General Privacy Policy

Thank you for your interest in our online presence. The protection of your personal data is a key concern for WTS Tax AG (hereinafter referred to as "WTS", "we" or "us"). With this General Privacy Policy, we would like to inform you in accordance with the provisions of the EU General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 – hereinafter "GDPR"), the German Federal Data Protection Act (hereinafter "BDSG") and the German Telecommunications Digital Services Data Protection Act (hereinafter "TDDDG") about the processing of your personal data in the context of the use of the websites available at https://www.wts.com/de-de (hereinafter "Website"), the use of our services and when contacting us.

Please note that this general privacy policy does not apply to our websites through which you can submit electronic job applications to us. For these websites, the data protection information for the job application process applies, which can be accessed via the following link: https://wts.com/de-de/datenschutzinformationen-bewerbungsprozess

The General Privacy Policy only applies if and to the extent that we also process your data outside of the job application process (e.g. if you contact us in other ways). In the event of a conflict with this General Privacy Policy, the data protection information for the job application process in relation to an application to us shall take precedence.

To navigate directly to the individual chapters of the data protection declaration, please click on the upper points highlighted in blue.

1. Controller
2. Data Protection Officer
3. No need for you to provide data
4. Sources of the processed personal data
5. Duration of storage
6. Purposes for which personal data are processed
7. Legal basis for the processing, including details of the processing purposes
8. Transfer of data to third parties
9. Transfer of personal data to third countries
10. Other data processing
11. Your rights in relation to data processing 
12. Automated decision-making, including profiling, within the meaning of Art. 22 GDPR
13. Data security
14 Validity of this privacy policy for other WTS companies
15. Status and amendments to this privacy policy

 

1. Controller

WTS Tax AG
Friedenstraße 22
81671 Munich, Germany

Tel. +49 (0) 89 286 46-0
Fax +49 (0) 89 286 46-111
E-Mail: info@wts.de

WTS Tax AG is represented by the Management Board: Fritz Esterer, Dipl.-Oec., Tim Zech, Jürgen Scholz

WTS Tax AG operates the Website as the sole responsible party, unless expressly stated otherwise below. On the Website, it also provides information about all companies belonging to the WTS Group and about WTS Legal Rechtsanwaltsgesellschaft mbH. With regard to the validity of this General Privacy Policy, please also refer to section 14.

2. Data Protection Officer

The Group Data Protection Officer of WTS is

Dr. Nicolai Wiegand
Taylor Wessing Partnerschaftsgesellschaft mbB
Isartorplatz 8
80331 München
T +49 (0) 89 21038-237
E-Mail: N.Wiegand@taylorwessing.com

with the exception of the following companies: WTS PRETAX GmbH, WTS RET GmbH, First Council GmbH, Gesellschaft für internationale Zusammenarbeit im Bereich des Steuerrechts mbH - and WTS Brühmüller GmbH.

The data protection officer of WTS Advisory AG is: Beatriz Loos, SiDIT GmbH, info@sidit.de, +49 (0) 931 / 780877-0 

3. No need to provide personal data

There is no legal obligation to provide us with your personal data. If, for example, you technically prevent us from receiving the data required to use our Website, it is possible that you will not be able to use our services or only to a limited extent.

The provision of personal data when ordering publications, newsletters, information material and press releases is voluntary and is neither contractually nor legally required. If you do not provide this data, we may be unable to send you the requested publications.

The provision of personal data when registering for our seminars is necessary for the conclusion and performance of a contract. If you do not provide this data, we may be unable to conclude a contract for your participation in a seminar or provide the corresponding service.

The provision of your data in the context of contacting us via our contact form or contacting one of our experts is voluntary. However, without the required information, in particular a contact option, it is not possible for us to process your request.

In principle, we are under no obligation to provide us with your personal data in the context of a client relationship between you or your employer. However, if you do not provide it, we may not be able to provide you and/or your employer with accurate and/or complete advice.

4. Sources of the processed personal data

In principle, we only collect your personal data from you. Should this be different in exceptional cases, however, we will inform you separately. If we do not receive your personal data from you during the processing of your mandate, it will be forwarded to us by our clients or the relevant public authorities, such as tax authorities or social security institutions. When processing data via our online forms (e.g. the newsletter registration form or contact forms), we receive the data from the person who enters it into the relevant form.

5. Storage period

The personal data is only stored for as long as is necessary to fulfill the respective purpose associated with the processing. If this purpose no longer applies, we delete or anonymize the data as a matter of principle, provided and insofar as the deletion does not conflict with any legitimate retention reasons and obligations (e.g. in accordance with tax or professional regulations). In the latter case, the data will only be processed to a limited extent, i.e. only to fulfill the reason for retention or the retention obligation and otherwise only with your consent, to assert, exercise or defend legal claims, to protect the rights of another natural or legal person or for reasons of an important public interest of the European Union (EU) or an EU member state. If there is a retention obligation, we will delete or anonymize the data once the retention obligation no longer applies.

