vasiliy fedotov / lighthouse arts gmbh
revaler str. 99 10245 berlin germany
managing director / owner: vasiliy fedotov
link to the imprint: https://khroma.berlin/impressum
types of processed data:
inventory data (e.g., personal master data, names, or addresses). contact data (e.g., email, telephone numbers). content data (e.g., text input, photographs, videos). usage data (e.g., websites visited, interest in content, access times). meta/communication data (e.g., device information, ip addresses). categories of data subjects:
visitors and users of the online offering (hereinafter, the data subjects are collectively referred to as “users”).
purpose of processing:
provision of the online offering, its functions, and content. answering contact inquiries and communicating with users. security measures. range measurement/marketing. terms used:
“personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); 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 (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
“processing” means any operation or set of operations that is performed on personal data, whether or not by automated means. the term is broad and covers virtually any handling of data.
“pseudonymization” means the processing of personal data in a way that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
“profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
“controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
relevant legal bases:
the legal basis for obtaining consent is article 6(1)(a) and article 7 of the gdpr. the legal basis for processing for the performance of our services and the execution of contractual measures is article 6(1)(b) of the gdpr. the legal basis for processing to fulfill our legal obligations is article 6(1)(c) of the gdpr. in the event that vital interests of the data subject or another natural person require the processing of personal data, article 6(1)(d) of the gdpr serves as the legal basis. the legal basis for the processing necessary to perform a task carried out in the public interest or in the exercise of official authority vested in the controller is article 6(1)(e) of the gdpr. the legal basis for processing to safeguard our legitimate interests is article 6(1)(f) of the gdpr. the processing of data for purposes other than those for which the data was collected is governed by the provisions of article 6(4) of the gdpr.
in accordance with the legal requirements, taking into account the state of the art, the implementation costs, and the nature, scope, context, and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
these measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access, input, disclosure, availability, and separation of the data. we have also set up procedures to ensure the exercise of data subject rights, data deletion, and data vulnerability. furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and processes in accordance with the principle of data protection through technology design and data protection-friendly default settings.
collaboration with processors and third parties:
if, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them, or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g., if the transmission of the data to third parties, such as payment service providers, is required for the performance of a contract in accordance with article 6(1)(b) of the gdpr), if you have consented, if a legal obligation provides for it, or on the basis of our legitimate interests (e.g., when using agents, web hosts, etc.).
if we commission third parties with the processing of data on the basis of a so-called “order processing contract,” this is done on the basis of article 28 of the gdpr.
transfers to third countries:
if we process data in a third country (i.e., outside the european union (eu) or the european economic area (eea)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation, or on the basis of our legitimate interests. subject to legal or contractual permissions, we process or allow data to be processed in a third country only if the special requirements of article 44 et seq. of the gdpr are met. this means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the eu (e.g., for the usa through the “privacy shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
rights of data subjects:
you have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the legal requirements.
you have the right, in accordance with the legal requirements, to request the completion of data concerning you or the rectification of inaccurate data concerning you.
in accordance with the legal requirements, you have the right to request that data concerning you be deleted without delay or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.
you have the right to request that the data concerning you that you have provided to us be received in accordance with the legal requirements and to request its transmission to other controllers.
you also have the right, in accordance with the legal requirements, to file a complaint with the competent supervisory authority.
right to withdraw:
you have the right to revoke consents granted in accordance with the legal requirements.
right to object:
you have the right to object to the future processing of data concerning you in accordance with the legal requirements at any time. the objection may be made in particular against processing for direct marketing purposes.
cookies and right to object to direct marketing:
“cookies” are small files that are stored on users’ computers. different information can be stored within the cookies. a cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit within an online service. temporary cookies, or “session cookies” or “transient cookies,” are cookies that are deleted after a user leaves an online offer and closes his browser. in such a cookie, for example, the content of a shopping cart in an online shop or a login status can be stored. cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. for example, the login status can be saved when users visit it after several days. the interests of users used for range measurement or marketing purposes can also be stored in such a cookie. third-party cookies are cookies that are offered by providers other than the responsible person operating the online offer (otherwise, if they are only its cookies, they are called “first-party cookies”).
if users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. stored cookies can be deleted in the system settings of the browser. the exclusion of cookies can lead to functional restrictions of this online offer.
deletion of data:
if the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. this means that the data is blocked and not processed for other purposes. this applies, for example, to data that must be retained for commercial or tax law reasons.
