Privacy Policy | Tower360 GmbH
As of 05.01.2024
Who we are
The data controller responsible in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European
Union and other data protection regulations is:
Tower360 GmbH
Rödingsmarkt 9
20459 Hamburg
Germany
040 87408207
E-Mail-Adresse: Datenschutz@tower360.co
Webseite: www.tower360.co
How to contact the data protection officer
The designated data protection officer is:
DataCo GmbH
Nymphenburger Str. 86
80636 Munich
Germany
Tel.: +49 89 7400 45840
Webseite: www.dataguard.de
General information on data processing
On this page, we provide you with information regarding the processing of your personal data on our website.
How we collect and use your personal data will depend on how you interact with us or the services you use. We only collect, use or share your personal data where we have a legitimate purpose and a legal basis for doing so.
What do we mean by ‘legal basis’?
Consent (Art. 6(1) (a) GDPR)– You have given us your consent to process your personal data for the specific purpose we have explained to you. You have the right to withdraw your consent at any time. For further information on how to withdraw consent, please see the ‘Exercising your rights’ subsections in the subsequent sections of this Privacy Policy.
Legal Obligation (Art 6(1) (c) GDPR) – We need to use you’re your data to comply with the law.
Vital Interests (Art 6(1) (d) GDPR) – Processing your data is necessary to protect your vital interests or of another person. For example, to prevent you from serious physical harm.
Legitmate Interests (Art 6(1) (f) GDPR) – Processing your data is necessary to support a legitimate interest we or another party has, only where this is not outweighed by your own interests.
Please note where your data is processed under the performance of a contract or for a legal obligation, if you do not provide the data requested, we may be unable to provide you with our app.
Data sharing and international transfers
As explained throughout this Privacy Policy, we use various service providers to help us deliver our services and keep your data secure. When we use these service providers, it is necessary for us to share your personal data with them.
We have agreements in place with all our service providers that we share your data with that oblige them to protect your data.
Where your personal data is shared outside the EU, we ensure that your personal data is given an equivalent level of protection, either because the jurisdiction to which your data is transferred has an ‘adequate’ data protection standard according to the European Commission, or by using another safeguard such as an enhanced contractual agreement, i.e. Standard Contractual Clauses adopted by the European Commission (SCCs).
For example, where we use US service providers, we either rely on SCCs or the EU-US Data Protection Framework, depending on the specific provider. You can request a copy of SCCs we have concluded with our service providers by sending an email to the email address provided in this Privacy Policy.
Your rights
When your personal data is processed, you are a data subject within the meaning of the GDPR and have the following rights:
1. Right of access (Art. 15 GDPR)
You may request the data controller to confirm whether your personal data is processed by them.
If such processing occurs, you can request the following information from the data controller:
  • Purposes of processing
  • Categories of personal data being processed.
  • Recipients or categories of recipients to whom the personal data have been or will be disclosed.
  • Planned storage period or the criteria for determining this period
  • The existence of the rights of rectification, erasure or restriction or opposition.
  • The existence of the right to lodge a complaint with a supervisory authority.
  • If applicable, origin of the data (if collected from a third party).
  • If applicable, existence of automated decision-making including profiling with meaningful information about the logic involved, the scope and the effects to be expected.
  • If applicable, transfer of personal data to a third country or international organization.
2. Right to rectification (Art. 16 GDPR)
You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay
3. Right to the restriction of processing (Art. 18 GDPR)
You may request the restriction of the processing of your personal data under the following conditions:
  • If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
  • The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
  • The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
  • If you have objected to the processing pursuant and it is not yet certain whether the legitimate interests of the data controller override your interests.
4. Right to erasure ("Right to be forgotten") (Art. 17 GDPR)
If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:
  • Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
  • You withdraw your consent on which the processing is based pursuant to and where there is no other legal basis for processing the data.
  • You object to the processing of the data and there are no longer overriding legitimate grounds for processing, or you object pursuant to Art. 21 (2) GDPR.
