Privacy

Data protection

We are very pleased that you are interested in our company. Data protection is of a particularly high priority for the management of the GGH GMBH. You can basically use the website of GGH GMBH without providing any personal data. However, if a data subject wants to use special company services 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 person concerned.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to GGH GMBH. By means of this data protection declaration, our company would like to inform the public about the type, 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 data protection declaration.

As the controller responsible for processing, GGH GMBH has implemented numerous technical and organizational measures to ensure the most complete possible protection of personal data processed via this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us in alternative ways, for example by telephone.


1. Definitions

The data protection declaration of GGH GMBH is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance.

We use the following terms, among others, in this data protection declaration:

a) Personal data

Personal data is any information relating to an identified or identifiable natural person (hereinafter "data subject"). A natural person is considered to be identifiable if, directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier or to one or more special features, the expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person can be identified.

b) Data subject

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

c) Processing

Processing is any process carried out with or without the help of automated procedures or any such series of processes in connection with personal data such as collecting, recording, organizing, organizing, storing, adapting or changing, reading out, querying, using, disclosure by transmission, distribution or any other form of making available, matching or linking, restriction, deletion or destruction.

d) Restriction of processing

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


e) Profiling

Profiling is any type of automated processing of personal data, which consists in using this personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, personal Analyze or predict that natural person's preferences, interests, reliability, behavior, whereabouts or relocation.

f) Pseudonymization

Pseudonymization is the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data not assigned to an identified or identifiable natural person.

g) Controller or data controller

The person responsible or responsible for processing is the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data. If the purposes and means of this processing are specified by Union law or the law of the Member States, the person responsible or the specific criteria for his naming can be provided for by Union law or the law of the Member States.

h) processors

Processor is a natural or legal person, authority, institution or other body that processes personal data on behalf of the person responsible.

 

i) Recipient

Recipient is a natural or legal person, public authority, institution or other body to which personal data is disclosed, regardless of whether it is a third party or not. However, authorities that may receive personal data in the context of a specific investigation mandate under Union or Member State law are not considered recipients.

 

j) Third Party

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

 

k) Consent

Consent is any expression of will voluntarily given by the data subject in an informed manner and unequivocally for the specific case in the form of a declaration or other clear confirmatory action with which the data subject indicates that they consent to the processing of their personal data is.



2. Name and address of the person responsible for processing

The person responsible 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:


GGH GMBH

An der Trift 68

63303 Dreieich

Germany

Tel.: 0178-1313244

E-Mail: info@casa-vetro.de

Website: www.slkfactory.de


3. Collection of general data and information

The website of GGH GMBH collects a series of general data and information each time the website is accessed by an affected person or an automated system. This general data and information is stored in the log files of the server. The (1) browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-websites, which are accessed via an accessing system on our website can be controlled, (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 to avert threats in the event of attacks on our information technology systems.

When using these general data and information, the GGH GMBH does not draw any conclusions about the data subject. Rather, this information is required to (1) deliver the content of our website correctly, (2) optimize the content of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website and ( 4) to provide law enforcement authorities with the information necessary for law enforcement in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by GGH GMBH 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 are stored separately from all personal data provided by an affected person.
4. Routine deletion and blocking of personal data

The person responsible for processing processes and stores the personal data of the person concerned only for the period of time necessary to achieve the purpose of storage or if this is required by the European directive and regulation giver or another legislator in laws or regulations which the person responsible for processing subject, was provided.

If the purpose of storage no longer applies or if a storage period stipulated by the European legislator for directives and regulations or another competent legislator expires, the personal data will be blocked or deleted as a matter of routine and in accordance with the statutory provisions.

5. Rights of the data subject

a) Right to Confirmation

Every data subject has the right, granted by the European directive and regulation giver, to request confirmation from the data controller as to whether personal data relating to them is being processed. If a data subject wishes to exercise this right to confirmation, they can contact an employee of the data controller at any time.

 

b) Right to information

Every person affected by the processing of personal data has the right, granted by the European directive and regulation giver, to receive free information about the personal data stored about him and a copy of this information from the person responsible for processing at any time. Furthermore, the European legislator for directives and regulations has granted the data subject access to the following information:
the processing purposes
the categories of personal data being processed
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 organizations
if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria used to determine that duration
the existence of a right to correction or deletion of the personal data concerning you or to restriction of processing by the person responsible or a right to object to this processing
the existence of a right of appeal to a supervisory authority
if the personal data are not collected from the data subject: all available information about the origin of the data
the existence of automated decision-making including profiling in accordance with Article 22 (1) and (4) GDPR and - at least in these cases - meaningful information about the logic involved and the scope and intended effects of such processing for the data subject


Furthermore, the data subject has a right to information as to whether personal data has been transmitted to a third country or to an international organization. If this is the case, the person concerned has the right to receive information about the appropriate guarantees in connection with the transmission.

