in DE-80807 Munich, Max-Bill-Str. 30,
as the owner and data controller (hereafter referred to as the "administrator" or the "data controller") of the
website https://www.minniti.de/cmt (hereafter referred to
as the "site"), and the derived file "wg29-expose.pdf" (hereafter referred to as
the "exposè") in a portable document format (hereafter referred to as the "PDF"), of the download section of the
exposè and of the services connected to it (hereafter referred
to as the “services"). The "data controller", “data processor” and "administrator" role are owned by Mr. Giovanni
The administrator respects the privacy of every user who visits the site or the download section of the exposè and
uses the services (hereafter referred to as "user").
The policy does not apply to third party site or exposè or download section of the exposè accessible via external
hyperlinks on the site or exposè or download section of the exposè.
The processing of personal data of individuals will be in accordance with current applicable law for data privacy and
regulation in Germany, containing the code regarding the
protection of personal data, as amended by regulation (EU) no. 679 of 27 April 2016 - applicable from 25 May 2018
(hereafter referred to as "applicable privacy law").
Links to the site or exposè or download section of the exposè mentioned above and not to other site that may be
consulted by the user through special links. Policy remark is
done before submitting any personal information and/or completing any electronic form on this site or exposè or
download section of the exposè. This policy and how to use and manage
cookies may be subject to updates at any time. In this case, the administrator will publish a notice on the homepage
of the site or exposè or download section of the exposè.
In any case, the administrator invites you to periodically check the privacy statement to be informed of any
1. Navigation data
The computer systems and software procedures used to operate this site or the download section of the exposè acquire,
in normal operation, some personal data that
are then implicitly transmitted in the use of Internet communication protocols. This is information that is not
collected to be associated with identified data subjects,
but which by its very nature could, through processing and association with data held by third parties, allow users
to be identified.
This category of data includes:
• Identification and contact data (e.g. name, surname, e-mail, telephone number, etc.);
• Data relating to the content of electronic communications exchanged with the site or exposè or download section of
the exposè for the purposes referred to in paragraph 2 (A);
• Data relating to the IP address or the ID of the device of a user through which the site or exposè or download
section of the exposè is accessed or the services are used;
• Data relating to the type of browser used by users, as well as the date and time of use to access the site or
exposè or download section of the exposè or the services.
2. Data retention times and conservation purpose
The data referred to in the previous paragraph (1) are used for the sole purpose of obtaining anonymous statistical
information on the use of the site or download section
of the exposè and to check its correct functioning, as well as for the following purposes:
• A) Respond to requests from users sent via the site or exposè or download section of the exposè;
• B) Improve the presentation, features and functionality of the site or exposè or download section of the exposè
and the services, as well as the administration and management of user
• C) Allow users to participate in surveys and surveys anonymously;
• D) Provide assistance on the services offered, at the request of users;
• E) Prevent fraud or crimes committed through the site or exposè or download section of the exposè or
• F) Fulfill legal or tax obligations pursuant to applicable law;
• G) Subject to consent, contact users through automated tools (email, sms, mms, social, unmanned calls) and
non-automated (paper mail and telephone with operator) to offer
them commercial offers and promotions, as well as involve them in market research and surveys, also by sending
• H) Subject to consent, analyze the choices and commercial preferences of users in using the site or exposè or
download section of the exposè or services, in order to customize the
offer of products and services dedicated to them.
For the purposes referred to in letters A) to F), the administrator will process the personal data of users based on
their requests and their legitimate interest.
For the purposes referred to in letters G) and H), the administrator will process the personal data of users on the
basis of their consent. Personal data processed
by the administrator on the basis of the user's consent will be kept for the time strictly necessary to achieve the
purposes for which they were originally collected
and, in any case, will no longer be processed as a result of any revocation of consent given.
Where the processing of personal data should instead take place in
compliance with legal, tax or judicial obligations, or to ascertain responsibility in case of hypothetical computer
crimes against the site or download section of the
exposè, the data may be stored up to a maximum of ten (10) years. For more information about the criteria and time
frame for which we store your data, you can contact
the administrator at the e-mail address: email@example.com
3. Data provided voluntarily by users/visitors
If users/visitors, connecting to this site or exposè or download section of the exposè, send their personal data to
access certain services, or to make requests in chat and/or email mode,
this involves the acquisition by the administrator of the address of the sender and/or any other personal data that
will be processed exclusively to respond to the request, or for
the provision of the service.
Personal data provided by users/visitors will be communicated to third parties only if the communication is necessary
to comply with the requests of
the users/visitors themselves.
