DATA PRIVACY

We are delighted to welcome you to our website, and would like to thank you for your interest in our company and range of services. Protecting your personal data is very important to us. All web activities are carried out in accordance with the applicable legislation on protecting personal data and data security. This privacy statement tells you about how TERRITORY handles information that is collected during your visit to the website.

DATA PRIVACY POLICY

1. INTRODUCTION

The following information is meant to give you, the “data subject”, an overview of how we process your personal data and your rights as defined by data protection regulations. In general, you can use our webpages without entering any personal data. However, if you wish to use specific services provided by our company via our website, processing of personal data may become necessary. We will generally obtain your consent if processing of personal data is required and there is no pre-existing legal basis for such processing.

The processing of personal data such as your name, address or email address will always be performed in accordance with the General Data Protection Regulation (GDPR) and also in accordance with the country-specific data protection regulations applicable for “Territory CTR GmbH”. In this Privacy Policy, we would like to inform you of the scope and purpose of the personal data that we collect, use and process.

As the party responsible for the processing (data controller), we have implemented a number of technical and organizational measures to ensure that the protection of the personal data processed via this web page is as comprehensive as possible. Nevertheless, Internet-based data transmissions can always be subject to weaknesses in security. As such, absolute protection cannot be guaranteed. For this reason, you also have the option to provide us with your personal data via alternative channels such as telephone or regular mail.

 

2. DATA CONTROLLER

The data controller as defined by the GDPR is:

Territory CTR GmbH
Carl-Bertelsmann-Straße 33, 33311 Gütersloh, Germany

Phone: +49 5241 23480-50
Fax: +49 5241 23480-22
Email: kontakt@territory.de

Manager of the responsible body: Stefan Postler, Gero Hesse, Soheil Dastyari

 

3. DATA PROTECTION OFFICER

You can contact the data protection officer using the details below:

Wolfgang Wobbe

Data Protection Officer Gruner + Jahr GmbH, Hamburg

Phone: +49 (0) 40 / 37 03 – 2832
Fax: +49 (0) 40 / 37 03 17 – 2832
Email: wobbe.wolfgang@guj.de

Please do not hesitate to contact our data protection officer directly if you have any questions or suggestions regarding data privacy.

 

4. DEFINITIONS

This Privacy Policy uses the terms used by the European regulatory authority in the General Data Protection Regulation (GDPR). We intend our Privacy Policy to be easy to read and comprehensible for both the general public and our customers and business partners. To ensure this, we would like to define the terms we will be using in advance.

In this Privacy Policy, we will use the following terms, among others:

  1. Personal data
    Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is a natural person 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of said natural person.
  2. Data subject
    A data subject is any identified or identifiable natural person whose personal data is processed by the party responsible for the processing (our company).
  3. Processing
    Processing means any operation or set of operations which is performed on personal data or sets of personal data either with or without the aid of automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  4. Restriction of processing
    Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.
  5. 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 analyze or predict aspects concerning said natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
  6. Pseudonymization
    Pseudonymization means 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 organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
  7. Processor
    Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
  8. Recipient
    Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed. A recipient may or may not be a third party. However, public authorities which receive personal data within the context of a specific inquiry in accordance with Union or Member State law shall not be regarded as recipients.
  9. Third party
    Third party means a natural or legal person, public authority, agency or body other than the data subject, the controller, the processor and the persons who are authorized to process personal data under the direct authority of the controller or processor.
  10. Consent
    Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by means of a statement or a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

5. LEGAL BASIS FOR PROCESSING

Art. 6, Para. 1(a) of the GDPR provides the legal basis for our company for data processing operations where we obtain consent for a specific processing purpose.

If the processing of personal data is required for the fulfillment of a contract to which you are a contractual party, as is the case in processing operations that are required for the delivery of goods or other services or counter-performance of services, for example, the processing is based on Art. 6, Para. 1(b) of the GDPR. The same applies for processing operations that are necessary in order to carry out measures in advance of a contract, e.g., in case of queries relating to our products or services.

