Data protection

1. General information on the collection of personal data

1.1

In the following, we provide information about the processing of personal data when using our website. Personal data is all data that can be related to you personally, e.g. name, address, email addresses, user behaviour. In doing so, we would like to inform you about our processing procedures and at the same time fulfil our legal obligations, in particular those arising from the EU General Data Protection Regulation (GDPR).

1.2

The controller pursuant to Art. 4 (7) GDPR is German LNG Terminal GmbH, Elbehafen, 25541 Brunsbüttel, info@germanlng.com (see our legal notice). You can reach our data protection officer at helge.helms@germanlng.com or at our postal address with the addition “the data protection officer”.

1.3

In principle, any processing of personal data is prohibited by law and is only permitted if the data processing falls under one of the following justifications:

• • Art. 6 para. 1 sentence 1 lit. a GDPR (“consent”): Where the data subject has voluntarily, in an informed and unambiguous manner, indicated by a statement or other unambiguous affirmative act that he or she consents to the processing of personal data relating to him or her for one or more specific purposes;
• • Art. 6 para. 1 sentence 1 lit. b GDPR: If the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• • Art. 6 para. 1 sentence 1 lit. c GDPR: If processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a legal obligation to retain data);
• • Art. 6 para. 1 sentence 1 lit. d GDPR: Where processing is necessary in order to protect the vital interests of the data subject or of another natural person;
• • Art. 6 para. 1 sentence 1 lit. e GDPR: If 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, or
    
  • Art. 6 para. 1 sentence 1 lit. f GDPR (“Legitimate interests”): Where processing is necessary for the purposes of the legitimate interests (in particular legal or economic interests) pursued by the controller or by a third party, except where such interests are overridden by the interests or rights of the data subject which require protection of personal data (in particular where the data subject is a minor).

The storage of information in the end user’s terminal equipment or access to information that is already stored in the terminal equipment is only permitted if it is covered by one of the following justifications:

• • § 25 para. 1 TTDSG: If the end user has consented on the basis of clear and comprehensive information. Consent must be given in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR;
• • § 25 para. 2 no. 1 TTDSG: If the sole purpose is to carry out the transmission of a communication over a public telecommunications network or
• • § 25 para. 2 no. 2 TTDSG: If the storage or access is absolutely necessary so that the provider of a telemedia service can provide a telemedia service expressly requested by the user.

1.4

For the processing operations carried out by us, we indicate below how long the data will be stored by us and when it will be deleted or blocked. Unless an explicit storage period is specified below, your personal data will be erased or blocked as soon as the purpose or legal basis for storage no longer applies. Your data will generally only be stored on our servers in Germany, subject to any disclosure in accordance with the provisions in section 1.8. However, your data may be stored beyond the specified period in the event of an (impending) legal dispute with you or other legal proceedings or if storage is provided for by statutory provisions to which we are subject as the controller (e.g. § 257 HGB, § 147 AO). If the storage period prescribed by the statutory provisions expires, the personal data will be blocked or deleted unless further storage by us is necessary and there is a legal basis for this.

1.5

When you contact us by e-mail or via a contact form, the data you provide (your e-mail address, your name and telephone number if applicable) will be stored by us in order to answer your questions. If the enquiry is assigned to a contract, we will delete the data arising in this context after the contract period, otherwise after storage is no longer required, or restrict processing if there are statutory retention obligations.

1.6

If we use contracted service providers for individual functions of our offer or wish to use your data for advertising purposes, we will always carefully select and monitor these service providers and inform you in detail below about the respective processes. We will also state the specified criteria for the storage period.

1.7

We use suitable technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorised access by third parties (e.g. TLS encryption for our website), taking into account the state of the art, the implementation costs and the nature, scope, context and purpose of the processing as well as the existing risks of a data breach (including its probability and effects) for the data subject. Our security measures are continuously improved in line with technological developments. We will be happy to provide you with more detailed information on request. Please contact our data protection officer.