  • Your personal data has been processed unlawfully.
  • The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject.
  • Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.
The right to deletion does not exist if the processing is necessary to exercise
  • the right to freedom of speech and information;
  • to fulfil a legal obligation required by the law of the Union or Member States to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative. for reasons of public interest in the field of public health.
  • for archival purposes of public interest, scientific or historical research purposes or for statistical purposes.
  • to enforce, exercise or defend legal claims.
5. Right to data portability
You have the right to receive your personal data given to the data controller in a structured and machinereadable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data.
6. Right to object
For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (e) or 6 (1) (f) GDPR; this also applies to profiling based on these provisions.
If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.
7. Right to complain 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 if you consider that the processing of personal data concerning you infringes the GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR. A list, of the locally competent supervisory authorities in Germany can be found on the website of the Federal Commissioner for Data Protection at the following link:
https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html
Data processing when you load our website
1. Description and scope of data processing
Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device.
The following data is collected:
  • Date and time of access
This data is stored in the log files of our system.
2. Purpose of data processing
The temporary storage of the IP address by the system is necessary for the delivery of the website to the computer of the user. For this purpose, the user’s IP address must be kept for the duration of the session.
The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimize the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.
3. Legal basis for data processing
The legal basis for the temporary storage of data and logfiles is Art. 6 (1) (f) GDPR.
4. Duration of storage
The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the website is accomplished.
If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is not possible.
5. Exercising your rights
The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. The user can object to this. Whether the objection is successful is to be determined within the framework of a balancing of interests.
Use of cookies
1. Description and scope of data processing
When you visit our website, we use technical tools for various functions, in particular cookies, which can be stored on your device. When you visit our website for the first time and at any time later, you have the choice of whether you generally permit the setting of cookies or which individual additional functions you would like to select. You can make changes in your browser settings or via our consent manager. Cookies are text files or information in a database that are stored on your hard drive and assigned to the browser you are using so that certain information can be passed to the entity that sets the cookie.
We use technically necessary cookies, which are required for the technical structure of the website. Without these cookies, our website cannot be displayed (completely correctly) or the support functions are not possible.
The following data is stored and transmitted in the technical necessary cookies:
  • Language settings
We use cookies on our website that are not technically necessary. Technically unnecessary cookies are text files that are not only used for the functionality of the website, but also collect other data.
As a result, the following data will be processed:
  • IP-address
  • Internet user location
  • Date and time of the website request
  • Tracking of the surfing behavior
  • Linking the website visit with other social media platforms
2. Purpose of data processing
The purpose of using technically necessary cookies is to ensure the functionality of our website. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.
We need technical necessary cookies for the following purposes:
  • Storage of language settings
  • Functionality of the website
  • Compliance with legal obligations, consent storage
The use of technically not necessary cookies is carried out for the purpose of improving the quality of our website, its content and thus our reach and profitability. By setting these cookies, we learn how the website is used and can thus constantly optimize our offer. These cookies serve us particularly for the following purposes:
  • Marketing, statistics, analysis, optimization
3. Legal basis for data processing
The regulations of the Telecommunications-Telemedia Data Protection Act (TTDSG) are relevant for the storage of information in the end user's terminal equipment and/or access to information already stored in the end user's terminal equipment. If the setting and reading of cookies is technically necessary, this is done to ensure the functionality of our website. In this case, the storage of and access to cookies on your terminal equipment is carried out on the basis of § 25(2)(2) TTDSG. This storage of and access to the information in your terminal equipment serves to facilitate your use of our website and to be able to offer you our services as you have requested. Some functions of our website also do not work without the use of these cookies and could therefore not be offered. The cookies are generally deleted after the session ends (e.g. logging out or closing the browser) or after the expiry of a specified duration. Information on different storage periods for cookies can be found in the following sections of this data protection declaration.