If a data subject wishes to exercise this right to information, they can contact an employee of the data controller at any time.


c) Right to Rectification

Every person affected by the processing of personal data has the right granted by the European directive and regulation giver to demand the immediate correction of incorrect personal data concerning them. Furthermore, the data subject has the right, taking into account the purposes of the processing, to request the completion of incomplete personal data - also by means of a supplementary declaration.

If a data subject wishes to exercise this right to rectification, they can contact an employee of the data controller at any time.

 

d) Right to Erasure (Right to be forgotten)

Any person affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to demand that the person responsible delete the personal data concerning them immediately if one of the following reasons applies and if the processing is not necessary:
The personal data were collected for such purposes or otherwise processed for which they are no longer necessary.
The data subject revokes their consent on which the processing was based pursuant to Art. 6 Para. 1 Letter a DS-GVO or Art. 9 Para. 2 Letter a DS-GVO and there is no other legal basis for the processing.
The data subject objects to the processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate reasons for the processing, or the data subject objects to the processing pursuant to Article 21 (2) GDPR processing on.
The personal data have been unlawfully processed.
Erasure of the personal data is necessary to fulfill a legal obligation in Union or Member State law to which the controller is subject.
The personal data was collected in relation to information society services offered in accordance with Art. 8 Para. 1 DS-GVO.

If one of the above reasons applies and a person concerned wishes to have personal data stored at GGH GMBH deleted, he or she can contact an employee of the person responsible for processing at any time. The employee of GGH GMBH will ensure that the request for deletion is complied with immediately.

If the personal data was made public by GGH GMBH and our company, as the person responsible, is obliged to delete the personal data in accordance with Art. 17 Para. 1 DS-GVO, GGH GMBH will take appropriate measures, taking into account the available technology and the implementation costs of a technical nature, in order to inform other persons responsible for data processing who process the published personal data that the person concerned has requested the deletion of all links to this personal data or copies or replications of this personal data from these other persons responsible for data processing has requested, insofar as the processing is not necessary. The employee of GGH GMBH will arrange the necessary in individual cases.

 

e) Right to Restriction of Processing

Any person affected by the processing of personal data has the right, granted by the European directive and regulation giver, to demand that the person responsible restrict the processing if one of the following conditions is met:
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, the data subject rejects the deletion of the personal data and instead requests the restriction of the use of the personal data.
The person responsible no longer needs the personal data for the purposes of processing, but the data subject needs them to assert, exercise or defend legal claims.
The data subject has lodged an objection to the processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored at GGH GMBH, they can contact an employee of the data controller at any time. The employee of GGH GMBH will arrange the restriction of the processing.

 

f) Right to Data Portability

Every person affected by the processing of personal data has the right, granted by the European directive and regulation giver, to receive the personal data relating to them, which the person concerned has provided to a person responsible, in a structured, common and machine-readable format. You also have the right to transmit this data to another person responsible without hindrance from the person responsible to whom the personal data was provided, provided that the processing is based on the consent in accordance with Art. 6 Para. 1 Letter a DS-GVO or Art. 9 Para 2 letter a DS-GVO or on a contract in accordance with Article 6 paragraph 1 letter b DS-GVO and the processing is carried out using automated procedures, provided that the processing is not necessary for the performance of a task that is in the public interest or takes place in the exercise of official authority, which has been transferred to the person responsible.

Furthermore, when exercising their right to data portability in accordance with Art. 20 Para the rights and freedoms of other persons are not impaired by this.

In order to assert the right to data transferability, the person concerned can contact an employee of GGH GMBH at any time.

g) Right to Object

Every person affected by the processing of personal data has the right granted by the European directive and regulation giver, for reasons that arise from their particular situation, at any time against the processing of personal data concerning them, which is based on Art. 6 para. 1 letter e or f DS-GVO to file an objection. This also applies to profiling based on these provisions.

GGH GMBH will no longer process the personal data in the event of an objection, unless we can demonstrate compelling legitimate grounds for the processing which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend of legal claims.

If GGH GMBH processes personal data in order to operate direct advertising, the person concerned has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling insofar as it is associated with such direct advertising. If the data subject objects to GGH GMBH to the processing for direct marketing purposes, GGH GMBH will no longer process the personal data for these purposes.

In addition, the data subject has the right, for reasons arising from their particular situation, against the processing of personal data relating to them, which is carried out at GGH GMBH for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 Para. 1 DS- GMO to object, unless such processing is necessary to fulfill a task in the public interest.