If our company is subject to a legal obligation that requires the processing of personal data, e.g. fulfilment of tax obligations, then the processing is based on Art. 6, Para. 1(c) of the GDPR.

In rare cases, the processing of personal data may become necessary in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our company were injured and his/her name, age, health insurance information and other vital information would have to be provided to the attending physician, hospital or other third parties. In this case, the processing would be based on Art. 6, Para. 1(d) of the GDPR.

Finally, processing operations could be based on Art. 6, Para. 1(f) of the GDPR. This is used as the legal basis for processing operations that are not covered by any of the aforementioned legal bases if the processing is required in order to protect the legitimate interests of our company or a third party to an extent that outweighs the interests, fundamental rights and freedoms of the data subject. We are permitted to carry out such processing operations because they are mentioned specifically in European law. This is reflected in Recital 47, Sentence 2 of the GDPR, which states that a legitimate interest can be assumed if you are a client of our company.

 

6. TECHNOLOGY

6.1 SSL/TLS ENCRYPTION

This website uses an SSL or TSL encryption to ensure data processing security and to protect confidential contents that you send to us as the owner of the website, such as orders, login information and contact requests. When you are using an encrypted connection, the “http://” in the address line of your browser will be replaced by “https://” and a padlock symbol will be displayed on your browser bar.

When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

 

6.2 DATA COLLECTION WHEN VISITING OUR WEBSITE

When using our website for informational purposes only, i.e., when you do not register and transmit information to us in other ways, we shall only collect the data that your browser sends to our server (in what is known as “server log files”). Our website collects a series of general data and information every time you or an automated system visit one of our pages. These general data and information are stored in the server’s log files. The collected data may include:

  1. Browser types and versions used
  2. The operating system used by the accessing system
  3. The webpage from which an accessing system is directed to our website (referrer)
  4. The sub-pages that are visited by an accessing system on our website
  5. The date and time of access to the website
  6. The Internet protocol address (IP address)
  7. The Internet service provider of the accessing system

When using these general data and information, we do not draw any conclusions regarding your person. This information is required in order to:

  1. Correctly deliver the contents of our website
  2. Optimize the contents of our website as well as site-related advertising
  3. Ensure the continued functionality of our IT systems and technology of our website
  4. Enable us to provide the required information to law enforcement authorities in the event of a cyber attack

The collected data is analyzed for statistical purposes, and also with the aim of increasing data protection and security in our company so that we can ultimately provide an optimum level of protection for the personal data that we process. The data in the server log files are stored separately from all other personal data provided by a data subject.

The legal basis for the data processing is Art. 6, Para. 1, Sentence 1(f) of the GDPR. Our legitimate interest is established by the purposes for data collection listed above.

 

6.3 DATA COLLECTION WHEN VISITING OUR WEBSITE

When using our website for informational purposes only, i.e., when you do not register and transmit information to us in other ways, we shall only collect the data that your browser sends to our server (in what is known as “server log files”). Our website collects a series of general data and information every time you or an automated system visit one of our pages. These general data and information are stored in the server’s log files. The collected data may include:

  1. Browser types and versions used
  2. The operating system used by the accessing system
  3. The webpage from which an accessing system is directed to our website (referrer)
  4. The sub-pages that are visited by an accessing system on our website
  5. The date and time of access to the website
  6. A shortened Internet protocol address (anonymized IP address)
  7. The Internet service provider of the accessing system

When using these general data and information, we do not draw any conclusions regarding your person. This information is required in order to:

  1. Correctly deliver the contents of our website
  2. Optimize the contents of our website as well as site-related advertising
  3. Ensure the continued functionality of our IT systems and technology of our website
  4. Enable us to provide the required information to law enforcement authorities in the event of a cyber attack

The collected data is analyzed for statistical purposes, and also with the aim of increasing data protection and security in our company so that we can ultimately provide an optimum level of protection for the personal data that we process. The anonymous data in the server log files are stored separately from all other personal data provided by a data subject.

