- Name and contact data of the Controller and the Data Protection Officer.
- Purposes and legal bases of data processing.
- Recipients and data processing in third countries.
- Data shared in social networks.
- Storage period.
- Your rights as a data subject.
As part of our appearance at trade shows, VITA Zahnfabrik will take photographs and make video recordings for visual documentation and communication. It cannot be ruled out that you may be either directly or indirectly identified via the photographs/video recordings, in which case this material constitutes personal data within the meaning of the EU General Data Protection Regulation (GDPR).
We would like to inform you about the processing of your personal data in connection with the photographs/video recordings produced during our appearance at trade shows and your rights as a data subject in the following paragraphs.
VITA Zahnfabrik H. Rauter GmbH & Co. KG, (hereinafter “we” or “VITA Zahnfabrik”), Spitalgasse 3, 79713 Bad Saeckingen, Germany, phone +49 (0)7761-56 20, fax +49 (0)7761-56 22 99, email info (at) vita-zahnfabrik.com, URL www.vita-zahnfabrik.com, legal notice available at https://www.vita-zahnfabrik.com/de/Impressum-1014,854.html. Our Data Protection Officer may be contacted by sending an email to datenschutz (at) vita-zahnfabrik.com or to our postal address with the addition “Der Datenschutzbeauftragte” in the first line of the address field.
2.1 Photographs and video recordings in connection with VITA’s appearance at trade shows
The visual documentation and covering of our appearance at trade shows, as part of our public relations activities, may also include the processing and publishing of your personal data, in particular, photographs/video recordings depicting you as an individual or member of a group.
Generally, we will only take portrait/close-ups of you if you have expressed your consent to us or the commissioned photographer, which may also occur by conclusive behavior on your part (e.g. smiling at the camera). Generally, any of these photographs and/or video recordings will be based on your consent (Art. 6 (1) (a) GDPR), provided, however, that in individual cases such photographs may also be based on our legitimate interests in the documentation of our events and the covering of these events as part of our public relations activities (Art. 6 (1) (f) GDPR). If you have granted your consent to the processing of your personal data you may withdraw this consent at any time with effect for the future without giving any reasons and/or object to the corresponding type of processing (see Section 6 below).
In addition, we will also produce photographs or record videos as panoramic shots or of groups of people that are not intended to show individuals in the form of portrait or close-up shots; these photographs or videos will be produced based on our overriding legitimate interests in the documentation of our event and in the covering of this event as part of our public relations activities (Art. 6 (1) (f) GDPR). Should you have any objections to such photographs or video recordings of panoramic shots or groups of people, you may object to them (cf. Section 6 below). We will then examine on a case-by-case basis, whether your legitimate interests as a data subject are overriding. Generally, we will comply with your objection – unless overriding business interests of VITA Zahnfabrik exist – and remove the relevant photographs and/or video recordings on which you are depicted with effect for the future.
The production of photographs/video recordings does not generally conflict with possible indications on your ethnicity, religion, or health (e.g. complexion, headdress, glasses). However, we will never process the photographs and/or video recordings to obtain information of this type. In particular, we will not have them automatically searched for such information. Furthermore, VITA Zahnfabrik would like to draw your attention to the fact that upon publishing the photographs/video recordings these may be retrieved worldwide from the internet and social networks and can be found using search engines. Therefore, the subsequent use of photographs/video recordings by third parties which is beyond the control of VITA Zahnfabrik may not be ruled out.
2.2 VITA Magic Mirror
As part of the VITA Magic Mirror activities, we will process your personal data if this is required for preparing and performing the underlying contract entered with you. The purposes shall include, in particular,
- preparing and carrying out the VITA Magic Mirror activities;
- taking individualized photographs and offering the option of emailing them and/or their transfer to the social wall of VITA Zahnfabrik using #myperfectmatch as well as to the social networks such as Facebook, Instagram and Twitter by you as the depicted individual.
Your data will be processed in accordance with Art. 6 (1) (b) GDPR. To this end, we will need the personal data from you that is required for using the VITA Magic Mirror; i.e. the photo that you took yourself and on which you may be recognized, as the case may be, and the email address that you provided, if applicable.
In the absence of this information, we will not be able to perform the underlying VITA Magic Mirror contract entered with you. We will delete any personal data that you enter into our system within twenty-four (24) hours from the end of the photographic event. The final paragraph of Section 2.1 will apply accordingly.
2.3 VITA shade determination using “Easyshade”
In the course of the VITA shade determination, we will process your personal data if you have granted your consent to us and if this is required for preparing and performing the underlying contract entered with you. The purposes shall include, in particular,
- preparing and carrying out the VITA shade determination;
- taking individual photographs of your teeth/your mouth together with the option to print and/or email them by you as the depicted individual.
