Data Protection Information

We thank for your interest in our online presence. The protection of your personal data is a central concern for WTS Group Aktiengesellschaft Steuerberatungsgesellschaft (referred to in the following as "WTS", "we" or "us"). With this data protection information, we would like to inform you, in accordance with the stipulations of the EU General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 - referred to in the following as "GDPR"), about the processing of your personal data, within the course of the use of the website which can be called up at https://www.wts.com/de-en (referred to in the following as "website"), the use of our services and features, as well as the establishing of contact with us.

To navigate directly to the respective chapters of the data protection information, please click on the blue coloured headings.

1. Controller
2. Data Protection Officer
3. Categories of personal data which we process

a. Surfing on our website (page view, own cookies and web analysis, social media plug-ins)
b. Establishing of contact/correspondence by email, telephone, fax, conference systems of WTS, contact form or direct marketing
c. Subscription to our newsletters and publications, information material and/or press releases
d. Registration / Conduction of WTS events
e. Registration/Conduction of WTS webinars and if appropriate recordings
f. Application via the WTS application form or sending of documents by letter post or email (also by personnel providers)
g. Use of our social media sites (Fanpages)
h. Registration with the WTS Community Network
i. Activity as tax consultants or lawyers for our clients
j. Other purposes (Surveys and studies, company- and Group management, compliance, security and data protection, Group Security, public health)

4. Sources of personal data processed
5. Storage duration
6. Purposes of processing personal data
7. Legal basis for processing, including details of the purposes of processing

a. Overview of the legal bases
b. Details of the purposes of processing

8. Recipients or categories of recipients of personal data
9. Transfer of personal data to third countries
10. Your rights with respect to data processing

a. Right to access (Art. 15 GDPR)
b. Right to rectification (Art. 16 GDPR)
c. Right to erasure (Art. 17 GDPR)
d. Right to restriction of the processing (Art. 18 GDPR)
e. Right to notification (Art. 19 GDPR)
f. Right to data portability (Art. 20 GDPR)
g. Right to object (Art. 21 GDPR)
h. Right to complain with a supervisory authority (Art. 77 GDPR)
i. Right to withdraw consent

11. No obligation to provide data by yourself
12. Automated decision making, including profiling, as specified by Art. 22 GDPR
13. Data Security
14. Validity of this Data Protection Information for other WTS companies
15. Status and changes to this data protection information

 

1. Controller

WTS Group Aktiengesellschaft Steuerberatungsgesellschaft

Thomas-Wimmer-Ring 1
80539 Munich, Germany
Tel. +49 (0) 89 286 46-0
Fax +49 (0) 89 286 46-111
Email: info@wts.de

WTS Group Aktiengesellschaft Steuerberatungsgesellschaft is represented by the executive board: Tax Consultant Fritz Esterer, Dipl.-Oec. (Chairman), WP Tax Consultant Franz Prinz zu Hohenlohe, Lawyer Johannes Krabichler, Tax Consultant Jürgen Scholz.

WTS Group Aktiengesellschaft Steuerberatungsgesellschaft operates this website as the sole controller, unless expressly stated to the contrary below. It furthermore informs you on this website about all the companies affiliated to the WTS Group and about WTS Legal Rechtsanwaltsgesellschaft mbH. Please also note Section 14 with regard to the validity of this Data Protection Information.

2. Data Protection Officer

Group Data Protection Officer of WTS is

Dr. Thorsten B. Behling - Attorney at Law (Germany)
WTS Steuerberatungsgesellschaft GmbH
Sachsenring 83
50677 Cologne, Germany
email: thorsten.behling@wts.de

except for the following companies: FAS AG, FINVIA WTS Vermögenscontrolling GmbH, First Council GmbH, Gesellschaft für internationale Zusammenarbeit im Bereich des Steuerrechts mbH and WTS Legal Rechtsanwaltsgesellschaft mbH. For the latter company, in deviation from the data protection officer named above, Timo Meisener (Attorney at Law Germany) WTS Legal Rechtsanwaltsgesellschaft mbH, Klaus-Bungert-Str. 7, 40468 Dusseldorf, e-mail: timo.meisener@wts-legal.de Germany is appointed as data protection officer.

3. Categories of personal data which we process

Within the use of our website, the provision of the called-up features or services for you or your employer, as well as with establishing contact or correspondence with us - dependent on the features and services that you use or we provide to you or your employer - we process the personal data and data categories listed below:

a. Surfing on our website (page view, own cookies and web analysis, social media plug-ins)

• IP address (in some cases as appropriate, only in abbreviated form)
• Information about the browser type and version
• Operating system of your device
• Your Internet service provider
• Date and time of access
• Websites from which you have accessed our website
• Websites that are accessed by you via our website
• Cookie data (e.g. pseudonymous cookie ID, length of stay on our website, page views, movement via links), unless and insofar as you should prevent this, as explained in section 7 b) aa)
• As appropriate, content shared by you

For details of processing please refer to Section 7 b) aa) and the sub-items there.

b. Establishing of contact/correspondence by email, telephone, fax, conference systems of WTS, contact form or direct marketing

• Master data (e.g. salutation, title, first name, last name)
• Contact data (e.g. email address, as appropriate, telephone number or fax number)
• Metadata of your message (e.g. date and time of the dispatch)
• Message content/object of your request/conversation content
• As appropriate, video images transmitted
• As appropriate, contents of documents

If you should send us personal data by email, please ensure adequate encryption since data transfer by email is not secure and monitoring by third parties is possible. For details of processing please, refer to Section 7 b) bb).

c. Subscription to our newsletters and publications, information material and/or press releases

• Master data (e.g. salutation, title, first name, last name)
• As appropriate, company information (e.g. name of the company, your department)
• Contact data (e.g. email address)
• As appropriate, address data (e.g. street, post code, location, country)
• Your interest in certain topics

d. Registration/Conduction of WTS events

• Master data (e.g. salutation, first name, last name)
• Contact data (e.g. email address, telephone number, as appropriate, fax number)
• Company specifications (e.g. name and address of the company)
• Additional specifications (e.g. different invoice address, SAP/Order Number)

e. Registration/Conduction of WTS webinars and if appropriate recordings

• Master data (e.g. first name, last name)
• Contact data (e.g. email address)
• Company specifications (e.g. name and address of the company)
• Metadata about the event (e.g. invitation, cancellation, attendance)
• As appropriate, your voice and contents of questions
• As appropriate, recording of your contributions (if you have consented)

f. Application via the WTS application form or sending of documents by letter post or email (also by personnel providers)

• Master data (e.g. salutation, title, first name, last name)
• Address data (e.g. street, house number, post code, location, country)
• Contact data (e.g. telephone, mobile communications number, email address)
• Knowledge (e.g. knowledge of language, additional knowledge)
• Application or profile data (e.g. cover letter, CV, certificates, earliest entry date, job desired, locations desired, salary requested)
• Consent to inclusion into the applicant pool
• Your consent to contact references named by you and, as appropriate, data from correspondence with these references
• Consent to forwarding of your profile to us through a personnel provider or a contract between you and the personnel provider

If you should send us personal application data by email, for example in attachments, please ensure adequate encryption since data transfer by email is not secure and monitoring by third parties is possible.

g. Use of our social media sites (Fanpages)

Within the course of use of our social media pages (some available in German only) on:

• Facebook (call-up via the following external link)
• LinkedIn (call-up via the following external link)
• Twitter (call-up via the following external link)
• YouTube (call-up via the following external link)
• XING (call-up via the following external link)
• kununu (call-up via the following external link)
• Instagram (call-up via the following external link)

(referred to jointly as "social media page"), we process the following categories of personal data:

• User name and profile photo of the social media visitor or followers
• Comment information (e.g. profile photo, user name/name displayed, comment content)
• Contents of messages to us
• Details on “Likes” concerning our posts
• Specifications of posts which are shared by us
• Photos of persons displayed in posts on our social media pages
• Name and photos of employees (e.g. with XING and LinkedIn)

h. Registration with the WTS Community Network

• Personal master data (e.g. salutation, title, first name, last name, as appropriate former name
• Contact data (e.g. email address, as appropriate telephone number, fax number)
• As appropriate specifications of current position (e.g. employer company, location, position)
• Specifications related to time with WTS (e.g. position, leaving date)

