Legal Notice

Data Protection Policy For Settlin

Welcome to the website of “Settlin”. This page describes the company’s approach and commitment to the protection of your personal data. In general, this website can be used without providing any personal data, however, there are a few pages where you are required to enter personal data, and in these cases, you will be required to give your consent prior to and in order for us to provide you with the services or information you are requesting.

Personal Data is processed in confidence and in line with the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016, (General Data Protection Regulation).

In order to implement the appropriate protection of your personal data, we have undertaken technical and organizational measures to ensure that both our employees and external service providers comply with the applicable legal requirements. Internet-based services, however, can be susceptible to previously unknown security vulnerabilities, so absolute protection at any one time cannot be guaranteed. We do our utmost best, though, to address these once they are known. You are welcome to transfer personal data to us by alternative means, e.g. by post, telephone or fax, should you not feel completely comfortable with the level of risk of us processing your personal data online.

1. Definitions

Your personal data is protected in accordance with the EU General Data Protection Regulation (GDPR), other country’s Data Protection Laws/ Regulations. Accordingly, our privacy policy uses the terms defined there, as outlined below:

• 1. Personal data: Personal data means any information relating to an identified or identifiable natural person (the “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.
• 2. Processing: Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• 3. Restriction of processing: Restriction of processing means the marking of stored personal data with the aim of limiting its processing in the future.
• 4. Profiling: Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
• 5. Pseudonymization: Pseudonymization means the processing of personal data in such a manner 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 to ensure that the personal data is not attributed to an identified or identifiable natural person.
• 6. Controller: Controller means the 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 any law, the controller or the specific criteria for its nomination may be provided for by any law.
• 7. Third party: Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, is authorized to process personal data.
• 8. Consent: Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Data Controller

2. Name and address of the data controller: The persons responsible for data processing pursuant to the General Data Protection Regulation, Data Protection Laws in other jurisdictions and other provisions relating to data protection are:

Michael Onwuatuegwu.
Belßstr. 78B
12249 Berlin, Germany
Phone: +491768235814
Email: info@ojirasoft.com
Website: www.ojirasoft.com

3. Data Protection Officer

3. Name and address of data protection officer:The data controller’s data protection officer is:

Michael Onwuatuegwu.
Belßstr. 78B
12249 Berlin, Germany
Phone: +491768235814
Email: info@ojirasoft.com
Website: www.ojirasoft.com

Your trust and the protection of your data are important concerns to us. This is why it is important for us to answer any and all questions relating to how your data is protected and used. If you require any information over and above that provided here or have any comments, please do not hesitate to contact us at any time.

4. Rights of Data Subjects

You have the following rights regarding your personal data:

• 1. Right to be informed: You have the right to be informed about whether or not personal data concerning you is being processed by a data controller. Where that is the case, you also have the right to be informed of the particulars of the data processing. The right to be informed encompasses the data in question, the purposes for which it is processed, the categories of personal data being processed, and the recipients or categories of recipient to which the personal data is or has been disclosed. It further encompasses the envisaged period for which the personal data will be stored, the origin of the data if it was not collected from you personally, and the existence of any automated decision-making, including profiling. The right to be informed also includes an entitlement to information about the right to rectification or deletion of personal data, and an entitlement to information about the right to lodge a complaint with a supervisory authority.
• 2. Right to erasure (right to be forgotten):You may request erasure where the purpose for the collection or processing of the data has ceased to exist, or the data is no longer necessary to this end; you have exercised your right to object to the processing of your personal data; you have withdrawn your consent to data processing and there are no legal grounds to justify continued processing; the erasure arises from a legal obligation; or there is no legal basis for processing the data.
• 3. Right to data portability: You have the right to receive any personal data concerning you, which you have provided to us as a data controller, in a structured, commonly used, and machine-readable format. You also have the right to transmit this data to another controller without hindrance from the controller to which the personal data was furnished. This right applies where data was processed automatically in the performance of a contract or on the basis of consent. Furthermore, this right encompasses the entitlement to have the personal data transmitted directly from one controller to another, where technically feasible.
• 4. Right to object: The right to object includes, on one hand, the option of objecting to the processing of your personal data for marketing purposes. You also have the right to object to processing of personal data that was originally obtained lawfully for other purposes.
• 5. Right to restriction of processing: Under certain conditions, you have the right to demand that the controller place restrictions on your personal data so as to prevent further processing. For instance, such restrictions can be demanded for the duration of the verification process if the accuracy of the stored data is disputed.
• 6. Right to rectification: The right to rectification comprises your right as a data subject to demand from us, the controller, the immediate rectification of inaccurate personal data concerning you.