6. Purposes for which personal data are processed

We observe the principle of processing personal data for a specific purpose and only process your personal data for the purposes explained in this general privacy policy. We process your personal data for the following purposes:

• Processing your request(s) (e.g. via our newsletter registration form, contact forms of the contact persons)
• Handling mandates as tax consultants or lawyers for our clients
• Direct advertising - including the sending of publications requested by you (e.g. WTS Infoletter/Newsletter, International WTS Journal, WTS Journal, WTS Tax Weekly) or press releases
• Sending invitations to specific seminar topics
• Performance of contracts and implementation of pre-contractual measures (e.g. seminar registration and implementation, project management, commercial consulting)
• Customer care
• Information about activities in the WTS Community Network
• Authentication as website administrator
• Distribution of our Website content in social media used by you (social media)

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

The basis for the processing of personal data is the GDPR, the BDSG and other European and German regulations and laws.

a. Overview of the legal bases

The following list gives you an overview of the legal bases in accordance with the GDPR that we may rely on when processing your personal data:

Legal basis	Description / Justification
Consent Art. 6 para. 1 s. 1 lit. a) GDPR, in case of special categories of personal data Art. 9 para. 2 lit. a) GDPR	This legal basis applies if you have agreed that we process your data for one or more purpose (e.g. subscription to publications, 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.
Fulfillment of the contract or implementation of pre-contractual measures Art. 6 para. 1 sentence 1 lit. b) GDPR	If we have concluded a contract with you (e.g. mandate agreement, consulting contract or for participation in a seminar) or if you have asked us to carry out a pre-contractual measure (e.g. request for a seminar), this legal basis allows us to process all data from you that is necessary to fulfill the contract or to carry out the pre-contractual measure.
Fulfillment of a legal obligation Art. 6 para. 1 sentence 1 lit. c) GDPR	This legal basis allows us to process your data if this is necessary to fulfill a legal obligation (e.g. to fulfill commercial or tax law or professional obligations) to which we are subject.
Legitimate own interests or legitimate interests of third parties Art. 6 para. 1 sentence 1 lit. f) GDPR	In some cases, we also base the processing of personal data on our legitimate interests or the legitimate interests of third parties. Legitimate interests are all legal, economic and non-material interests that are not disapproved of by the legal system.
Processing of special categories of personal data pursuant to Art. 9 para. 1 GDPR on the basis of Art. 9 para. 2, in particular lit. a), b) or 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 (lit. a), for the exercise of rights by the data subjects in labor or social law (lit. b) or for the assertion, exercise and defense of legal claims (lit. f).
Processing of special categories of personal data pursuant to Art. 9 (1) GDPR on the basis of Art. 9 (2) (a), (b), (f) or (g) GDPR	If you instruct one of our professional tax advisory firms to provide business-related assistance in tax matters, we will, if necessary, process special categories of personal data of you, your clients, employees or business partners within the framework of a corresponding mandate agreement, primarily on the basis of Section 11 (2) sentence 3 German Tax Consultancy Act in conjunction with Art. 9 (2) (g) GDPR. Furthermore, we may also process this data on the basis of separate consents of the data subjects (lit. a), for the exercise of rights by the data subjects in labor or social law (lit. b) or for the assertion, exercise and defense of legal claims (lit. f).
Processing of special categories of personal data pursuant to Art. 9 (1) GDPR on the basis of Art. 9 (2) (a), (b), (f) or (g) GDPR	If you instruct one of our law firms to provide legal services, we process, if necessary, special categories of personal data of you, your clients, employees or business partners within the framework of a corresponding mandate agreement on the basis of separate consents of the data subjects (lit. a), for the exercise of rights by the data subjects in labor or social law (lit. b), for the assertion, exercise and defense of legal claims (lit. f) or for reasons of substantial public interest (lit. g) in the activities of lawyers as an independent organ of the administration of justice pursuant to Section 1 of the Federal Lawyers' Act (BRAO).

b. Details of processing purposes

aa. Use of our website

(i) Calling up our website

For technical reasons, when you visit our Website, it automatically records the IP address (in some cases only in abbreviated form) of the device you are using. We base this processing on Art. 6 para. 1 sentence 1 lit. f) GDPR. The processing of this data is absolutely necessary for accessing our Website, as the Website data can only be sent to your browser using the IP address. Our legitimate interest lies in providing you with a functioning Website. In addition, further data (such as 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 accessed our Website, websites that you access via our Website) is collected by us and stored in log files. This is also done for our legitimate interests on the basis of Art. 6 para. 1 sentence 1 lit. f) GDPR. Our legitimate interest lies in ensuring the security of our Website.

(ii) Use of cookies and similar technologies

We use cookies and similar technologies (collectively "Cookies") on our Website. Cookies are data records and information that are generated by our web server and stored on the hard disk of your end device when your computer communicates with the web server.

