The Pickwicks ‘Club’

Pickwicks Frankfurt and its branches at Oberursel and Langen are integral parts of the Pickwicks ‘organization’

  1. constituted by its members
  2. headed by the Committee
  3. funded by fees provided by its members
  4. publicly represented at this website
  5. being non-profit
  6. providing services to the membership and interested members of the public
  7. joining forces and pursuing common goals as an English-speaking social club.

While this may create the impression of an officially established Club, Pickwicks is not: It is a loose association of people interested in the English language and a certain amount of shared activities; it is not registered anywhere, has no statutes, and the money collected from our registered members is not accumulated, but spent on subsidies for activities.

Data handling

In connection with this, and also with regard to the European Union’s new General Data Protection Regulation (Datenschutz-Grundverordnung), that comes into effect on 25th May 2018, please note the way we handle your data:

No personal data is collected on this website.

If you choose to contact us by sending an email to the Club or any Committee member, we will store and archive

  • your name
  • your email address
  • the content of your message, which may contain more personal data.

We will keep this information confidential and delete it upon request.

You can also sign up to our Groups.io email list. The data entered there (compulsory only: email address) are under the control of Groups.io. You can unsubscribe from that email list at any time.

If you decide to become a paid-up member, we will store and archive

  • your name
  • your email address
  • your birthday month
  • any optional information you like to provide (telephone number, street address, …)

This information will be stored by our membership officer only.

Should you decide to terminate your membership with the Pickwicks Club, we will delete this information.

Or, in more legal words:

Privacy Policy

Data protection is of a particularly high priority for the Pickwicks English Club. The use of the Internet pages of the Pickwicks English Club is possible  without any indication of personal data; however, if a data subject wants to use  special services via our website, processing of personal data could become  necessary. If the processing of personal data is necessary and there is no  statutory basis for such processing, we generally obtain consent from the data  subject.

The processing of personal data, such as the name, address, e-mail address,  or telephone number of a data subject shall always be in line with the General  Data Protection Regulation (GDPR), and in accordance with the country-specific  data protection regulations applicable to the Pickwicks English Club. By means  of this data protection declaration, our Club would like to inform the general  public of the nature, scope, and purpose of the personal data we collect, use  and process. Furthermore, data subjects are informed, by means of this data  protection declaration, of the rights to which they are entitled.

As the controller, the Pickwicks English Club has implemented numerous  technical and organizational measures to ensure the most complete protection of  personal data processed through this website. However, Internet-based data  transmissions may in principle have security gaps, so absolute protection may  not be guaranteed. For this reason, every data subject is free to transfer  personal data to us via alternative means, e.g. by telephone.

1. Definitions

The data protection declaration of the Pickwicks English Club is based on the  terms used by the European legislator for the adoption of the General Data  Protection Regulation (GDPR). Our data protection declaration should be legible  and understandable for the general public. To ensure this, we would like to  first explain the terminology used.

In this data protection declaration, we use, inter alia, the following  terms:

a) Personal data

Personal data means any information relating to an identified or identifiable  natural person (“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 or to one or more factors specific to the physical, physiological,  genetic, mental, economic, cultural or social identity of that natural  person.

b) Data subject

Data subject is any identified or identifiable natural person, whose personal  data is processed by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on  personal data or on sets of personal data, whether or not by automated means,  such as collection, recording, organisation, structuring, storage, adaptation or  alteration, retrieval, consultation, use, disclosure by transmission,  dissemination or otherwise making available, alignment or combination,  restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim  of limiting their processing in the future.

e) Profiling

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 analyse or predict aspects concerning that  natural person’s performance at work, economic situation, health, personal  preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner 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  separately and is subject to technical and organisational measures to ensure  that the personal data are not attributed to an identified or identifiable  natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is 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; where the purposes and means of such processing are determined by Union or  Member State law, the controller or the specific criteria for its nomination may  be provided for by Union or Member State law.

h) Processor

Processor is a natural or legal person, public authority, agency or other  body which processes personal data on behalf of the controller.

i) Recipient

Recipient is a natural or legal person, public authority, agency or another  body, to which the personal data are disclosed, whether a third party or not.  However, public authorities which may receive personal data in the framework of  a particular inquiry in accordance with Union or Member State law shall not be  regarded as recipients; the processing of those data by those public authorities  shall be in compliance with the applicable data protection rules according to  the purposes of the processing.

j) Third party

Third party is a natural or legal person, public authority, agency or body  other than the data subject, controller, processor and persons who, under the  direct authority of the controller or processor, are authorised to process  personal data.

