Privacy

This English translation is for information purposes only, the German version is authoritative.

Status: February 2021

1. General notes and mandatory information

ATCP Management GmbH takes 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 data protection declaration.

When you use this website, various personal data are collected. Personal data is data that relates to an identified or identifiable natural person. This includes, for example, your name, your address and your IP address. 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.

Note on the responsible controller

The responsible body is the natural or legal person who alone or jointly with others decides on the purposes and means of the processing of personal data. The responsible body pursuant to Art. 4 No. 7 of the General Data Protection Regulation (DS-GVO) is the

ATCP Management GmbH
Wittestraße 30, Haus F, 13509 Berlin

represented by den Geschäftsführer: David Esquenazi

Telephone: +49 (0)30 374 381 9999
E-Mail: info@aroundtowncommercial.com
(see also our imprint).

You can reach our data protection officer at

datenschutzbeauftragter@aroundtowncommercial.com or at our postal address by indicating „der Datenschutzbeauftragte“.

 

3. SSL or TLS encryption

This website uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as enquiries 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. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

 

4. Collection of general data when visiting our website

Type and purpose of processing

If you visit our website without using the services offered by us and without providing us with personal data, information of a general nature is automatically collected. This information (server log files) may contain personal data in limited cases. Your browser automatically transmits the following information to us:

  • Browser type and browser version,
  • operating system used,
  • referrer URL,
  • host name of the accessing computer,
  • time of the service request, and
  • IP address.

We process this data

  • to ensure a problem-free connection to the website,
  • to ensure problem-free use of the website
  • evaluating system security and system stability
  • optimization of the website

 

We do not combine this data with other data sources. We do not use your data to draw conclusions about your person.

Legal basis and legitimate interest

The processing is carried out in accordance with Art. 6 para. 1 p. 1 lit. f) DSGVO on the basis of our legitimate interest in improving the security, stability and functionality of the website.

Recipients

Recipients of the data are technical service providers who act as order processors for the operation and maintenance of the website.

Third country transfer

There is no transfer of data to a third country.

Storage period

The automatically collected personal data is deleted as soon as it is no longer required for the purpose for which it was collected. For the data used to provide the website, this is generally the case when the respective session has ended.

After the end of your session or after you have closed the browser window, all log files are deleted. We do not store any corresponding personal data beyond the time of your visit to our website.

Provision mandatory or required

The provision of the aforementioned personal data is neither legally nor contractually required. Without the provision of the IP address, the service and functionality of the website cannot be guaranteed. In addition, individual services and services may not be available or may be restricted.

 

5. Cookies

Some of the websites use so-called cookies. Cookies do not cause any damage to your computer and do not contain viruses. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called “session cookies”. These cookies are necessary to enable the use of our website. Session cookies are automatically deleted at the end of your visit.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases (e.g. the acceptance of third-party cookies) or generally and activate the automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of this website may be limited.

Depending on the provider of your browser, you will find the necessary information under the following links:

 

Storage period and cookies used:

If you allow us to use cookies through your browser settings or consent, the following cookies may be used on our websites:

_ga: 24 months

_gid: 24 hours

_gat: 1 minute(s)

cookieconsent: 12 months

 

5.1 Technically necessary cookies

Type and purpose of processing:

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is also recognized after a page change.

Legal basis and legitimate interest:

The processing is carried out in accordance with Art. 6 para. 1 p. 1 lit. f) DSGVO on the basis of our legitimate interest in a user-friendly design of our website and to give you the opportunity to consent or not to consent to the use of cookies as well as to revoke your consent after it has been given.

Recipients:

Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website.

Third country transfer:

There is no transfer of data to a third country.

Provision mandatory or required:

The provision of the aforementioned personal data is neither legally nor contractually required. However, without this data, the service and functionality of our website cannot be guaranteed. In addition, individual services and services may not be available or may be restricted.

Objection

Please read the information on your right to object in accordance with Art. 21 DSGVO below.