As far as cookies are set that are not technically necessary, this is done on the basis of your expressed consent, which you can provide via the cookie banner. The basis for storing and accessing information in this case is § 25(1) TTDSG in conjunction with. Art. 6(1)(1)(a), Art. 7 GDPR. You can withdraw your consent at any time with effect for the future or subsequently grant it again by configuring your settings for cookies accordingly. Alternatively, you can prevent the storage of cookies by making the appropriate settings in your browser software. Please note that the browser settings you make only affect the browser you are using. If personal data is processed following the storage of and access to the information on your terminal equipment, the provisions of the GDPR are relevant. Information on this can be found in the following sections of this privacy policy.
4. Exercising your rights
You can withdraw your consent to the use of cookies at any time and manage your consent preferences via the cookie banner on the Tower360.co website.
Contact form
1. Description and scope of data processing
A contact form is available on our website, which can be used for electronic contact. If you make use of this option, the data entered in the contact form will be transmitted to us and stored.
When sending the message the following data will also be stored:
  • Email address
  • Last name
  • First name
  • Address
  • Telephone / mobile phone number
  • Roles in the company,
  • Company,
  • Number of assets
  • Date and time
1. Description and scope of data processing
The processing of the personal data from the form as well as if you contact us by mail serves us exclusively for the purpose of establishing contact.
The other personal data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.
3. Legal basis for data processing
The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (f) GDPR. Our legitimate interest is to provide you with the best possible response to the request you send to us via the contact form. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.
4. Duration of storage
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be inferred from the circumstances that the facts in question have been conclusively clarified.
The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.
5. Exercising your rights
If you contact us via the the contact form or via e-mail, you can object to the storage of your personal data at any time, by the following means:
If you wish to revoke your consent, you must send an e-mail to privacy@tower360.co with the subject "Revocation".
Corporate web profiles on social networks
Twitter:
Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland
On our company profile we provide information and offer Twitter users the possibility of communication. If you carry out an action on our Twitter company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Twitter, we cannot make any binding statements regarding the purpose and scope of the processing of your data.
Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We use the company's profile for:
  • The use of the company websites serves to improve the image and for better networking with regard to the Tower360 asset management platform.
Publications on the company profile can contain the following content:
  • Information about products
  • Information about services
Every user is free to publish personal data.
As far as we process your personal data in order to evaluate your online behavior, to offer you sweepstakes or to conduct lead campaigns, this is done on the basis of your express declaration of consent, Art. 6 (1) (a), Art. 7 GDPR. The legal basis for processing personal data for the purpose of communicating with customers and interested parties is Art. 6 (1) (f) GDPR. Thereby, our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.
The data generated on the company profile are not stored in our own systems.
You can object at any time to the processing of your personal data that we collect within the framework of your use of our corporate web profiles and assert your rights as a data subject mentioned the"Your rights" section of this privacy policy. Please send us an informal email to datenschutz@tower360.co. For further information on the processing of your personal data by Twitter and the corresponding objection options, please click here:
Use of corporate profiles in professionally oriented networks
1. Scope of data processing
We use corporate profiles on professionally oriented networks. We maintain a corporate presence on the following professionally oriented networks:
  • LinkedIn
  • XING
On our site we provide information and offer users the possibility of communication.
The corporate profile is used for job applications, information, public relations, and active sourcing.
We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate profile. Further information can be found in the privacy policy of:
If you carry out an action on our company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public.
2. Legal basis for data processing
The legal basis for the processing of personal data for the purpose of communication with customers and interested parties is Art. 6 (1) (f) GDPR. Our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.
3. Purpose of the data processing
Our corporate web profile serves to inform users about our services. Every user is free to publish personal data.
4. Duration of storage
The data generated on the company profile are not stored in our own systems.
5. Exercising your rights
You can object at any time to the processing of your personal data that we collect within the framework of your use of our corporate web profiles and assert your rights as a data subject mentioned the"Your rights" section of this privacy policy. Please send us an informal email to the email address stated in this privacy policy.
You can find further information on objection and removal options here:
Hosting
The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is:
  • Date and time of access
This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website - and server log files are therefore recorded.
The server of the website is geographically located in Germany.
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