In order to exercise the right to object, the data subject can contact any employee of GGH GMBH or another employee directly. In connection with the use of information society services, the data subject is also free, notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

 

h) Automated decisions in individual cases including profiling

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations not to be subject to a decision based solely on automated processing - including profiling - which has legal effects on them or significantly affects them in a similar way, if the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the data controller, or (2) is permissible on the basis of Union or Member State legislation to which the controller is subject and such legislation requires appropriate measures to safeguard the rights and freedoms and legitimate interests of the data subject or (3) is carried out with the express consent of the data subject.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, the GGH GMBH shall implement suitable measures to safeguard the rights and freedoms and the legitimate safeguarding the interests of the data subject, including 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 assert rights relating to automated decisions, they can contact an employee of the data controller at any time.


i) Right to withdraw consent under data protection law

Every person affected by the processing of personal data has the right granted by the European directive and regulation giver to revoke consent to the processing of personal data at any time.

If the data subject wishes to assert their right to revoke consent, they can contact an employee of the data controller at any time.

 

6. Data protection regulations for the deployment and use of Facebook

The person responsible for processing has integrated components of the company Facebook on this website. Facebook is a social network.

A social network is a social meeting place operated on the Internet, an online community that usually enables users to communicate with one another and to interact in virtual space. A social network can serve as a platform for exchanging opinions and experiences, or it allows the Internet community to provide personal or company-related information. Among other things, Facebook enables users of the social network to create private profiles, upload photos and network via friend requests.

Facebook's operating company is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a person concerned lives outside the USA or Canada, the person responsible for processing personal data is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time one of the individual pages of this website is called up, which is operated by the person responsible for processing and on which a Facebook component (Facebook plug-in) has been integrated, the Internet browser on the information technology system of the person concerned is automatically activated by the respective Facebook component causes a representation of the corresponding Facebook component to be downloaded from Facebook. A complete overview of all Facebook plug-ins can be found at https://developers.facebook.com/docs/plugins/?locale=de_DE. As part of this technical process, Facebook is informed which specific subpage of our website is visited by the person concerned.

If the person concerned is logged on to Facebook at the same time, Facebook recognizes which specific subpage of our website the person concerned is visiting each time the person concerned calls up our website and for the entire duration of their stay on our website. This information is collected by the Facebook component and assigned to the respective Facebook account of the person concerned by Facebook. If the person concerned clicks on one of the Facebook buttons integrated on our website, for example the “Like” button, or if the person concerned makes a comment, Facebook assigns this information to the personal Facebook user account of the person concerned and stores this personal data .

Facebook always receives information via the Facebook component that the person concerned has visited our website if the person concerned is logged in to Facebook at the same time as accessing our website; this takes place regardless of whether the person concerned clicks on the Facebook component or not. If the person concerned does not want this information to be transmitted to Facebook in this way, they can prevent the transmission by logging out of their Facebook account before accessing our website.

The data policy published by Facebook, which can be accessed at https://de-de.facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. It also explains what setting options Facebook offers to protect the privacy of the data subject. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by the person concerned to suppress data transmission to Facebook.


7. Data protection regulations for the application and use of Google Analytics (with anonymization function)


The person responsible for processing has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analysis service. Web analysis is the collection, collection and evaluation of data on the behavior of visitors to websites. A web analysis service collects, among other things, data about the website from which a person concerned 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. A web analysis is mainly used to optimize a website and for the cost-benefit analysis of internet advertising.

The operating company of the Google Analytics component is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, USA.

The person responsible for processing uses the addition "_gat._anonymizeIp" for the web analysis via Google Analytics. By means of this addition, the IP address of the Internet connection of the data subject is shortened and anonymized by Google if our Internet pages are accessed from a member state of the European Union or from another state party to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyze visitor flows on our website. Google uses the data and information obtained, among other things, to evaluate the use of our website, to compile online reports for us that show the activities on our website, and to provide other services related to the use of our website.

Google Analytics places a cookie on the information technology system of the data subject. What cookies are has already been explained above. By setting the cookie, Google is enabled to analyze the use of our website. Each time one of the individual pages of this website is called up, which is operated by the person responsible for processing and on which a Google Analytics component has been integrated, the Internet browser on the information technology system of the person concerned is automatically activated by the respective Google Analytics component to transmit data to Google for online analysis. As part of this technical process, Google obtains knowledge of personal data, such as the IP address of the person concerned, which Google uses, among other things, to trace the origin of visitors and clicks and subsequently to enable commission statements.

The cookie is used to store personal information, such as access time, the location from which access was made and the frequency of visits to our website by the person concerned. Each time you visit our website, this personal data, including the IP address of the Internet connection used by the person concerned, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical process to third parties.

