{"id":6111,"date":"2019-03-11T14:20:59","date_gmt":"2019-03-11T13:20:59","guid":{"rendered":"https:\/\/sapigmbh.de\/datenschutzerklaerung\/"},"modified":"2026-10-23T09:25:11","modified_gmt":"2026-10-23T07:25:11","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/sapigmbh.com\/en\/privacy-policy\/","title":{"rendered":"Privacy Policy"},"content":{"rendered":"<h1>Who we are<\/h1>\n<p>Our website address is: https:\/\/sapigmbh.com.<\/p>\n<p>We are very pleased that you have shown interest in our company. Data protection is of particularly high priority for the management of Sapi GmbH. The use of the Sapi GmbH website is generally possible without providing any personal data. However, if a data subject wishes to use special services of our company via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.<\/p>\n<p>The processing of personal data, such as the name, address, e-mail address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to Sapi GmbH. By means of this privacy policy, our company would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of the rights to which they are entitled by means of this privacy policy.<\/p>\n<p>As the controller, Sapi GmbH has implemented numerous technical and organisational measures to ensure the most complete protection possible of personal data processed via this website. Nevertheless, Internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.<\/p>\n<h2>1. Definitions<\/h2>\n<p>The privacy policy of Sapi GmbH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR, DS-GVO). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.<br \/>\nIn this privacy policy we use, among others, the following terms:<br \/>\na) personal data<br \/>\nPersonal data means any information relating to an identified or identifiable natural person (hereinafter &#8220;data subject&#8221;). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.<br \/>\nb) data subject<br \/>\nData subject means any identified or identifiable natural person whose personal data is processed by the controller.<br \/>\nc) processing<br \/>\nProcessing means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.<br \/>\nd) restriction of processing<br \/>\nRestriction of processing means the marking of stored personal data with the aim of limiting its processing in the future.<br \/>\ne) profiling<br \/>\nProfiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person&#8217;s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.<br \/>\nf) pseudonymisation<br \/>\nPseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.<br \/>\ng) controller or controller responsible for the processing<br \/>\nController or controller responsible for the processing means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.<br \/>\nh) processor<br \/>\nProcessor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.<br \/>\ni) recipient<br \/>\nRecipient means a natural or legal person, public authority, agency or another body to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.<br \/>\nj) third party<br \/>\nThird party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.<br \/>\nk) consent<br \/>\nConsent means any freely given, specific, informed and unambiguous indication of the data subject&#8217;s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.<\/p>\n<h2>2. Name and address of the controller<\/h2>\n<p>The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:<br \/>\nSapi GmbH<br \/>\nEnkingerweg 4<br \/>\nD-86753 M\u00f6ttingen<br \/>\nGermany<br \/>\nTel.: +49 (0) 9083-9615-0<br \/>\nFax: +49 (0) 9083-9615-99<br \/>\nE-mail: info@sapigmbh.de<\/p>\n<h2>3. Cookies<\/h2>\n<p>The Sapi GmbH website uses cookies. Cookies are text files that are placed and stored on a computer system via an Internet browser.<br \/>\nMany websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which websites and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognised and identified by means of the unique cookie ID.<br \/>\nThrough the use of cookies, Sapi GmbH can provide the users of this website with more user-friendly services that would not be possible without setting cookies.<br \/>\nBy means of a cookie, the information and offers on our website can be optimised in the interests of the user. As already mentioned, cookies enable us to recognise the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter their access data each time they visit the website, because this is handled by the website and the cookie stored on the user&#8217;s computer system. Another example is the cookie of a shopping basket in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping basket by means of a cookie.<br \/>\nThe data subject can prevent the setting of cookies by our website at any time by means of a corresponding setting of the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.<\/p>\n<h2>4. Collection of general data and information<\/h2>\n<p>The Sapi GmbH website collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-pages that are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems.<br \/>\nWhen using this general data and information, Sapi GmbH does not draw any conclusions about the data subject. Rather, this information is required in order to (1) deliver the content of our website correctly, (2) optimise the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by Sapi GmbH statistically on the one hand and, on the other hand, with the aim of increasing data protection and data security in our company, in order ultimately to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.<\/p>\n<h2>5. Registration on our website<\/h2>\n<p>The data subject has the possibility to register on the website of the controller by providing personal data. Which personal data is transmitted to the controller in this process is determined by the respective input mask used for the registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for its own purposes. The controller may arrange for the data to be passed on to one or more processors, for example a parcel service provider, who will also use the personal data exclusively for internal use attributable to the controller.