4. "Contact" form
The data that will be provided by the administrator through this form are the name and surname, your e-mail address
and telephone number and will be used exclusively to respond
to your requests or questions you would like to contact us. Providing such data is mandatory in order to formulate a
request to the administrator and any refusal to grant them will
prevent you from obtaining an answer.
5. Processing methods
Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which
they were collected. Specific security measures are observed
to prevent data loss, illicit or incorrect use and unauthorized access. All personal data will be processed mainly
through electronic tools and methods, however the treatment by
paper means is not excluded in advance by the administrator.
The data controller will take all necessary security measures in order to minimize the risk of destruction or loss,
accidental, of the data, unauthorized access or processing that is not permitted or does not comply with the
purposes indicated in this document.
However, since it is not possible to guarantee that the measures taken for the security of the site or exposè or
download section of the exposè and the transmission of data are such as to
exclude any risk of unauthorized access or loss of data, we urge the user to make sure that his computer is equipped
with current software updates and antivirus software for data
network protection - both inbound and outbound - and that your internet service provider has adopted firewalls and
anti-spam filters, or other appropriate measures for the security
of data transmission.
6. Optional supply of data
Apart from that specified for navigation data, users/visitors are free to provide their personal data. Failure to
provide such data may entail the impossibility of obtaining what
7. Information collected passively
In providing the services the administrator will use software and/or third-party services to collect information
passively, without your knowledge, while you are browsing or
interacting with the content of the site or exposè or download section of the exposè, as well as information on the
device you use.
The only purpose of passive collection of this information
is to learn more about how you use and interact with the site or exposè or download section of the exposè, with the
aim of improving your experience in the use of the services and identify
possible errors during the implementation of the site or exposè or download section of the exposè.
The information collected includes, by way of example and not exhaustively:
• The IP address of your device;
• The screen size of the device used;
• Device (unique identifier) and browser information;
• Geographical position (country);
• Selected language with which the site or exposè or download section of the exposè is displayed;
• Pages visit of the site or exposè or download section of the exposè;
• Date and time when the pages were the site or exposè or download section of the exposè where visited;
For this purpose, we use the third-party web analysis service, which passively collects information in order to
examine the use of the site or exposè or download section of the exposè and,
in general, to gather information about the activities of the site or exposè or download section of the exposè. It
is also noted that the administrator may use third party services such as
Google Analytics, which collects information about your browsing through cookies or other mechanisms.
Under no circumstances does the administrator collect or store identifying
data if needed by the site or exposè or download section of the exposè (including, in particular, bank details or
8. Transfer of personal data abroad
Users' personal data will not be transferred to countries that do not belong to the European Union and which do not
ensure data protection levels in line with the applicable privacy law.
9. Processing of personal data of minors
The use of the site or exposè or download section of the exposè and the services is reserved only for users over 18
years of age. The administrator does not process personal data of minors
under eighteen (18) years without parental consent.
10. Place of data processing
The processing operations connected to the services of the site or exposè or download section of the exposès
indicated above take place at the office
of the administrator, in DE-80807 Munich, Max-Bill-Str. 30 and/or at the designated place of the hosting company
and/or management of the site or exposè or download section of the exposè
and are only handled by technical staff of the office in charge of processing, or by persons in charge of occasional
No data deriving from the service
is communicated or disseminated. The personal data provided by users who request dispatch of informative material
are used only to perform the service or provision requested
and are communicated to third parties only if this is necessary for that purpose.
11. Data controller
The holder of the processing of personal data is the administrator.
12. Rights of the interested parties
Pursuant to the applicable privacy law, users will be entitled to:
• Be informed of the purposes and methods of processing their personal data;
• Access to personal data;
• Obtain a copy of your personal data, where these are stored in countries outside the European Union, as well as
obtain information on the place where such personal data is stored
• Request the correction, updating or integration of personal data;
• Request cancellation, anonymisation or blocking of the processing of personal data;
• Oppose, in whole or in part, any processing performed through automated decision-making processes, including
• Revoke your consent to the processing, where provided, freely and at any time;
• Contact the data protection manager of the data controller;
• File a complaint to the german privacy guarantor for the protection of personal data.
Pursuant to the applicable privacy law, from May 2018, users will also have the right to exercise the following
• The right to data portability, that is the right to receive personal data in a structured format, commonly used
and readable by automatic device, and the possibility of being
able to transmit them to another data controller
freely and without impediments;
• The right to request the limitation of the processing of personal data;
Requests for updating, rectification, cancellation or otherwise relating to the processing and storage of data must
be forwarded to the data controller at our office in
DE-80807 Munich, Max-Bill-Str. 30, or via email at firstname.lastname@example.org indicating as
object: "Cancellation of personal data".
