Privacy Policy
1. Privacy at a glance
General information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. For detailed information on the subject of data protection, please refer to our privacy policy listed below.
Data collection on this website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. You can find the operator's contact details in the section "Information about the responsible party" in this privacy policy.
How do we collect your data?
Your data is collected in part by you providing it to us. This may be data that you enter in an email, for example. Other data is collected automatically or with your consent by our IT systems when you visit the website. This is primarily technical data (e.g., internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Part of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders, or other order inquiries.
What rights do you have regarding your data?
You have the right to receive information about the origin, recipient, and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
You can contact us at any time regarding this and other questions on the subject of data protection.
2. General information and mandatory disclosures
Data protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.
We would like to point out that data transmission over the Internet (e.g., when communicating by email) may have security gaps. Complete protection of data against access by third parties is not possible.
Information about the responsible party
The responsible party for data processing on this website is:
Fortem Advisory
Dennis Stahlhut
Holsen 7a, 59075 Hamm
Phone: +49 2381 877 8947
Email: info@fortem-advisory.com
The responsible party is the natural or legal person who alone or jointly with others determines the purposes and means of processing personal data (e.g., names, email addresses, etc.).
Storage duration
Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, deletion will take place after these reasons no longer apply.
Specific retention periods: Server log files are deleted after 72 hours. Contact form data (Formspree) is automatically deleted after 60 days on Formspree's servers. Data forwarded to us via email is deleted after your request has been fully processed, unless statutory retention obligations apply (up to 6 years for commercial correspondence under Section 257 HGB, up to 10 years for tax-relevant data under Section 147 AO).
General information on the legal basis for data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, if special categories of data are processed according to Art. 9(1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your end device (e.g., via device fingerprinting), data processing is additionally carried out on the basis of Section 25(1) TDDDG. Consent can be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.
Recipients of personal data
In the course of our business activities, we work with various external parties. In some cases, the transfer of personal data to these external parties is necessary. We only pass on personal data to external parties if this is necessary for the performance of a contract, if we are legally obligated to do so (e.g., passing on data to tax authorities), if we have a legitimate interest pursuant to Art. 6(1)(f) GDPR in the transfer, or if another legal basis permits the data transfer. When using processors, we only pass on our customers' personal data on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.
Revocation of your consent to data processing
Many data processing operations are only possible with your express consent. You can revoke consent that has already been given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Right to object to data collection in special cases and to direct advertising (Art. 21 GDPR)
IF DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR THE PURPOSE OF SUCH ADVERTISING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT ADVERTISING (OBJECTION PURSUANT TO ART. 21(2) GDPR).
Right to lodge a complaint with the competent supervisory authority
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work, or the place of the alleged violation. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.
The supervisory authority responsible for us is:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW)
Kavalleriestr. 2-4
40213 Düsseldorf, Germany
Website: https://www.ldi.nrw.de
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of data to another controller, this will only be done insofar as it is technically feasible.
Information, correction and deletion
Within the framework of the applicable legal provisions, you have the right to free information about your stored personal data, its origin and recipients, and the purpose of data processing, and, if applicable, a right to correction or deletion of this data at any time. You can contact us at any time regarding this and other questions on the subject of personal data.
Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:
- If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
- If the processing of your personal data was/is carried out unlawfully, you can request the restriction of data processing instead of deletion.
- If we no longer need your personal data, but you need it for the exercise, defense, or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
- If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data may only be processed, apart from being stored, with your consent or for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.
SSL/TLS encryption
This site uses SSL/TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.
When SSL/TLS encryption is activated, the data you transmit to us cannot be read by third parties.
3. Data collection on this website
Cookies
Our websites use so-called "cookies." Cookies are small data packets and do not cause any damage to your end device. They are stored on your end device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or until they are automatically deleted by your web browser.
Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g., cookies for processing payment services).
Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for advertising purposes.
Cookies that are required for the electronic communication process, for the provision of certain functions you have requested (e.g., for the shopping cart function), or for the optimization of the website (e.g., cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and Section 25(1) TDDDG); consent can be revoked at any time.
You can set your browser to inform you about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.
Cloudflare
This website uses the services of Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA ("Cloudflare") as a Content Delivery Network (CDN). Cloudflare offers a globally distributed network that optimizes the delivery of website content. For this purpose, personal data may be processed in server log files by Cloudflare. Cloudflare may set technically necessary cookies (e.g., __cf_bm for bot protection). These cookies are essential for the functionality of the website and do not require consent. The use of Cloudflare is based on our legitimate interest in providing our website as error-free and secure as possible (Art. 6(1)(f) GDPR). Data transfer to the USA is based on the EU Commission's standard contractual clauses. For more information, please refer to Cloudflare's privacy policy: https://www.cloudflare.com/privacypolicy/
Server log files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
- Browser type and browser version
- Operating system used
- Referrer URL
- Hostname of the accessing computer
- Time of the server request
- IP address
This data is not merged with other data sources.
This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website, for which the server log files must be collected.
Storage duration
Server log files are automatically deleted by Cloudflare after a maximum of 72 hours. We do not store them beyond that period.
Contact form (Formspree)
The contact form on this website is provided by Formspree, Inc., 1123 Broadway, Suite 220, New York, NY 10010, USA.
Scope of data processing
When you use the contact form, the data you enter (name, email address, message) is transmitted to Formspree's servers in the USA. Formspree forwards this data to us by email. Your IP address and the time of submission are also recorded.
Purpose of processing
The processing serves to handle your contact request and to communicate with you in the context of pre-contractual or contractual measures.
Legal basis
Processing is based on Art. 6(1)(b) GDPR (performance of pre-contractual measures at the request of the data subject) or Art. 6(1)(f) GDPR (legitimate interest in efficient processing of inquiries).
Transfer to third country (USA)
Formspree is based in the USA. Data transfer to the USA is based on the EU Commission's standard contractual clauses pursuant to Art. 46(2)(c) GDPR. Formspree is also certified under the EU-US Data Privacy Framework (DPF), ensuring an adequate level of data protection pursuant to Art. 45 GDPR. Please note that the USA is a third country without an adequacy decision for non-DPF-certified companies and US authorities may potentially access the data.
Storage duration
Data submitted via the contact form will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory statutory provisions, in particular retention periods, remain unaffected. Formspree automatically deletes the data after 60 days in accordance with their privacy policy.
For more information: Formspree Privacy Policy.
Inquiry by email, telephone, or fax
If you contact us by email, telephone, or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.
This data is processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time.
The data you send to us via contact inquiries will remain with us until you request deletion, revoke your consent to storage, or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory statutory provisions, in particular statutory retention periods, remain unaffected.