<br \/>\nBy registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) of the data subject, the date and the time of registration are also stored. This data is stored against the background that this is the only way to prevent the misuse of our services and that, if necessary, this data makes it possible to investigate criminal offences committed. In this respect, the storage of this data is necessary to safeguard the controller. As a matter of principle, this data is not passed on to third parties unless there is a legal obligation to pass it on or the passing on serves the purpose of criminal prosecution.<br \/>\nThe registration of the data subject with voluntary provision of personal data enables the controller to offer the data subject content or services which, due to the nature of the matter, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely deleted from the controller&#8217;s database.<br \/>\nThe controller shall at any time, upon request, provide each data subject with information as to which personal data about the data subject is stored. Furthermore, the controller shall correct or delete personal data at the request or notification of the data subject, insofar as this does not conflict with any statutory retention obligations. All employees of the controller are available to the data subject as contact persons in this context.<\/p>\n<h2>6. Subscription to our newsletter<\/h2>\n<p>On the Sapi GmbH website, users are given the opportunity to subscribe to our company&#8217;s newsletter. Which personal data is transmitted to the controller when the newsletter is ordered is determined by the input mask used for this purpose.<br \/>\nSapi GmbH informs its customers and business partners at regular intervals by means of a newsletter about the company&#8217;s offers. Our company&#8217;s newsletter can generally only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter mailing. For legal reasons, a confirmation e-mail is sent using the double opt-in procedure to the e-mail address entered by a data subject for the first time for the newsletter mailing. This confirmation e-mail serves to verify whether the owner of the e-mail address, as the data subject, has authorised receipt of the newsletter.<br \/>\nWhen registering for the newsletter, we also store the IP address of the computer system used by the data subject at the time of registration, as assigned by the Internet service provider (ISP), as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject&#8217;s e-mail address at a later date and therefore serves the legal protection of the controller.<br \/>\nThe personal data collected in the context of a registration for the newsletter is used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter may be informed by e-mail if this is necessary for the operation of the newsletter service or a related registration, as might be the case in the event of changes to the newsletter offer or changes in the technical circumstances. The personal data collected as part of the newsletter service is not passed on to third parties. The subscription to our newsletter can be cancelled by the data subject at any time. The consent to the storage of personal data that the data subject has given us for the newsletter mailing can be revoked at any time. For the purpose of revoking consent, each newsletter contains a corresponding link. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller or to inform the controller of this in another way.<\/p>\n<h2>7. Newsletter tracking<\/h2>\n<p>The newsletters of Sapi GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in e-mails sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. On the basis of the embedded tracking pixel, Sapi GmbH can recognise whether and when an e-mail was opened by a data subject and which links in the e-mail were accessed by the data subject.<br \/>\nSuch personal data collected via the tracking pixels contained in the newsletters is stored and evaluated by the controller in order to optimise the newsletter mailing and to adapt the content of future newsletters even better to the interests of the data subject. This personal data is not passed on to third parties. Data subjects are entitled at any time to revoke the separate declaration of consent given in this regard via the double opt-in procedure. After revocation, this personal data will be deleted by the controller. Sapi GmbH automatically interprets unsubscribing from the newsletter as a revocation.<\/p>\n<h2>Newsletter<\/h2>\n<p>On our websites, we offer you the opportunity to subscribe to our newsletter. With this newsletter, we inform you at irregular intervals about our products, offers and industry news.<\/p>\n<p>To receive the newsletter, we need your e-mail address. The provision of further data (e.g. name, company) is voluntary and is used to be able to address you personally.<\/p>\n<p>We use the so-called double opt-in procedure for sending the newsletter: we will only send you a newsletter once you have expressly confirmed that you wish to receive the newsletter by clicking on a confirmation link in a confirmation e-mail sent by us. By activating the confirmation link, you give us your consent pursuant to Art. 6(1)(a) GDPR (DSGVO) to the use of your personal data for the purpose of sending the newsletter.<\/p>\n<p>When you register for the newsletter, we store your IP address as well as the date and time of registration and confirmation in order to be able to trace any possible misuse of your e-mail address at a later date (proof of consent pursuant to Art. 7(1) GDPR (DSGVO)).