5. Legal Basis for Processing

For the majority of processing operations, we obtain consent from you. In these cases, Art. 6 (1) lit. a and Art. 7 GDPR constitute the legal basis for processing operations. Processing of personal data can also be necessary for the performance of a contract or for acts preparatory to such a contract, as is the case, in particular, with processing operations related to the supply of information material requested by you or applications for places on our courses. In such cases, processing is based on Art. 6 (1) lit. b GDPR. Insofar as we are subject to a legal obligation to process personal data, for instance to meet tax obligations, the processing is based on Art. 6 (1) GDPR. In certain cases, the processing of personal data may be required to protect the vital interests of the data subject or another natural person. In this case, the processing would be based on Art. 6 (1) GDPR. If data processing operations are not covered by any of the above legal bases, Art. 6 (1) GDPR may apply. This may be the case if, for instance, processing is necessary to safeguard a legitimate interest on the part of “Ojira”, or of a third party, except where such interests are overridden by the interests, fundamental rights, and freedoms of the data subject. A legitimate interest is, for example, conducting company business to protect the interests of employees and shareholders and includes analysis and optimization of our marketing activities. Accordingly, we regard the use of cookies to track user behavior as part of our marketing activities, provided it does not relate to sensitive data or identifiable individuals, and the delivery of personalized marketing to the corresponding user profiles, as necessary for the pursuit of our legitimate interests.

6. Transfer to Third Countries

If we process data in a third country (i.e. in a country outside of the European Union or outside of the European Economic Area) or if data is processed in third countries in connection with the use of services rendered by third parties or disclosed or transferred to third countries, this is done solely for the purpose of fulfilling contractual obligations or in preparation to enter into a contract; on the basis of your consent, a legal obligation, or our legitimate interest. We only process, transfer, or have data processed in a third country in compliance with the provisions of Articles 44 of the General Data Protection Regulation (GDPR). Processing is carried out, for example, on the basis of special guarantees, such as the verification of a level of data protection comparable to that guaranteed in the European Union, compliance with officially recognized contractual obligations or evidence of some other, recognized level of data protection.

7. Cooperation with External Data Processors and Third Parties

If, during our processing operations, data is disclosed, transferred, or otherwise made available to other persons and enterprises, this is always done for a lawful purpose, on the basis of consent, a legal obligation, a legitimate interest, or as necessary for the performance of a data processing contract pursuant to Article 28 of the GDPR.

8. Cookies

“Settlin” website uses cookies. Cookies are used to enable web-based applications to manage the status of your visit to a website and facilitate navigation between the different website services and content. Cookies are installed on the hard drive of your computer and do not cause any damage. A cookie is a small data file which is transferred from the web server to your device when you browse our website. Cookies only contain information which we or a third party send to your computer; cookies cannot access private data. Accepting cookies does not give us access to your personal information. Various data is saved in cookies. This is done primarily to store information on the user during or after a visit to a website. There are two main types of cookies: temporary and permanent. Temporary cookies are deleted when the user leaves the website. Permanent cookies remain after the browser has been closed and are used to measure audience reach and analyze user behavior. Some cookies do not originate from the entity responsible for the website, but from third parties.

Most browsers accept cookies by default. If you would like to stop the use of cookies to measure audience reach, analyze user behavior, and display personalized ads, the default cookie setting can be deactivated in your browser. Permanent cookies that are installed for the aforementioned purpose can also be deleted in the same way.