 

5.2 Technically unnecessary cookies

Furthermore, we use cookies to better tailor the offer on our website to the interests of our visitors or to generally improve it based on statistical evaluations.

Please refer to the information below on the display, tracking, remarketing and web analysis technologies used to find out which providers set cookies.

Legal basis:

The legal basis for these processing operations is in each case your consent, Art. 6 para. 1 lit. a) DSGVO.

Recipients:

Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website.

For further recipients, please refer to the information below on the display, tracking, remarketing and web analysis technologies used.

Third country transfer:

Please refer to the listings of each display, tracking, remarketing and web analytics provider for information on this.

Provision prescribed or required:

Of course, you can also view our website without cookies in principle. Web browsers are regularly set to accept cookies. In general, you can deactivate the use of cookies at any time via your browser settings (see Revocation of consent).

Furthermore, by displaying a cookie consent tool, you are given the opportunity to give your consent to certain processing before visiting our website or to use the website exclusively with technically necessary cookies.

Please note that individual functions of our website may not work if you have deactivated the use of cookies.

Withdrawal of consent:

You can withdraw your consent at any time via our cookie consent tool.

Profiling:

To what extent we analyze the behavior of website visitors with pseudonymized user profiles, please see the information below on the display, tracking, remarketing and web analysis technologies used.

 

6. Other tools

6.1 Google Web Fonts

This site uses so-called web fonts provided by Google for the uniform display of fonts. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When you call up a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

For this purpose, the browser you are using must connect to Google’s servers. This informs Google that our website has been accessed via your IP address. Google Web Fonts are used in the interest of a uniform and appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 (1) sentence 1 lit. f) DSGVO.

If your browser does not support web fonts, a standard font will be used by your computer.

 

Further information on Google Web Fonts can be found at

https://developers.google.com/fonts/faq and in Google’s privacy policy: https://www.google.com/policies/privacy/.

 

6.2 Google Analytics

We use Google Analytics on this website. This is a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”).

We use Google Analytics to analyze and regularly improve the use of our website. By evaluating the statistics, we can continuously improve our offer for you and make our website even more interesting for you. The legal basis for the processing is Art. Art. 6 para. 1 p. 1 lit. f) DSGVO.

Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and enable an analysis of your use of our website.

Information about your use of the website, which is obtained using the cookie, is regularly transmitted to Google servers and stored by Google. A further transmission to servers of Google LLC. in the USA and storage there is not excluded.

This website uses Google Analytics exclusively with the extension “anonymizeIp()”. This means that IP addresses within member states of the European Union or in other contracting states of the Agreement on the European Economic Area are shortened beforehand and only then processed further. A personal reference can thus be excluded.

Only in exceptional cases will the full IP address be transferred to a Google server in the USA and then shortened there. The legal basis here is Art. 6 para. 1 sentence 1 lit. f) DSGVO, based on our legitimate interest in analyzing user behavior for the purposes of optimizing our offer and marketing. Google evaluates the information on the behavior of users on our website.

The IP address transmitted by your browser when using Google Analytics will not be merged with other data stored by Google.

If you do not wish cookies to be stored (or wish to deactivate Google Analytics), you can prevent them from being stored by making the appropriate setting in your browser software. However, it will then not be possible to use all the functions of this website to their full extent. Furthermore, you can also prevent the collection of the data generated by the cookie and related to your use of the website by Google. Simply download and install the browser add-on available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de. This will also prevent the IP address from being recorded. This will also prevent Google Analytics from processing your data.

Google Analytics is also used to analyze your usage across devices. This is done via a user ID. The first time you access a page that uses Google Analytics, you will be permanently assigned a unique, anonymized ID. This is set across all devices. This makes it possible for Google to assign interaction data from different devices and from different sessions to a single user. No personal data is processed through anonymization.

Nevertheless, you can object to this processing at any time with effect for the future. To do so, you must deactivate Google Analytics on all devices and also in all browsers. We have described how to deactivate Google Analytics above.