The legal basis for the data processing is Art. 6, Para. 1, Sentence 1(f) of the GDPR. Our legitimate interest is established by the purposes for data collection listed above.

 

7. COOKIES

7.1 GENERAL INFORMATION ON COOKIES

We use cookies on our website. These are small files that your browser creates automatically and which are stored on your IT system (laptop, tablet, smartphone or similar) when you visit our website. Cookies do not harm your device; they do not contain viruses, Trojans or other malware.

The cookie stores information that arises in connection with the specific device you are using to access our website. However, this does not mean that we receive any direct information regarding your identity.

The purpose of using cookies is to make the use of our website more convenient for you. For example, we use “session cookies” to detect whether you have already visited individual pages on our website. These are automatically deleted when you leave our website.

In addition to this, we also use temporary cookies, which are stored on your device for a certain determined period of time, to optimize user friendliness. If you visit our site again to use our services, we will automatically be able to detect that you have visited us before and which entries and settings you have already made so you do not need to enter them again.

In addition to this, we use cookies to collect statistical data on the use of our website and analyze it to optimize how it is presented to you. These cookies enable us to recognize you during repeat visits to our website and automatically detect that you have visited us before. These cookies are automatically deleted after a defined time period.

The data processed by the cookies are required for the aforementioned purposes in order to protect our legitimate interests and the interests of third parties in accordance with Art. 6, Para. 1, Sentence 1(f) of the GDPR.

Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer, or set it to notify you whenever a website wants to create a new cookie on it. However, deactivating cookies completely may prevent you from being able to use all the functions of our website.

 

8. THE CONTENTS OF OUR WEBSITE

8.1 GETTING IN TOUCH/CONTACT FORM

Personal data is collected when you contact us (e.g. via the contact form or email). The data we collect when you use a contact form can be determined from the contact form in question. These data are only stored and used so that we can answer your queries, contact you and carry out the technical administration required in order to do so. The legal basis for the data processing is our legitimate interest in responding to your request in accordance with Art. 6, Para. 1(f) of the GDPR. If you contact us with the intention of concluding a contract, Art. 6, Para. 1(b) of the GDPR shall form an additional legal basis for the processing. Your data shall be deleted once your query has been conclusively processed; this is the case when it can be concluded from the circumstances that the facts of the matter have been conclusively clarified, and providing that no legal retention obligations exist.

 

9. SENDING NEWSLETTERS

9.1 MARKETING NEWSLETTER

On our website, you are given the option to subscribe to our company’s newsletter. The personal data transmitted to us during the subscription to the newsletter can be determined from the data entry screen used for this purpose.

We use our newsletter to inform our customers and business partners at regular intervals about the products we offer. Generally speaking, you can only receive our company’s newsletter if:

  1. You have a valid email address
  2. You have also subscribed to the newsletter

For legal reasons, we use the double opt-in process for subscriptions to our newsletter. This means that we will send a confirmation email to the email address you entered initially in order to receive the newsletter. This confirmation email is used to verify whether you, the owner of the email address, have authorized receipt of the newsletter.

If you subscribe to the newsletter, we shall also store the IP address assigned to your system by your Internet service provider (ISP), as well as the date and time of your registration. The collection of this data is required in order to trace any (potential) misuse of your email address at a later point in time, and is therefore necessary for our legal protection.

Any personal data collected as part of a registration process shall be used exclusively for the purpose of delivering the newsletter. In addition to this, subscribers to the newsletter may be sent information via email if this is necessary for the operation of the newsletter service or if registration is required, as may be the case in the event of changes to the newsletter or a change to the technical circumstances. The personal data collected as part of the newsletter service is not disclosed to third parties. You can cancel your subscription to our newsletter at any time. Your consent to the storage of your personal data, which you provided to us so that we can send you the newsletter, can be revoked at any time. Every newsletter contains a link enabling you to cancel the newsletter subscription. Furthermore, you also have the option of canceling the newsletter subscription directly via our website or informing us of your cancellation in another way.