(1) Consent management platform

We use a consent management platform (hereinafter “CMP”) on our Website to obtain and manage the consent of Website users to the use of Cookies. For this purpose, (a) opt-in and opt-out data, (b) user agent, (c) consent ID, (d) time of consent, (e) consent type, (f) banner language, (g) IP address and (h) geographical location are stored.

The legal basis for the processing of this personal data is the fulfillment of our legal obligations, as we are legally obliged to record and document consents given by users of our Website and to give you the opportunity to revoke consents already given (Art. 6 para. 1 sentence 1 lit. c GDPR and § 25 para. 1 sentence 2 TDDDG).

For the processing of personal data through the use of Cookies in connection with our Website, please refer to the cookie information provided on our CMP, which is part of this General Privacy Policy.

(2) Classification of cookies

We use the following types of cookies on our website for the following purposes:

Technically necessary cookies

Necessary Cookies are essential for the proper functioning of our Website; they enable you to navigate our Website efficiently and use functional features. An example of this is saving your last actions (e.g. entered text) when you return to a page within the same session.

The legal basis for the processing of this data is the fulfillment of our contractual obligations (Art. 6 para. 1 sentence 1 lit. b) GDPR) or the protection of our legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), which consist in particular in making our Website available to you with its essential functions.

Cookies that are not absolutely necessary

Non-essential cookies can be divided into the following subcategories:

• Analysis/statistics Cookies: These Cookies help us to understand how visitors interact with our Website by providing us with information such as which web pages or search terms visitors use to reach our Website, how long they usually stay on our Website or how many subpages they visit on average. We use this information to improve the content of our Website and to compile statistics on the individual use of our Website for internal market research purposes.
• Advertising Cookies: These Cookies are used to provide you with content that is relevant to you and your interests (direct marketing). They can be used to display targeted advertising or to limit the frequency of advertisements displayed. They also help us measure the effectiveness of advertising campaigns on our Website and other websites. We may also use these Cookies to remember which websites you have visited.

 

The legal basis for the processing of this data is your consent (Art. 6 para. 1 sentence 1 lit. a) GDPR and Section 25 para. 1 sentence 1 TDDDG), which you have given on our CMP. You can refuse the use of non-essential Cookies on our CMP or delete the data collected in this context at a later date via the browser settings.

 

bb. Contact/correspondence by telephone, fax, WTS online conference systems, contact forms (including request for quotation/RfP form) or e-mail; direct advertising

If you contact us via our contact form or by email, we will process the data you provide (e.g. personal and/or contact data, message content and any documents transmitted in the process) to process your request and to contact you. The provision of this data is necessary in order to process and respond to your request. The legal basis for the processing of your personal data is the fulfillment of our contractual obligations (Art. 6 para. 1 sentence 1 lit. b) GDPR) as well as the protection of our legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), which include, among other things, contacting and communicating with you about the concerns you have raised with us.

If we are in contact with you via telephone, fax or the online conference system of WTS (e.g. in the context of client support), we process personal master data (e.g. salutation, title, first name, surname), contact data (e.g. e-mail address, telephone number or fax number), message content/subject matter of your request/content of the conversation, any transmitted video/images and any contents of documents. The processing of the data provided is necessary in order to respond to your request and, if applicable, to carry out pre-contractual measures requested by you (e.g. to send you an offer requested by you). Processing may also be necessary for the performance of a contract if such a contract exists between you or your employer and us and this requires us to contact you or if such contact is at least expedient in the context of the performance of the contract. The legal basis for the aforementioned processing is Art. 6 (1) sentence 1 lit. (a), (b) and (f) GDPR. Insofar as we rely on a legitimate interest, this is to fulfill our primary and secondary contractual obligations to your employer, to stay in contact with you or your employer, to promote our sales and to be able to process your requests addressed to us appropriately, promptly and efficiently.

If you have expressly consented to this, we may also contact you by email for the purpose of direct marketing; if we do not contact you as a consumer, we may also contact you by telephone for the purpose of direct marketing if we have at least your presumed consent. As a consumer, however, we would only contact you by telephone for the purpose of direct advertising if you have expressly consented to this.

You have the option of withdrawing your consent at any time with effect for the future. Revocation does not affect the lawfulness of the processing of your data up to the time of revocation. You can declare your revocation as described in section 10.i. Alternatively, it may also be possible to unsubscribe from the mailing list via an unsubscribe link at the end of an email containing direct advertising. Such a link is provided, for example, after the text "No further WTS e-mailings". Finally, you can also object to the processing of your data in this way, as explained in section 10.g.