You can deactivate this analysis in your customer account under “My data”, “Personal data”.

We also use the “demographic characteristics” function of Google Analytics on our website. Demographic data is specific information about groups of people.

Based on this function, reports can be created that contain information about the age, gender and interests (so-called demographic characteristics) of the users of our site. The data comes from interest-based advertising from Google, the Google Display Network and from visitor data from third-party providers. You can deactivate this function at any time via the ad settings in your Google account. However, it is also possible to deactivate Google Analytics as described above. Simply download and install the browser add-on available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

Further information can be found here:

To the user terms and conditions: https://www.google.com/analytics/terms/de.html.

The Google privacy statement: https://privacy.google.com/businesses/compliance/#!#gdpr

On Google (Universal) Analytics: https://support.google.com/analytics/answer/3379636?hl=de

As far as legally required, we have obtained your consent for the processing of your data as described above in accordance with Art. 6 para. 1 p. 1 lit. a) DSGVO. Your consent also includes the transfer of data to the USA with the risk of data access by authorities and, moreover, without an adequacy decision by the EU Commission and without suitable guarantees regarding an adequate level of protection with regard to the data. You can revoke your consent at any time with effect for the future. To exercise your revocation, deactivate this tool in the cookie banner of the website.

 

6.3 Google Maps

We use Google Maps on our website, an online map service provided by Google Ireland Limited, Gordon House, 4 Barrow St, DublinD04 E5W5, Ireland, hereinafter referred to as “Google”.

We can thus show you our locations via interactive maps. You can use the route planner to show you a route to us. You can also use other map functions.

If you call up our page on which Google Maps is integrated, information such as IP address and usage data will be transmitted to Google. The transmission of data to servers of Google LLC. in the USA is not excluded. You do not need to be logged into your Google account to do this.

If you are logged in to Google when you visit our site, the usage data relating to your visit to our site with the Google Maps tool will be added to your account. If you do not wish this, please log out before visiting our site on which Google Maps is integrated.

Google stores the collected data as a usage profile and evaluates it in any case, i.e. even if you are not logged into your Google account. The legal basis for the collection, storage and evaluation is Art. 6 para. 1 lit. f) DSGVO, so-called legitimate interest. Google’s legitimate interest is the use of the data for personalized advertising, market research and the creation of customized pages. You may exercise your right to object to the creation of a usage profile based on your data.

Insofar as personal data is transferred to Google LLC. in the USA, as described above, compliance with a sufficient level of data protection applicable in the EU is ensured by Google’s certification for the EU-US Privacy Shield. You can find the current certificate at https://www.privacyshield.gov/list.

By switching off JavaScript in your browser, you can completely prevent your data from being transmitted to Google via Google Maps. By switching it off, Google Maps can no longer be used. The maps will no longer be displayed on the website.

 

For more information, please click here:

To the terms of use:

https://www.google.de/intl/de/policies/terms/regional.html.

To the terms of use for Google Maps:

https://www.google.com/intl/de_US/help/terms_maps.html.

Google privacy policy:

https://www.google.de/intl/de/policies/privacy/.

 

7. Contact via e-mail and contact form

Nature and purpose of processing:

If you would like to contact us via our contact form – as far as currently available – or send us a direct email, we will be happy to contact you afterwards and can advise you on, among other things, enquiries about letting, rental properties or enquiries relating to an existing tenancy agreement.

In the course of this, the contact details you provide will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We do not pass this data on to third parties without your consent.

 

Legal basis

The processing of the data entered in the contact form is based on a legitimate interest according to Art. 6 para. 1 lit. f) DSGVO.

By providing the contact form, we would like to enable you to contact us in an uncomplicated manner. The information you provide will be stored for the purpose of processing the enquiry and for possible follow-up questions.

If you contact us to request a quotation, the data entered in the contact form will be processed to carry out pre-contractual measures in accordance with Art. 6 para. 1 lit. b) DSGVO.

