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Data Protection

Data protection statement for the ITS website in accordance with the provisions of the GDPR

The International Tracing Service (hereinafter “ITS”) is pleased that you are visiting our website. The security and confidentiality of your data  during your use of our website are very important for us. That being the case, we would like to inform you here concerning which personal data we collect from you when you visit our website, and what purpose they are used for.

Since changes in the law or changes in the internal processes of our entity may make an adjustment of this data protection statement necessary, we ask you to read the data protection statement through regularly. The data protection statement can be accessed, saved and printed out at any time under data protection statement.

§ 1   Controller and scope

The controller, per the meaning of the EU General Data Protection Regulation (hereinafter GDPR) and other national data protection laws of the member states as well as other legal data protection provisions, is:

International Tracing Service
Große Allee 5 – 9
34454 Bad Arolsen
Germany

Tel.: +49 (0)5691 629-0
E-Mail: email@its-arolsen.org
Website: www.its-arolsen.org

This data protection statement applies for the Internet offer of the ITS accessible under the domain www.its-arolsen.org and the subdomains dpcampinventory.its-arolsen.org, digitalcollections.its-arolsen.org and findmittel.its-arolsen.org.

§ 2   Data protection officer

The controller’s external data protection officer is:

Karsten Kinast, LL.M. (lawyer)
KINAST Rechtsanwaltsgesellschaft mbH
Hohenzollernring 54
D-50672 Köln (Cologne)

Tel.: +49 (0)221 – 222 183 – 0
E-Mail: mail@kinast-partner.de
Website: www.kinast-partner.de/externer-datenschutzbeauftragter/

§ 3   Bases of data processing

Personal data are any information relating to an identified or identifiable natural person. By way of an example this includes information such as your name, age, address, telephone number, date of birth, e-mail address, your IP address or user behaviour information. Information with which we cannot establish a relationship with your person (or can only do so with unreasonable effort), e.g. through anonymization of the information, does not constitute personal data. The processing of personal data (e.g. collection, requesting, use, storage or transfer always requires a legal basis or your consent. Processed personal data are erased as soon as the purpose of the processing has been attained, and if there are no longer any applicable legal obligations to retain them.

If we process your personal data in order to make certain offers available, we will subsequently inform you of the specific processes, the scope and the purpose of the data processing, the legal basis for the processing and the relevant retention periods.

§ 4 Individual processing procedures

1.   Provision and use of the website

a.   Nature and scope of the data processing

When you access and use our website we collect the personal data that your browser automatically transfers to our server. This information is temporarily stored in a so-called log file. When you use our website, we collect the following data, which are technically necessary for us to display our website to you and guarantee stability and security:

    • IP address of the accessing computer
    • Date and time of access
    • Browser used
    • System used by visitor to site

    In addition, a pseudonymised user statistic may be produced using the data in the log files. This pseudonymised statistic enables us to improve the experience of users on our website.

    b.   Legal basis

    For the aforementioned data processing, the legal basis is article 6 paragraph 1 lit. f GDPR. The processing of the aforementioned data is necessary for the provision and further development of a website and as such serves the legitimate interest of the ITS.

    c.   Retention period

    As soon as the aforementioned data are no longer necessary for displaying the website, they are erased. The collection of data for provision of the website and the storage of data in log files is absolutely essential for the operation of the Internet site. Consequently, the user cannot legitimately object. Data storage may continue in individual cases when it is legally required.

    2.   Newsletter

    a.   Nature and scope of the data processing

    On our website you have the option of subscribing to a free newsletter. In order to send the newsletter to you regularly, we require the following information from you:

      • E-mail address 
      • Title
      • Surname and first name

      When you click on the send button, your data are transferred to our web server from the browser. To distribute the newsletter, your data are transferred to “Cleverreach” and “MailChimp”, our partners in the context of the dispatch of the newsletter. In the course of the cooperation with the partner “MailChimp”, the latter also produces personalised appraisal of newsletter usage. This includes collection and processing of the respective opening rates and further clicking behaviour within the newsletter itself. 