<\/p>\n<p>The data collected by us when you register for the newsletter is used exclusively for the purpose of sending advertising by newsletter and is not passed on to third parties, with the exception of the processors named below, who act exclusively on our behalf and in accordance with our instructions.<\/p>\n<p>You can unsubscribe from the newsletter at any time via the unsubscribe link contained in every newsletter or by sending an informal message to <a href=\"mailto:info@sapigmbh.com\">info@sapigmbh.com<\/a>. After you have unsubscribed, your e-mail address will be deleted from our newsletter mailing system without delay and added to a block list to prevent you from being contacted again by mistake.<\/p>\n<h3>Newsletter management via Listmonk (self-hosted)<\/h3>\n<p>To manage our newsletter recipients and to create and deliver newsletter campaigns, we use the open-source software <strong>Listmonk<\/strong>. Listmonk is hosted on a server operated by ourselves within the European Union. No transfer of your data to external providers takes place in the context of this software; all recipient and campaign data remains on our own infrastructure.<\/p>\n<p>The data stored in Listmonk comprises: your e-mail address, optionally your name and your company, the date and IP address of registration and the date of the confirmation of consent. The legal basis is Art. 6(1)(a) GDPR (DSGVO) (consent) and Art. 6(1)(f) GDPR (DSGVO) (legitimate interest in the efficient management of our recipient lists).<\/p>\n<h3>Sending of the newsletter via Amazon Simple Email Service (Amazon SES)<\/h3>\n<p>For the technical sending of our newsletters (the delivery of the individual e-mails to the recipients&#8217; mailbox providers), we use the <strong>Amazon Simple Email Service (Amazon SES)<\/strong> service of<\/p>\n<p><strong>Amazon Web Services EMEA SARL<\/strong><br \/>\n38 Avenue John F. Kennedy<br \/>\nL-1855 Luxembourg<br \/>\n(&#8220;AWS&#8221;)<\/p>\n<p>Your e-mail address is processed exclusively on servers within the European Union (Stockholm region, Sweden). Amazon SES receives from us only the data required for sending: your e-mail address, the content of the newsletter and technical sending metadata (date, time, delivery status, bounces, complaints).<\/p>\n<p>A data processing agreement pursuant to Art. 28 GDPR (DSGVO) is in place with AWS (part of the &#8220;AWS Service Terms&#8221; \/ &#8220;Global AWS Data Processing Addendum&#8221;), which ensures that AWS processes your data exclusively in accordance with our instructions and guarantees a level of protection equivalent to the European data protection level. No transfer to third countries outside the EU takes place in the context of our newsletter mailing.<\/p>\n<p>The legal basis for the use of Amazon SES as a processor is Art. 6(1)(f) GDPR (DSGVO). Our legitimate interest lies in the reliable, technically secure delivery of our newsletters, authenticated towards the recipients&#8217; mailbox providers (in particular DKIM signing and SPF authentication).<\/p>\n<h2>8. Contact option via the website<\/h2>\n<p>Due to legal requirements, the Sapi GmbH website contains information that enables quick electronic contact with our company as well as direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject is stored automatically. Such personal data transmitted on a voluntary basis by a data subject to the controller is stored for the purposes of processing or contacting the data subject. This personal data is not passed on to third parties.<\/p>\n<h2>9. Routine erasure and blocking of personal data<\/h2>\n<p>The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or insofar as this has been provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.<br \/>\nIf the purpose of storage no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or erased in accordance with the statutory provisions.<\/p>\n<h2>10. Rights of the data subject<\/h2>\n<p>a) Right to confirmationEvery data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her is being processed. If a data subject wishes to exercise this right to confirmation, he or she may contact an employee of the controller at any time.<br \/>\nb) Right of access<br \/>\nEvery data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller, at any time and free of charge, information about the personal data stored about him or her and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:<br \/>\nthe purposes of the processing<br \/>\nthe categories of personal data concerned<br \/>\nthe recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations<br \/>\nwhere possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period<br \/>\nthe existence of the right to request from the controller rectification or erasure of personal data concerning him or her, or restriction of processing, or to object to such processing<br \/>\nthe existence of the right to lodge a complaint with a supervisory authority<br \/>\nwhere the personal data is not collected from the data subject: any available information as to its source<br \/>\nthe existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR (DS-GVO) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject<br \/>\nFurthermore, the data subject has the right to obtain information as to whether personal data has been transferred to a third country or to an international organisation. Where this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.<br \/>\nIf a data subject wishes to exercise this right of access, he or she may contact an employee of the controller at any time.<br \/>\nc) Right to rectification<br \/>\nEvery data subject affected by the processing of personal data has the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject also has the right to have incomplete personal data completed, including by means of providing a supplementary statement.