Recipients of the data

Recipients of the data are our internal departments that process your enquiry.

Third country transfer:

There is no transfer of data to a third country.

Storage period:

Data will be deleted at the latest 3 months after processing the enquiry.

If a contractual relationship arises, we are subject to the statutory retention periods according to the German Commercial Code (HGB) and delete your data after these periods have expired.

 

8. Your rights

If you have any questions or complaints about data protection, you can contact our company. You can find the contact details under point 1 of this data protection declaration.

Provided the legal requirements are met, you also have the following rights:

  • You can request confirmation from us as to whether we are processing personal data about you. If this is the case, you have the right to information about this personal data and the information listed in Art. 15 DSGVO, such as information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it was not collected by us;
  • in accordance with Art. 16 DSGVO, to demand the immediate correction of inaccurate or incomplete personal data stored by us;
  • in accordance with Art. 17 DSGVO, to request the deletion of your personal data stored by us, unless the processing is necessary for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims;
  • in accordance with Art. 18 DSGVO, to request the restriction of the processing of your personal data, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you object to its erasure and we no longer require the data, but you need it to assert, exercise or defend legal claims or you have objected to the processing in accordance with Art. 21 DSGVO;
  • pursuant to Art. 20 DSGVO, to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another controller; and
  • complain to a supervisory authority in accordance with Art. 77 DSGVO. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters for this purpose.

You can reach the competent authority in Berlin as follows:

Berlin Commissioner for Data Protection and Freedom of Information:

Maja Smoltczyk
Friedrichstraße 219
10969 Berlin
Visitor entrance: Puttkamer Straße 16 – 18 (5th floor)

Telephone: 0049 30/138 89-0
fax: 0049 30/215 50 50

E-mail: mailbox@datenschutz-berlin.de

Homepage: https://www.datenschutz-berlin.de

 

Further German supervisory authorities can be found at:

https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

 

In addition to this, you have the right to object to the processing of your personal data at any time, provided that we are processing your personal data for the pursuit of legitimate interests and there are grounds arising from your particular situation. We will then no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing is for the establishment, exercise or defence of legal claims, Article 21 DSGVO. You can find our contact details under point 1 of this data protection declaration.

If you have any further questions regarding data processing or data protection, please contact our data protection officer (for contact details, see point 1 of this data protection declaration).

 

9. Data processing Applicant management

If you are on our careers website and wish to apply for a vacancy, the following points apply to you.


9.1 Data collection

If you apply to us as an employee via the applicant portal on the website, we process data that you have sent us in connection with your application in order to check your suitability for the position (or other open positions in our company, if applicable) and to carry out the application procedure.

The following categories of personal data are included:

(1) Contact data (first and last name, address).

(2) Communication data (telephone number, mobile number, fax number, e-mail address, language of communication)

(3) Personal data (date of birth, place of birth, nationality, marital status, gender)

(4) Job-related and personal data (desired place of work and working hours, availability, desired salary, willingness to move and travel, work permit)

(5) Qualification data (school leaving certificate, training/studies, language skills and professional skills)

(6) Data on assessment and evaluation in the application procedure

(7) Data on the applicant’s career to date (curriculum vitae, training and work certificates, qualification certificates)

(8) Application photo

(9) Application history (consent to data storage, inclusion in applicant/talent pool)

 

9.2 Data processing for the purpose of contract initiation and processing

Personal data is processed in applicant management for the purpose of initiating contracts for employment. The legal basis of the data processing required in connection with the decision on the establishment of an employment/training relationship is Section 26 BDSG, Art. 6 para. 1 p. 1 lit. b) DSGVO.

 

With regard to the above categories of personal data, we use them for the following purposes:

(1) Personal approach

(2) Applicant communication, contacting for suitable positions

(3) Planned employment

(4) Matching of job requirements and skills and perceptions of the applicant.