 

i. Activity as tax consultants or lawyers for our clients

• Personal master data (e.g. form of address, title, first name, last name)
• Business contact details (e.g. e-mail address, telephone number, fax number if applicable)
• Company details (e.g. name of company, address, country)
• As appropriate, private contact and address data (e-mail address, telephone number, street, postal code, city, country)
• Contents of your messages and requests to us
• Data on the employment relationship (for example, personnel number, entry, leaving)
• As appropriate, salary data
• As appropriate, social data (e.g. severe disability)
• As appropriate religious affiliation
• As appropriate political opinions
• As appropriate health data
• As appropriate, data on business trips and stays abroad
• As appropriate, data on official expenses
• As appropriate, bank data
• As appropriate, other mandate-relevant data

j. Other purposes (Surveys and studies, company- and Group management, compliance, security and data protection, Group Security, public health)

• All types of data referred to in Section 3, as appropriate
• IP address when accessing the website with the survey tool, as appropriate
• Your entries/answers and our individually for you evaluated results of surveys and studies conducted by us, as appropriate
• Video recordings, as appropriate
• Health data, as appropriate

4. Sources of personal data processed

We basically collect personal data related to your person from you only. If this should exceptionally not be the case, we inform you separately. In case we receive your personal data in context of conduction of mandates from other informant than you, data is transferred to us by our clients or capable public bodies as e.g. financial authorities or social insurance carriers. Within the course of processing of data via our online forms (e.g. registration form for the newsletter, contact forms of the contact persons), we are provided with the personal data by the person who enters it into the respective form.

If you should provide us with personal data of third parties (e.g. as a personnel provider), you are obliged to comply with all data-protection law requirements, in particular with those of Artt. 5 to 9 and 12 ff. GDPR. Otherwise, we do not have any intention to obtain this data and reserve the right to initiate legal proceedings against you.

5. Storage duration

Obtained or collected personal-related data is only stored as long as necessary for the respective purpose associated with the storage (e.g. performance of a contract/mandate). When this purpose is fulfilled, we basically delete or anonymize the data, provided that, and insofar as, deletion does not contravene any legitimate retention purposes and obligation (e.g. stipulations from tax or professional law). In the latter case, the data processing is restricted to fulfilment of the retention purposes or the retention obligation. Apart from that, processing will only take place with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union (EU) or of an EU Member State. In case of the existence of a retention obligation, we delete or anonymize the data after the safe omission of the retention obligation.

6. Purposes of processing personal data

We adhere to the principle of purpose limitation and process your personal data only for the purposes, which are explained in this data protection information. If you visit our web site, it is not prescribed by law or contract that you must actively disclose details of your person. However, we process certain data in individual cases, thereby using our own cookies, deploying social plug-ins and operating social media sites. Further information on this can be found under Section 7 b) aa).

We use the personal data provided by you for the following purposes:

• Handling of your request(s) (e.g. via our registration form for the newsletter, contact forms of the contact persons )
• Performance of mandates as tax consultants or lawyers for our clients
• Direct marketing - among other things distribution of publications requested by you (e.g. WTS Info Letter/Newsletter, International WTS Journal, WTS Journal, WTS Tax Weekly) or press releases
• Forwarding of invitations on certain seminar topics
• Performance of contract, as well as measures prior to contract entering (e.g. seminar registration and conduction; project management, consulting services)
• Other establishing of contact (e.g. with our "Experts" named on the website)
• Customer care
• Decision about entering into an employment relationship and possibly also for the contracting, performance and termination of same
• Company and/or Group control (e.g. budget planning and reporting)
• Compliance with legal requirements (e.g. for the fulfilment of tax and legal (storage) obligations under commercial law and the application of a compliance management, including compliance checks)
• Data protection, security management and audits
• Information about activities in the WTS Community Network
• Authentication as a website administrator
• Distributing our website contents in the social media used by you
• Operating our social media channels

7. Legal basis for processing, including details of the purposes of processing

Basis for the processing of personal data are the GDPR, the German Federal Data Protection Act (BDSG) as well as further European and German legislation.

a. Overview of the legal bases

The following schedule gives you an overview of the existing and applied legal bases in accordance with GDPR and GDPA, to which we appeal to in the processing of your data, where appropriate:

Legal basis	Description / Explanation
Consent Art. 6 para. 1 s. 1 a) GDPR, in case of special categories of personal data Art. 9 para. 2 lit. 1 GDPR, in the case of employees and applicants, Art. 88 GDPR, in acc. with § 26 para. 2 BDSG (German Federal Data Protection Act), in the case of special categories of personal data in acc. with § 26 para 3 and § 22 para 2 BDSG.	This legal basis applies if you have agreed that we process your data for one or more purpose (e.g. subscription to publications, inclusion into our applicant pool, address references or registration with the WTS Community Network). If you have given us your consent, you can withdraw it at any time with effect for the future (see Section 10 i). Lawfulness of processing of your data up to the time of the withdrawal is not affected by the withdrawal.
Performance of a contract or request for pre-contractual measures Art. 6 para. 1 s. 1 b) GDPR	If we have entered into a contract with you (e.g. mandate agreement, consulting contract or participation in a seminar) or if you have requested us with pre-contractual measures (e.g. request for a seminar), these legal bases allows us to process all data from you which is necessary for the performance of the contract or for taking pre-contractual measures.
Compliance with a legal obligation Art. 6 para. 1 s. 1 c) GDPR	These legal bases allow us to process your data, when this is necessary for the fulfilment of a legal obligation we are subject to (e.g. for compliance with commercial, tax or professional law).
Legitimate own interests or those of third party Art. 6 para. 1 s. 1 f) GDPR	In part, we base the processing of personal data on legitimate interests pursued by us or by a third party. Potentially all legal, economic and idea-related interests, which are not disapproved of by the legal system, may form such legitimate interests. Examples are as follows: Data processing for communication with you as contact person on behalf of our client Direct marketing (provided that not already covered by Art. 6 para. 1 s. 1 a) GDPR), e.g. in order to let you or your company know about our seminars. You have the right to object to direct marketing at any time with effect for the future, as explained in Section 10g) Processing of personal data of contact persons at contract partners or prospective customers, as far as not already covered by Art. 6 para. 1 s. 1) GDPR. Data processing in context of professional activities by tax consultants or lawyers for our clients based on a respective mandate agreement Access to website and participation in surveys and studies conducted by us.
Decision on entering into an employment relationship Art. 88 GDPR in acc. with § 26 para. 1 s. 1 BDSG (German Federal Data Protection Act)	If you apply for a job with us, e.g. via our website (in the job portal), we use your data for the decision on entering into an employment relationship with you, as well as possibly for the performance and termination of the same.
Processing of special categories of personal data according to Art. 9 para. 1 GDPR on the basis of Art. 9 para. 2, in particular a), b) and f) GDPR	If you commission one of our commercial companies, we process, if necessary, special categories of personal data of you, your customers, employees and/or business partners within the framework of a corresponding agreement on the basis of separate consents of the data subjects (a), for the exercise of rights of the data subjects in the field of employment or social law (b) or for the establishment, exercise and defence of legal claims (f).
Processing of special categories of personal data according to Art. 9 para. 1 GDPR on the basis of Art. 9 para. 2 a), b), f) and g) GDPR	If you commission one of our tax consulting companies to provide businesslike assistance in tax matters, we will process special categories of personal data of you, your customers, employees or business partners, if necessary, within the framework of a corresponding mandate agreement, primarily on the basis of § 11 para. 2 s. 2 StBerG (German Tax Consultancy Act) in connection with Art. 9 para. 2 g) GDPR. Furthermore, we may process this data based on separate consents of the data subjects (a), for the exercise of rights of the data subjects in the field of employment or social law (b) or for the establishment, exercise and defence of legal claims (f).
Processing of special categories of personal data according to Art. 9 para. 1 GDPR on the basis of Art. 9 para. 2 a), b), f) and g) GDPR	If you commission one of our law firms to provide legal services, we will process special categories of personal data of you, your customers, employees or business partners, if necessary, within the framework of a corresponding mandate agreement on the basis of separate consents of the data subjects (a), for the exercise of rights of the data subjects in the field of employment or social law (b), for the establishment, exercise and defence of legal claims (f) or for reasons of substantial public interest (g) regarding the professional activity of lawyers as an independent organ of the administration of justice according to § 1 BRAO (Federal Lawyers' Act).

