Privacy gb-admin 8. May 2023


1. introduction

With the following information, we would like to give you as a “data subject” an overview of the processing of your personal data by us and your rights under data protection laws. In principle, it is possible to use our Internet pages without entering personal data. However, if you want to use special services of our enterprise 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 will generally obtain your consent.

The processing of personal data, such as your name, address, or e-mail address, is always in line with the German Data Protection Regulation (Datenschutz-Grundverordnung – DS-GVO), and in accordance with the country-specific data protection regulations applicable to the “steercom GmbH GmbH”. By means of this privacy policy, we would like to inform you about the scope and purpose of the personal data collected, used and processed by us.

As the controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, you are also free to transmit personal data to us by alternative means, for example by telephone or by mail.

You can also take simple and easy-to-implement measures to protect yourself against unauthorized access to your data by third parties. Therefore, we would like to give you some tips here on how to handle your data securely:
● Protect your account (login, user or customer account) and your IT system (computer, laptop, tablet or mobile device) with strong passwords.
● Only you should have access to the passwords.
● Make sure you only ever use your passwords for one account (login, user or customer account).
● Do not use one password for different websites, applications or online services.
● Especially when using publicly accessible or shared IT systems, be sure to log out after each login to a website, application, or online service.

Passwords should consist of at least 12 characters and be chosen so that they cannot be easily guessed. Therefore, they should not contain common words from everyday life, your own name or names of relatives, but upper and lower case, numbers and special characters.

2. responsible person

The responsible person in the sense of the DS-GVO is:

steercom GmbH
Danziger Street 35a
D-20099 Hamburg

Telephone: +49-40-511 16-26

Representatives of the responsible person: Carsten Leminsky, Wolfgang Hackenberg

3. data protection officer
We would like to point out that no data protection officer has to be appointed.
The contact person for data protection: Wolfgang Hackenberg

4. definitions

The data protection declaration is based on the terms used by the European Directive and Ordinance Maker when issuing the Basic Data Protection Regulation (DS-GVO). Our data protection declaration 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 terminology used in advance.

We use the following terms, among others, in this data protection declaration:

1. personal data
Personal data is any information relating to an identified or identifiable natural person. 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.
2. data subject
Data subject is any identified or identifiable natural person whose personal data is processed by the controller (our company).
3. processing
Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
4. restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
5. profiling
Profiling is any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
6. pseudonymization
Pseudonymization is the processing of personal data in such a way 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 separate and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
7. processor
Processor means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
8. recipient
Recipient means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigative task under Union or Member State law shall not be considered as recipients.
9. third party
Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.
10. consent
Consent is any expression of will in the form of a declaration or other unambiguous affirmative act, given voluntarily by the data subject for the specific case in an informed manner and unambiguously, by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.

5. legal basis of the processing

Art. 6 (1) lit. a DS-GVO (in conjunction with Section 25 (1) TTDSG) 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 you are a party, as is the case, for example, with processing operations that are necessary for a delivery of goods or the provision of another service or consideration, the processing is based on Article 6 (1) lit. b DS-GVO. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services.

If our company is subject to a legal obligation by which a processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6 (1) lit. c DS-GVO.

In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result 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. Then the processing would be based on Art. 6 (1) lit. d DS-GVO.

Finally, processing operations could be based on Art. 6(1)(f) 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 protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if you are a customer of our company (recital 47 sentence 2 DS-GVO).

Our offer is basically directed at adults. Persons under the age of 16 may not transmit any personal data to us without the consent of their parents or legal guardians. We do not request personal data from children and young people, do not collect them and do not pass them on to third parties.

6. technology

6.1 SSL/TLS Encryption
This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us as the operator. You can recognize an encrypted connection by the fact that there is a https:// instead of a http:// in the address line of the browser and by the lock symbol in your browser line.

We use this technology to protect your transmitted data.