The letter must contain:
• Name and surname of the applicant;
• Written request for cancellation/updating/correction;
• E-mail address used for registration (e-mail);
• Password to access your personal area (if available);
• Photocopy of the identity card or passport;
• Address and contact telephone;
13. What are cookies
As clarified by the german privacy guarantor, cookies are small files sent by the
site or exposè or download section of the exposès visited or exposed by users and stored on the device used to
access such site or exposes (e.g. computer, smartphone, tablet and any other
device used to access the site or exposè or download section of the exposès).
When users visit the same site or exposè or download section of the exposè again, the browser reads the cookies
on the device and retransmits the information to the site or exposè or download section of the exposè that
originally created the cookies. They are cookies that allow, for example, to
perform statistical analysis based on your choices or remember which language you selected the first time you surfed
our site or exposè or download section of the exposè.
nature, nor are used persistent cookies of any kind, or systems for
tracking users. The use of session cookies (which are not stored permanently on the user's computer and disappear
when the browser is closed) is strictly limited to the
transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe
browsing and efficient site or exposè or download section of the exposè.
Session cookies used on this site or exposè or download section of the exposè avoid the use of other technologies
that could compromise the privacy of users' browsing and do not allow the
acquisition of personal identification data.
14. Change cookie settings
Most browsers are configured to automatically accept cookies. You can also change cookie settings or accept others
and disable others. The administrator reminds you that
removing cookies from a bit of space may limit the ability to browse the site or exposè or download section of the
exposè and prevent you from doing its functions.
Below you can see how you can manage or disable cookies in each browser.
site accessible by links on our site.
15. What types of cookies and how we use it
To allow the provision of our services, we use both persistent cookies (cookies that refer to a long-term
and session cookies, which are not stored permanently on the visitor's computer and disappear when the
browser is closed.
The type of cookies are:
• Technical cookies: Useful in order to provide a better service to users. These include navigation cookies
and internal functionalities, thanks to which the user navigates
the site or exposè or download section of the exposè fluently and accesses the login area with stored
credentials and preferences;
• Analytical cookies: Thanks to the help of Google Analytics (also includes DoubleClick), Zoopim, Yandex
Metrica can be used to detect the number of visitors to the site or
download section of the exposè, the pages visite or exposè or download section of the exposèd, the time
spent on the site or exposè or download section of the exposè and any statistical data
useful to understand the profile of users and to improve the performance of our service and its tool;
• Profiling cookies: They are useful in order to create "user profiles" and to send promotional messages in
line with the preferences and choices that emerge from the user's
browsing. The following cookies can be used for remarketing activities with Google and/or with
• Third-party cookies: They are used to allow the sharing of site or exposè or download section of the
exposè content through social networks, (e.g. Facebook cookies, linked to the
social media buttons, LinkedIn, Twitter, ...);
Personal data belonging to the user or the download section of the exposè are not subject to disclosure.
16. Rights of the interested parties (Part 1)
In relation to the treatments described in the Notice, as an interested party you may, pursuant to Article 7
of the Privacy Code, exercise specific rights, including that of:
• Obtain from the data controller the confirmation of the existence or not of their data and their
availability in an intelligible form to have knowledge of the origin of the data,
the logic, the purposes and the modalities on which the treatment is based, together with the identification
details of the data controller;
• Obtain the indication of the managers and of the designated representative pursuant to Article 5,
paragraph 2, of the Privacy Code, of the subjects or categories of subjects
to whom the Data may be communicated or who may become aware of it as appointed representative in the
territory of the State, of managers or agents;
• Obtain cancellation, transformation into anonymous form or blocking of data processed in violation of the
law, as well as updating, correction or, if interested, integration
• Obtain confirmation that the information relating to the origin of the Data, the purposes and the method
of treatment have been brought to the attention, including as regards
their content, of those to whom the Data have been communicated or disseminated, except for the case where
such fulfillment proves impossible or involves the use of clearly
disproportionate means to the protected right;
• Object, in whole or in part, for legitimate reasons to the processing of data concerning you, even if
pertinent to the purpose of collection, as well as to the processing of
data concerning you for the purpose of sending advertising material or direct sales or for the fulfillment
of market research or commercial communication. As of 25 May 2018,
as an interested party, you may exercise the following specific rights pursuant to articles 15-21 of the
General Data Protection Regulation (hereafter referred to as "GDPR").