      To send out the newsletter, we use the co-called Double Opt-In procedure, i.e. we will only send you the newsletter if you have first confirmed your subscription via link contained in a confirmation e-mail sent to an address provided by you for this purpose. In this way, we hope to ensure that only you, as the owner of the e-mail address given, can subscribe to the newsletter. You must send your confirmation promptly after receiving the confirmation e-mail, otherwise your newsletter subscription will be automatically erased from our database. You can withdraw the consent given for storing your  e-mail address and using it to send the newsletter at any time, e.g. via the “unsubscribe” link in the newsletter.

      b.   Legal basis

      In accordance with article 6 paragraph 1 lit. a GDPR, the processing of your e-mail address for sending the newsletter is based on your voluntary consent given, by means of the declaration below:


      Declaration of consent:

      By providing my data and confirming with the “Send” button, I declare my consent to the processing of my e-mail address and my surname and first name, for regular dispatch of the newsletter. I may unsubscribe from the newsletter service at any time, by clicking on the corresponding link in the newsletter.

      I may at any time withdraw my consent for the collection of personal data gathered during the registration process.


      The analyses of usage of the newsletter enable the ITS to measure its reach, to specify the offer and to optimise it and make it more economical. The legal bases for this are found in article 6 paragraph 1 lit f GDPR. 

      c.   Duration of storage

      Your e-mail address and your surname and first name will be stored for as long as you have subscribed to the newsletter. When you unsubscribe from the newsletter, your e-mail address and your surname and first name will be deleted. We may continue to store them in individual cases when legally required.

      3.   Contact form for those persecuted by the Nazis, their relatives and representatives

      a.   Nature and scope of the data processing

      On our website we offer you the option of contacting us using the form provided for search requests. As part of the process of submitting your request using the contact form, reference is made to this data protection declaration in order to obtain your consent. Should you make use of the contact form, the following personal data concerning you will be processed:

      • Title
      • First name and surname
      • Institution
      • Street and house number
      • Postcode and town
      • Country
      • Telephone number
      • E-Mail address

      Your providing the above data allows us to collate and process your enquiry and enables us to answer you. The personal data processed in connection with your search request will be transferred to the ITS archive after processing has concluded, and from this point on are subject to a protection period of 25 years. After this 25-year protection period has lapsed, in the event of a new enquiry on the same facts, the personal data processed in connection with your search request will be passed on to the enquirers.

      Likewise, in the course of data collation with the partner archives (copyholders), your personal data will be shared in the form of a data copy, regardless of the 25-year protection period, in the context of the agreements existing under international law between the ITS and its copyholders.

      b.   Legal basis

      The data processing described above (cf. § 4 3. a.) undertaken for the purpose of making contact in the context of a search request takes place, in accordance with article 6 paragraph 1 lit. a GDPR, on the basis of your consent, which is freely given, by means of the declaration below:

      Declaration of consent:

      By providing my data and confirming with the “Send” button, I declare my consent to the processing of my title, my first name and surname, my institution, my address, my telephone number and my e-mail address for the reply to my search request. Moreover I agree to the processing of the information on the person I am searching for and its being associated with me. This information will in any case include the following mandatory details from the online form:

      • Enquiry reference
      • Surname and first name
      • Name at birth
      • Gender
      • Aliases, if applicable
      • Date of birth (year)
      • Place of birth
      • Civil status during persecution
      • Surname and first name of father
      • Maiden name and first name of mother

      If my enquiry concerns a living relative of mine, I affirm that I am authorised to submit the information on them within the search request.

      I declare my consent to addition of my personal data connected to the enquiry into the ITS archive and to their being transferred to the enquirers in the event of an enquiry on the same facts after a protection period of 25 years .