 

b. Details of the purposes of processing

aa. Surfing on our website (Page view, own cookies and web analytics, social media plug-ins)

(i) Communication with the website by opening the page

For technical reasons, our website automatically collects the IP address of the device you are using when you open our website. The legal ground for this processing is Art. 6 para. 1 s. 1 f) GDPR. The processing of this data is mandatory for opening our website, as the website data can only be sent to your browser using the IP address. Our legitimate interest is to provide you with a functioning website.

In addition, further data (such as information about the browser type and its version, the operating system of your end device, your Internet service provider, date and time of access, websites from which you have accessed our website, websites that are accessed by you via our website) are collected by us and stored in log files. This is also done for our legitimate interests based on Art. 6 para. 1 s. 1 f) GDPR. Our legitimate interest is to ensure the security of our website.

(ii) Use of cookies

We use so-called cookies on our website. Cookies are small data packages that are generated by our web server and stored on your computer's hard drive when your computer communicates with the web server. A distinction must be made between session cookies, which are used for the mere functionality of our website and which are deleted immediately after the browser is closed, and cross-session cookies (so-called persistent cookies), which are stored and used beyond one session. We use the following cookies:

(1) Use of our own cookies (admin cookie)

For technical reasons and to a very limited extent, we automatically collect data and information from the computer system of the device that is surfing our site. Currently, we use the session cookie "Pimcore_admin_sid.". This contains a session ID and the information that the page user has logged in as an administrator and thus has access to restricted areas of the website ("admin cookie"). The processing of this data is necessary for the functionality of our website and our legitimate interest is to identify our website administrators, to provide them with a functioning website. The legal basis for the processing of this cookie is accordingly our legitimate interests, according to Art. 6 para. 1 s. 1 f) GDPR.

(2) Web analytics software Matomo

We use the open source software tool "Matomo" on our website, a service of InnoCraft Ltd., 150 Willis St, 6011 Wellington, New Zealand, NZBN 6106769. Matomo enables us to analyze the use of our website and to make our offer more user-friendly. For this purpose, Matomo places cookies on the end device you use and transfers the usage data generated there to our server. Since this is only necessary to distinguish individual users, your IP address is shortened immediately after collection by the Matomo extension "AnonymizeIP". The software is set so that the IP addresses are not stored completely, but 2 bytes of the IP address are masked. A direct personal reference can be excluded from this point on. We therefore have no technical means of identifying you personally as a visitor. The IP address transmitted by your browser via Matomo is not linked to any other data we collect. No personal data is passed on to third parties or processed on servers that are outside the control of WTS. Data from repeated visits are not merged.

In doing so, we process the types of data mentioned in section 3 a (IP address or shortened IP address, information about the browser type and its version, the operating system of your terminal device, your Internet service provider, date and time of access, websites from which you have accessed our website, as well as websites that are accessed by you via our website) and base this processing on Art. 6 para. 1 s. 1 f) GDPR. The processing of this data is helpful for the further development of our website and our legitimate interest is to know the behavior of visitors to our website in order to improve our offer and thus make our website more attractive and user-friendly.

Matomo places the following cookies:

Cookie name	What is this cookie used for?	Period of validity
_pk_id	This cookie is used to record the behavior of visitors to our website and to recognize them on a subsequent visit. For this purpose, the cookie contains a pseudonymized user ID that is used exclusively for website analysis.	13 month
_pk_ref	This cookie is used to store attribution information as well as information from which web page you came to our website.	6 month
_pk_ses	These cookies are used to record your behavior on our website during the session. We use them to collect statistics about your website usage, such as your usage of the website. We use this data only for website analysis.	30 minutes
_pk_cvar
_pk_hsr
_pk_testcookie	This cookie is used to check whether your browser accepts cookies. It is deleted immediately after it has been set.	Session
piwik_ignore	This cookie is used to allow our web server to recognize your objection regarding the use of Matomo if you have declared it as explained below.	2 years

 

You can object to this processing at any time. If you do not agree with the storage and evaluation of this data from your visit, they explain this below by mouse click. In this case, a so-called opt-out cookie will be stored in your browser. This has the effect that Matomo does not collect any session data. Please note that deleting your cookies will also delete the opt-out cookie. In this case, you can activate it again.

For more information on Matomo's terms of use and data protection regulations, please visit: https://matomo.org/privacy/

 

(3) Cookie of our booking tool

We have integrated an booking tool on our website for event registrations. Our booking tool sets a cookie so that all functions can be used to their full extent. For this purpose, in particular the types of data mentioned in section 3.a (in particular cookie data) are processed. When using the booking tool, a cookie with the name "hl" is set. This has a validity period of 1 year and is used to save the language setting you have selected in the booking tool. We base the processing on Art. 6 para. 1 s. 1 f) GDPR. Our legitimate interest is to provide you with a functional booking tool that is adapted to your language settings. Information in connection with the processing when booking events can be found under sections 7.b.dd and ee.

(4) Prevention of cookies

You can avail yourself of your right to reject cookies at any time. Without prejudice to the other opportunities as explained above, you can prevent cookies by setting your browser so that no cookies are accepted at all, or that you issue individual acceptance for setting a cookie. Please consult the help section of your browser for details of this. You can also delete existing cookies via your browser. If you do not accept any cookies or delete existing cookies, it is possible that you cannot use all functions on a website. In addition, you can declare your objection or withdraw as explained in section 10 g and i.

(iii) Social media plug-ins (“share” buttons)

We use so-called social media plug-ins (“plug-ins” or “share buttons”) on our website. The providers of these are described in more detail below. This plug-ins allow you to share content on our website in the social media in which you are active on a purely voluntary basis. The plug-ins are embedded on a number of our sites through the so-called “double-click procedure”. This procedure prevents information about you being forwarded to the respective provider of the plug-in without any action from you. If you want to activate the plug-in of a particular provider, your action is required and you need to activate the plug-in.

In detail, the respective plug-in can be activated as follows:

If you click on one of the "Share Now" buttons on our website, a dialog box opens. Here you can activate the plug-ins (buttons) individually by clicking on them ("first click"). You can notice the active buttons by their colored background. The respective provider of the plug-in receives personal data about you solely from the activation. This is regardless of whether or not you are logged-in to the provider’s service when the button is activated. If you log-in to the respective provider or are already logged-in, the provider may be able to assign data to your social media account and merge these together with your plain data, which it has collected about you through cookies, even without our actions or our knowledge. We have no knowledge of the actual content of these data or the period in which these data were recorded.

If you now click on an active button (“second click”), you will be forwarded to the provider’s website, whereby you leave our website. You share the content selected on our page in the selected social media directly by double clicking on the button of the respective provider in the dialogue box. The respective provider of the plug-in thereby receives personal data about you. Details about this and information on how you may be able to prevent this on the pages of the respective provider can be found in the data protection policies of the respective provider of the plug-in. This is because we are, insofar, not responsible for processing the data. In the following sections, you find further information on the respective provider and how you can inspect the data protection policies of the respective provider of the plug-in.

The legal basis for our processing of your data explained in the section in the context of the various plug-ins is the consent you have given to us, Art. 6 para. 1 s. 1 a) GDPR, whereby you issue your consent via your click on the button of the respective provider. You can withdraw this consent for the future by either closing the website or by pressing the “Back” button on your web browser. This does not affect the legitimacy of the processing performed until then. Please note that we thereby collect the data solely for one-time transmission, so that processing by us is finished with the transmission. The deletion of content shared and the data processed in this context by the social media provider is therefore solely the responsibility of the social media provider. For the rest, the following applies with regard to the processing of your data in the context of the different plug-ins:

(1) Facebook plug-ins (“Share button”)

We use the share button of the social network Facebook on our website. This is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). This is designated with a Facebook logo. A summary of the Facebook plug-ins and what they look like can be found under the following external link: https://developers.facebook.com/docs/plugins

If you activate the Facebook plug-in on a page of our web presence, your browser makes a direct connection to the Facebook servers. The content of the plug-in is transmitted directly to your browser by Facebook and embedded into the page. This integration provides Facebook with the information that your browser has called-up the relevant page of our web presence, even if you do not have a Facebook profile or are not logged-in to Facebook. This information (including your IP address) is transmitted by your browser directly to a Facebook server in the USA, where it is stored. If you are logged-in to Facebook, Facebook can directly assign your visit to our website to your Facebook profile. If you interact with the plug-ins, this information is likewise transmitted directly to a Facebook server, where it is stored. In addition, the information is published on your Facebook profile and displayed to your Facebook friends.