The legal basis for data processing for the purpose of sending out newsletters is Art. 6, Para. 1(a) of the GDPR.

10. WEB ANALYTICS

10.1 GOOGLE ANALYTICS

We use Google Analytics, a web analytics service provided by Google Inc. (https://www.google.de/intl/en/about/) (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter referred to as “Google”) on our websites. This involves the creation of pseudonymized user profiles and the use of cookies (see Section 4). The information generated by the cookie regarding your use of the website shall be transmitted to a Google server in the United States and stored there. Examples of this information include:

  1. Your browser type/version
  2. The operating system you use to access our website
  3. Your referrer URL (the previously visited page)
  4. The host name of the computer you use to access our website (IP address)
  5. The time of the server request

are transmitted to a Google server in the United States and stored there. This information is used to analyze website use, to create reports about website activities, and to provide additional services in relation to website and Internet use for market research purposes and to ensure that the design of this website suits its users’ needs. This information may be transmitted to third parties, if such transmission is legally required or if said third parties are subcontracted for the processing of these data. Your IP address will never be combined with other Google data. The IP addresses will be anonymized to ensure that attribution is not possible (IP masking).

You can prevent the installation of cookies by changing the corresponding settings in your browser software; however, we would like to point out that this may prevent you from fully utilizing all the functions of our website.

You have provided your consent to this as defined in Art. 6, Para. 1(a) of the GDPR via our opt-in cookie banner.

Furthermore, you can download and install a browser add-on (http://tools.google.com/dlpage/gaoptout?hl=en) in order to prevent Google from collecting and processing the data generated by the cookie relating to your use of the website (including your IP address).

As an alternative to the browser add-on, particularly for browsers on mobile devices, you can also prevent data collection by Google Analytics by clicking on the following link: deactivate Google Analytics. Deactivate Google Analytics This places an opt-out cookie on your device in order to prevent future collection of your data when you visit this website. The opt-out cookie will only work in this browser and only for our website, and will be placed on your device. If you delete the cookies in your browser, you will have to install the opt-out cookie again.

Additional information regarding data protection in relation to Google Analytics can be found in the Google Analytics Help section (https://support.google.com/analytics/answer/6004245?hl=de).

 

11. PLUGINS AND OTHER SERVICES

11.1 ADOBE TYPEKIT

We use Adobe Typekit to improve the visual design of our website. Typekit is an Adobe Systems Software Ireland Ltd. service which gives us access to a font library. To integrate the fonts we use, your browser must establish a connection with an Adobe server in the USA and download the font required for our website. During this process, Adobe receives the information that our website has been accessed from your IP address. Additional information regarding the Adobe Typekit can be found in Adobe’s privacy policy, which you can find here: www.adobe.com/privacy/typekit.html

You have provided your consent to this as defined in Art. 6, Para. 1(a) of the GDPR via our opt-in cookie banner.

 

11.2 GOOGLE MAPS

We use Google Maps (API), a service provided by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA on our website. Google Maps is a web service that provides interactive maps in order to visually represent geographic information. You can use this service to view our location and a obtain route description, thus making it easier to visit us by car, for example.

When the subpages with integrated Google Maps are accessed, information generated regarding your use of our website (e.g. your IP address) is transmitted to a Google server in the USA and stored there. This occurs regardless of whether Google provides a user account via which you are logged in or whether there is no user account. If you are logged in with Google, your data will be directly associated with your account. If you do not wish the data to be associated with your Google profile, you will have to log out of your Google user account. Google stores your data (even the data of users who are not logged in) as user profiles and analyzes them. This type of analysis is performed in accordance with Art. 6, Para. 1(f) of the GDPR based on Google’s legitimate interest in providing personalized advertising, market research and/or a website design that suits the needs of its users. You have the right to object to the creation of these user profiles; however, your assertion of this right must be addressed to Google.