<br \/>\nIf a data subject wishes to exercise this right to rectification, he or she may contact an employee of the controller at any time.<br \/>\nd) Right to erasure (right to be forgotten)<br \/>\nEvery data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, where one of the following grounds applies and insofar as the processing is not necessary:<br \/>\nThe personal data was collected or otherwise processed for purposes for which it is no longer necessary.<br \/>\nThe data subject withdraws the consent on which the processing was based pursuant to Art. 6(1)(a) GDPR (DS-GVO) or Art. 9(2)(a) GDPR (DS-GVO), and there is no other legal ground for the processing.<br \/>\nThe data subject objects to the processing pursuant to Art. 21(1) GDPR (DS-GVO) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR (DS-GVO).<br \/>\nThe personal data has been unlawfully processed.<br \/>\nThe personal data must be erased for compliance with a legal obligation under Union or Member State law to which the controller is subject.<br \/>\nThe personal data has been collected in relation to the offer of information society services referred to in Art. 8(1) GDPR (DS-GVO).<br \/>\nIf one of the aforementioned grounds applies and a data subject wishes to request the erasure of personal data stored by Sapi GmbH, he or she may contact an employee of the controller at any time. The employee of Sapi GmbH will arrange for the erasure request to be complied with without delay.<br \/>\nWhere Sapi GmbH has made the personal data public and our company, as the controller, is obliged pursuant to Art. 17(1) GDPR (DS-GVO) to erase the personal data, Sapi GmbH, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers which are processing the published personal data that the data subject has requested the erasure by such other controllers of any links to, or copies or replications of, that personal data, insofar as the processing is not necessary. The employee of Sapi GmbH will arrange for what is necessary in the individual case.<br \/>\ne) Right to restriction of processing<br \/>\nEvery data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:<br \/>\nThe accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.<br \/>\nThe processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead.<br \/>\nThe controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise or defence of legal claims.<br \/>\nThe data subject has objected to processing pursuant to Art. 21(1) GDPR (DS-GVO) and it has not yet been established whether the legitimate grounds of the controller override those of the data subject.<br \/>\nIf one of the aforementioned conditions is met and a data subject wishes to request the restriction of personal data stored by Sapi GmbH, he or she may contact an employee of the controller at any time. The employee of Sapi GmbH will arrange for the restriction of the processing.<br \/>\nf) Right to data portability<br \/>\nEvery data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided, where the processing is based on consent pursuant to Art. 6(1)(a) GDPR (DS-GVO) or Art. 9(2)(a) GDPR (DS-GVO) or on a contract pursuant to Art. 6(1)(b) GDPR (DS-GVO) and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.<br \/>\nFurthermore, in exercising his or her right to data portability pursuant to Art. 20(1) GDPR (DS-GVO), the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.<br \/>\nIn order to assert the right to data portability, the data subject may contact an employee of Sapi GmbH at any time.<br \/>\ng) Right to object<br \/>\nEvery data subject affected by the processing of personal data has the right granted by the European legislator to object at any time, on grounds relating to his or her particular situation, to the processing of personal data concerning him or her which is based on Art. 6(1)(e) or (f) GDPR (DS-GVO). This also applies to profiling based on these provisions.<br \/>\nIn the event of an objection, Sapi GmbH will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims.<br \/>\nIf Sapi GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for the purpose of such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Sapi GmbH processing for direct marketing purposes, Sapi GmbH will no longer process the personal data for these purposes.<br \/>\nIn addition, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her which is carried out by Sapi GmbH for scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) GDPR (DS-GVO), unless such processing is necessary for the performance of a task carried out in the public interest.<br \/>\nTo exercise the right to object, the data subject may directly contact any employee of Sapi GmbH or another employee. In the context of the use of information society services, and notwithstanding Directive 2002\/58\/EC, the data subject is also free to exercise his or her right to object by automated means using technical specifications.<br \/>\nh) Automated individual decision-making, including profiling<br \/>\nEvery data subject affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject&#8217;s rights and freedoms and legitimate interests, or (3) is based on the data subject&#8217;s explicit consent.<br \/>\nIf the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is based on the data subject&#8217;s explicit consent, Sapi GmbH shall implement suitable measures to safeguard the data subject&#8217;s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.<br \/>\nIf the data subject wishes to exercise rights relating to automated decisions, he or she may contact an employee of the controller at any time.<br \/>\ni) Right to withdraw consent under data protection law<br \/>\nEvery data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.<br \/>\nIf the data subject wishes to exercise his or her right to withdraw consent, he or she may contact an employee of the controller at any time.