The purpose and scope of processing your data by Facebook, your rights in this respect and the setting options to protect your private sphere can be seen in Facebook’s data protection policies under the following external link: https://de-de.facebook.com/policy.php

If you do not want Facebook to assign the data collected via our web presence directly to your Facebook profile, you need to log-out of Facebook before you visit our website. You can also completely prevent the loading of Facebook plug-ins with add-ons for your browser from the following external links, e.g. for

Mozilla Firefox: https://addons.mozilla.org/de/firefox/addon/facebook_blocker/

Opera: https://addons.opera.com/de/extensions/details/adblock-for-facebooktm/

 

(2) Twitter plug-ins (“Share button”)

Plug-ins from the microblogging service Twitter are used on our website. These are operated by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland (“Twitter”). The plug-ins are designated with a Twitter logo, for example in the form of a blue “Twitter bird”. A summary of the Twitter plug-ins and what they look like can be found under the following external link: https://dev.twitter.com/web/overview

If you activate the Twitter plug-in on a page of our web presence, your browser makes a direct connection to the Twitter servers. The content of the plug-in is transmitted directly to your browser by Twitter and embedded into the page. This integration provides Twitter with the information that your browser has called-up the relevant page of our web presence, even if you do not have a Twitter profile or are not logged-in to Twitter. This information (including your IP address) is transmitted by your browser directly to a Twitter server in the USA, where it is stored. If you are logged-in to Twitter, Twitter can directly assign your visit to our website to your Twitter account. If you interact with the plug-ins, for example by pressing the “Twitter” button, this information is likewise transmitted directly to a Twitter server, where it is stored. In addition, the information is published on your Twitter account and displayed to your contacts there.

The purpose and scope of processing your data by Twitter, your rights in this respect and the setting options to protect your private sphere can be seen in Twitter’s data protection policies under the following external link: https://twitter.com/privacy

If you do not want Twitter to assign the data collected via our web presence directly to your Twitter account, you need to log-out of Twitter before you visit our website. You can also completely prevent the loading of Twitter plug-ins with add-ons for your browser, e.g. with the script blocker “NoScript” from the following external link: http://noscript.net/

 

(3) LinkedIn plug-ins (“Share button”)

Our internet site features plug-ins from the social network LinkedIn or LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland (“LinkedIn”). You can recognize the plug-ins from LinkedIn by the corresponding logo or on the “Share on LinkedIn” button. When you visit our website, please note that the plug-in generates a connection between your internet browser and the LinkedIn server, insofar as you activate the plug-in, as described above. LinkedIn is thereby informed that our website has been visited by your IP address. If you click on the “Share on LinkedIn” button and are logged-in to your account with LinkedIn at the same time, you have the opportunity to link content from our internet site to your profile page on the LinkedIn account. You thereby enable LinkedIn to assign your visit to our website to your user account. Further details on the recording of data, on your legal opportunities and on the setting options can be found under the following external link: http://www.linkedin.com/static?key=privacy_policy&trk=hb_ft_priv

 

(4) XING plug-ins (“Share button”)

We use the “XING Share button” from New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany, on our website (“XING”). If you activate the share button on this internet site, your browser will temporarily generate a connection to XING servers to provide the “XING Share button” functions (particularly the calculation/display of the counter). XING does not store any personal data about you by calling-up this internet site. In particular, XING does not store any IP addresses. It also does not evaluate your user behavior by using cookies in combination with the “XING Share button”.
The current information on data protection regarding the “Share” button and further relevant information in this context can be called-up under the following external link: https://privacy.xing.com/en/privacy-policy

 

(5) YouTube plug-ins (“Share button”)

We use plug-ins from YouTube, a service of Google LLC., Amphitheatre Parkway, Mountain View, CA 94043, USA (“Youtube”). As soon as you visit our website, a connection to the YouTube servers is generated, insofar as you activate the plug-in, as described above. This informs the YouTube server of the particular page you have visited on our internet presence. If you are logged-in to your YouTube account, YouTube can assign your surfing behavior directly to your personal YouTube profile. If you do not want YouTube to have this opportunity, you need to log-out of your account before visiting our website. Further information on the processing of your data by YouTube can be seen in YouTube’s data protection policy under the following external link: https://policies.google.com/privacy?hl=de&gl=de#

bb. Establishing contact/ correspondence by email, telephone, fax, online conference systems of WTS, contact forms or e-mail; direct marketing

Provided that we should correspond by email and/or telephone, online conference systems of WTS, our contact form (e.g. within the context of client support), we process the data types indicated in Section to 3 b). The processing of the indicated data is necessary in order to handle your request and possibly also to take pre-contractual measures requested by you (e.g. in order to send you a quotation requested by you). The processing can also be necessary for the performance of a contract if such a contract should be established between you or your employer and us, and contract performance requires correspondence or at a minimum correspondence should be appropriate.

If you would like to contact one of our contact persons ("experts"), you can do so by clicking on the contact buttons provided with the information about him or her. These open the corresponding options for the communication (e.g. a contact form). The processing of the data provided is also necessary to answer your inquiry and to serve the purposes outlined above.

Legal bases for the processing explained in this section are Art. 6 para. 1 s. 1 a), b) and f) GDPR and § 7 para. 2 No. 2 UWG (German Act against unfair completion). As far as we build the processing upon legitimate interest, this consists of fulfilling our contractual main and secondary obligations with respect to your employer, of remaining in contact with you or your employer, of promoting our sales as well as of being able to handle your requests addressed to us adequately, in a timely manner and appropriately.

If you have explicitly consented to this, an establishing of contact can be implemented by email also for the purpose of direct marketing; an establishing of contact by telephone for the purpose of direct marketing can be implemented if we do not identify you as a consumer, if at a minimum your presumed consent is given. As a consumer, we would only contact you by telephone for the purpose of direct marketing if you have consented explicitly.

Provided that you have granted us your consent for the processing of your data for the purpose of direct marketing, you agree with the processing of your data for this purpose as follows:

"I herewith give my consent that the contact data indicated by me (email and telephone) may also be processed by WTS for establishing contact by email or telephone for the purpose of direct marketing. I can withdraw my consent to this at any time with effect for the future. The lawfulness of processing of my data up to the time of the withdrawal is not affected by the withdrawal. I have taken notice of the precise details of the processing of my data, as well as my rights concerning the data processing, as explained in the data protection information (in particular in Section 7 b, bb)."

You have the right to withdraw your consent at any time with effect for the future. Lawfulness of processing of your data up to the time of the withdrawal is not affected by the withdrawal. You can withdraw your consent as described in Section 10 i). As an alternative, it is further possible to be removed from the distribution list via a so-called "Unsubscribe link" at the end of a direct marketing email. Finally, you can also object to the ongoing processing of your data, as explained in Section 10 g).

 

cc. Subscription to newsletters and publications, information material and/or press releases

Provided that you request a newsletter, other publications, information material or press releases from us, we process the data types listed in Section to 3 c). In case of a transfer by email, the specification of your email address only is required for that. Furthermore, if you should request publications by letter post, the specification of your first and last name, your address data, as well as possibly the name of your company and your department (in case of distribution to your business address), are required. In this case, we base the processing on Art. 6 para. 1 s. 1 a) GDPR, since we process your data for distribution based on your consent.

(i) Declaration of consent for the subscription to email newsletters or other publications

If you give us your consent for the processing of your data for the dispatch (electronic and/or postal) of newsletters or other publications, you agreed with the processing of your data for this purpose as follows:

"I herewith give my consent, within the course of the registration to an email newsletter or another publication, that the personal data indicated by me can be processed for the dispatch of the publications selected by me. I can withdraw this consent at any time with effect for the future and thus cancel the respective publication again. The lawfulness of processing of my data up to the time of the withdrawal is not affected by the withdrawal. I have herewith taken note of the precise details of the processing of my data, as well as my rights concerning the data processing, as explained in the data protection information."

 

(ii) Declaration of consent to the subscription to press releases

If you give us your consent to the processing of your data for the purpose of the electronic distribution of press releases, you agreed with the processing of your data for this purpose as follows:

"I herewith give my consent that the personal data indicated by me within the course of the order of electronic press releases may be processed for the distribution of electronic press releases. I can withdraw this consent at any time with effect for the future and thus cancel the reception press releases. The lawfulness of processing of my data up to the time of the withdrawal is not affected by the withdrawal. I have herewith taken notice of the precise details of the processing of my data, as well as my rights concerning the data processing, as explained in the data protection information."

 

(iii) Withdrawal of your consent

You have the right to withdraw your consent at any time with effect for the future. Lawfulness of processing of your data up to the time of the withdrawal is not affected by the withdrawal. You can withdraw your consent as described in Section 10 i). As an alternative, it may further be possible to be removed from the distribution list of the respective newsletters, publications or press releases via the respective "Unsubscribe Link" at the end of each email with which we sent you newsletter, publications or press releases.

 

dd. Registration/Conduction of WTS events

If you register for one of our events/seminars, we process the data types designated in Section 3 d) for the seminar registration and conduction. We process this data based on Art. 6 para. 1 s. 1 b) GDPR, since the processing of the data is necessary in order to fulfil pre-contractual and contractual measures requested by you. Furthermore, we use this data in order to subsequently send you a summary of the documents of the event/seminar by email.

If not you, rather a third party (for example your employer), should be our contract, we process your personal data on the basis of Art. 6 para. 1 s. 1 f) GDPR. Here we have a legitimate interest in processing your data in our economic and legal interests, in complying with our contractual obligation with respect to this third party, as well as possibly processing in the interests of the third party, and in allowing you to participate in the event/seminar and, provided that for example you are an employee of the third party, to continue to train you correspondingly. In this case, you can object to the processing of your data, as explained under Section 10 g).

If you are interested in externally offered events and seminars, you can reach the corresponding offers via https://www.wts.com/de-de/events by selecting the category "External Lectures". Please note that in this case you will leave the WTS website to access further information or to register for the event and will be redirected to the website of the respective organizer.

 

ee. Registration/Conduction of WTS webinars and recording

If you register for a webinar, we process the data types designated in Section 3 e) for the webinar registration and conduction. We process this data on the basis of Art. 6 para. 1 s. 1 b) GDPR, since the processing of the data is necessary in order to fulfil the pre-contractual and contractual measures requested by you. Furthermore, we use this data to subsequently send you a summary of the documents of the webinar by email.

If not you, rather a third party (for example your employer) should be our contract, we base the processing described in the above-designated paragraph of this Section on Art. 6 para. 1 s. 1 f) GDPR. Here the legitimate interest lies in processing your data in our economic and legal interests, in complying with our contractual obligation with respect to this third party, as well as possibly in the interests of the third party, in allowing you to participate in the seminar and to continue to train you correspondingly. In this case, you can object to the processing of your data, as explained under Section 10 g).

Within the course of the conduction of the webinar, you further have the possibility to put questions to the lecturer. In this case, your question and request, as well as your voice, can be heard by all participants of the corresponding webinar. Processing of your question or your request and your voice in this case, we base on Art. 6 para. 1 s. 1 b) GDPR, since the processing of your data is necessary in order to respond to your question and/or your request and thus to comply with our contractual obligation.

Please note that it is not permitted to make recordings of our webinars. If we record our webinars ourselves, we will inform you of this in advance and ensure that your contributions are only recorded with your voluntarily declared explicit consent (Art. 6 (1) s. 1 a) GDPR). In this case, you will receive the consent text at the appropriate time before the start of the recording.

If you are interested in externally offered webinars, you can access the corresponding offers at https://www.wts.com/de-en/events by selection of the Category "External Lectures". Please note that in this case, for the call-up of further information and registration for the event, you leave the website of WTS and are transferred to the websites of the respective event organizer.

 

ff. Possible application through the WTS application form or sending documents by letter post or email (also by personnel providers)

If you apply to us for employment (e.g. via the application form that you can obtain from our website), we process the data types about you stated under Section 3 f), whereby the details you give must be truthful. We only process types of data other than those in Section 3 f), if and insofar as these help to prove your suitability for a certain position. If this is not the case, we do not have any intention to obtain such data. We process the corresponding data to decide upon commencing an employment relationship with you and, in case of a positive decision, also to initiate, perform and terminate the employment relationship, unless something to the contrary is stated below, on the basis of Art. 88 GDPR in conjunction with § 26 para. 1 s. 1 BDSG (German Federal Data Protection Act).

We would like to give you additional notices on data processing in an application procedure as follows:

In case you apply to WTS Group AG Steuerberatungsgesellschaft, this is responsible for processing your data. If you apply for employment with another WTS company in the sense of Section 14 or with WTS Legal Rechtsanwaltsgesellschaft mbH, WTS Group AG Steuerberatungsgesellschaft processes your data for the company concerned, so that the latter remains responsible for processing your data. You can reach WTS Group AG Steuerberatungsgesellschaft in this context under the following contact data:

WTS Group AG Steuerberatungsgesellschaft

Thomas-Wimmer-Ring 1
80539 Munich (Germany)
Tel.: +49 (0) 89 286 46-0
Fax: +49 (0) 89 286 46-111
Email: bewerbermanagement@wts.de

If you are interested in vacancies in the financial advisory sector, the appropriate jobs are offered through the career portal of FAS AG. In this case, please note that you will leave the WTS website and be forwarded to the website of FAS.

You have the chance to apply to us for a described vacancy or to apply on your own initiative. If you want to apply to WTS through the application form for an actual job vacancy or in the form of an initiative application, you have the option of disclosing the following data, among others:

• Master data (e.g. salutation, title, first name, last name)
• Address data (e.g. street, house number, post code, location, country)
• Contact data (e.g. telephone, mobile communications number, email address)
• Skills (e.g. language skills, additional qualifications)
• Application data (e.g. letter, CV, references, possible date of entry)

 

Some data fields are compulsory. This is because we cannot process your application further without these details and cannot check the extent of your suitability. Compulsory fields are marked with “*”. If you provide us with personal data (particularly in the free text fields and in the appendices that are not required for the purpose), we have no intention to obtain these data. The data sent as part of the initiative application may be viewed by the various WTS companies in order to check whether you are a suitable candidate for a vacant position. The legal basis for any data transfer that may take place in this context is a balancing of interests in accordance with Art. 6 para. 1 s. 1 f) GDPR. The legitimate interest of the WTS companies is to fill a vacancy in the best possible way.

In addition, you can have your application added to our pool of applicants. This gives you the chance of having your application inspected by other WTS companies or WTS Legal Rechtsanwaltsgesellschaft mbH or having it passed on to these, if these have a job vacancy that matches your credentials. If such a position becomes vacant, you may be contacted by the relevant WTS company or by WTS Legal Rechtsanwaltsgesellschaft mbH, informed about the position and invited to an interview. You will only be included in the pool of applicants after giving your explicit consent pursuant to Art. 6 para. 1 s. 1 a) GDPR in acc. with § 26 Abs. 2 BDSG under this phrasing:

"I consent my application data to be stored in the WTS pool of applicants for 12 months and therefore, to be accessed and used for own hiring by other companies in the WTS Group and by WTS Legal Rechtsanwaltsgesellschaft mbH. In case of suitable vacancies, these companies are allowed to contact me. I can withdraw my consent to this at any time with effect for the future, whereby the legitimacy of processing up to the date of my withdrawal is not affected by this. I am aware of the details of the processing of my data from the General Data Protection Information, in particular Section 7 b) ff).”

You can withdraw your consent at any time with effect for the future, as explained under Section 10 i). Regardless of this, you have the opportunity to delete your profile from our pool of applicants at any time. To do so, please contact bewerbermanagement@wts.de.

If you send application documents by email, please ensure that these are reasonably encrypted because data transmissions by email are insecure and it is possible that they are read by third parties.

References:

If you apply for a position for the career levels "Senior Manager" "Director" or "Partner", we may ask you to provide references and your express consent for us to contact them in the further course of the application process to secure our decision. In this respect, we base the processing on Art. 6 para. 1 s. 1 a) GDPR acc. with § 26 (2) BDSG, in the case of special categories of personal data in conjunction with § 26 (3) and § 22 (2) BDSG. You will receive the consent text at the appropriate time. The granting of your consent is voluntary. If you do not give us your consent, this will not result in any disadvantages for you.

Under the reservation of the statements in Section 5, your data recorded in the scope of an application will be deleted routinely after six months in case employment is rejected. However, the data will not be deleted after this period if you have given your consent to us, as described above, for inclusion in our pool of applicants. In this case, your data will be deleted twelve months after inclusion in the pool of applicants, unless you have explicitly given your consent to storage beyond this time or if you are undergoing an application procedure at this particular time. In the latter case, your data will be deleted again six months after conclusion of the application procedure.

gg. Use of our social media pages (Fanpages)

If you use our social media sites, we process the data types about you stated under Section 3 g). You have the opportunity to share, like or comment on our contributions, to ask questions and to assess or recommend us. You can also contact us through the contact options on our social media sites.

