Privacy Policy

Thank you for your interest in our website. The protection of your privacy is very important to us. Below we inform you in detail about how we handle your data.

I. Name and address of the data controller

The data controller in terms of the General Data Protection Regulation and other national data protection laws of the member states and other data protection regulations is:

HolmeZ SoftSolutions Pte. Ltd.
80 Robinson Road #02-00
Singapore 068898
E-mail: [email protected]

II. General information on data processing

1. Scope of the processing of personal data

As a matter of principle, we process personal data of our users only to the extent necessary to provide a functional website and our contents and services. The processing of personal data of our users only takes place with the consent of the user. An exception is made in those cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by legal regulations.

 

2. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, Art. 6 para. 1 lit. a EU General Data Protection Regulation (GDPR) serves as the legal basis.

In the processing of personal data necessary for the performance of a contract to which the data subject is a party, Art. 6 para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations which are necessary to carry out pre-contractual measures.

Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

If the processing is necessary to safeguard a legitimate interest of our company or of a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the former interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing.  

3. Data deletion and storage duration

The personal data of the data subject will be deleted or blocked as soon as the purpose of the storage no longer applies. Furthermore, data may be stored if this has been provided for by the European or national legislator in EU regulations, laws or other regulations to which the data controller is subject. Data will also be blocked or deleted when a storage period prescribed by the above-mentioned standards expires, unless there is a need to continue storing the data for the purpose of concluding or fulfilling a contract.

III. Providing the website and creation of log files

1. Description and scope of data processing

Whenever our website is accessed, our system automatically collects data and information from the computer system of the calling computer. The following data is collected:

The data are also stored in the log files of our system. These data are not stored together with other personal data of the user.

2. Legal basis for the data processing

The legal basis for the temporary storage of data and log files is Art. 6 para. 1 lit. f GDPR

3. Purpose of the data processing

The storage in log files is done to ensure the functionality of the website. In addition, the data serves us to optimise the website and to ensure the security of our information technology systems. The data will not be evaluated for marketing purposes.

These purposes also include our legitimate interest in data processing in accordance with Art. 6 para. 1 lit. f GDPR.

4. Duration of storage

The data will be deleted as soon as they are no longer necessary for the purpose for which they were collected. In the case of the collection of data for the provision of the website, this is the case when the respective session is ended.

4. Possibility of objection and removal

The collection of data for the provision of the website and the storage of the data in log files is mandatory for the operation of the site. There is therefore no possibility of objection on the part of the user.

IV. Use of cookies

1. Description and scope of data processing

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user’s computer system. If a user calls up a website, a cookie may be stored on the user’s operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

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

The language settings are stored and transmitted in the cookies.

These user data are pseudonymised by technical precautions so that it is no longer possible to assign them to the user. The data are not stored together with other personal data of the users.

2. Legal basis for the data processing

The legal basis for the processing of personal data using cookies is Art. 6 para. 1 lit. f GDPR.

3. Purpose of the data processing

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

a) Transfer of language settings
The user data collected through technically necessary cookies is not used to create user profiles. These purposes also include our legitimate interest in the processing pf personal data in accordance with Art. 6 para. 1 lit. f GDPR.

4. Duration of storage, possibility of objection and removal

Cookies are stored on the user’s computer and transmitted by the user to our site. Therefore you as a user have full control over the use of cookies. By changing the settings in your Internet browser, you can deactivate or restrict the transmission of cookies. Already stored cookies can be deleted at any time. This can also be done automatically. If cookies for our website are deactivated, it may not be possible to use all the functions of the website to their full extent.

V. Contact form and e-mail contact

1. Description and scope of data processing

On our website there is a contact form which can be used for electronic contact. If a user takes advantage of this possibility, the data entered will be transmitted to us and stored. These data are usually:

For the processing of the data, your consent will be obtained during the sending process and reference will be made to this privacy policy.

Alternatively, it is possible to contact us via the provided e-mail address. In this case, the user’s personal data transmitted with the e-mail will be stored.

In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation.

2. Legal basis for the data processing

The legal basis for the processing of the data is Art. 6 para. 1 lit. a GDPR if the user has given his consent.

The legal basis for the processing of data transmitted in the course of sending an e-mail is Art. 6 para. 1 lit. f GDPR. If the e-mail contact aims at the conclusion of a contract, the additional legal basis for processing is Art. 6 para. 1 lit. b GDPR.

3. Purpose of the data processing

The processing of the personal data from the input mask serves us only for the processing of the establishment of contact. In the case of contacting us by e-mail, this is also the necessary legitimate interest in the processing of the data.

