DGTL.ONE

Privacy Policy

We are delighted that you have shown interest in our company. Data protection is a particularly high priority for the management of DGTL.ONE Botosakis. The use of the DGTL.ONE Botosakis website is generally possible without providing any personal data. However, if a data subject wishes to use special services of our company 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 generally obtain the consent of the data subject.

The processing of personal data, such as the name, address, email address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection regulations applicable to DGTL.ONE Botosakis. By means of this privacy policy, our company would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of the rights to which they are entitled by means of this privacy policy.

As the controller, DGTL.ONE Botosakis has implemented numerous technical and organisational measures to ensure the most complete protection possible of personal data processed through this website. However, internet-based data transmissions may in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. Definitions

The privacy policy of DGTL.ONE Botosakis is based on the terms used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this privacy policy we use, among others, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter “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

A data subject is any identified or identifiable natural person whose personal data is processed by the controller.

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 its 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 other 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.

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.

k) Consent

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.

2. Name and address of the controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is:

DGTL.ONE · Owner: Fotios Botosakis · Alexanderstr. 153 · 70180 Stuttgart · Germany · Phone: +49 (0) 711 234 30 30 · Email: hello@dgtl.one · Website: dgtl.one

3. Collection of general data and information

The website of DGTL.ONE Botosakis collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be collected: (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 referrer), (4) the subpages accessed on our website by an accessing system, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information used for security purposes in the event of attacks on our information technology systems.

When using this general data and information, DGTL.ONE Botosakis does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimise the content of our website and its advertising, (3) ensure the long-term functionality of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by DGTL.ONE Botosakis statistically and with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.

4. Hosting and fonts

This website is operated on our own server infrastructure in Germany. The fonts used are loaded locally from our server. No connection to third-party servers, such as Google Fonts, is established when visiting this website.

5. Contact by email or phone

If a data subject contacts us by email or phone, we process the information provided, such as name, email address, phone number and the content of the enquiry, in order to handle the request and any follow-up questions. The legal basis is Art. 6(1)(b) GDPR if the enquiry relates to the performance of a contract or to pre-contractual measures, and otherwise Art. 6(1)(f) GDPR. The data is deleted as soon as it is no longer required for handling the request and no statutory retention obligations apply.

6. Routine erasure and blocking of personal data

The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage no longer applies, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with the statutory provisions.

7. Rights of the data subject

a) Right of confirmation

Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her is being processed. If a data subject wishes to exercise this right of confirmation, he or she may contact an employee of the controller at any time.

b) Right of access

Every data subject has the right granted by the European legislator to obtain from the controller, at any time and free of charge, information about the personal data stored about him or her and a copy of this information. Furthermore, the European legislator has granted 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 rectification or erasure of personal data or restriction of processing by the controller, 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) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has the right to be informed whether personal data has been transferred to a third country or to an international organisation. Where this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.

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

c) Right to rectification

Every data subject has the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject also has 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 contact an employee of the controller at any time.

d) Right to erasure (right to be forgotten)

Every data subject has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her 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 on which the processing is based according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) 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 Art. 8(1) GDPR.

If one of the aforementioned grounds applies and a data subject wishes to request the erasure of personal data stored by DGTL.ONE Botosakis, he or she may contact an employee of the controller at any time. The employee of DGTL.ONE Botosakis will arrange for the erasure request to be complied with immediately.

Where DGTL.ONE Botosakis has made personal data public and is obliged, as the controller, to erase the personal data pursuant to Art. 17(1) GDPR, DGTL.ONE Botosakis, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested erasure by such controllers of any links to, or copies or replications of, those personal data, as far as processing is not required. The employee of DGTL.ONE Botosakis will arrange the necessary measures in individual cases.

e) Right to restriction of processing

Every data subject has 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 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 Art. 21(1) 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 personal data stored by DGTL.ONE Botosakis, he or she may contact an employee of the controller at any time. The employee of DGTL.ONE Botosakis will arrange the restriction of the processing.

f) Right to data portability

Every data subject has the right granted by the European legislator to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out by automated means, 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 the controller.

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

To assert the right to data portability, the data subject may contact any employee of DGTL.ONE Botosakis at any time.

g) Right to object

Every data subject has 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 Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.

In the event of an objection, DGTL.ONE Botosakis will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims.

If DGTL.ONE Botosakis processes personal data for direct marketing purposes, the data subject has the right to object at any time to processing of personal data for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to DGTL.ONE Botosakis processing for direct marketing purposes, DGTL.ONE Botosakis will no longer process the personal data for these purposes.

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 DGTL.ONE Botosakis for scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may contact any employee of DGTL.ONE Botosakis directly. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject is also free to exercise his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

Every data subject has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, DGTL.ONE Botosakis shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise rights concerning automated decision-making, he or she may contact an employee of the controller at any time.

i) Right to withdraw data protection consent

Every data subject has the right granted by the European legislator to withdraw his or her consent to the processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may contact an employee of the controller at any time.

j) Right to lodge a complaint with a supervisory authority

Without prejudice to any other administrative or judicial remedy, every data subject has the right to lodge a complaint with a supervisory authority if he or she considers that the processing of personal data relating to him or her infringes the GDPR (Art. 77 GDPR). The authority responsible for us is the State Commissioner for Data Protection and Freedom of Information Baden-Württemberg (Landesbeauftragter für den Datenschutz und die Informationsfreiheit Baden-Württemberg), Lautenschlagerstraße 20, 70173 Stuttgart, Germany.

8. Data protection in applications and the application process

The controller collects and processes the personal data of applicants for the purpose of handling the application process. Processing may also be carried out electronically. This is in particular the case if an applicant submits application documents to the controller electronically, for example by email or via a web form on the website. If the controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of handling the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically erased two months after notification of the rejection decision, provided that no other legitimate interests of the controller oppose erasure. Other legitimate interest in this sense is, for example, a burden of proof in proceedings under the German General Equal Treatment Act (AGG).

9. Data protection provisions on the use of Matomo

The controller has integrated the Matomo component on this website. Matomo is an open-source software tool for web analytics. Web analytics is the collection, gathering and evaluation of data on the behaviour of visitors to websites. A web analytics tool collects, among other things, data on the website from which a data subject came to a website (so-called referrer), which subpages of the website were accessed, or how often and for how long a subpage was viewed. Web analytics is mainly used to optimise a website and to analyse the cost-benefit of internet advertising.

The software is operated on the controller’s server; the log files, which are sensitive under data protection law, are stored exclusively on this server.

The purpose of the Matomo component is the analysis of visitor flows on our website. The controller uses the data and information obtained, among other things, to evaluate the use of this website in order to compile online reports showing the activities on our websites.

Matomo is configured on this website so that no cookies are set. Each time a subpage of this website is accessed, the data subject’s browser transmits data for web analytics purposes to our server, in particular the page accessed, the date and time of access, the website from which the access was made (referrer), browser type and version, operating system, screen resolution and the IP address. The IP address is shortened (anonymised) before storage, so that it cannot be attributed to a specific person.

This data is stored exclusively on our own server and is not passed on to third parties. The legal basis is Art. 6(1)(f) GDPR. Our legitimate interest lies in the statistical evaluation of user behaviour in order to improve our website and our services.

The data subject can object to collection by Matomo at any time by activating the “Do Not Track” setting in his or her browser. If this setting is active, Matomo does not collect any data about the visit.

Further information and the applicable data protection provisions of Matomo can be found at https://matomo.org/privacy/.

10. Legal basis for the processing

Art. 6(1)(a) GDPR serves as the legal basis for processing operations for 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 the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or the provision of any other service or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to processing operations that are necessary for carrying out pre-contractual measures, for example in the case of enquiries about our products or services. If our company is subject to a legal obligation requiring the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured on our premises and 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. The processing would then be based on Art. 6(1)(d) GDPR. Finally, processing operations may be based on Art. 6(1)(f) GDPR. Processing operations not covered by any of the aforementioned legal bases are based on this provision if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not override. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator, which considered that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47, sentence 2 GDPR).

11. Legitimate interests pursued by the controller or a third party

Where the processing of personal data is based on Art. 6(1)(f) GDPR, our legitimate interest is the conduct of our business, responding to enquiries, the security and functionality of our website, and its analysis and improvement.

12. Period for which the personal data will be stored

The criterion for the duration of storage of personal data is the respective statutory retention period. After expiry of this period, the corresponding data is routinely erased, provided it is no longer required for the performance or initiation of a contract.

13. Provision of personal data as a statutory or contractual requirement; requirement necessary to enter into a contract; obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that a data subject provides us with personal data which must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data when our company concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences of failure to provide the personal data would be.

14. Existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

Last updated: September 2026