of asserting, exercising, or defending legal claims.
If personal data is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing. If you object to the processing for direct marketing purposes, the personal data will no longer be processed for these purposes.
In connection with the use of information society services, notwithstanding Directive 2002/58/EC, you may exercise your right to object by means of automated procedures using technical specifications. You have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1), unless the processing is necessary for the performance of a task carried out in the public interest.
9.9. Right to complain to a supervisory authority
You also have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
10. Responsible in the sense of the data protection regulations is:
Responsible in the sense of the data protection regulations is:
Wingfield International Limited
55 Loudoun Road St John's Wood, London, United Kingdom, NW8 0DL
If you have any questions about data protection or would like to exercise any of the above rights, please email us at info@my-wingfield.com. We will process your request as quickly as possible.
11. Changes
Due to the rapid development of the Internet and data protection law, we expressly reserve the right to make changes to this data protection declaration.
Last update of the privacy policy:
25.07.2024
Bleib am Ball
Abonniere den Newsletter und bleib immer auf dem Laufenden!