If you make an enquiry or comment on a contribution, in order to receive information about our products for the conclusion of a contract, we process your data based on Art. 6 para. 1 s. 1 b) or f) GDPR to perform the preliminary action you have requested to fulfil a contract with you or with your employer, or to be able to react to your contribution. In the latter case and insofar as you get into contact with us for pure information, we process your personal data on the basis of our legitimate interests pursuant to Art. 6 para. 1 s. 1 f) GDPR. In this case, our legitimate interests lie in answering your inquiry/comments, in presenting our enterprise on the internet in optimum fashion and in being able to inform interested parties

We process your profile picture on the basis of Art. 6 para. 1 s. 1 a) GDPR. You declare your consent that your photo may be displayed on our social media site (e.g. in the remarks section) by loading your profile picture onto your social media profile and in the interaction with our social media site. Your consent in this respect is given voluntarily and can be withdrawn at any time with effect for the future by adapting the settings for your private sphere in your social media profile. The legitimacy of processing up to the date of your withdrawal is not affected by this.

In addition, we can use the analysis tools reserved on the social media sites (e.g. Facebook Insights, Instagram Insights, YouTube Analytics). We do this to evaluate which contents are interesting for you as a user, the extent of the range of our contributions and the interaction of users with our contents. We thereby only have access to anonymized statistical information – thus not to personal data – that we cannot assign to you without additional information. These are processed on the basis of Art. 6 para. 1 s. 1 f) GDPR, whereby our legitimate interest is in optimizing our social media sites and making them more user-friendly.

If we show a photo of you in a post on one of our social media pages or if you can be seen and/or heard in a video, we process this data on the basis of consent granted to us pursuant to Art. 6 (1) s. 1 a) GDPR. You have the option to withdraw your consent in this regard at any time with effect for the future. The withdrawal does not affect the lawfulness of the processing of your data until the time of revocation.

Provided that you are displayed on our XING and LinkedIn social media pages in the area "Employee", with name and if applicable, photo, the processing is also implemented based on your consent according to Art. 6 para. 1 s. 1 a) GDPR. In this case, your consent is given by indicating in your Xing or LinkedIn profile that you work with WTS and have not carried out your privacy settings in a way a listing on our page is prevented. Your consent in this connection is also given freely and can be withdrawn by adaptation of your privacy setting at any time with effect for the future. If you should not give your consent, of course no disadvantages arise for you from this other than your name (and as applicable your profile photo) with Xing and LinkedIn not to be displayed on our page in the area “Employee”.

Please note that WTS does not have any control over the processing of your data in the sphere of control of the provider of the respective social media service or by service providers of other social media sites on the respective platform. For this reason, WTS also has no control over whether and, if so, to what extent your personal data are transmitted by such service providers to further recipients (also those in third states) or whether technical information concerning you is processed when you call-up our social media pages. Without prejudice to the data we process in accordance with Section 3 g), the following information can be called-up in particular:

• the IP address of your end device and/or your internet connection
• the date and time our social media sites are called-up
• your browser type
• the browser settings and the operating system
• the page last visited by you and the quantity of data transmitted

 

These statements concern all the following social media sites, unless we declare otherwise on the respective social media sites below.

(i) Facebook

As service provider of the Facebook-Fanpage listed in Section 3 g), we can e.g. inspect who calls our Fanpage and/or posts, comments and/or shares posts. We process your posts in this case, in order to facilitate the handling of your request and for example to answer a question raised by you. In addition, we process all information you provide when addressing us via the contact possibilities offered on our Facebook-Fanpage, e.g. your user name, the email address and your request. Furthermore, it is possible that Facebook Inc. 1601 Willow Road Menlo Park, CA 94025, USA (in the following "Facebook USA") and/or Facebook Ireland Ltd. 4 Grand Canal Square, Dublin 2, Ireland (in the following "Facebook Ireland"), provides us without being asked with anonymized - therefore not personal - statistical information, that we cannot assign to you without further additional information, about the use of our Facebook-Fanpage (e.g. .through so-called Facebook Insights).

Please find further information on the processing of your data by Facebook USA and/or Facebook Ireland in the data protection information via the following external link: https://www.facebook.com/about/privacy

 

(ii) LinkedIn

As a service provider of the LinkedIn page listed in Section 3 g), we can e.g. inspect who follows our LinkedIn page and which employees indicated to work with WTS in own LinkedIn profiles. Furthermore, we can see that our posts are marked with "I Like", shared or a comment has been written. In the case of comments, we process your data in order to facilitate a response to your request.

Furthermore, it is possible that LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland provides us without being asked with anonymized - therefore not personal - statistical information, which we cannot assign to you without further additional information, about the use of our LinkedIn page (e.g. analysis for company pages).

Please find further information on the processing of your data by LinkedIn in their data protection information via the following external link: https://www.linkedin.com/legal/privacy-policy

 

(iii) Twitter

As a service provider of the Twitter page listed in Section 3 g), we can e.g. see who follows our Twitter page, who likes to view our posts ("Tweets") regularly, who marks our Tweets with "I Like", who answers them or publishes them again ("retweets"). Provided that you respond to one of our Tweets, we process your data in order to facilitate your request to be handled. Provided that you follow us on Twitter, you have the possibility of writing a private message to us. In this case, we use your data in order to handle your request.

Further information on the processing of your data by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland can be found via the following external link: https://twitter.com/en/privacy

 

(iv) YouTube

As service provider of the YouTube page listed in Section 3 g), we can see e.g. who views our videos and who gave them an "I Like" note. Also we can view comments below our posts. We process your comments and your user name in this case, in order to facilitate the handling of your request and for example to answer a question raised by you.

Furthermore, it is possible that YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA provides us without being asked with anonymized - therefore not personal - statistical information, which we cannot assign to you without further additional information, about the use of our YouTube page (e.g. through YouTube Analytics).

Please find further information on the processing of your data by YouTube via the following external link: https://policies.google.com/privacy?hl=en-GB&gl=de (UK version)

 

(v) XING

As a service provider of the XING page listed in Section 3 g), we can see e.g., when and with which content evaluations are shared about our company. The corresponding evaluations are displayed on our Xing page pseudonymized and we do not have any possibility to assign these to a specific person. Furthermore, we can see which employees indicated on their own XING profiles that they work with WTS and have consented display on our XING page. Furthermore, we can see who "follows" our XING page and wishes display of news published by us on our Xing page in the own profile.

Further information on the processing of your data by New Work SE, Dammtorstrasse 30, 20354 Hamburg, Germany can be found via the following external link: https://privacy.xing.com/en/privacy-policy/printable-version

 

(vi) kununu

As a service provider of the kununu page listed in Section 3 g), we can see e.g., when and with which content evaluations are shared about our company. The corresponding evaluations are displayed on our kununu page pseudo-anonymized and we do not have any possibility to assign these to a specific person. Further information on the processing of your data by New Work SE, Dammtorstrasse 30, 20354 Hamburg, Germany can be found via the following external link: https://privacy.xing.com/en/privacy-policy/printable-version

 

(vii) Instagram

As a service provider of the Instagram page listed in Section 3 g), we can e.g. inspect, who calls our page and/or subscribes to it, assigns a "Like" to them (by clicking the "heart symbol" under a post), marks (“tags”) them, comments on them or publishes our Stories (content only available for 24 hours by repeating it on his/her own page ("repost"). We process your posts in this case in order to facilitate the handling of your request and e.g. to answer a question raised by you. In addition, we process all information you provide when addressing us via Instagram Direct (non-publicly visible message to us) or via the contact possibilities offered on our Instagram page, e.g. your user name, the email address and your request. Furthermore, it is possible that Facebook Inc. 1601 Willow Road Menlo Park, CA 94025, USA (in the following "Facebook USA") and/or Facebook Ireland Ltd. 4 Grand Canal Square, Dublin 2, Ireland (in the following "Facebook Ireland"), provides us without being asked with anonymized - therefore not personal - statistical information, that we cannot assign to you without further additional information, about the use of our Instagram page (e.g. .through so-called Instagram Insights).