      I am aware that the personal data processed in connection with my search request will be transferred to the following copyholders regardless of the 25-year protection period and processed further by them in accordance with the applicable data protection and international legal provisions:

        • Archives de l‘État en Belgique, Brüssel (Belgium)
        • Archives Nationales, Pierrefitte-sur Seine (France)
        • Centre de Documentation et de Recherche sur la Résistance (Luxemburg)
        • Instytut Pamięci Narodowej (IPN), Warsaw (Poland)
        • The Wiener Library, London (United Kingdom)
        • Yad Vashem, Jerusalem (Israel)
        • US Holocaust Memorial Museum (USHMM), Washington (USA)

        I may at any time withdraw my consent for the collection of personal data gathered during the use of the contact form.

        c.   Duration of storage

        In the event of a search request, the personal data you provide will be kept by the ITS for an undetermined period, in accordance with article 5 paragraph 1 e GDPR, on the basis of archiving purposes in the public interest. In addition to fulfilling the archival function of the ITS, the purpose of this is so that after the end of a period of 25 years from your enquiry, your data may be transferred to enquirers requesting information on the same facts and enable people to be reunited as a result of the facts enquired about.

        4.   Contact form for research applications

        a.   Nature and scope of the data processing

        On our website we offer you the option of contacting us using the form provided for search requests. As part of the submission process of your request by means of the contact form, reference is made to this data protection declaration in order to obtain your consent. Should you make use of the contact form, the following personal data concerning you will be processed: 

        • Title
        • First name and surname
        • Institution
        • Professional background
        • Street and house number
        • Postcode and town
        • Country
        • E-Mail adress
        • Subject and project proposal
        • Purpose of application
        • Planned research professions
        • Information on planned publications
        • Willingness to network with other applicants

        The provision of the data above serves to collate and process your enquiry and enables us to answer you. When you use the contact form, no personal data are transferred to third parties unless you expressly agree that you are willing to network.

        In this case your surname, first name and e-mail address will be transferred to other users who specifically ask about contacts with researchers with similar key subjects. The personal data processed in connection with your search request will be transferred to the ITS archive after processing has concluded.

        b.   Legal basis

        The data processing described above (cf. § 4 3. a.) undertaken for the purpose of making contact in the context of a research application takes place, in accordance with article 6 paragraph 1 lit. a GDPR, on the basis of your consent, which is freely given, by means of the declaration below:

        Declaration of consent:

        By providing my data and confirming with the “Send” button, I declare my consent to the use of my title, my first name and surname, my institution, my professional background, my address, my telephone number and my e-mail address for the reply to my contact request regarding a research application. Moreover I declare that I agree to the processing of the subject and project proposal of my research application, the purpose of the application, information on planned research visits, my information on planned publications and my willingness to network with other applicants.

        I declare my consent to addition of my personal data into the ITS archive and to their being held there. In the event of my having declared a willingness to network, I declare that I agree to the transfer of my surname, first name and e-mail address upon request to researchers with similar key subjects.

        I may at any time withdraw my consent for the collection of personal data gathered during the use of the contact form.


        c.   Duration of storage

        In the event of a search request, the personal data you provide will be kept by the ITS for an undetermined period, in accordance with article 5 paragraph 1 GDPR, on the basis of archiving purposes in the public interest. This fulfils the archival function of the ITS dictated by international law.

        5.   Donations

        We offer you the opportunity to make a donation to the ITS via our website. To enable this, we collaborate with our partner HelpDirect e.V.. If you click on the “Donations” field, an online form opens which is operated by HelpDirect e.V. as controller. With regard to the personal data processed for making the donation, we ask you to take note of the data protection declaration link there.

        § 5   Transfer of data

        We only transfer your personal data to third parties if:

        • You have given your express consent to this in accordance with article 6 paragraph 1 (1) lit. a GDPR 
        • This is permitted by law and is necessary for the performance of a contract to which the data subject is party, in accordance with article 6 paragraph 1 (1) lit. b GDPR
        • There is a legal obligation for the transfer, in accordance with article 6 paragraph 1 (1) lit. c GDPR
        • The transfer is necessary is necessary, in accordance with article 6 paragraph 1 (1) lit. f GDPR, to protect lawful corporate interests and for the establishment, exercise or protection of legal claims, and there is no reason to assume that you have an overriding interest in your data not being transferred.