1.8

Your personal data may be passed on or disclosed to third-party companies. These may also be located outside the European Economic Area (EEA), i.e. in third countries. Such processing takes place exclusively to fulfil contractual and business obligations and to maintain your business relationship with us (legal basis is Art. 6 para. 1 lit. b or lit. f in each case in conjunction with Art. 44 et seq. GDPR). We will inform you about the respective details of the transfer at the relevant points below. The European Commission certifies that some third countries have data protection standards comparable to the EEA standard by means of so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en). In other third countries to which personal data may be transferred, however, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is adequately guaranteed. This is possible via binding corporate rules, standard contractual clauses of the European Commission for the protection of personal data pursuant to Art. 46 para. 1, 2 lit. c GDPR (the standard contractual clauses of 2021 are available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0915&locale-en), certificates or recognised codes of conduct. Please contact our data protection officer if you would like more information on this.

1.9

We do not intend to use personal data collected from you for automated decision-making (including profiling).

1.10

We do not make the conclusion of contracts with us dependent on you providing us with personal data beforehand. As a customer, you are under no legal or contractual obligation to provide us with your personal data; however, we may only be able to provide certain services to a limited extent or not at all if you do not provide the necessary data. If this should exceptionally be the case within the scope of the products offered by us as presented below, you will be informed of this separately.

1.11

Under certain circumstances, we may be subject to a specific legal or statutory obligation to provide the lawfully processed personal data to third parties, in particular public authorities (Art. 6 para. 1 sentence 1 lit. c GDPR).

2. Your rights

2.1

You have the following rights vis-à-vis the controller with regard to your personal data:

• right of access,
• right to rectification or erasure,
• right to restriction of processing,
• right to object to processing,
• right to data portability.

2.2

You also have the right to complain to a data protection supervisory authority about the processing of your personal data by us. The supervisory authority responsible for us is the Independent Centre for Data Protection Schleswig-Holstein, Holstenstraße 98, 24103 Kiel, e-mail: mail@datenschutzzentrum.de, phone: 0431 988-1200, fax: 0431 988-1223.

3. Processing of personal data when visiting our website

When using the website for information purposes, i.e. simply viewing it without providing us with any other information, we process the personal data that your browser transmits to our server. The data described below is technically necessary for us to display our website to you and to ensure stability and security and must therefore be processed by us. The legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR:

• IP address
• date and time of the request
• time zone difference to Greenwich Mean Time (GMT)
• content of the request (page visited)
• access status/HTTP status code
• amount of data transferred in each case
• previously visited page
• browser
• operating system
• language and version of the browser software.

4. Other functions and offers on our website

4.1

In addition to the purely informational use of our website, we may offer various services via our website that you can use if you are interested and use other common functions to analyse or market our offers, which are presented in more detail below. For this purpose, you must generally provide additional personal data or we process such additional data that we use to provide the respective services. The aforementioned data processing principles apply to all data processing purposes described here.

4.2

We sometimes use external service providers to process your data. These are carefully selected by us, are bound by our instructions and are regularly monitored.

4.3

If our service providers or partners are based in a country outside the European Economic Area (EEA), we will inform you of the consequences of this circumstance in the description of the offer.

5. Objection to or cancellation of the processing of your data

5.1

If you have given your consent to the processing of your data, you can revoke this at any time. Such a revocation affects the permissibility of the processing of your personal data after you have given it to us. The permissibility of the processing of your data up to the time of your revocation remains unaffected.

5.2

Insofar as we base the processing of your personal data on the balancing of interests, you can object to the processing. This is the case if, in particular, the processing is not necessary for the fulfilment of a contract with you, which is described by us in each case in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data in the way we do. In the event of your objection, we will examine the situation and will either stop or adapt the data processing or show you our compelling reasons worthy of protection on the basis of which we will continue the processing.

5.3

Of course, you can object to the processing of your personal data for advertising and data analysis purposes at any time. The best way to object to advertising is to contact us using the contact details provided above.