Please find further information on the processing of your data by Facebook USA and/or Facebook Ireland in the data protection information via the following external link: https://help.instagram.com/519522125107875

 

hh. Registration for the WTS Community Network

Insofar as you register for the WTS Community Network, we process the categories of data from you specified under section 3 h). We base the processing of your data on Art. 6 para. 1 s. 1 a) GDPR. Provided that you give us your consent for the processing of your data for the purpose of information about the activities of the WTS Community Network, you agree with the processing of your data for this purpose as follows:

"I give my consent that the personal data indicated by me to WTS Community Network for registering with the WTS Community Network may be processed for these purposes. I can withdraw my consent at any time with effect for the future and herewith stop reception of messages from the WTS Community Network. The lawfulness of processing of my data up to the time of the withdrawal is not affected by the withdrawal. I have taken notice of the precise details of the processing of my data, as well as my rights concerning the data processing, as explained in the data protection information under section 7 b) hh)."

You have the possibility to withdraw your consent at any time with effect for the future. Lawfulness of the processing of your data is not affected by the withdrawal up to the time of the withdrawal. You can withdraw your consent as described in Section 10 i). Furthermore, an possibility alternative exists to deregister via the respective "Unsubscribe Link" at the end of every email, with which we sent you information related to the WTS Community Network.

 

ii. Activity as tax consultants or lawyers for our clients

As far as you or your employer as your business partner have established a mandate relationship with us, we process the data categories listed in Section 3 i), to act as tax consultants or lawyers under this mandate. Hereby the following purposes are pursued: fulfilment of our obligations under the Money Laundering Act, execution of the mandate relationship including correspondence, fulfilment of our contractual, statutory and professional obligations as a tax consultancy or law firm, invoicing, processing of mutual claims arising from and in connection with the tax consultancy or legal mandate (e.g. claims for performance, remuneration and liability); the legal basis for the processing is Art. 6 para. 1 s. 1 b) (mandate agreement), c) (legal obligation of WTS) and f) (legitimate interests of WTS) GDPR. To perform the mandate we need different data depending on the type of assignment. This may also include special categories of personal data such as religious affiliation, political opinions or health data. We process these on the basis of Art. 9 para. 2 a), b), f) or g) GDPR. We would ask you to indicate only those types of data that we require for processing in individual cases. If you provide data that we do not require for processing the mandate, we do not have any intention to obtain this data.

 

jj. Other purposes (surveys and studies, company-/Group management, compliance, security and data protection, Group Security, public health)

It is possible that the data types designated in Section 3 jj are also processed for the following purposes and on the following legal bases:

 

(i) Surveys and studies

We conduct surveys and studies you can voluntarily participate in. You also may, as appropriate, obtain the results and, if available also the results evaluated individually for you. We base the processing of your data on Art. 6 para. 1 s. 1 f) GDPR. Our legitimate interest is to identify trends, opinions and experiences of the participating businesses, especially regarding compliance with regulatory requirements. The evaluated results serve to develop our consultancy portfolio and to identify (individual) consultancy needs. Herein we have an economic interest. Therefore, our interest is to be qualified as legitimate within the meaning of the aforementioned provision. Affected by this is your IP address, which is required to access the website with the survey tool. We ask you not to enter any information in free text fields which contain personal references (e.g. names, but also functions in specific authorities). Should this nevertheless be the case, we have no intention to collect such data. The inevitable processing of this data, which we cannot prevent but can only terminate as quickly as possible, is also based on our legitimate interest in accordance with Art. 6 para. 1 s. 1 f) GDPR. If you wish to receive the general survey results or an individual evaluation of your entries by e-mail, we will process your name and the contact data requested to fulfil this wish and thus on the basis of Art. 6 para. 1 s. 1 b) GDPR. Your individual evaluation we will only provide to you.
If we contact you, following the evaluation, and provide you with your individual or the cross-company overall results, the statements made under Section 3 b) and 7 b) bb) apply.

 

(ii) Company and/or Group control

Within the scope of a consistent Group reporting and management (e.g., for customer support), we collect data for company and/or Group management (e.g., for budget planning and reporting).). Legal basis therefore is Art. 6 para. 1 s. 1 f) GDPR. Our legitimate interests are in the Company and Group control, as well as in a consistent Group management, for which we have an economic interest. Therefore our interest is to be qualified as legitimate according to this requirement. Affected by this are particularly the data types designated in Section 3, which we collected from you in connection with the contract performance and/or the provision of pre-contractual measures (e.g. in connection with seminar registrations).

 

(iii) Compliance with our legal obligations (Compliance)

To comply with legal requirements incumbent to us (e.g. for the fulfilment of tax and commercial legal obligations and the application of a Compliance Management, including compliance checks) data can be collected. The legal bases for this is Art. 6 para. 1 s. 1 c) GDPR.

 

(iv) Data protection and security management

In order to comply with the data protection requirements for which we are responsible, audits may also be carried out by our data protection officer Legal basis with respect to audits by our Data Protection Officer are Art. 6 para. 1 s. 1 c) GDPR, particularly in connection with Art. 24 para. 2 s. 2 and Art. 38 para. 2 and Art. 39 para. 1 b) and c) GDPR, and in addition Art. 6 para. 1 s. 1 f) GDPR. Our legitimate interest is in secure and data protection compliant processing of personal data.

 

(v) Visitor self-information for COVID-19 prevention

Due to the current spread of the new corona virus (COVID-19), we are required to implement preventive measures to contain the corona pandemic and to protect our employees, clients, business partners and visitors. Therefore, until further notice, we ask all our external visitors, before entering one of our offices, to answer in writing questions concerning their stay in areas in Germany identified by the Robert Koch Institute (RKI for short) as international risk areas or particularly affected areas in Germany, contact with demonstrably infected persons and their own current health symptoms, which are considered to be typical. We also collect the following data directly from you: Name, first name, company, function or title, address, place, date, signature. The purpose of the collection and data processing is to prevent or contain serious health risks, in particular to contain the COVID 19 pandemic, in particular by assessing the risk that could be associated with an external person staying on our premises. Should it subsequently turn out that contact with a demonstrably infected person may have occurred on our premises, we will, if necessary, provide your contact details to the authorities responsible for infection control and, if necessary, contact you as well. We process the data on the basis of Art. 6. para. 1 s. 1 f) GDPR (legitimate interests, in particular defense against health risks). With regard to data concerning health (special categories of personal data), we base our processing on Art. 9 para. 2 i) GDPR in conjunction with § 22 para. 1 no. 1 c) German Federal Data Protection Act, BDSG (public interest in the field of public health, such as protection against serious cross-border health risks). If we are legally obliged to do so, we will pass on your data to the relevant authorities so that they can contact our visitors for further action. In this respect, we process your data on the basis of Art. 9 para. 2 g) GDPR in particular in conjunction with §§ 25 para. 2, 16 Act on Protection against Infection, IfSG (Federal German Infection Protection Act), as well as, if applicable, corresponding legal regulations of the federal states according to § 17 para. 4 IfSG. There is basically no obligation towards us to provide us with this data in connection with a visit to our website. Without this information, however, it is not possible for us to make a corresponding risk assessment. Therefore, in these cases it is generally not possible to enter our premises for the reasons mentioned above until further notice.

8. Recipients or categories of recipients of personal data

We transfer personal data to the following recipients:

• Public entities, to which the data must be sent according to legal stipulations (e.g. financial authorities, supervisory authorities, social insurance carriers, professional associations , possibly prosecution authorities)
• Our clients, as necessary for fulfilment of contract
• Tax consultants and/or lawyers involved in fulfilment of contract as aligned with our clients
• Banks, insurance companies
• Internal departments which participate in the performance of the respective tasks, basically: Marketing, Personnel, IT & Security)
• Contractors (service enterprises, such as e.g. IT service providers which can be settled inside or outside of the WTS Group)
• Other Group companies and departments which participate in the performance of the respective tasks, e.g. Marketing, Personnel, IT, Information Security and Data Protection)
• Other WTS companies (these are those of the WTS Group, WTS Legal Rechtsanwaltsgesellschaft mbH and WTS Global Vereniging, Rotterdam, Netherlands as well as their Members firms)
• Providers of our social media pages
• Organizer and co-organizer of events

 

9. Transfer of personal data to third countries

Basically, we do not transfer personal data which we collect via over our website to countries outside of the European Union or the European Economic Area (third countries). If data is transferred to third countries as necessary for contract performance, for internal communication or administration within the WTS, or due to the registered office of a service provider being in a third country, this is always subject to prior detailed checking and assessment by our Data Protection Officer. It is also only implemented if, at the site in the third country, an adequate data protection level is ensured or appropriate safeguards grant an adequate data protection level (Art. 45 ff. GDPR) or in exceptional cases where neither an adequacy decision nor appropriate safeguards are required (Art. 49 para. 1 GDPR). Provided that and insofar as you wish to be provided with further information on the individual safeguards, you can refer to our Data Protection Officers named in Section 2.