<\/p>\n<h2>11. Legal basis for processing<\/h2>\n<p>Art. 6(1)(a) GDPR (DS-GVO) serves as the legal basis for our company for processing operations in which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the delivery of goods or the provision of any other service or consideration, the processing is based on Art. 6(1)(b) GDPR (DS-GVO). The same applies to processing operations necessary for carrying out pre-contractual measures, for example in the case of enquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1)(c) GDPR (DS-GVO). In rare cases, the processing of personal data could become necessary in order to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured on our premises and his or her name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. The processing would then be based on Art. 6(1)(d) GDPR (DS-GVO). Finally, processing operations could be based on Art. 6(1)(f) GDPR (DS-GVO). Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or of a third party, provided that the interests, fundamental rights and freedoms of the data subject do not override them. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, sentence 2 GDPR (DS-GVO)).<\/p>\n<h2>12. Legitimate interests in the processing pursued by the controller or a third party<\/h2>\n<p>Where the processing of personal data is based on Article 6(1)(f) GDPR (DS-GVO), our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and our shareholders.<\/p>\n<h2>13. Period for which the personal data is stored<\/h2>\n<p>The criterion for the duration of the storage of personal data is the respective statutory retention period. After expiry of this period, the corresponding data is routinely erased, provided that it is no longer required for the performance of the contract or the initiation of a contract.<\/p>\n<h2>14. Statutory or contractual requirements to provide the personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide it<\/h2>\n<p>We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data, which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences of failure to provide the personal data would be.<\/p>\n<h2>15. Existence of automated decision-making<\/h2>\n<p>As a responsible company, we do not use automated decision-making or profiling.<\/p>\n<h2>16. Web analysis by Microsoft Clarity<\/h2>\n<p>This website uses <strong>Microsoft Clarity<\/strong>, a web analysis service of Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland (&#8220;Microsoft&#8221;). Microsoft Clarity enables us to better understand the behaviour of visitors to our website and to continuously improve our online offering.<\/p>\n<p>Microsoft Clarity collects information about the use of our website by means of cookies and similar technologies. This includes in particular:<\/p>\n<ul>\n<li>mouse pointer movements, clicks and scrolling behaviour,<\/li>\n<li>pages visited and time spent on them,<\/li>\n<li>technical information such as browser type, operating system, screen resolution and language,<\/li>\n<li>a truncated IP address for approximate location determination, and<\/li>\n<li>aggregated heatmaps and session recordings (&#8220;session replays&#8221;).<\/li>\n<\/ul>\n<p>Microsoft Clarity uses technical measures to anonymise the data collected. Personal entries in forms are masked before transmission to Microsoft. Direct identification of individual users by us or Microsoft on the basis of this data is not intended.<\/p>\n<p>The data collected by means of Microsoft Clarity may be transferred to and processed on servers of Microsoft Corporation in the United States. Microsoft has joined the EU-U.S. Data Privacy Framework; a transfer to the USA therefore takes place on the basis of the adequacy decision of the EU Commission pursuant to Art. 45 GDPR (DSGVO) and, additionally, on the basis of the EU Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR (DSGVO).<\/p>\n<p>The legal basis for the use of Microsoft Clarity is your consent pursuant to Art. 6(1)(a) GDPR (DSGVO) and \u00a7 25(1) TDDDG. You give this consent via our cookie consent banner when you first visit our website. Without your consent, Microsoft Clarity will not be loaded.<\/p>\n<p>You can withdraw your consent at any time with effect for the future by adjusting your cookie settings on our website. The lawfulness of the processing carried out until the withdrawal remains unaffected by the withdrawal.<\/p>\n<p>Further information on data processing by Microsoft can be found in Microsoft&#8217;s privacy statement at <a href=\"https:\/\/privacy.microsoft.com\/de-de\/privacystatement\" target=\"_blank\" rel=\"noopener external noreferrer\" data-wpel-link=\"external\">https:\/\/privacy.microsoft.com\/de-de\/privacystatement<\/a>. Detailed information specifically on Microsoft Clarity is available at <a href=\"https:\/\/learn.microsoft.com\/de-de\/clarity\/\" target=\"_blank\" rel=\"noopener external noreferrer\" data-wpel-link=\"external\">https:\/\/learn.microsoft.com\/de-de\/clarity\/<\/a>.<\/p>\n<p><strong>&#8220;We improve our products and advertising by using Microsoft Clarity to see how you use our website. By using our website, you agree that we and Microsoft can collect and use this data.&#8221;<\/strong><\/p>\n<p>This privacy policy was created by the privacy policy generator of the Wuppertal external data protection officers in cooperation with RC GmbH, which recycles used notebooks, and the data protection lawyers of the law firm WILDE BEUGER SOLMECKE | Rechtsanw\u00e4lte<\/p>\n<p><em>Last updated: 21 May 2026<\/em><\/p>\n","protected":false},"excerpt":{"rendered":"<p>Who we are Our website address is: https:\/\/sapigmbh.com. We are very pleased that you have shown interest in our company. Data protection is of particularly high priority for the management of Sapi GmbH. The use of the Sapi GmbH website is generally possible without providing any personal data. 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