        § 6   Use of cookies

        a.   Nature and scope of the data processing

        We use cookies on our website. Cookies are small files which are sent to the browser of your terminal and stored there when you visit our Internet pages. Some functions of our website cannot be offered without use of functional cookies. Other cookies enable us to carry out various analyses. For example, cookies are able to recognise the browser you use when you visit our website again, and transmit different information to us. With the aid of cookies, amongst other things we can make our Internet offer more user-friendly and effective, by tracking your use of our website and ascertaining your preferred settings (e.g. country and language settings). If third parties process information using cookies, they collect this information directly via your browser. Cookies do not cause any harm to your terminal. They cannot run any programs and do not contain viruses.

        Different types of cookies are used on our website, the type and function of which is explained in more detail below:

        Transient cookies

        On our website transient cookies are used which are automatically deleted as soon as you close your browser. This type of cookies makes it possible to record your session ID. This enables several different requests from your browser to be allocated to a single session.

        Persistent cookies

        We use persistent cookies on our website . Persistent cookies are cookies that are stored on your browser for a longer period and which transmit information to us. The duration of storage is determined depending on the cookie. You can delete persistent cookies yourself using your browser settings.

        Performance-related cookies

        Using these cookies we are able to make an analysis of the website usage and improve the service and functionality of our website. They collect information on how our website is used by visitors, which pages are visited the most, or whether error messages are displayed on certain pages.

        b.   Legal basis 

        In accord with the purposes of processing as laid out above (cf. § 6. a.), the legal basis for the processing of personal data using cookies is set forth in article 6 paragraph 1 lit. f GDPR. If you have given us your consent to the use of cookies as a result of notices we provide on the website (“cookie banners”), the lawfulness of their usage is also based on article 6 paragraph 1 (1) lit. a GDPR.

        c.   Duration of storage

        As soon as the data transferred to us via the cookies are no longer necessary to attain the purposes described above, this information will be erased. Continuation of storage may then occur in individual cases when legally required.

        d.   Configuration of browser settings

        Most browsers are configured to accept cookies by default. Nevertheless, you can configure your browser to only accept certain cookies, or to not accept any cookies. However, we point out to you that you may not be able to use all the functions of our website if cookies are disabled on our website through your browser settings. You can also delete cookies that have already been saved to your browser through your browser settings, or view the duration of storage. Furthermore, it is possible to configure your browser to notify you before cookies are saved. Since different browsers may have different functionalities, we ask that you use the help menu of your browser for configuration possibilities. 

        If you would like to obtain a comprehensive overview of all instances of access to your Internet browser by third parties, we recommend you install the plug-ins specially developed for this purpose.

        § 7 Tracking and analysis tools

        We use tracking and analysis tools in order to ensure continuous optimisation and needs-based design of our website. With the aid of tracking measures we are also able to statistically record visitors’ use of our website and further develop our online offer for you with the help of the information we obtain from this. Use of the tracking and analysis tools described below is justified on the basis of these interests, in accordance with article 6 paragraph 1 (1) lit. f GDPR. If you have given us your consent to the use of cookies as a result of notices we provide on the website (“cookie banners”), the lawfulness of their use is also based on article 6 paragraph 1 (1) lit. a GDPR. The following description of tracking and analysis tools also provides information on the purposes of the processing concerned and the data that are processed.

        1.   Google Analytics

        This website uses Google Analytics, a web analytics service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (“Google”). Google Analytics uses so-called “cookies”, text files that are stored on your computer which enable an analysis of your use of the website. 

        The information generated by these cookies, for example on the time, place and frequency of your use of this website, are generally speaking transmitted to a Google server in the USA and stored there. When using Google Analytics, there is a possibility that the cookies set by Google Analytics may collect other personal data as well as the IP address. We point out to you that Google may transfer this information to third parties if required to do so by law, or if third parties process these data on behalf of Google.