9. Access Data

When you visit our website, access data relating to this event is saved in a log file either by us or by our hosting provider. We collect usage data in connection with your visit, which is saved temporarily for statistical purposes and subsequently deleted. This data is collected for internal purposes only and is not transferred to third parties.

The data includes:

• IP address of the device from which the request is sent
• Date and time of the request
• Access method/function requested by the end device
• Input values transferred by the end device from which the request is sent (e.g. file name)
• Web server access status (file transferred, file not found, command not executed, etc.)
• Name of file requested and data volume transferred
• URL from which the file was requested/the desired function was initiated

12. Analysis, Market Research, and Opinion Polling

We analyze our pool of data on business processes, contracts, and queries with a view to identifying market trends and customer and user requirements, and effectively running our business operations. To this end, we process user, contact, usage, and contract data and communication data relating to interested parties or visitors to our website on the basis of our legitimate interest in maintaining and optimizing our business pursuant to Art. 6 (1) GDPR. Such analyses are performed for the purpose of business assessments, marketing and sales, and market research. They enable us to optimize our website content and services, making them more user-friendly, and help us optimize our business operations. Insofar as possible, data is anonymized for analysis and profiling. Analysis and profiling results are not disclosed to third parties.

13. Contacting Us via Our Website

When using our contact form to send an inquiry, the data you enter including your contact data is saved for the purpose of processing your request and for any follow-up questions. No data is disclosed to third parties. However, should this become necessary in order to process your inquiry, we will obtain your consent in advance.

14. Deletion and blocking of personal data

We process and save your personal data only insofar as necessary for data storage reasons or as required under the provisions of relevant European directives and/or regulations. Data is stored in compliance with any and all applicable retention periods. Under Regulation (EU) 2016/679 of the European Parliament on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and Directive 95/46/EC (General Data Protection Regulation) the statutory data retention period is 10 years or as long as is legally required by laws governing safeguarding, employment and education. Your data will be routinely deleted on expiry of said periods, unless required for the performance of a contract or for acts preparatory to a contract.

15. Social Media Presence

We maintain a social media presence to communicate with active customers, interested parties, and users. User data can be processed in countries outside of Europe, where different data protection standards apply. We would therefore like to draw your attention to the fact that this can involve certain risks for the user: For instance, data processing is subject to different requirements in terms of transparency or legal enforcement. User data is also used for market research and advertising purposes. In addition, the data collected, e.g. on user behavior, may be used to deliver targeted content or services or to create user profiles based on the user’s interests. These are in turn used to run targeted, interest-based ads both on social media and through other channels. This information is often collected with the help of cookies installed on user devices and subsequently analyzed according to specific criteria. The individual profile data saved on social media sites can also be linked to the data saved with the help of cookies. Providers are obligated to comply with EU Data Protection Regulations. The maintenance of a presence on social media and the resulting processing of personal data take place pursuant to Art. 6 (1) GDPR on the basis of our legitimate interest in effective, up-to-date information on and communication with users and interested parties. Where consent to data processing has been obtained, processing takes place pursuant to Art. 6 (1) and Art. 7 GDPR. For details of the individual policies on data processing and opt-out options, we ask that you refer to the individual providers’ specifications. Please note that the most effective way to enforce user rights and obtain information is through the individual providers themselves. Only they hold the relevant databases and have the technical and organizational means to this end. We are happy to assist you further with this where necessary.

16. Integration of Third Party Services

We integrate content and services from third parties on the basis of our legitimate interests in optimisation and economic operation. The integration and display of these services requires the perception of the IP address, as information is transmitted to the browser in this case. As far as we can see, we only try to include content from those providers who use the IP address only for the purpose of delivering the content. However, third party providers may collect data for statistical or marketing purposes by using pixel tags or web beacons. In addition, cookies can be set on your end device which collect information about your operating system, the history of the websites visited, times of access and metadata. Under certain circumstances, this pseudonymous user data can also be merged with information from other sources.