6.2 Data collection when visiting the website
When using our website for information purposes only, i.e. when not registering or otherwise transmitting information to us, we only collect data that your browser transmits to our server (in so-called “server log files”). Our website collects a series of general data and information with each call of a page by you or by an automated system. This general data and information is stored in the server log files. The following can be recorded

1. browser types and versions used,
2. the operating system used by the accessing system,
3. the website from which an accessing system arrives at our website (so-called referrer),
4. the sub-websites that are accessed via an accessing system on our website,
5. the date and time of an access to the Internet site,
6. an Internet protocol address (IP address) and,
7. the Internet service provider of the accessing system.

When using this general data and information, we do not draw any conclusions about your person. Rather, this information is required in order to

1. deliver the contents of our Internet site correctly,
2. optimize the content of our website as well as the advertising for it,
3. to ensure the long-term functionality of our IT systems and the technology of our website, and
4. to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.

Therefore, the data and information collected is, on the one hand, statistically analyzed by us and, on the other hand, it is evaluated with the aim of increasing the data protection and data security of our enterprise so as to ultimately ensure an optimal level of protection for the personal data we process. The data of the server log files are stored separately from any personal data provided by a data subject.

The legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f DS-GVO. Our legitimate interest follows from the purposes for data collection listed above.

7. cookies

7.1 General information about cookies
Cookies are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone or similar) when you visit our site.

In the cookie, information is stored that results in each case from the context of the specific end device used. This does not mean, however, that we thereby gain direct knowledge of your identity.

The use of cookies serves to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site.

In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your terminal device for a certain fixed period of time. If you visit our site again to use our services, it is automatically recognized that you have already been with us and which entries and settings you have made so that you do not have to enter them again.

On the other hand, we use cookies to statistically record the use of our website and to evaluate our offer for you for the purpose of optimization. These cookies enable us to automatically recognize that you have already visited our website when you visit it again. The cookies set in this way are automatically deleted after a defined period of time. The respective storage period of the cookies can be found in the settings of the consent tool used.

7.2 Legal basis for the use of cookies
The data processed by the cookies, which are required for the proper functioning of the website, are thus necessary to protect our legitimate interests as well as those of third parties in accordance with Art. 6 (1) lit. f DS-GVO.

For all other cookies, it applies that you have given your consent to this via our opt-in cookie banner within the meaning of Art. 6 (1) lit. a DS-GVO.

7.3 Information on how to avoid cookies in common browsers
Via the settings of the browser you are using, you have the option to delete cookies, to allow only selected cookies or to disable cookies completely at any time. You can obtain further information on the support pages of the respective providers:
● Chrome:
● Safari:
● Firefox:
● Microsoft Edge:

7.4 Compliance GDPR/CCPA (Consent Management Tool).
We use the consent management tool “Complianz GDPR/CCPA Cookie Consent” (Complianz) provided by Complianz B.V., Kalmarweg 14-5, 9723 JG Groningen, Netherlands. This service allows us to obtain and manage the consent of website users for data processing.

Complianz uses cookies to collect data generated by end users who use our website. When an end user provides consent, Complianz automatically logs the following data:

● Browser information,
● date and time of access,
● Device information,
● The URL, of the page visited,
● Banner language,
● Consent ID,
● The consent status of the end user, which serves as proof of consent.
The consent status is also stored in the end user’s browser so that the website can automatically read and follow the end user’s consent in all subsequent page requests and future end user sessions for up to 12 months. Consent data (consent and withdrawal of consent) is stored for three years. The retention period corresponds to the regular limitation period according to § 195 BGB. The data will then be deleted immediately.

The functionality of the website is not guaranteed without the described processing. There is no possibility for the user to object as long as there is a legal obligation to obtain the user’s consent to certain data processing operations (Artt. 7 para. 1, 6 para. 1 p. 1 lit. c DSGVO).

Complianz is a recipient of your personal data and acts as a processor for us. The data processing takes place exclusively in the European Union.

Detailed information on the use of Complianz can be found at:

7.5 Cookie consent with Consent Manager Provider
Our website uses the cookie consent technology of Consent Manager Provider to obtain your consent to the storage of certain cookies on your terminal device and to document this in a data protection-compliant manner. The provider of this technology is Jaohawi AB, Håltegelvägen 1b, 72348 Västerås, Sweden, website: (hereinafter “Consent Manager Provider”).