Google LLC, with headquarters in the USA, is certified for the US/European data protection agreement “Privacy Shield”, which ensures compliance with the data protection levels applicable in the EU.

If you do not agree with the future transmission of your data to Google as part of your use of Google Maps, you also have the option of completely deactivate the Google Maps web service by switching off JavaScript in your browser. If you do this, you will not be able to use Google Maps or the map shown on this website.

You have provided your consent to this as defined in Art. 6, Para. 1(a) of the GDPR via our opt-in cookie banner.

The Google terms of use can be found at https://policies.google.com/terms?hl=en&gl=en. The additional terms of use for Google Maps can be found at hthttps://www.google.com/intl/en_US/help/terms_maps.html

Detailed information regarding the privacy policy in relation to Google Maps can be found on Google’s website (“Google Privacy Policy”): http://www.google.de/intl/de/policies/privacy/

 

11.3 GOOGLE RECAPTCHA

We use Google reCAPTCHA, a service provided by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA on our website (“Google”). This function is primarily used to distinguish whether data has been entered by a natural person or whether it constitutes misuse by means of machine data entry and automated processing. This service also includes the sending to Google of the IP address and any additional data required by Google for the reCAPTCHA service, and is performed in accordance with Art. 6, Para. 1(f) of the GDPR based on our legitimate interest in the determination of the individual intent of actions on the Internet and preventing misuse and spam.

Google LLC, with headquarters in the USA, is certified for the US/European data protection agreement “Privacy Shield”, which ensures compliance with the data protection levels applicable in the EU.

Further information regarding Google reCAPTCHA and Google’s Privacy Policy can be found at: https://www.google.com/intl/en/policies/privacy/

 

11.4 GOOGLE TAG MANAGER

This website uses Google Tag Manager, a domain that does not use cookies or collect personal data.

This tool can be used to implement “website tags” (i.e. keywords integrated into HTML elements) and manage them via an interface. By using Google Tag Manager, we are automatically able to see which button, link or personalized image you have actively clicked on, thus allowing us to record which content on our website is of particular interest to you.

The tool also triggers other tags, which may also collect data. Google Tag Manager does not access this data. If you have carried out a deactivation at a domain or cookie level, this will remain in effect for all tracking tags that are implemented by the Google Tag Manager.

You have provided your consent to this as defined in Art. 6, Para. 1(a) of the GDPR via our opt-in cookie banner.

 

11.5 VIMEO (VIDEOS)

Our website integrates plugins from the video portal Vimeo, a service provided by Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA. If you access a page on our website that contains such a plugin, your browser will establish a direct connection with the Vimeo servers. Vimeo will transmit the content of the plugin directly to your browser and integrate it into the page. As a result of the integration, Vimeo will receive the information that your browser has accessed the relevant page of our website, even if you do not have a Vimeo account or are not currently logged in to Vimeo. This information (including your IP address) will be transmitted directly to a Vimeo server in the USA by your browser and stored there.

If you are logged in to Vimeo, Vimeo will be able to directly associate your visit to our website with your Vimeo account. If you interact with the plugins (e.g. by pressing the Play button on a video), the relevant information will also be transmitted directly to a Vimeo server and stored there.

The data processing operations described above are performed in accordance with Art. 6, Para. 1(f) of the GDPR based on Vimeo’s legitimate interest in market research and proving a website design that suits the needs of its users.

If you do not want Vimeo to directly associate the collected data with your Vimeo account, you must log out from your Vimeo account before vising our website.

The purpose and scope of the data collection, the further processing and use of the data by Vimeo, and your rights and configuration options for the protection of your privacy can be found in Vimeo’s privacy policy: https://vimeo.com/privacy

The Google Analytics tracking tool is automatically integrated into Vimeo videos that are integrated into our page. This is Vimeo’s own tracking process. We do not have access to this tracking process and cannot influence it from our end. Google Analytics uses “cookies” for tracking; these are text files which are stored on your computer and permit the analysis of your use of the website. The information generated by the cookie about your use of the website is typically transmitted to and stored by Google on servers in the USA.

