Privacy Policy

1. Controller

The controller within the meaning of Art. 4(7) GDPR for the processing of personal data on this website is:

• Fairplay-Management GmbH
• Schauenburgerstraße 116, 24118 Kiel, Germany
• Managing Director (Geschäftsführer): Darius Karampoor
• Commercial register: HRB 21360 KI, Local Court of Kiel
• Email: agentur@fairplay-management.de
• Phone: +49 431 58649991

2. Data protection officer

Our data protection officer (Datenschutzbeauftragter) is:

• compolicy GmbH
• Schwedenkai 1, 24103 Kiel, Germany
• info@compolicy.de

3. Cookies, analytics and third-party services

This website does not use cookies. It does not use analytics tools, advertising, social media buttons or embedded third-party content such as videos or maps.

All files needed to display the pages, including the fonts (Inter, Noto Sans JP), are delivered from the server we use. Your browser therefore does not connect to any third-party server when you visit this website.

4. Server log files

When you visit this website, the server automatically records the following information sent by your browser in log files in order to deliver the pages:

• IP address
• Date and time of access
• Page or file requested and the server response
• Amount of data transferred
• Previously visited page (referrer)
• Browser type and version, and operating system (user agent)

Purpose: delivering the website, keeping it secure and stable, and detecting and investigating faults and unauthorised access. We do not use this information for statistics and do not combine it with other data to identify individuals.

Legal basis: Art. 6(1)(f) GDPR (our legitimate interest in operating the website securely and reliably).

Retention: log files are deleted automatically after about two weeks. Where needed to investigate a specific fault or attack, we may keep them until the matter is resolved.

5. Hosting

This website runs on a server in Germany provided by OVH GmbH, Oskar-Jäger-Str. 173, 50825 Köln, Germany. OVH GmbH provides the server infrastructure as a processor under Art. 28 GDPR, acting on our instructions.

6. Enquiries (form, email, phone)

The contact form on this website does not send or store your input on our server. When you press "Create email", your email program opens a pre-filled message. We only receive your information if you send that email. The same applies if you contact us directly by email or phone.

Data processed: company, department and position, name, email address, phone number, type of enquiry, budget range, your message, and the information that comes with sending an email (such as date and time).

Purpose: answering your enquiry, scheduling a consultation, preparing proposals and quotes, and follow-up communication.

Legal basis: Art. 6(1)(b) GDPR (steps prior to entering into a contract) for enquiries about a possible engagement; otherwise Art. 6(1)(f) GDPR (our legitimate interest in answering enquiries properly).

Retention: we delete your data once your enquiry has been dealt with and the data is no longer needed. Where German commercial or tax law requires us to keep records, for example if a contract is concluded (Section 257 of the German Commercial Code, Section 147 of the German Fiscal Code: six or ten years), we keep them until that period ends.

You are not legally or contractually required to provide personal data. Without contact details, however, we cannot answer your enquiry.

The processing by your own email provider is governed by that provider’s privacy policy.

7. Email service we use

We use Microsoft 365 to receive and store email. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland, acting as a processor under Art. 28 GDPR on our instructions.

Microsoft may process data in the United States. Such transfers are based on the European Commission’s adequacy decision for the EU-U.S. Data Privacy Framework of 10 July 2023 and Microsoft’s participation in it, as well as on the European Commission’s standard contractual clauses.

8. Recipients

We do not sell personal data. Apart from the processors named above, we only share personal data with third parties if you have consented or if we are legally required to do so.

Within our company, only the employees who need it to handle your enquiry have access to your personal data.

9. Transfers outside the EU (including Japan)

The server of this website and our business are located in Germany. When we reply to an enquiry from Japan, your personal data is sent to Japan together with our email.

In its Implementing Decision (EU) 2019/419 of 23 January 2019, the European Commission found that Japan ensures an adequate level of protection for personal data. Transfers to Japan are based on this adequacy decision (Art. 45 GDPR).

10. Japanese data protection law

This policy is based on the GDPR. Where the Japanese Act on the Protection of Personal Information applies to personal information we receive from people in Japan, we also comply with that Act.

Japan’s Personal Information Protection Commission has designated the EU member states as foreign countries with a personal information protection system equivalent to Japan’s in protecting individual rights and interests.

11. Your rights

Under the GDPR you have the following rights with respect to us:

• Right of access to your personal data (Art. 15)
• Right to rectification of inaccurate or incomplete data (Art. 16)
• Right to erasure (Art. 17)
• Right to restriction of processing (Art. 18)
• Right to receive the data you provided in a structured, commonly used format and to transmit it to another controller (Art. 20)
• Right to withdraw consent at any time where processing is based on consent (Art. 7(3)); this does not affect the lawfulness of processing before the withdrawal

Right to object (Art. 21): you may object at any time, on grounds relating to your particular situation, to processing based on our legitimate interests (Art. 6(1)(f) GDPR). We will then stop the processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

We do not make decisions based solely on automated processing, including profiling.

To exercise your rights, please contact agentur@fairplay-management.de. You are welcome to write to us in Japanese.

12. Right to lodge a complaint

If you believe that our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with a supervisory authority (Art. 77 GDPR). The authority responsible for us is:

• Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein (ULD)
• Holstenstraße 98, 24103 Kiel, Germany
• mail@datenschutzzentrum.de · https://www.datenschutzzentrum.de

You may also contact the supervisory authority in the EU member state of your habitual residence, place of work or place of the alleged infringement.

13. Security

Connections to this website are encrypted with TLS. We take appropriate technical and organisational measures to protect personal data against loss, alteration and unauthorised access, and review them as needed.

14. Links to other websites

This website links to other websites, including our German website (https://fairplay-management.de). The privacy policies of those websites apply there. Unlike this website, our German website uses cookies and analytics tools; please see its privacy policy (in German) for details.

15. Changes to this policy

We may update this policy when the law or this website changes. The current version is always available on this page.