• Right of access - Article 15 of the GDPR: the right to obtain confirmation that personal data
you is being processed and, in this case, obtain access to your personal data - including a copy thereof -
and communication , among others, of the following information:
- Purpose of the processing;
- Categories of personal data processed;
- The recipients to whom these have been or will be communicated, in particular if they are recipients of
non-EU third countries or intergerman organizations;
- The data retention period or criteria used;
- Interested parties (correction, deletion of personal data, limitation of processing and right to object to
- Make a claim;
- Receive information on the origin of personal data, if they have not been collected from the person
- The existence of an automated decision-making process, including profiling in the event that the data are
transferred to a non-EU third country or intergerman
organization, the existence of adequate guarantees pursuant to art. 46 GDPR;
• Right of rectification - Article 16 GDPR: right to obtain, without undue delay, the correction of
inaccurate personal data concerning you and/or the integration of incomplete
16. Rights of the interested parties (Part 2)
• Right to cancellation (right to be forgotten) - Article 17 GDPR: right to obtain, without undue
delay, the cancellation of personal data concerning you when:
- The data are no longer necessary with respect to the purposes for which they were collected or otherwise
- You have revoked your consent and there is no other legal basis for the processing;
- Has successfully opposed the processing of personal data;
- The data were processed unlawfully;
- The data must be deleted to fulfill a legal obligation;
- The personal data have been collected with regard to the information society service offer referred to in
Article 8 (1) of the GDPR.
It is understood that the right to cancellation does not apply to the extent that the processing is
necessary for the owner, for the exercise of the rights to freedom of
expression and information, for the fulfillment of a legal obligation or for the execution of a task
performed in the public interest, for purposes of archiving in the
public interest, scientific or historical research or for statistical purposes, for the assessment, exercise
or defense of a right in court.
• Right to limitation of treatment - Article 18 GDPR: right to obtain limitation of treatment,
- The interested party disputes the accuracy of personal data, for the period necessary for the holder to
verify the accuracy of such data;
- The processing is illegal and the interested party opposes the cancellation of personal data and asks
instead that its use is limited;
- The personal data are necessary for the interested party to ascertain, exercise or defend a right in
- The interested party opposed the treatment pursuant to art. 21 GDPR, in the period of waiting for the
verification on the possible prevalence of legitimate reasons of
the holder of the treatment with respect to those of the interested party;
• Right to data portability - Article 20 GDPR: right to receive, in a structured format, commonly
used and readable by an automatic device, the personal data concerning
you provided to the owner and the right to transmit them to another holder without impediments, if the
treatment is based on consent and is done by automated means. Furthermore,
the right to obtain that your personal data is transmitted directly by the data controller to another data
controller if this is technically feasible;
• Right of opposition - Article 21 GDPR: right to object, at any time for reasons related to your
particular situation, to the processing of personal data concerning you
based on the lawfulness of legitimate interest or the performance of a task in the public interest or
exercise of public powers, including profiling, unless there are legitimate
reasons for the data controller to continue processing that prevail over the interests, rights and freedoms
of the data subject or for the assessment, exercise or defense of a
right in court. Furthermore, the right to oppose the processing at any time if personal data are processed
for direct marketing purposes, including profiling, to the extent that
it is related to such direct marketing. In particular, you have the right not to be subjected to a decision
based solely on automated processing, including profiling, which produces
legal effects that affect you or that significantly affects your person, except that this decision is
necessary for the conclusion or execution of a contract between you and the
owner, or is authorized by European Union law or by German law, or based on your explicit
16. Rights of the interested parties (Part 3)
• Right of withdrawal of consent - Right to withdraw consent to the processing of your data at any
time, while maintaining the lawfulness of the processing based on consent
• Right to propose a complaint - Right to propose a complain to the authority for the protection of
The above rights may be exercised against the owner by contacting the indicated references. The exercise of
your rights as an interested party is free under Article 12 of the GDPR.
However, in the case of manifestly unfounded or excessive requests, also due to their repetitiveness, the
administrator may charge a reasonable fee, in light of the administrative costs
incurred to manage your request, or deny the satisfaction of your request.
17. Severability clause
If any of these policies are determined to be illegal, invalid (e.g. due to a far too broad conception,
"outdated" orthography, english words and/or grammar, missing translation into all
european languages or into all languages of the universe) or otherwise unenforceable by reason of the laws of any
state or country in which these terms and conditions are intended
invalid or unenforceable, it shall be severed and deleted from this
clause and the remaining policies shall survive, remain in full force and effect and continue to be binding and
18. Terms and Conditions
The agreement that sets the rules and guidelines that the user must agree to and follow in order to use and access
the site are subject to our terms and conditions .
For more information, please see our complete terms and conditions statement at https://www.minniti.de/terms.
For any questions regarding the interpretation of the above privacy and cookies rules of this site, you can write a
letter to DE-80807 Munich, Max-Bill-Str. 30 or send an email
to (email@example.com) indicating as object: "Information about your privacy and cookies rules" to receive the
assistance you need.