10. Your rights with respect to data processing

You have the following rights with respect to us, as explained below, granted by Art. 15 to 21 GDPR, as well as the right to any-time withdrawal of your consent declared with respect to us, and the right to lodge a complaint to the supervisory authorities. You can exercise your rights form-free with respect to us and do this either directly to the contact data indicated in Section 1 or via our Data Protection Officer whose contact data can be found in Section 2. Except for possible transmission or connection charges, no costs arise to you for that.

a. Right to access (Art. 15 GDPR)

You have the right to obtain confirmation from us whether or not and which personal data is processed by us related to your person: With regard to this data in particular, you can obtain information about the purposes related to the processing (Section 6 and 7), the categories of data that we process (Section 3), the categories of recipients (Section 8) and our intention to transfer the data to recipients in a third country (Section 9). The information furthermore contains specifications about the origin of the data, provided that it has not been obtained from you. You furthermore have the right to obtain a copy of the personal data which is subject of the processing, insofar as the rights and freedoms of other persons with respect to their personal data are adversely affected.

 

b. Right to rectification (Art. 16 GDPR)

You have the right to obtain from us the rectification without undue delay of inaccurate personal data concerning you. You have furthermore the right to obtain completion of incomplete personal data, considering the purposes of the processing - also by means of a supplementary statement.

 

c. Right to erasure (Art. 17 GDPR)

You have the right to obtain from us erasure without undue delay of your personal data if one of the following grounds applies and none of the exceptions listed below the grounds applies:

• The data processed by you is no longer necessary for the purposes explained in this data protection information.
• You have withdrawn your consent (see also Section 10. i) and we do not have any other legal basis for processing your data.
• The data was processed unlawfully.
• Deletion is required for compliance with a legal obligation in union or member state law which we are subject to.
• You have objected to the processing of your data by us (see also Section 10. g) and we do not have any overriding legitimate reasons for the processing of your data.

 

We do not have to comply with your request for erasure, however, if one of the following applies:

• The processing is necessary for the exercise of the right to free speech and to information.
• The processing is necessary in order to fulfil a legal obligation we are subject to according European Union or member state law (e.g. legal retention obligations).
• The processing is required for the establishment, exercise or defence of legal claims.
• The processing is required for reasons of public interest in the public health area.

 

d. Right to restriction of the processing (Art. 18 GDPR)

You have the right to obtain from us the restriction of the processing of your personal data. You have this right in particular if one of the following applies:

• You contest the accuracy of your data.
• The processing of the data is unlawful and you oppose the erasure of the data.
• We do not need your data any longer, however you still require it for the establishment, exercise or defence of legal claims.
• You have objected to the processing (see also Section 10 g)) and we are in the process of verification whether our legitimated grounds override your legitimate grounds for the objection to the processing.

 

e. Right to notification (Art. 19 GDPR)

If you have claim from us to rectify or erase your data or to restrict their processing, we are obliged to inform all recipients to whom your personal data was disclosed to carry out the rectification, or deletion of the data or the restriction of the processing, unless this proves impossible or involves disproportionate effort. You have likewise the right with respect to us to be informed of these recipients.

 

f. Right to data portability (Art. 20 GDPR)

You have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format and to transmit it to another controller, as far as you have provided this data to us based on consent or a contract, and the data is processed by automated means. You have the right to have the data transmitted directly from us to the other controller, as far as this is technically feasible and the rights and freedoms of other persons are not adversely affected.

g. Right to object (Art. 21 GDPR)

You have the right to object to the processing of personal data concerning you at any time, for reasons related to your particular situation, as far as the processing of this data is based the necessity for the purposes of the legitimate interests pursued by us or those by a third party, or for the performance of a task that is in the public interest.

You can object to the processing of your data for direct marketing purposes at any time with effect for the future. We will always follow your objection. Please note however, that we cannot exclude the case where, on an individual basis, we are possibly not capable of calling back a marketing measure. if your objection should reach us at a time when the marketing measure has already been activated by us irrevocably. In such a case, however, we will of course exempt you from the distribution of every future marketing measure.

h. Right to complain with a supervisory authority (Art. 77 GDPR)

In addition, you can at any time lodge a complaint with the competent data protection supervisory authority, for example at your place of residence or at the place of the suspected infringement.

The following data protection supervisory authority is competent for WTS:

Bayerisches Landesamt für Datenschutzaufsicht (Bavarian State Office for Data Protection Supervision)
Promenade 27
91522 Ansbach
Germany
https://www.lda.bayern.de

 

i. Right to withdraw consent

Provided that, and as far as, you have given us your consent to the processing of your data, you have the right to withdraw this consent at any time with effect for the future. Lawfulness of the processing based on consent up to the time of the withdrawal is not affected by the withdrawal, rather the withdrawal can only affect the lawfulness of future processing.

11. No obligation to provide data by yourself

No legal obligation exists to provide your personal data to us.

Should you prevent, e.g. technically, that we are provided with data which is required for the use of our website, it is possible that you cannot use our services or can use them to a limited extent only.

The provision of personal data in the course of ordering publications, newsletters, information material and press releases, is freely given and not contractually or legally required. If you do not provide necessary data this may imply we are incapable of sending you the publications requested.

The provision of the personal data within the course of the registration to our seminars is required for a contract conclusion, as well as for its conduction. A non-provision of this data can result in our not being able to close any contract concerning your participation in a seminar and or to provide any corresponding performance.

The provision of your data within the course of establishing of contact with us via our contact form, or the establishing of contact with one of our Experts, is voluntary. Without the required information, in particular a contact channel, however, it is not possible for us to handle your request.

The provision of your personal data within the course of an application is necessary for the decision on the establishment of an employment relationship with you. A non-provision of this data can result in our not being able to make any decision.

There is basically no obligation to provide us with personal data in the context of a contract established between you or your employer and us. In case of a non-provision of data this may imply we may not be able to provide you or your employer with any, correct or comprehensive advice.

12. Automated decision making, including profiling, as specified by Art. 22 GDPR

Your personal data will not be used for automated decision-making, including profiling, in accordance with Art. 22 para 1 and 4 GDPR. Provided that these are used, we inform in detail regarding the logic as well as the significance and the envisaged consequences of such a processing for the data subject.

13. Data Security

We take technical and organisational security measures to protect your personal data against accidental or unlawful deletion, against alteration or loss and against unauthorised transmission or access.

14. Validity of this Data Protection Information for other WTS companies 

If and insofar as you are in contact with another company in the WTS Group (referred to below as “other WTS company”) or WTS Legal Rechtsanwaltsgesellschaft mbH, this other WTS company or WTS Legal Rechtsanwaltsgesellschaft mbH processes your data. If this other WTS company or WTS Legal Rechtsanwaltsgesellschaft mbH refers to this Data Protection Information (e.g. in an email signature), the statements contained in this Data Protection Information also apply accordingly to the other WTS company or to WTS Legal Rechtsanwaltsgesellschaft mbH, if and insofar as the statements made in this Data Protection Information do not refer solely to the provision and functions of this website and our social media sites.

The information in this Data Protection Information therefore applies accordingly to other WTS companies and to WTS Legal Rechtsanwaltsgesellschaft mbH, which refer to this Data Protection Information , particularly the Sections stated below: Section 2 (Data Protection Officer), Section 3 (data categories, with the exception of a), c), g) and h), Sections 4 to 7 (with the exception of Section 7 b) aa), cc), gg) and hh) and Sections 8 to 15. The names and contact data of this other WTS company or WTS Legal Rechtsanwaltsgesellschaft mbH can be taken from the respective email signature, the company information or, in the case of postal correspondence, the respective sender details.

15. Status and changes to this data protection information

This data protection information corresponds to the status indicated below. The right to change this data protection information remains reserved. We therefore kindly request you to inspect the data protection information on a regular basis to get informed about possible changes.

As of April 2021