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

If you request newsletters, other publications, information material or press releases from us, we process personal master data (e.g. salutation, title, first name, surname), company details (e.g. name of the company, your department), contact data (e.g. e-mail address), address data (e.g. street, zip code, town, country) and your interest in certain topics. If you also request publications by post, you will also need to provide your first name and surname, your address details and, if applicable, the name of your company and your department (if sent to your business address). We base the processing on Art. 6 para. 1 sentence 1 lit. a) GDPR, as we process your data for dispatch on the legal basis of your consent.

(i) Subscription to e-mail newsletters or other publications including press releases

We will only send you our newsletter and carry out statistical surveys and analyses and log the registration process if you order it from us at and have given your consent in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR, § 25 para.1 TDDDG.

The contents of the newsletter are described in detail when you register for the newsletter. To register for the newsletter, it is sufficient to provide your e-mail address. If you provide further voluntary information, such as your name and/or gender, this will be used exclusively to personalize the newsletter addressed to you.

For security reasons, we use the so-called double opt-in procedure to register for our newsletter so that no one can register with other people's email addresses. After registering for our newsletter, you will therefore first receive an e-mail asking you to confirm your registration. Your registration only becomes effective once it has been confirmed.

Furthermore, your registration for the newsletter will be logged. The logging includes the storage of the time of registration and confirmation, the data you provide and your IP address. If you make changes to your data, these changes will also be logged.

(ii) Withdrawal of your consent

You have the option of withdrawing your consent(s) at any time with effect for the future. Revocation does not affect the lawfulness of the processing of your data up to the time of revocation. You can declare your revocation as described in section 10.i. Alternatively, you can unsubscribe from the respective newsletter, publication or press release by clicking on the "unsubscribe link" at the end of each email we send you.

dd. Registration/implementation of WTS events

If you register for one of our events/seminars, we process personal master data (e.g. title, first name, surname), contact details (e.g. e-mail address, telephone number, fax number if applicable), company details (e.g. name and address of the company) and additional details (e.g. different billing address, SAP/order number) as part of the seminar registration and implementation. We process this data on the legal basis of Art. 6 para. 1 sentence 1 lit. b) GDPR, as the processing of the data is necessary in order to carry out the pre-contractual and contractual measures requested by you. In addition, we use this data to send you a summary of the documents by e-mail after the event (seminar).

If our contractual partner is not you but a third party (e.g. your employer), we process your personal data on the basis of Art. 6 para. 1 sentence 1 lit. f) GDPR. Our legitimate interest in the processing of your data lies in our economic and legal interest in fulfilling our contractual obligation towards this third party and, if applicable, in the interest of the third party in allowing you to participate in the event (seminar) and, if you are an employee of the third party, for example, to train you accordingly. In this case, you can object to the processing of your data as explained in section 10.g.

If you are interested in externally offered events and seminars, you can access 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 our Website and be redirected to the website of the respective organizer in order to access further information or to register for the event.

ee. Registration/conducting and recording of WTS webinars

If you register for a webinar, we process personal master data (e.g. first name, surname), contact details (e.g. email address), company details (e.g. name and address of the company), metadata about the event (e.g. invitation, cancellation, participation), your voice and the content of any questions you ask and, if applicable, the recording of your contributions (if you have given your consent) in connection with the webinar registration and execution. We process this data on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR, as the processing of the data is necessary to carry out the pre-contractual and contractual measures requested by you. In addition, we use this data to send you a summary of the documents by email following a webinar.

If our contractual partner is not you but a third party (e.g. your employer), we base the processing described in the aforementioned paragraphs of this section on the legal basis of Art. 6 para. 1 sentence 1 lit. f) GDPR. The legitimate interest in the processing of your data lies in our economic and legal interest in fulfilling our contractual obligation towards this third party and, if applicable, in the interest of the third party in allowing you to participate in the webinar and to train you accordingly. In this case, you can object to the processing of your data as explained in section 10.g.

During the webinar, you also have the opportunity to ask questions to the lecturer. In this case, your question or query and your voice can be heard by all participants in the corresponding webinar. We also base the processing of your question or concern and your voice on Art. 6 para. 1 sentence 1 lit. b) GDPR, as the processing of your data is necessary to answer your question or concern and thus to fulfill our contractual obligation.

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

If you are interested in externally offered webinars, you can access 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 our Website to access further information or register for the event and will be redirected to the website of the respective organizer.

ff. Use of our social media pages (fan pages)

If you use our social media pages on Facebook (available at the following external link), LinkedIn (available at the following external link), YouTube (available at the following external link), XING (available at the following external link), kununu (available at the following external link) and/or Instagram (available at the following external link) (hereinafter collectively referred to as "Social Media Pages"), we process your user name and profile picture, comment details (e.g. profile picture, user/ad name, comment content), content of messages to us, likes or "likes" regarding our posts, information about posts shared by us, photos, person/ad name, comment content).profile picture, user/show name, comment content), content of messages to us, likes or "like" information regarding our posts, information on posts shared by us, photos of people shown in posts on our Social Media Pages and names and photos of employees (e.g. on XING and LinkedIn). You have the opportunity to share, like and comment on our posts, ask questions and rate or recommend us. You can also get in touch with us via the contact options on our Social Media Pages.