 

9.3 Data processing based on your consent

It is possible that your application will be deposited in an applicant/talent pool for the submission of job offers suitable for you.

In order to be able to save your application for a later date, we need your consent in accordance with Art. 6 Para. 1 S. 1 lit. a) DSGVO.

If you have given us your written consent to include your application documents in the applicant/talent pool, the processing is lawful based on your consent.

Your consent is given on a voluntary basis and can be revoked at any time with effect for the future. As of receipt of the revocation declaration, we may no longer process your application documents for the above-mentioned purposes. The revocation of your consent does not affect the lawfulness of the processing carried out up to that point.

 

The declaration of revocation can be sent by post or e-mail to the following address:

ATCP Management GmbH
Wittestraße 30, House F
13509 Berlin

E-mail: widerruf@aroundtowncommercial.com

 

9.4 Data processing based on balancing of interests

If data is required for legal prosecution after completion of the application process, we have a legitimate interest in enforcing our claims or representation for the defense of claims, Art. 6 para. 1 lit. f) DSGVO.


9.5 Storage period in applicant management

In the event of rejection, your application documents will be deleted no later than 6 months after the application process has been completed.

If you are able to accept a position during the application process, your data will be further processed by us for the purposes of the employment relationship.

If you are hired, your personal data will be deleted 3 years after the end of the year in which the employment relationship ended.

In the event that you have consented to further storage of your personal data (e.g. applicant/talent pool), we will delete the data after 12 months have elapsed since you gave your consent.

 

9.6 Personio applicant portal

For our applicant management we use the services of Personio GmbH, an applicant management software. If you apply by e-mail or via the applicant web form, the transmitted data is transferred via TLS encryption and stored in a database that we use via Personio. We have agreed with Personio on commissioned processing in accordance with Art. 28 DSGVO and technical-organisational measures.

Personio uses a cloud system. The data is stored in Germany. The contractual use of the cloud services is explicitly limited to the EU/EEA area. The access options are regulated accordingly. A comprehensive data protection and IT security concept was developed with the cloud provider. Personal data is stored in the cloud exclusively in encrypted form (encryption algorithms according to the state of the art, AES-256 if possible). The keys are generated outside the cloud. Only Personio has access to the master key and the keys derived from it. Further information on data protection at Personio can be found at: https://www.personio.de/datenschutz/.

 

9.7 Categories of Recipients / Disclosure of Personal Data

Within our company, access to your data is granted to those departments that need it to fulfil the above-mentioned purposes.

In some cases, we use external service providers to process your data within the framework of commissioned processing. These have been carefully selected and commissioned by us, are bound by our instructions and are regularly monitored. As a result, commissioned processors may only process your personal data in the way we have explicitly instructed them to. They also maintain agreed technical and organisational measures to process your data securely.

Personal data will only be transferred by us to third parties if this is necessary for the aforementioned purposes or if you have given your prior consent. Recipients of personal data may include: Authorities, lawyers, call centers, print service providers.

 

10. Language settings

Nature and purpose of processing:

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognised even after a page change.

We require cookies for the following applications:

  • To determine the visitor’s preferred language and set it accordingly on the website.

Storage period and cookie used

pll_languae: 12 months

Legal basis and legitimate interest:

The processing is carried out in accordance with Art. 6 para. 1 p. 1 lit. f) DSGVO on the basis of our legitimate interest in a user-friendly design of our website.

Recipients:

Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website.

Third country transfer:

There is no transfer of data to a third country.

Provision mandatory or required:

The provision of the aforementioned personal data is neither legally nor contractually required. However, without this data, the service and functionality of our website cannot be guaranteed. In addition, individual services and services may not be available or may be restricted.

Objection

Please read the information about your right to object according to Art. 21 DSGVO above.

 

11. Miscellaneous

We reserve the right to change this data protection declaration at any time in compliance with data protection regulations.

If you have any questions, suggestions or comments on the subject of data protection, please feel free to contact our data protection officer using the contact details above.