        Google will use the information generated by the cookies on behalf of the website operator to evaluate your use of the website, to compile reports on website activities and to provide other services associated to website usage and Internet usage for the website operator. We point out that on this website Google Analytics is configured in such a way that it is possible to generate extended reports on website usage. If your browser and cookie settings allow the recording of demographic characteristics and user interests, Google Analytics delivers the relevant reports to us. According to its own statements, Google does not merge the IP address transmitted by your browser in the context of Google Analytics with other data held by Google.

        You can generally prevent cookies from being saved by adjusting the settings of your browser software accordingly. However, we point out that if you do so, you may not be able to fully use all the functions of this website. 

        There is a possibility that the cookies set by Google Analytics may collect other personal data as well as the IP address. To prevent information on your use of the website by Google Analytics from being gathered by and transmitted to Google Analytics, you can download and install a plug-in for your browser at the following link:
        tools.google.com/dlpage/gaoptout

        This plug-in prevents information on your visit to the website from being transmitted to Google Analytics. This plug-in does not prevent any other analysis.

        Please note that you cannot use the browser plug-in described above when visiting our website via the browser of a mobile terminal (smartphone or tablet). When using a mobile device, you can prevent Google Analytics from collecting your usage data by clicking on the following link: 

        When you click on this link, an opt-out cookie is placed in your browser. This prevents information about your visit to the website from being transmitted to Google Analytics. Please note that the opt-out cookie is only valid for this browser and this domain. If you delete the cookies in this browser, the opt-out cookie will also be deleted. You must click the link again to prevent further collection by Google Analytics. The use of the opt-out cookie is also available as an alternative to the above plug-in when using the browser on your computer.

        To ensure the best possible protection of your personal data, Google Analytics has been extended on this website by the code “anonymizeIp”. This code has the effect of deleting the last 8 bits of the IP address, thus allowing your IP address to be anonymously recorded (so-called IP masking). Google essentially shortens your IP address, making it anonymous, even before transmission within member states of the European Union or in any other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

        2.   Matomo

        This website uses Matomo, open source software for the statistical evaluation of visitor access. To this end, Matomo uses cookies (cf. § 6). The information generated by these cookies about your use of our website is transmitted to our server and combined there into a pseudonymised user profile. This enables us to evaluate the use of our website and to design the website on the basis of users’ requirements. This information is not passed on to third parties. The IP address is not connected to any other personal data concerning you. An allocation of your IP address is prevented by anonymization using IP masking. On our website Matomo is configured in such a way that a “Do Not Track” setting in your browser is observed.

        You can generally prevent cookies from being saved by adjusting the settings of your browser software accordingly. However, we point out that if you do so, you may not be able to fully use all the functions of this website.

        If you do not agree with the storage and evaluation of the data, you can opt out of it via the following link. This will set a so-called opt-out cookie in your browser, with the result that Matomo will not collect any session data.

        § 8 Plugins

        To raise public awareness of our institution, on our website we use social plug-ins of the social media Facebook, Google+ and Twitter, on the basis of article 6 paragraph 1 (1) lit. f GDPR. The use of social plug-ins for advertising purposes is a legitimate interest in accordance with the GDPR. Data protection compliant operation of social plug-ins is the responsibility of the respective provider. In order to offer you the best possible protection, we have integrated the social plug-ins used into our website by means of the two-click method.

        1.   Facebook, Google+ and Twitter

        Our website contains social plug-ins of the social media “Facebook”( Facebook Inc., 1601 S. California Ave, Palo Alto, California 94304, USA), “Google+” (Google Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, USA) and “Twitter” (Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA). These services are provided by the respective companies (“providers”). As part of our online presence, the social plug-ins are identified by the respective buttons belonging to the service. On the basis of the data transmitted to the respective service via the social plug-ins, the service can associate you with the account you have with it. To increase the protection of your data on our website, the social plug-ins are integrated into our website by means of the so-called “2-click solution”. This ensures that no automatic connection to the servers is established by the respective providers when a page of our website containing such a social plug-in is called up.