If you make an inquiry or comment on a post in order to receive information about our products for the conclusion of a contract, we process your data on the basis of Art. 6 para. 1 sentence 1 lit. b) or f) GDPR to carry out pre-contractual measures that you have requested, to fulfil a contract with you or your employer or to be able to respond to your post. In the latter case and if you contact us purely for information purposes, we process your personal data on the legal basis of our legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR. Our legitimate interest lies in responding to your enquiry/comment and thus being able to present our company optimally on the Internet and inform interested parties.

We process your profile picture on the legal basis of Art. 6 para. 1 sentence 1 lit. a) GDPR, whereby by uploading your profile picture to your social media profile and interacting with our social media page, you have given your consent for your photo to be shown on our social media page (e.g. in a comment). Your consent in this regard is given voluntarily and can be revoked at any time with effect for the future by adjusting your privacy settings in your social media profile. This does not affect the lawfulness of the processing until your revocation.

In addition, we may use the analysis tools provided on the Social Media Pages (e.g. page insights for Instagram and Facebook, YouTube Analytics) to evaluate which content is of interest to you as a user and how wide the reach of our posts and the interaction of users with our content is. We only have access to aggregated and anonymized - i.e. non-personal - statistical information that we cannot assign to you without further additional information. This may also have been created by the respective service providers on the basis of personal user data. For more detailed information on the corresponding services and analysis options, please refer to the data protection notices of the respective service providers. In this respect, WTS also has no control over whether and, if so, to what extent your personal data is transferred by such service providers to other recipients (including those in third countries) or information concerning you is processed when you visit our social media pages. The processing is carried out on the legal basis of Art. 6 para. 1 sentence 1 lit. f) GDPR, whereby our legitimate interest lies in the optimization and user-friendly design of our social media pages.

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 given to us in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR. You have the option to withdraw your consent in this regard at any time with effect for the future. Withdrawal does not affect the lawfulness of the processing of your data up to the time of withdrawal.

If you are displayed on our XING and LinkedIn social media pages under the "Employees" section with your name and, if applicable, photo, the processing is also based on your consent in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR. Your consent lies in the fact that you have indicated in your XING and/or LinkedIn profile that you work at WTS and have not set your privacy settings to prevent a listing on our site. Your consent in this regard is also given voluntarily and can be revoked at any time with effect for the future by adjusting your privacy settings. If you do not give your consent, you will of course not suffer any disadvantages beyond the fact that your name (and possibly your profile picture) will not be displayed on XING and LinkedIn in the "Employees" section of our Website.

(i) Facebook and Instagram

Via our Facebook fan page, for example, we can see who has accessed our fan page and/or posted, commented on and/or shared posts. We process your posts in order to be able to process your request and, for example, to answer a question you have asked. In addition, we process all information that you provide when you contact us via the contact options provided on our Facebook fan page, e.g. your username, email address and your request.

Via our Instagram page, we can, for example, see who has accessed our page and/or subscribed to it, "liked" posts (by clicking the heart symbol under a post), marked posts, commented on them or published one of our stories (short content that is only available for 24 hours) themselves with their own repost. We process your contributions in order to be able to process your request and, for example, to answer a question you have asked. In addition, we process all the information you provide when you contact us via Instagram Direct (non-publicly visible message to us) or via the contact options provided on our Instagram page, e.g. your username, email address and your request. Meta Platforms Inc, 1601 Willow Road Menlo Park, CA 94025, USA (hereinafter "Meta USA") and/or Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (hereinafter "Meta Ireland") process various data provided by you on Facebook and/or Instagram, including personal data, by Meta Ireland and us as joint controllers within the meaning of Art. 26 GDPR in order to compile usage statistics (Page Insights). For this purpose, we have concluded a joint controller agreement with Meta Ireland in accordance with the legal requirements, which you can view here: https://www.facebook.com/legal/terms/page_controller_addendum

The legal basis for the processing of personal data in this context is our legitimate interest in being able to inform you effectively and communicate with you and to improve the information we provide, in particular on our Facebook and/or Instagram pages (Art. 6 para. 1 sentence 1 lit. f) GDPR) or the consent you have given (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on the processing of your data by Meta USA and/or Meta Ireland can be found under the following external link: https://www.facebook.com/about/privacy and https://help.instagram.com/519522125107875

(ii) LinkedIn

Via our LinkedIn page, for example, we can see who follows our LinkedIn page and which employees have indicated in their own LinkedIn profiles that they work at WTS. We can also see who has marked our posts with "Like", shared them or written a comment on them. In the case of comments, we process your data in order to respond to them or answer them.

At LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ("LinkedIn"), various data provided by you, including personal data, is processed by LinkedIn and us as joint controllers within the meaning of Art. 26 GDPR in order to generate usage statistics (Page Insights). For this purpose, we have concluded an agreement with LinkedIn as joint controllers in accordance with the legal requirements, which you can view here: https://legal.linkedin.com/pages-joint-controller-addendum .

The legal basis for the processing of personal data in this context is our legitimate interest in being able to inform you effectively and communicate with you and to improve the information we provide, in particular on our LinkedIn page (Art. 6 para. 1 sentence 1 lit. f) GDPR) or the consent you have given (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on the processing of your data by LinkedIn can be found in their privacy policy under the following external link: https://www.linkedin.com/legal/privacy-policy

(iii) YouTube

Via our YouTube page, for example, we can see who has watched our videos and given them a "Like". We can also view comments under our posts. We process your comments and your username in order to be able to process your request and, for example, to answer a question you have asked.

YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA ("YouTube") processes various data provided by you, including personal data, for the creation of usage statistics (YouTube Analytics) by YouTube and us as joint controllers within the meaning of Art. 26 GDPR. For this purpose, we have concluded an agreement with YouTube as joint controllers in accordance with the legal requirements.

The legal basis for the processing of personal data in this context is our legitimate interest in being able to inform you effectively and communicate with you and to improve the information we provide, in particular on our presence on YouTube (Art. 6 para. 1 sentence 1 lit. f) GDPR) or the consent you have given (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on the processing of your data by YouTube can be found at the following external link: https://policies.google.com/privacy?hl=de&gl=de

(iv) XING and kununu

Via our XING page, for example, we can see when and with what content reviews have been submitted for our company. The corresponding reviews are displayed pseudonymously on our XING page and we have no way of relating them to a specific person. In addition, we can see which employees have indicated on their own XING profiles that they work for WTS and have allowed an advertisement on our XING page. In addition, we can see who "follows" our XING page, i.e. who would like to see news in their profile that we publish on our XING page.

For example, we can use our kununu page to see when and with what content reviews have been submitted for our company. The corresponding reviews are displayed pseudonymously on our kununu page and we have no way of relating them to a specific person.

Further information on the processing of your data by New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany can be found at the following external link: https://privacy.xing.com/de/datenschutzerklaerung

gg. Acting as tax advisors or lawyers for our clients

If you or your employer or business partner have entered into a client relationship with us, we process personal master data (e.g. salutation, title, first name, surname), business contact data (e.g. e-mail address, telephone number, fax number if applicable), company details (e.g. company name, address, country), private contact and address data if applicable (e-mail address, telephone number, street, zip code, city, country), contents of your messages and applications to us in order to process the mandate as a professional, tax consultant and/or lawyer. If necessary and depending on the client relationship, data on the employment relationship (e.g. personnel number, joining, leaving), salary data, social data (e.g. severe disability), religious affiliation, political opinions, health data, data on business trips and stays abroad, data on business expenses, bank data and other data relevant to the mandate may also be processed. The purposes are as follows: fulfillment of our obligations under the Money Laundering Act, execution of the client relationship including correspondence, fulfillment 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 consultancy relationship (e.g. processing of claims arising from and in connection with the tax consultancy or legal consultancy relationship). legal consultancy relationship (e.g. performance, remuneration and liability claims); the legal basis for processing is Art. 6 para. 1 sentence 1 lit. b) (mandate agreement), lit. c) (legal obligation of WTS) and lit. f) (legitimate interests of WTS or the client) GDPR. Depending on the type of mandate, we require different data to process the mandate. This may also include special categories of personal data such as information on religious affiliation, political opinions or health data. We process these on the legal basis of Art. 9 para. 2 lit. a), b), f) or g) GDPR. We would ask you to only provide the types of data that we require for processing in each individual case. If you provide data that we do not need to process the mandate, we do not intend to collect this data.

hh. Surveys and studies

We conduct surveys and studies in which you participate voluntarily and whose results (which may also be individually prepared for you) you may receive from us. The legal basis for this is Art. 6 para. 1 sentence 1 lit. f) GDPR. Our legitimate interest lies in determining trends, opinions and experiences of the participating companies, in particular with regard to the fulfillment of regulatory requirements. We use the results obtained to further develop our consulting services and to identify (individual) consulting needs. We have an economic interest in this. Our interest therefore qualifies as legitimate within the meaning of the aforementioned regulation. This affects your IP address, which is required to access the Website with the survey tool. We ask you not to provide any information in free text fields that is personally identifiable (e.g. names, but also functions in certain authorities). Should this nevertheless be the case, we have no intention of collecting this data. The unavoidable processing of this data, which we cannot prevent but can only end as quickly as possible, is also based on our legitimate interest in accordance with Art. 6 para. 1 sentence 1 lit. 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 your requested contact data to fulfill this request and thus on the basis of Art. 6 para. 1 sentence 1 lit. b) GDPR. We will only make your individual evaluation available to you.