The person concerned can prevent the setting of cookies by our website, as already described above, at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a cookie on the information technology system of the person concerned. In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the option of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website and the processing of this data by Google. To do this, the data subject must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on tells Google Analytics via JavaScript that no data and information about visits to websites may be transmitted to Google Analytics. The installation of the browser add-on is evaluated by Google as a contradiction. If the information technology system of the person concerned is later deleted, formatted or reinstalled, the person concerned must reinstall the browser add-on in order to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the person concerned or another person who is attributable to their sphere of influence, there is the possibility of reinstalling or reactivating the browser add-on.

Further information and Google's applicable data protection regulations can be found at https://www.google.de/intl/de/policies/privacy/ and at http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail under this link https://www.google.com/intl/de_de/analytics/.


8. Data protection regulations for the deployment and use of Google AdWords

The person responsible for processing has integrated Google AdWords on this website. Google AdWords is an internet advertising service that allows advertisers to place ads in both Google's search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define certain keywords that will be used to display an ad in Google's search engine results only when the user uses the search engine to retrieve a keyword-related search result. In the Google advertising network, the ads are distributed to topic-relevant websites using an automatic algorithm and taking into account the previously defined keywords.

The operator of the Google AdWords services is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, USA.

The purpose of Google AdWords is to promote our website by displaying interest-based advertising on the websites of third-party companies and in the search engine results of the Google search engine and displaying third-party advertising on our website.

If a data subject accesses our website via a Google ad, a so-called conversion cookie is stored on the information technology system of the data subject by Google. What cookies are has already been explained above. A conversion cookie loses its validity after thirty days and is not used to identify the person concerned. If the cookie has not yet expired, the conversion cookie is used to determine whether certain sub-pages, such as the shopping cart from an online shop system, were accessed on our website. The conversion cookie enables both us and Google to understand whether a person who came to our website via an AdWords ad generated revenue, i.e. completed or canceled a purchase.

The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. In turn, we use these visit statistics to determine the total number of users who were referred to us via AdWords ads, i.e. to determine the success or failure of the respective AdWords ad and to optimize our AdWords ads for the future . Neither our company nor other Google AdWords advertisers receive information from Google that could be used to identify the person concerned.

The conversion cookie is used to store personal information, such as the website visited by the person concerned. Accordingly, each time you visit our website, personal data, including the IP address of the Internet connection used by the person concerned, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical process to third parties.


The person concerned can prevent the setting of cookies by our website, as already described above, at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Google from setting a conversion cookie on the information technology system of the person concerned. In addition, a cookie already set by Google AdWords can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the option of objecting to interest-based advertising by Google. To do this, the person concerned must call up the link www.google.de/settings/ads from each of the Internet browsers they use and make the desired settings there.

Further information and Google's applicable data protection regulations can be found at https://www.google.de/intl/de/policies/privacy/.


9. Payment Method: Data protection regulations for PayPal as a payment method

The person responsible for processing has integrated PayPal components on this website. PayPal is an online payment service provider. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. PayPal also offers the option of processing virtual payments via credit cards if a user does not have a PayPal account. A PayPal account is managed via an email address, which is why there is no classic account number. PayPal makes it possible to trigger online payments to third parties or to receive payments. PayPal also assumes trustee functions and offers buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.

If the data subject selects "PayPal" as the payment option during the ordering process in our online shop, the data of the data subject is automatically transmitted to PayPal. By selecting this payment option, the person concerned agrees to the transmission of personal data required for payment processing.


The personal data transmitted to PayPal is usually first name, last name, address, email address, IP address, telephone number, mobile phone number or other data required for payment processing. Personal data related to the respective order are also required to process the purchase contract.

The transmission of the data is intended for payment processing and fraud prevention. The person responsible for processing will transmit personal data to PayPal in particular if there is a legitimate interest in the transmission. The personal data exchanged between PayPal and the person responsible for processing may be transmitted by PayPal to credit agencies. The purpose of this transmission is to check identity and creditworthiness.


PayPal may pass on the personal data to affiliated companies and service providers or subcontractors insofar as this is necessary to fulfill the contractual obligations or the data is to be processed in the order.

The data subject has the option of withdrawing their consent to the handling of personal data from PayPal at any time. A revocation does not affect personal data that must be processed, used or transmitted for (contractual) payment processing.

PayPal's applicable data protection regulations can be found at https://www.paypal.com/de/webapps/mpp/ua/privacy-full.


10. Legal Basis for Processing

Art. 6 I lit. a GDPR serves our company 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 to fulfill a contract to which the data subject is party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in the case of inquiries about our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may become 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 in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 I lit. d GDPR. Ultimately, processing operations could be based on Art. 6 I lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and fundamental freedoms of the person concerned do not prevail. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, he took the view that a legitimate interest could be assumed if the data subject is a customer of the person responsible (recital 47 sentence 2 DS-GVO).