        The activation of the function of the respective social plug-in takes place in two steps. To activate a social plug-in, you must first click on the link on our website. This first activates the social plug-in and your browser establishes a connection with the servers of the provider in question. With a second click you can now interact with the social plug-in and submit your recommendation, for example. If you are already logged in to one of the social networks of the providers, the providers can immediately associate the visit to this website with your profile. If you interact with social plug-ins by clicking on them, the corresponding information is also transmitted directly to a server of the providers and stored there. The information may also be published on the social network and displayed there under your contacts. If you wish to prevent such immediate assignment of your data collected via our website to your profile, you must log out of your account of the respective provider before visiting our website.

        The scope and purpose of the data collection by the respective service as well as the further processing and use of your data there can be obtained directly in the data protection declarations of the website of the service in question. There you will also find further information on the data protection rights that correspond to you, and settings options for the protection of your privacy.

        a) Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA

        www.facebook.com/policy.php
        www.facebook.com/help/186325668085084

        b) Google Inc., 1600 Amphitheater Parkway, Mountain View, California 94043, USA

        www.google.com/policies/privacy/partners/

        c) Twitter Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA

        twitter.com/privacy

        § 9   Hyperlinks

        Our website contains so-called hyperlinks to websites of other providers. When you activate these hyperlinks, you will be rerouted directly to the other providers’ website. You can recognise this by the change in URL, among other things. We accept no responsibility for the confidential handling of your data on these third party websites, as we have no influence on whether these companies observe data protection regulations. Please find out about the way in which these companies handle your personal data directly on the websites in question.

        § 10   Data subject rights

        In accordance with the GDPR, as a data subject whose personal data are processed, you have the following rights:

          • In accordance with article 15 GDPR you can request information about your personal data processed by us. In particular, you may obtain information about the purposes of processing, the categories of the personal data, the categories of recipients to whom your data have been or will be disclosed, the planned duration of storage, the existence of a right to correction, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origin of your data if not collected from us, about a transfer to third countries or international organisations and the existence of automated decision-making, including profiling and where applicable, meaningful information about the details involved.
          • In accordance with article 16 GDPR, you can immediately demand the correction of incorrect data or the completion of your personal data stored with us.
          • In accordance with article 17 GDPR, you may request the erasure of your personal data stored with us, provided processing is not necessary to exercise the right to freedom of expression and information, to fulfil a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims.
          • In accordance with article 18 GDPR, you may request the restriction of the processing of your personal data if you contest the accuracy of the data, if the processing is unlawful, or if we no longer need the data and you oppose their erasure because you require them for the establishment, exercise or defence of legal claims. The right stemming from article 18 GDPR is also applicable to you if you have objected to the processing in accordance with article 21 GDPR.
          • In accordance with article 20 GDPR, you have the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to demand those data be transmitted to another controller.
          • In accordance with article 7 paragraph 3 GDPR, you have the right to withdraw the consent you have given us at any time. As a result of this, we may no longer continue with the data processing based on this consent in the future.
          • In accordance with article 77 GDPR, you have the right to lodge a complaint with a supervisory authority. To do so, generally speaking you may contact a supervisory authority of your habitual residence, place of work or the registered address of our company.

          § 11   Right to object

          In instances of processing of your personal data based on legitimate interests in accordance with article 6 paragraph 1 (1) lit. f GDPR, you have the right, pursuant to article 21 GDPR, to object to the processing of your personal data on grounds relating to your particular situation or the objection is against direct marketing. In the case of direct marketing, you have a general right to object, which will be implemented by us without your indicating a particular situation.

          § 12   Data security and security measures

          We undertake to protect your privacy and treat your personal data confidentially. To prevent manipulation, loss or misuse of your data stored with us, we take comprehensive technical and organisational security precautions, which are regularly checked and adjusted to technological advances. Among others, these include the use of accepted encryption procedures (SSL).
However, we would like to point out that due to the structure of the Internet, it is possible that the rules of data protection and the aforementioned security measures may not be observed by other persons or institutions for which we are not responsible. In particular, data which are divulged in unencrypted form – e.g. when this takes place by e-mail – can be read by third parties. We have no technical influence over this. It is the responsibility of the user to protect the data provided by him or her against misuse with encryption or in any other way.