Your data will be processed in accordance with Art. 6 (1) (b) GDPR and, in a supplementary manner, in accordance with Art. 6 (1) (a) GDPR. We will need the personal data from you that is required for performing the VITA shade determination; i.e. the photo that you took yourself of your teeth/your mouth and on which you may be recognized in exceptional circumstances and, as the case may be, the email address that you provided to us for forwarding the pictures, if applicable. In the absence of this information, we will not be able to perform the underlying VITA shade determination contract entered with you. We will delete any pictures taken and your email address that you may have provided to us for mailing your pictures from our systems within 24 (twenty-four) hours from the completion of the shade determination. The final paragraph of Section 2.1 will apply accordingly.
We will only disclose your personal data to external third parties, if this is required for safeguarding our legitimate interests, if this is permissible in accordance with other statutory provisions, or if you have granted your consent. External recipients may include, but are not limited to service providers (e.g. hosting providers or photography/video studios). Processors (e.g., photographers and operators of the VITA Fotobox) will be carefully selected by us and audited at regular intervals; they may use the data exclusively for the purposes determined by us and in accordance with our instructions based on a data processing agreement pursuant to Art. 28 GDPR.
In the event data is transmitted to a recipient whose registered office, place of residence, or place of data processing is not within a member state of the European Union (EU) or another country that is a party to the Agreement on the European Economic Area (EEA), we will ensure prior to passing on your data that, except for the statutorily permitted exceptions, the recipient complies with an adequate level of data protection or that you have provided your consent to this data transmission. Please contact us at datenschutz (at) vita-zahnfabrik.com, if you wish to receive a copy of the specific guarantees regarding the transmission of your data to third countries.
When photographs or video recordings are shared via the VITA Zahnfabrik social media channels these photographs and/or video recordings may be transmitted to a country outside the EU/EEA, in particular, to the U.S. The social networks or their parent entities, respectively, that we use and that are listed below, are certified under the EU-U.S. Privacy Shield and bound to the provisions of the GDPR.
The use of your data by these social networks is beyond our control. We can neither foresee nor have any influence on to what extent, where and how long data will be stored, to what extent social networks will comply with their duty to erase or delete data, for which analytical purposes data will be used and/or how it will be linked, and to whom data will be passed on. Please refer to the information provided below on the operators of the social networks used by us and on their respective privacy policies:
- YouTube is operated by Google Ireland Limited, Gordon House, Barrow Street
In this context, we would also like to draw your attention to our supplementary privacy policies for our corresponding channels and/or fan pages in the above-mentioned social networks.
We will store your personal data only as long as required for meeting the processing purposes. We will also erase your personal data if we are obligated to do so subject statutory requirements. For further details on the erasure (deletion) of your personal data please refer to the paragraphs in Section 2 above.
In the event of a withdrawal, we will no longer process your personal data, unless its continued processing is permitted in accordance with the applicable statutory provisions, or even compellingly required (e.g. due to retention periods under commercial or tax law). Generally, we will comply with your objection – unless overriding business interests exist – and remove the relevant photographs and/or video recordings on which you are depicted with effect for the future.
As a person affected by the processing of personal data (“data subject”), you are entitled to numerous rights, including
- Right of access (Art. 15 GDPR, Section 34 German Federal Data Protection Act – “BDSG”),
- Right to rectification (Art. 16 GDPR),
- Right to erasure (Art. 17 GDPR, Section 35 of the BDSG),
- Right to restriction of processing (Art. 18 GDPR),
- Right to data portability (Art. 20 GDPR).
- Right to object to data processing based on legitimate interests (Art. 21 GDPR): If reasons exist that are based on grounds relating to your particular situation, you may object to data processing by us at any time, to the extent that this is based on legitimate interests within the meaning of Art. 6 (1) (f) GDPR exist. Should you exercise your right to object, we will discontinue the processing of your data, unless we are able to show that there are compelling reasons that permit the continued data processing and override your rights, or if data processing serves the purpose of enforcing, exercising, or defending legal claims.
- Furthermore, you have the right to withdraw any consent granted at any time with effect for the future (Art. 7 (3) GDPR).
Finally, you have the right to lodge a complaint with a supervisory authority(Art. 77 DSGVO). The following supervisory authority has competence over us: The State Officer for Data Protection and Freedom of Information Baden-Wuerttemberg (Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Baden-Württemberg – LfDI), contact data: Koenigstrasse 10a, 70173 Stuttgart, Germany, phone +49 (0)711 615541-0, fax +49 (0)711 615541-15, email poststelle (at) lfdi.bwl.de, URL https://www.baden-wuerttemberg.datenschutz.de.
Should you wish to exercise any or all of your above-mentioned rights please contact us at datenschutz (at) vita-zahnfabrik.com or send a letter to our Data Protection Officer at the address mentioned in Section 1 above.
Last revised: March 2019 (subject to change)