6. Processing of data from your end devices

6.1

We use cookies on our websites. Cookies are small text files that are assigned to the browser you are using and stored on your hard drive by means of a characteristic character string and through which certain information flows to the location that sets the cookie. Cookies cannot execute programmes or transfer viruses to your computer and therefore cannot cause any damage. They are used to make the website more user-friendly and effective overall, i.e. more convenient for you.

Cookies may contain data that makes it possible to recognise the device used. In some cases, however, cookies only contain information on certain settings that are not personally identifiable. However, cookies cannot directly identify a user.

A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. In terms of their function, a distinction is made between cookies:

• Technical Cookies: Diese sind zwingend erforderlich, um sich auf der Webseite zu bewegen, grundlegende Funktionen zu nutzen und die Sicherheit der Webseite zu gewährleisten; sie sammeln weder Informationen über Sie zu Marketingzwecken noch speichern sie, welche Webseiten Sie besucht haben;

• Performance cookies: These collect information about how you use our website, which pages you visit and, for example, whether errors occur when using the website; they do not collect any information that could identify you – all information collected is anonymous and is only used to improve our website and to find out what interests our users;

• Advertising cookies, targeting cookies: These are used to provide the website user with customised advertising on the website or offers from third parties and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;

• Sharing cookies: These are used to improve the interactivity of our website with other services (e.g. social networks); sharing cookies are stored for a maximum of 13 months.

The legal basis for cookies that are absolutely necessary to provide you with the expressly requested service is § 25 para. 2 no. 2 TTDSG. Any use of cookies that is not absolutely technically necessary for this purpose constitutes data processing that is only permitted with your express and active consent in accordance with § 25 para. 1 TTDSG in conjunction with Art. 6 para. 1 sentence 1 lit. a GDPR. This applies in particular to the use of performance, advertising, targeting or sharing cookies. In addition, we only pass on your personal data processed by cookies to third parties if you have given your express consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.

6.2

When you first access the website, we give you the option of setting which of the cookies used by our website you wish to accept and which you do not. Essential cookies are loaded in any case. You can also set which cookies may be stored in your browser. You can also give your consent to the processing of all cookies by clicking on the “Accept all” button or reject all functional cookies by clicking on the “Reject” button. You can manage and change your settings at a later date by clicking on the icon in the bottom right-hand corner of the browser.

The following cookies are used on our website:

See Cookie Policy https://germanlng.com/cookie-policy-eu/?lang=en

On this website, we use the web analysis service Matomo to analyse and check the use of our website. We can use the statistics obtained to improve our offer and make it more interesting for you as a user.

We operate Matomo in a version that does not require cookies. This means that no Matomo cookies are stored on your computer for the purpose of web analysis. To analyse website usage, your IP address and information such as timestamps, websites visited and your language settings are recorded. We store the information collected in this way on our server.

This website uses Matomo with the “AnonymiseIP” extension. This means that IP addresses are further processed in abbreviated form and cannot be directly linked to individuals. The IP address transmitted by your browser using Matomo is not merged with other data collected by us. The legal basis for the use of Matomo is Art. 6 para. 1 sentence 1 lit. f GDPR.

You can prevent the use of Matomo by removing the following tick to activate the opt-out plug-in: [Matomo iFrame]. In this case, an opt-out cookie is stored in your browser that prevents Matomo from storing usage data. If you delete your cookies, the Matomo opt-out cookie will also be deleted. The opt-out must be reactivated when you visit our website again.

The Matomo programme is an open source project. Information from the third-party provider on data protection can be found at https://matomo.org/privacy-policy/.

8.1

We currently use the following social media plug-ins: LinkedIn, which are only loaded if you have previously activated the function by giving your consent. We offer you the opportunity to interact with social networks and other users via the plug-ins. The legal basis for the use of the plug-ins is Art. 6 para. 1 sentence 1 lit. a GDPR, i.e. the integration only takes place with your consent.