The other personal data processed during the sending process serves to prevent misuse of the contact form and to ensure the security of our information technology systems. 

4. Duration of storage

The data will be deleted as soon as they are no longer necessary for the purpose for which they were collected.

5. Possibility of objection and removal

The user has the possibility to revoke his consent to the processing of personal data at any time. If the user contacts us by e-mail, he can object to the storage of his personal data at any time. In such a case the conversation cannot be continued.

All personal data stored in the course of the contact will be deleted in this case.

VI. Disclosure of personal data to third parties

1. Website analysis services

(a) Description and extent of the processing of personal data, the purpose of the processing, the duration of the storage, the possibilities of opposition and removal

Web analysis with Google Analytics

This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, in the event that IP anonymisation is activated on this website, your IP address will be shortened by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area before this happens. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activities and to provide further services to the website operator in connection with website and internet use. The IP address transmitted by your browser within the framework of Google Analytics is not combined with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de. Mobile users can deactivate Google Analytics under this link.

We have also made settings so that Google Analytics deletes the last part of the IP addresses of visitors to our website. This also means that we do not come into possession of any data that would allow us to draw conclusions about your person.  

b) Legal basis for the processing of personal data

The legal basis for the processing of the data is Art. 6 para. 1 lit. f GDPR.

2. Advertising and marketing services

(a) Description and extent of the processing of personal data

Google AdWords and Google Display Network

Our website uses the online advertising systems Google AdWords and Google Display Network. Google assures to protect the data of its customers and users. Google Adwords sets a cookie on your computer. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of the Adwords client’s website and the cookie has not expired, Google and the client can recognise that the user clicked on the ad and was redirected to that page. The information thus obtained is used to compile statistics, which are evaluated in an anonymous form. We also use these Google Adwords functions to address visitors to this website again to websites of third parties or Internet users with specific interest profiles based on their Internet use. We do not collect any personal information in this process. This analysis is used for the billing and evaluation of advertisements and does not contain any personal data about you. We would like to point out that Google has its own data protection guidelines. We assume no responsibility or liability for these guidelines and procedures. Please inform yourself about Google’s privacy policy before using our website.

b) Legal basis for the processing of personal data

The legal basis for the processing of the data is Art. 6 para. 1 lit. f GDPR.

c) Purpose of the data processing

The advertising is necessary to finance and optimise our website.

d) Duration of storage

The data will be deleted as soon as they are no longer necessary for the purpose for which they were collected. This is usually the case when the respective session has ended.

e) Possibility of objection and removal

Users who do not wish to participate in tracking can easily disable the Google Conversion Tracking cookie via their Internet browser under User Preferences. These users will not be included in the conversion tracking statistics.

 VII. Rights of the data subject

If personal data are processed by you, you are the data subject within the meaning of the GDPR and you are entitled to the following rights in relation to the data controller:

1. Right of access to information

You can request confirmation from the data controller as to whether personal data concerning you is being processed by us. In the event of such processing, you may request the following information from the data controller:

(1) the purposes for which the personal data are processed;

(2) the categories of personal data processed;

(3) the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;

(4) the planned duration of storage of personal data relating to you or, if it is not possible to give specific details, criteria for determining the duration of storage;

(5) the existence of a right of rectification or deletion of personal data relating to you, a right to have the processing limited by the controller or a right to object to such processing;

(6) the existence of a right of appeal to a supervisory authority;

(7) all available information on the origin of the data, if the personal data are not collected from the data subject;

(8) the existence of automated decision making, including profiling, in accordance with Art. 22 (1) and (4) GDPR and, at least in these cases, meaningful information on the logic involved and the scope and intended effects of such processing on the data subject.

You have the right to request information as to whether personal data concerning you is transferred to a third country or to an international organisation. In this context, you may request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transfer.

Right of rectification

You have the right to ask the data controller to correct and/or complete the data if the personal data processed concerning you is incorrect or incomplete. The data controller shall make the correction without delay.

Right to limit processing

(1) if you dispute the accuracy of the personal data concerning you for a period of time which enables the person responsible to verify the accuracy of the personal data;

(2) the processing is unlawful and you object to the deletion of the personal data and request instead the restriction of the use of the personal data;

(3) the controller no longer needs the personal data for the purposes of the processing, but you need it for the purpose of exercising or defending legal claims; or

(4) if you have lodged an objection to the processing in accordance with Art. 21 para. 1 GDPR and it has not yet been established whether the legitimate reasons given by the data controller outweigh your reasons.