You have provided your consent to this as defined in Art. 6, Para. 1(a) of the GDPR via our opt-in cookie banner.

 

11.6 YOUTUBE (VIDEOS)

We have integrated YouTube elements into this website. YouTube is an online video portal that gives video publishers the opportunity to post video clips free of charge and enables other users to watch, evaluate and comment on these video clips also free of charge. YouTube allows the publication of all types of videos, which is why the online portal can be used to view entire films and TV shows as well as music videos, trailers and original videos created by users.

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Any visit to an individual page of this website that we operate and that contains an integrated YouTube component (YouTube video) will cause the Internet browser on your IT system to automatically download a representation of the YouTube component in question from YouTube. Further information regarding YouTube can be viewed at https://www.youtube.com/yt/about/. As part of this technical process, YouTube and Google will receive information regarding which specific subpage of our website you have visited.

If the data subject is logged into a YouTube account while accessing a subpage that contains a YouTube video, YouTube will detect which specific subpage of our website you are visiting. This information will be collected by YouTube and Google and associated with your YouTube account.

If you are logged in to YouTube when you access our website, YouTube and Google will always be notified via the YouTube component that you have visited our website; this occurs irrespective of whether you have clicked on a YouTube video or not. If you do not wish for this type of information to be provided to YouTube and Google, you can prevent the transmission of these data by logging out of your YouTube account before accessing our website.

You have provided your consent to this as defined in Art. 6, Para. 1(a) of the GDPR via our opt-in cookie banner.

The privacy policy published by YouTube, which can be viewed at https://www.google.de/intl/en/policies/privacy/, provides information regarding the collection, processing and use of personal data by YouTube and Google.

 

12. YOUR RIGHTS AS DATA SUBJECT

12.1 RIGHT TO CONFIRMATION

You have the right to obtain confirmation from us regarding whether personal data concerning your person are being processed.

 

12.2 RIGHT OF ACCESS (ART. 15, GDPR)

You have the right to receive from us, at any time and free of charge, information regarding personal data that we have stored on you a copy of these data.

 

12.3 RIGHT TO RECTIFICATION (ART. 16, GDPR)

You have the right to request the rectification of incorrect personal data regarding your person. Furthermore, the data subject also has the right to have incomplete personal data completed, taking into account the purposes of the processing.

 

12.4 ERASURE (ART. 17, GDPR)

You have the right to obtain from us without undue delay the erasure of personal data concerning your person, insofar as there is a legal basis therefor and to the extent that processing is not deemed necessary.

 

12.5 RESTRICTION OF PROCESSING (ART. 18, GDPR)

You have the right to request that we restrict the processing of your data on legal grounds.

 

12.6 DATA PORTABILITY (ART. 20, GDPR)

With regard to personal data that you have provided to us, you have a right to receive the data in a structured, commonly used and machine-readable format. You have also the right to transmit these data to another controller without hindrance from us, the controller to which the personal data have been provided, to the extent that the processing is based on consent pursuant to Art. 6, Para. 1(a) of the GDPR or Art. 9, Para. 2(a) of the GDPR or on a contract pursuant to Art. 6., Para 1(b) of the GDPR and if the processing is carried out by automated means, providing 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 us.

Furthermore, as part of your right to data portability in accordance with Art. 20, Para. 1 of the GDPR, you have the right to have your personal data transmitted directly from one controller to another, where technically feasible, providing this does not impair the rights and freedoms of other persons.

12.7 OBJECTION (ART. 21, GDPR)

You have the right to object, on grounds relating to your special situation, at any time to the processing of your personal data which is based on Art. 6, Para. 1(e) (Data processing in the public interest) or 1(f) (Data processing based on legitimate interests) of the GDPR.

This also applies for any profiling as defined in Art. 4, No. 4 of the GDPR that is based on these provisions.