If we contact you following the evaluation and provide you with your individual or company-wide overall results, the statements made under sections 3.b and 7.b.bb apply.

8. Disclosure of data to third parties

We will not pass on or otherwise disseminate your personal data to third parties unless this is necessary for the provision and use of our products and services or the conclusion and execution of contracts (legal basis: Art. 6 para. 1 sentence 1 lit. b) GDPR), you have consented to the disclosure (legal basis: Art. 6 para. 1 sentence 1 lit. a) GDPR) or the disclosure of personal data is permitted on the basis of relevant legal provisions.

We are also entitled to outsource the processing of your personal data in whole or in part to external service providers who act for us as processors in accordance with Art. 4 No. 8 GDPR within the framework of data protection regulations. In particular, we use external service providers for the provision and operation of the Website and our respective services in order to

·       to host the Website and store its backend database,

·       to monitor the performance of the Website and to identify and rectify problems and errors on the Website,

·       to be able to provide a consent management platform for you as a user,

·       evaluate our Website and compile reports on Website activity, and

·       and to place relevant advertisements.

In all cases, we have concluded data processing agreements with the service providers involved in accordance with Art. 28 GDPR, which stipulate in particular that data processing is carried out exclusively in accordance with our instructions and in compliance with the applicable data protection laws.

In addition, we may pass on personal data to the following recipients:

• Public bodies to which the data must be transmitted by law (e.g. tax authorities, supervisory authorities, social insurance institutions, employers' liability insurance associations, law enforcement authorities if applicable)
• Our clients, if necessary in the context of the mandate processing
• Tax consultants or lawyers who are involved in the processing of mandates in coordination with our clients
• Banks, insurance companies
• Internal departments involved in the execution of the respective tasks (essentially: Marketing, Human Resources, IT & Security)
• Contractors (service companies, such as IT service providers, which may be located within or outside the WTS Group)
• Other Group companies and departments involved in the execution of the respective tasks (e.g. marketing, HR, IT, information security, data protection department)
• Other WTS companies (these are the WTS Group, WTS Legal Rechtsanwaltsgesellschaft mbH and WTS Global Verenigung, Rotterdam, Netherlands, as well as their member companies)
• Provider of our social media pages
• Organizer and co-organizer

9. Transfer of personal data to third countries

In principle, we do not transfer personal data that we collect via our Website to countries outside the European Union or the European Economic Area (third countries). If data is transferred to third countries as necessary for the fulfillment of a contract, for internal communication or administration or, for example, due to the location of a service provider in a third country, will only do so if an adequate level of data protection exists at the location in the third country or if suitable guarantees exist (e.g. the use of standard contractual clauses to ensure an adequate level of data protection).(e.g. the use of standard contractual clauses) to ensure an adequate level of data protection (Art. 45 et seq. GDPR) or, exceptionally, neither an adequacy decision nor appropriate safeguards are required (Art. 49 para. 1 subpara. 1 GDPR). In this way, we ensure that your personal data is adequately protected by the recipient in accordance with European data protection standards. If and insofar as you would like to receive further information on the guarantees in individual cases, you are welcome to contact our data protection officer named in section 2.

10. Other Data Processing 

In addition to the data processing described in this General Privacy Policy, we may also process your personal data for other purposes if we are authorized to do so under applicable data protection law.

Personal data may also be processed in other ways and also disclosed to third parties if we are legally obliged to do so - e.g. by court order or to fulfill legal obligations (legal basis: Art. 6 para. 1 sentence 1 lit. c GDPR) or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to safeguard legitimate interests (legal basis: Art. 6 para. 1 sentence 1 lit. c GDPR). 1 lit. c) GDPR) or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to safeguard legitimate interests (legal basis: Art. 6 para. 1 sentence 1 lit. f) GDPR), such as the provision of joint products and services or to protect vital interests (legal basis: Art. 6 para. 1 sentence 1 lit. d) GDPR).

If we process your data for other purposes, we will expressly inform you of this if this is required by applicable law.

11. Your rights in relation to data processing

You have the following rights vis-à-vis us under Art. 15 to 21 GDPR as well as the right to withdraw your consent at any time and the right to lodge a complaint with the supervisory authority. You can assert your rights against us in any form, either directly using the contact details provided in section 1 or via our data protection officer, whose contact details can be found in section 2. With the exception of any transmission or connection fees, you will not incur any costs for this.

a. Right to information (Art. 15 GDPR)

You have the right to request confirmation from us as to whether and which of your personal data is being processed by us: With regard to this data, you may in particular request information about the purposes of the processing, the categories of data that we process, the categories of recipients and our intention to transfer the data to recipients in a third country. The information also includes information about the origin of the data if it was not collected from you. You also have the right to request a copy of the personal data that is the subject of the processing, provided that this does not adversely affect the rights and freedoms of other persons with regard to their personal data.

b. Right to rectification (Art. 16 GDPR)

You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. You also have the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.

c. Right to erasure (Art. 17 GDPR)

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

• The data processed by you are no longer necessary for the purposes explained in this General Privacy Policy.
• You have withdrawn your consent (see section 10.i) and we have no other legal basis for processing your data.
• The data was processed unlawfully.
• The deletion is necessary to fulfill a legal obligation under Union or Member State law that applies to us.
• You have objected to the processing of your data by us (see section 10.g) and we have no overriding legitimate grounds for processing your data.