Consent of the data subject is any freely given, specific, informed and  unambiguous indication of the data subject’s wishes by which he or she, by a  statement or by a clear affirmative action, signifies agreement to the  processing of personal data relating to him or her.

k) Consent

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR),  other data protection laws applicable in Member states of the European Union and  other provisions related to data protection is:

Pickwicks English Club
c/o Thomas Mechau
Mühlgasse 29
60486 Frankfurt am Main
Germany

Phone: +49-69 70791038
Email: info@pickwicks.de
Website: www.Pickwicks.de

3. Collection of general data and information

The website of the Pickwicks English Club collects a series of general data  and information when a data subject or automated system calls up the website.  This general data and information are stored in the server log files. Collected  may be (1) the browser types and versions used, (2) the operating system used by  the accessing system, (3) the website from which an accessing system reaches our  website (so-called referrers), (4) the sub-websites, (5) the date and time of  access to the Internet site, (6) an Internet protocol address (IP address), (7)  the Internet service provider of the accessing system, and (8) any other similar  data and information that may be used in the event of attacks on our information  technology systems.

When using these general data and information, the Pickwicks English Club  does not draw any conclusions about the data subject. Rather, this information  is needed to (1) deliver the content of our website correctly, (2) optimize the  content of our website as well as its advertisement, (3) ensure the long-term  viability of our information technology systems and website technology, and (4)  provide law enforcement authorities with the information necessary for criminal  prosecution in case of a cyber-attack. Therefore, the Pickwicks English Club  analyzes anonymously collected data and information statistically, with the aim  of increasing the data protection and data security of our Club, and to ensure  an optimal level of protection for the personal data we process. The anonymous  data of the server log files are stored separately from all personal data  provided by a data subject.

4. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data  subject only for the period necessary to achieve the purpose of storage, or as  far as this is granted by the European legislator or other legislators in laws  or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed  by the European legislator or another competent legislator expires, the personal  data are routinely blocked or erased in accordance with legal requirements.

5. Rights of the data subject

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to  obtain from the controller the confirmation as to whether or not personal data  concerning him or her are being processed. If a data subject wishes to avail  himself of this right of confirmation, he or she may, at any time, contact the  controller.

b) Right of access

Each data subject shall have the right granted by the European legislator to  obtain from the controller free information about his or her personal data  stored at any time and a copy of this information. Furthermore, the European  directives and regulations grant the data subject access to the following  information:

      • the purposes of the processing;
      • the categories of personal data concerned;
      • the recipients or categories of recipients to whom the personal data have  been or will be disclosed, in particular recipients in third countries or  international organisations;
      • where possible, the envisaged period for which the personal data will be  stored, or, if not possible, the criteria used to determine that period;
      • the existence of the right to request from the controller rectification or  erasure of personal data, or restriction of processing of personal data  concerning the data subject, or to object to such processing;
      • the existence of the right to lodge a complaint with a supervisory  authority;
      • where the personal data are not collected from the data subject, any  available information as to their source;
      • the existence of automated decision-making, including profiling, referred to  in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful  information about the logic involved, as well as the significance and envisaged  consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to  whether personal data are transferred to a third country or to an international  organisation. Where this is the case, the data subject shall have the right to  be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she  may, at any time, contact the controller.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to  obtain from the controller without undue delay the rectification of inaccurate  personal data concerning him or her. Taking into account the purposes of the  processing, the data subject shall have the right to have incomplete personal  data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she  may, at any time, contact the controller.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to  obtain from the controller the erasure of personal data concerning him or her  without undue delay, and the controller shall have the obligation to erase  personal data without undue delay where one of the following grounds applies, as  long as the processing is not necessary:

      • The personal data are no longer necessary in relation to the purposes for  which they were collected or otherwise processed.
      • The data subject withdraws consent to which the processing is based  according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2)  of the GDPR, and where there is no other legal ground for the processing.
      • The data subject objects to the processing pursuant to Article 21(1) of the  GDPR and there are no overriding legitimate grounds for the processing, or the  data subject objects to the processing pursuant to Article 21(2) of the GDPR.
      • The personal data have been unlawfully processed.
      • The personal data must be erased for compliance with a legal obligation in  Union or Member State law to which the controller is subject.
      • The personal data have been collected in relation to the offer of  information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to  request the erasure of personal data stored by the Pickwicks English Club, he or  she may, at any time, contact the controller. The Pickwicks English Club shall  promptly ensure that the erasure request is complied with immediately.

Where the controller has made personal data public and is obliged pursuant to  Article 17(1) to erase the personal data, the controller, taking account of  available technology and the cost of implementation, shall take reasonable  steps, including technical measures, to inform other controllers processing the  personal data that the data subject has requested erasure by such controllers of  any links to, or copy or replication of, those personal data, as far as  processing is not required. The Pickwicks English Club will arrange the  necessary measures in individual cases.

e) Right of restriction of processing

Each data subject shall have the right granted by the European legislator to  obtain from the controller restriction of processing where one of the following  applies:

      • The accuracy of the personal data is contested by the data subject, for a  period enabling the controller to verify the accuracy of the personal data.
      • The processing is unlawful and the data subject opposes the erasure of the  personal data and requests instead the restriction of their use instead.
      • The controller no longer needs the personal data for the purposes of the  processing, but they are required by the data subject for the establishment,  exercise or defence of legal claims.
      • The data subject has objected to processing pursuant to Article 21(1) of the  GDPR pending the verification whether the legitimate grounds of the controller  override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to  request the restriction of the processing of personal data stored by the  Pickwicks English Club, he or she may at any time contact the controller. The  Pickwicks English Club will arrange the restriction of the processing.

f) Right to data portability

Each data subject shall have the right granted by the European legislator, to  receive the personal data concerning him or her, which was provided to a  controller, in a structured, commonly used and machine-readable format. He or  she shall have the right to transmit those data to another controller without  hindrance from the controller to which the personal data have been provided, as  long as the processing is based on consent pursuant to point (a) of Article 6(1)  of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant  to point (b) of Article 6(1) of the GDPR, and the processing is carried out by  automated means, as long as the processing is not necessary for the performance  of a task carried out in the public interest or in the exercise of official  authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to  Article 20(1) of the GDPR, the data subject shall have the right to have  personal data transmitted directly from one controller to another, where  technically feasible and when doing so does not adversely affect the rights and  freedoms of others.

In order to assert the right to data portability, the data subject may at any  time contact the Pickwicks English Club.

g) Right to object

Each data subject shall have the right granted by the European legislator to  object, on grounds relating to his or her particular situation, at any time, to  processing of personal data concerning him or her, which is based on point (e)  or (f) of Article 6(1) of the GDPR. This also applies to profiling based on  these provisions.

The Pickwicks English Club shall no longer process the personal data in the  event of the objection, unless we can demonstrate compelling legitimate grounds  for the processing which override the interests, rights and freedoms of the data  subject, or for the establishment, exercise or defence of legal claims.

In addition, the data subject has the right, on grounds relating to his or  her particular situation, to object to processing of personal data concerning  him or her by the Pickwicks English Club for scientific or historical research  purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR,  unless the processing is necessary for the performance of a task carried out for  reasons of public interest.

In order to exercise the right to object, the data subject may contact the  Pickwicks English Club. In addition, the data subject is free in the context of  the use of information society services, and notwithstanding Directive  2002/58/EC, to use his or her right to object by automated means using technical  specifications.

h) Right to withdraw data protection consent

  • Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
  •  
  • If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact the Pickwicks English Club.

6. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the  respective statutory retention period. After expiration of that period, the  corresponding data is routinely deleted, as long as it is no longer necessary  for the fulfillment of the contract or the initiation of a contract.

This Privacy Policy is an adapted version of a policy for commercial enterprises which was output by the Privacy Policy Generator of the External  Data Protection Officers that was developed in cooperation with the Media Law  Lawyers from WBS-LAW.

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