The plug-in provider stores the data collected about you as usage profiles and uses these for the purposes of advertising, market research and/or customising its website. Such an evaluation is carried out in particular (even for users who are not logged in) to display customised advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact the respective plug-in provider to exercise this right. Data is passed on regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in with the plug-in provider, your data collected by us will be assigned directly to your existing account with the plug-in provider. If you press the activated button and, for example, link the page, the plug-in provider also saves this information in your user account and shares it publicly with your contacts. We recommend that you log out regularly after using a social network, especially before activating the button, as this will prevent you from being assigned to your profile with the plug-in provider.

8.3

The information collected is stored on the provider’s servers, in the case of international providers also outside Europe. For these cases, the provider has, according to its own information, imposed a standard that corresponds to the former EU-US Privacy Shield and has promised to comply with applicable data protection laws when transferring data internationally. We have also agreed so-called standard data protection clauses with the providers, the purpose of which is to maintain an appropriate level of data protection in the third country.

8.4

You can withdraw your consent at any time without this affecting the permissibility of processing up to the time of withdrawal. The easiest way to revoke your consent is via our Consent Manager or via the functions of the social media providers.

8.5

Further information on the purpose and scope of data collection and its processing by the plug-in provider can be found in the data protection declarations of these providers provided below. There you will also find further information on your rights in this regard and setting options to protect your privacy. Addresses of the respective plug-in providers and URL of the respective data protection notices: https://linkedin.com/legal/privacy-policy.

9. Our presence on social networks

9.1

We have various presences on social media platforms. We operate these presences with the following providers: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, linkedin.com; information on LinkedIn’s data protection can be found at https://linkedin.com/legal/privacy-policy.

9.2

We use the technical platform and services of the providers for these information services. We would like to point out that you use our presence on social media platforms and their functions on your own responsibility. This applies in particular to the use of interactive functions (e.g. commenting, sharing, rating). When you visit our websites, the providers of the social media platforms collect, among other things, your IP address and other information that is stored on your end device in the form of cookies. This information is used to provide us, as the operator of the accounts, with statistical information about the interaction with us.

9.3

The data collected about you in this context is processed by the platforms and may be transferred to countries outside the European Union, in particular the USA. According to their own information, all of the aforementioned providers maintain an appropriate level of data protection that corresponds to that of the former EU-US Privacy Shield and we have concluded the standard data protection clauses with the companies. We do not know how the social media platforms use the data from your visit to our account and interaction with our posts for their own purposes, how long this data is stored and whether data is passed on to third parties. Data processing may differ depending on whether you are registered and logged in to the social network or whether you visit the site as a non-registered and/or non-logged-in user. When you access a post or the account, the IP address assigned to your end device is transmitted to the provider of the social media platform. If you are currently logged in as a user, a cookie on your end device can be used to track how you have moved around the web. Buttons integrated into websites enable the platforms to record your visits to these websites and assign them to your respective profile. This data can be used to offer you customised content or advertising. If you want to avoid this, you should log out or deactivate the “stay logged in” function, delete the cookies on your device and restart your browser.

9.4

As the provider of the information service, we also only process the data from your use of our service that you provide to us and that requires interaction. For example, if you ask a question that we can only answer by email, we will store your information in accordance with the general principles of our data processing, which we describe in this privacy policy. The legal basis for the processing of your data on the social media platform is Art. 6 para. 1 sentence 1 lit. f GDPR.

9.5

To exercise your rights as a data subject, you can contact us or the provider of the social media platform. If one party is not responsible for responding or must receive the information from the other party, we or the provider will then forward your enquiry to the respective partner. Please contact the operator of the social media platform directly for questions about profiling and the processing of your data when using the website. If you have any questions about the processing of your interaction with us on our site, please write to the contact details we have provided above.

9.6

What information the social media platform receives and how it is used is described by the providers in their privacy policies (see link above). There you will also find information about contact options and the settings options for adverts.