 

However, we must or may not implement your deletion request if one of the following reasons applies:

• Processing is necessary for exercising the right to freedom of expression and information.
• The processing is necessary in order to fulfill a legal obligation to which we are subject under the law of the European Union or a member state (e.g. statutory retention obligations).
• The processing is necessary for the establishment, exercise or defense of legal claims.
• Processing is necessary for reasons of public interest in the area of public health.

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

You have the right to demand that we restrict the processing of your personal data. You have this right in particular if one of the following reasons applies:

• You dispute the accuracy of your data.
• The processing of the data is unlawful and you refuse the deletion of the data.
• We no longer need your data, but you still need it to assert, exercise or defend legal claims.
• You have objected to the processing (see section 10.g) and we are still checking whether our legitimate reasons for processing outweigh your legitimate reasons for objecting.

e. Right to information (Art. 19 GDPR)

If you have requested the rectification or erasure of your data or the restriction of processing from us, we are obliged to notify all recipients to whom your personal data has been disclosed of the rectification or erasure of the data or the restriction of processing, unless this proves impossible or involves disproportionate effort. You also have the right vis-à-vis us to be informed about 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 those data to another controller or to have them transmitted by us to another controller, provided that you have provided the data to us with your consent or on the basis of a contract and the data are processed by automated means. You have the right to have the data transmitted by us directly to the other controller, insofar as this is technically feasible and the rights and freedoms of other persons are not affected.

g. Right to object (Art. 21 GDPR)

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, where the processing of such data is necessary for the purposes of the legitimate interests pursued by us or by a third party or for the performance of a task carried out in the public interest.

You can object to the processing of your data for advertising purposes at any time for the future. We will always comply with your objection. Please note, however, that we cannot rule out the possibility that we may no longer be able to recall an advertising medium in individual cases if we receive your objection at a time when the display of this advertising medium has already been unstoppably initiated by us. In such a case, however, we will of course exclude you from the display of any future advertising material.

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

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

The following data protection supervisory authority is responsible for WTS:

Bavarian State Office for Data Protection Supervision
Promenade 27
91522 Ansbach
https://www.lda.bayern.de

i. Right to withdraw consent (Art. 7 (3) GDPR)

If and insofar as you have given us your consent to process your data, you have the right to withdraw this consent at any time with effect for the future. The revocation does not affect the legality of the processing carried out on the legal basis of the consent up to the time of revocation; rather, the revocation can only affect the legality of future processing.

12.Automated decision-making, including profiling, within the meaning of Art. 22 GDPR

Your personal data will not be used for automated decision-making, including profiling, in accordance with Art. 22 (1) and (4) GDPR. If these are used, we provide meaningful information on the logic involved and the scope and intended effects of such processing for the data subject.

13.Data security 

We take technical and organizational security measures to protect your personal data against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure or access.

14. Validity of this privacy policy for other WTS companies

If and to the extent that you are in contact with another company of the WTS Group (hereinafter referred to as "WTS Group Company") or WTS Legal Rechtsanwaltsgesellschaft mbH, this WTS Group Company or WTS Legal Rechtsanwaltsgesellschaft mbH will process your data. If this WTS Group Company or WTS Legal Rechtsanwaltsgesellschaft mbH refers to this General Privacy Policy (e.g. in an e-mail signature), the statements contained in this General Privacy Policy also apply accordingly to the WTS Group Company or WTS Legal Rechtsanwaltsgesellschaft mbH, unless and insofar as the statements contained in this General Privacy Policy relate solely to the provision and functions of this Website and our Social Media Pages.

Therefore, with regard to WTS Group Company and WTS Legal Rechtsanwaltsgesellschaft mbH that refer to this General Privacy Policy, the information in this General Privacy Policy applies accordingly, unless privacy policies of the respective WTS Group Company or WTS Legal Rechtsanwaltsgesellschaft mbH contain deviating provisions. The names and contact details of the WTS Group Company or WTS Legal Rechtsanwaltsgesellschaft mbH can be found in the respective e-mail signature, the company details or, in the case of postal correspondence, the respective sender details.

15. Status and amendments to this general privacy policy

This General Privacy Policy corresponds to the status stated below. We reserve the right to amend this General Privacy Policy. We would therefore ask you to consult the General Privacy Policy on an ongoing basis so that you can keep yourself informed of any changes.

 

Status: May 2025