when you contact us (e.g., via a contact form, email, telephone, or through social media), the user’s details are processed for the purpose of handling the contact request and its processing, pursuant to article 6(1)(b) (in the context of contractual or pre-contractual relationships) and article 6(1)(f) (other inquiries) of the gdpr. the user’s details can be stored in a customer relationship management system (“crm system”) or a comparable request organization.
we will delete the requests if they are no longer necessary. we review the necessity every two years; furthermore, statutory retention obligations apply.
with the following information, we inform you about the content of our newsletter, as well as the registration, dispatch, and statistical evaluation procedure, and your rights of objection. by subscribing to our newsletter, you agree to receive it and the described procedures.
newsletter content: we send newsletters, emails, and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipients or legal permission. if the content of the newsletter is specifically described during registration, it is decisive for users’ consent. in addition, our newsletters contain information about our services and us.
double-opt-in and logging: registration for our newsletter takes place in a double-opt-in process. this means that after registration, you will receive an email in which you will be asked to confirm your registration. this confirmation is necessary to ensure that no one can register with foreign email addresses. newsletter registrations are logged to prove the registration process in accordance with legal requirements. this includes the storage of the registration and confirmation time, as well as the ip address. changes to your data stored with the shipping service provider are also logged.
registration data: to subscribe to the newsletter, it is sufficient to provide your email address. optionally, we ask you to provide a name for personalization in the newsletter.
the sending of the newsletter and the associated performance measurement are based on the recipients’ consent under article 6(1)(a), article 7 of the gdpr in conjunction with section 7(2)(3) of the german act against unfair competition (uwg) or, if consent is not required, on the basis of our legitimate interests in direct marketing under article 6(1)(f) gdpr in conjunction with section 7(3) uwg.
the registration process is logged based on our legitimate interests under article 6(1)(f) gdpr. our interest is in the use of a user-friendly and secure newsletter system that serves both our business interests and meets user expectations while also allowing us to prove consent.
termination/revocation: you can cancel the receipt of our newsletter at any time, i.e., revoke your consent. a link to unsubscribe from the newsletter can be found at the end of each newsletter. we can store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to prove a previously given consent. the processing of this data is limited to the purpose of possible defense against claims. individual requests for deletion are possible at any time, provided that the former existence of consent is confirmed.
newsletter – mailchimp
the mailing service provider may use the data of recipients in pseudonymous form, i.e., without assigning it to a user, to optimize or improve their own services, e.g., for technical optimization of the mailing and presentation of the newsletter or for statistical purposes. however, the mailing service provider does not use the data of our newsletter recipients to write to them themselves or to pass the data on to third parties.
newsletter – tracking
the newsletters contain a so-called “web beacon,” i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a mailing service provider, from their server. as part of this retrieval, technical information such as information about the browser and your system, as well as your ip address and the time of retrieval, is initially collected.
these details are used to improve the service on the basis of technical data or user behavior. this includes the locations from which the newsletters are retrieved (identifiable via the ip address) or the times of retrieval. the analysis is also used to determine whether the newsletters are opened, when they are opened, and which links are clicked. for technical reasons, this information can be assigned to individual newsletter recipients. however, neither we nor, if used, the mailing service provider, intend to monitor individual users. the evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
a separate revocation of the tracking is not possible; in this case, the entire newsletter subscription must be canceled.
google is certified under the privacy shield agreement and, thereby, offers a guarantee to comply with european data protection law (privacy shield certification).
google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering, and to provide us with further services associated with the use of this online offering and internet usage. pseudonymous user profiles can be created from the processed data.
we only use google analytics with ip anonymization enabled. this means that the ip address of users is shortened by google within member states of the european union or in other contracting states of the agreement on the european economic area. only in exceptional cases is the full ip address transmitted to a google server in the usa and shortened there.
the ip address transmitted by the user’s browser will not be merged with other google data. users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent google from collecting the data generated by the cookie and related to their use of the online offering and the processing of this data by google by downloading and installing the browser plug-in available at the following link: google analytics opt-out browser add-on.
user data is deleted or anonymized after 14 months.
integration of third-party services and content
we use content or service offerings from third-party providers within our online offering based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offering within the meaning of article 6(1)(f) gdpr) in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
this always presupposes that the third-party providers of this content perceive the ip address of the users since they would not be able to send the content to their browser without the ip address. the ip address is, therefore, required for the display of this content. we endeavor to use only content whose respective providers use the ip address solely for the delivery of the content. third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. the “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. the pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring web pages, visit time, and other information about the use of our online offering, as well as be linked to such information from other sources.