When you enter our website, a connection is made to Consent Manager Provider’s servers to obtain your consents and other statements regarding cookie use. Subsequently, Consent Manager Provider stores a cookie in your browser in order to be able to assign the consents granted to you or their revocation.

The data collected in this way will be stored until you request us to delete it, delete the Consent Manager Provider cookie yourself, or until the purpose for storing the data no longer applies. Mandatory legal storage obligations remain unaffected.

Consent Manager Provider is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 p. 1 lit. c DSGVO.

8. contents of our website

8.1 Data processing for order processing
The personal data collected by us will be passed on to the transport company commissioned with the delivery as part of the contract processing, insofar as this is necessary for the delivery of the goods. We pass on your payment data to the commissioned credit institution within the framework of payment processing, insofar as this is necessary for payment processing. If payment service providers are used, we inform explicitly about this below. The legal basis for the transfer of data is here Art. 6 para. 1 lit. b DS-GVO.

8.2 Conclusion of contracts with online store, merchants and shipment of goods
We transmit personal data to third parties only if this is necessary in the context of contract processing, such as to the companies entrusted with the delivery of the goods or the credit institution entrusted with the payment processing. A further transmission of the data does not take place or only if you have expressly agreed to the transmission. Your data will not be passed on to third parties without your express consent, for example for advertising purposes.

The basis for data processing is Art. 6 (1) lit. b DS-GVO, which permits the processing of data for the performance of contracts or pre-contractual measures.

8.3 Contacting us / contact form
In the context of contacting us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of using a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. The legal basis for processing the data is our legitimate interest in responding to your request pursuant to Art. 6 (1) lit. f DS-GVO. If your contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b DS-GVO. Your data will be deleted after final processing of your request, this is the case if it can be inferred from the circumstances that the matter concerned has been conclusively clarified and the deletion is not contrary to any statutory retention obligations.

9 Our activities in social networks

So that we can also communicate with you in social networks and inform you about our services, we are represented there with our own pages. If you visit one of our social media pages, we are jointly responsible for the processing operations triggered by this, within the meaning of Art. 26 DS-GVO, with the provider of the respective social media platform.

We are not the original provider of these pages, but merely use them within the scope of the possibilities offered to us by the respective providers.
As a precaution, we therefore point out that your data may also be processed outside the European Union or the European Economic Area. Use may therefore be associated with data protection risks for you, as safeguarding your rights, e.g. to information, deletion, objection, etc., could be more difficult and processing in the social networks often takes place directly for advertising purposes or for the analysis of user behavior by the providers, without this being able to be influenced by us. If usage profiles are created by the provider, this often involves the use of cookies or the assignment of usage behavior to your own member profile of the social networks.

The described processing operations of personal data are carried out in accordance with Art. 6 Para. 1 lit. f DS-GVO on the basis of our legitimate interest and the legitimate interest of the respective provider in order to be able to communicate with you in a timely manner or to inform you about our services. If you have to give your consent to data processing as a user with the respective providers, the legal basis refers to Art. 6 (1) lit. a DS-GVO in conjunction with. Art. 7 DS-GVO.

Since we do not have access to the providers’ databases, we would like to point out that it is best to assert your rights (e.g. to information, correction, deletion, etc.) directly with the respective provider. We have listed further information on the processing of your data in the social networks below with the respective social network provider used by us:

9.1 LinkedIn
(Co-)responsible for data processing in Europe:
LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland.

Privacy Policy:

9.2 XING (New Work SE)
(Co-) controller for data processing in Germany:
New Work SE, Am Strandkai 1, 20457 Hamburg, Germany.

Privacy policy:

Information requests for XING members:

10. web analytics

10.1 Google Analytics 4 (GA4)
On our websites, we use Google Analytics 4 (GA4), a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

In this context, pseudonymized usage profiles are created and cookies (see item “Cookies”) are used. The information generated by the cookie about your use of this website may include:

● a short-term recording of the IP address without permanent storage.
● location data
● browser type/version
● operating system used
● referrer URL (previously visited page)
● time of the server request
The pseudonymized data may be transmitted by Google to a server in the USA and stored there.

The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services related to website and internet usage for the purposes of market research and demand-oriented design of these web pages. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data.

These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 Para. 1 lit. a DS-GVO.

Further information on data protection when using GA4 can be found at:

11 Plugins and other services

11.1 Font Awesome
Our website uses so-called web fonts for the uniform display of fonts, which are provided by Fonticons Inc, 307 S Main St Ste 202 Bentonville, AR, USA. When you call up a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.

For this purpose, the browser you are using must connect to the servers of Fonticons, Inc. This enables Fonticons, Inc. to know that our website has been accessed via your IP address. Font Awesome is used in the interest of a uniform and appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f DS-GVO.

If your browser does not support Font Awesome, a standard font will be used by your end device.

For more information on the privacy policy of Fonticons Inc. please visit:

11.2 Google WebFonts
Our website uses so-called Web Fonts for the uniform display of fonts. The Google WebFonts are provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ireland Limited is part of the Google group of companies with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 Para. 1 lit. a DS-GVO.

Further information on Google WebFonts and Google’s privacy policy can be found at: ;

12. your rights as a data subject

12.1 Right to confirmation
You have the right to request confirmation from us as to whether personal data concerning you is being processed.

12.2 Right to information Art. 15 DS-GVO.
You have the right to obtain from us, at any time and free of charge, information about the personal data stored about you, as well as a copy of this data in accordance with the legal provisions.

12.3 Right to rectification Art. 16 DS-GVO
You have the right to demand that incorrect personal data concerning you be corrected. Furthermore, you have the right to request the completion of incomplete personal data, taking into account the purposes of the processing.

12.4 Deletion Art. 17 DS-GVO
You have the right to demand that we delete the personal data concerning you without undue delay, provided that one of the reasons provided for by law applies and insofar as the processing or storage is not necessary.

12.5 Restriction of processing Art. 18 DS-GVO
You have the right to demand that we restrict processing if one of the legal requirements applies.

12.6 Data portability Art. 20 DS-GVO
You have the right to receive the personal data concerning you, which has been provided to us by you, in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from us to whom the personal data has been provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) DS-GVO or Art. 9(2)(a) DS-GVO or on a contract pursuant to Art. 6(1)(b) DS-GVO and the processing is carried out with the aid of automated procedures, 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 us.

Furthermore, when exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to obtain that the personal data be transferred directly from one controller to another controller, insofar as this is technically feasible and insofar as this does not adversely affect the rights and freedoms of other persons.

12.7 Objection Art. 21 DS-GVO
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) (data processing in the public interest) or (f) (data processing on the basis of a balance of interests) DS-GVO.

This also applies to profiling based on these provisions within the meaning of Art. 4 No. 4 DS-GVO.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or insofar as the processing serves the assertion, exercise or defense of legal claims.

In individual cases, we process personal data to conduct direct marketing. You may object to the processing of personal data for the purpose of such advertising at any time. This also applies to profiling, insofar as it is related to such direct advertising. If you object to us processing for direct marketing purposes, we will no longer process the personal data for these purposes.

In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you which is carried out by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the DS-GVO, unless such processing is necessary for the performance of a task carried out in the public interest.

You are free to exercise your right to object by means of automated procedures using technical specifications in connection with the use of information society services, notwithstanding Directive 2002/58/EC.

12.8 Revocation of consent under data protection law
You have the right to revoke consent to the processing of personal data at any time with effect for the future.

12.9 Complaint to a supervisory authority
You have the right to complain about our processing of personal data to a supervisory authority responsible for data protection.

13 Routine storage, deletion and blocking of personal data.

We process and store your personal data only for the period of time necessary to achieve the purpose of storage or if this has been provided for by the legal provisions to which our company is subject.

If the storage purpose ceases to apply or if a prescribed storage period expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

14 Duration of storage of personal data

The criterion for the duration of storage of personal data is the respective statutory retention period. After expiry of the period, the corresponding data will be routinely deleted, provided that they are no longer required for the fulfillment or initiation of the contract.

15. topicality and change of the data protection declaration

This data protection declaration is currently valid and has the status: June 2023.

Due to the further development of our Internet pages and offers or due to changed legal or official requirements, it may become necessary to change this data protection declaration. The current data protection declaration can be accessed and printed out at any time on the website under

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