Where the processing of personal data relating to you has been restricted, such data may be processed, with the exception of storage, only with your consent or for the purpose of pursuing, exercising or defending legal claims or protecting the rights of another natural or legal person or on grounds of an important public interest of the Union or of a Member State.

If the restriction on processing has been restricted in accordance with the above conditions, you will be informed by the data controller before the restriction is lifted.

Right to deletion

a.) Duty to delete

You may request the data controller to delete personal data concerning you without delay and the data controller is obliged to delete such data without delay if one of the following reasons applies:

(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.

(2) You revoke your consent on which the processing was based pursuant to Art. 6 para. 1 lit. a or Art. 9 para. 2 lit. a GDPR, and there is no other legal basis for the processing.

(3) Pursuant to Art. 21 para. 1 GDPR, you lodge an objection to the processing and there are no legitimate grounds for processing that take precedence, or you lodge an objection to the processing pursuant to Art. 21 GDPR.

(4) Personal data concerning you have been processed unlawfully.

(5) The deletion of personal data concerning you is necessary to comply with a legal obligation under Union law or the law of the Member States to which the data controller is subject.

(6) The personal data concerning you have been collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.

Information to third parties

If the data controller has made public the personal data concerning you and is obliged to delete them pursuant to Art. 17 para. 1 GDPR, he shall take reasonable measures, including technical measures, taking into account the available technology and the implementation costs, to inform data controllers who process the personal data that you, as a data subject, have requested them to delete all links to these personal data or copies or replications of these personal data.

Exceptions

The right to deletion does not exist insofar as the processing is necessary

(1 ) for the exercise of the right to freedom of expression and information;

(2) in order to comply with a legal obligation to which the processing is subject under Union or national law to which the data controller is subject or in order to perform a task carried out in the public interest or in the exercise of official authority vested in the data controller;

(3) for reasons of public interest in the field of public health pursuant to Art. 9 para. 2 lit. h and i and Art. 9 para. 3 GDPR;

(4) for archiving, scientific or historical research purposes in the public interest or for statistical purposes pursuant to Art. 89 para. 1 GDPR insofar as the law referred to in section a) is likely to render impossible or seriously prejudice the attainment of the objectives of such processing, or

(5) to assert, exercise or defend legal claims.

Right to information

If you have asserted the right to rectify, erase or limit the processing vis-à-vis the data controller, the data controller is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this rectification, deletion or limitation of processing, unless this proves impossible or involves a disproportionate effort.

You have the right to be informed of these recipients by the data controller.

Right to data transferability

You have the right to receive the personal data concerning you that you have provided to the data controller in a structured, common and machine-readable format. You also have the right to have this data communicated to another person in charge without interference from the person in charge to whom the personal data has been communicated, provided that

(1) the processing is based on a consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit a GDPR or to a contract pursuant to Art. 6 para. 1 lit. b GDPR

(2) the processing is carried out by means of automated procedures.

In exercising this right, you also have the right to obtain that the personal data concerning you be transferred directly from one responsible party to another, as far as this is technically feasible. The freedoms and rights of other persons must not be affected by this.

The right to data transferability shall not apply to processing of personal data which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.

Right of objection

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is carried out pursuant to Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions.

The data controller shall no longer process the personal data concerning you, unless he can demonstrate compelling reasons for processing which are justified on grounds of protection of your interests, rights and freedoms, or if the processing serves to assert, exercise or defend legal claims. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it relates to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You may exercise your right of objection in connection with the use of information society services, without prejudice to Directive 2002/58/EC, by means of automated procedures involving technical specifications.

Right to revoke the declaration of consent under data protection law

You have the right to revoke your data protection declaration of consent at any time. Revocation of your consent does not affect the legality of the processing that has taken place on the basis of your consent until revocation.

Automated decision in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, that has legal effect on you or significantly affects you in a similar manner. This shall not apply if the decision

(1) is necessary for the conclusion or performance of a contract between you and the person responsible

(2) is authorised by Union law or the law of the Member States to which the person responsible is subject and that law contains appropriate measures to safeguard your rights and freedoms and your legitimate interests; or

(3) with your express consent. However, these decisions may not be based on special categories of personal data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 lit. a or g GDPR applies and appropriate measures have been taken to protect rights and freedoms and your legitimate interests.

With regard to the cases referred to in (1) and (3), the data controller shall take appropriate measures to safeguard the rights and freedoms and your legitimate interests, which shall include at least the right to obtain the intervention of any person from the responsible person, to express his or her point of view and to challenge the decision.

Right of appeal to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State in which you are resident, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you is in breach of the GDPR.

The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and the results of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR.