Privacy policy

Data protection information (as of May 14, 2018)


Data protection information about our data processing in accordance with Articles (Art.) 13, 14 and 21 of the General Data Protection Regulation (DSGVO) We take data protection seriously and hereby inform you how we process your data and what claims and rights you are entitled to under the data protection regulations. Valid as of May 25, 2018.


1. entity responsible for data processing and contact details

Responsible party in terms of data protection law:
smartlab Innovationsgesellschaft mbH
Data protection coordinator Pascal Beckers
Krefelder Straße 195
52070 Aachen
E-mail address:

Contact details of our data protection officer:
Data protection officer
HEC Harald Eul Consulting GmbH
Auf der Höhe 34 50321 Brühl
E-mail address:


2. purposes and legal basis on which we process your data

We process personal data in accordance with the provisions of the General Data Protection Regulation (DSGVO), the Federal Data Protection Act (BDSG) and other applicable data protection regulations (details below). Which data is processed in detail and how it is used depends largely on the services requested or agreed in each case. Further details or additions to the purposes of data processing can be found in the respective contractual documents, forms, a declaration of consent and/or other information provided to you (e.g. in the context of using our website or our terms and conditions). In addition, this data protection information may be updated from time to time, as you can see from our website


2.1. purposes for the fulfillment of a contract or pre-contractual measures (Art. 6 para. 1 b DSGVO)

The processing of personal data is carried out for the execution of our contracts with you and the execution of your orders as well as for the implementation of measures and activities in the context of pre-contractual relationships, e.g. with interested parties. In particular, the processing thus serves the provision of services in accordance with your orders and requests and include the services, measures and activities necessary for this. This essentially includes contract-related communication with you, the verifiability of transactions, orders and other agreements, as well as for quality control through appropriate documentation, goodwill procedures, measures for the control and optimization of business processes, as well as for the fulfillment of general due diligence obligations, management and control by affiliated companies (e.g. parent company); statistical evaluations for corporate management, cost recording and controlling, reporting, internal and external communication, emergency management, billing and tax valuation of operational services, risk management, assertion of legal claims and defense in the event of legal disputes; ensuring IT security (e.g. system and plausibility tests) and general security, including building and facility security, safeguarding and exercising domiciliary rights (e.g., through access controls); ensuring the integrity, authenticity, and availability of data, preventing and investigating criminal acts; monitoring by supervisory bodies or control authorities (e.g., auditing).


2.2. purposes within the scope of a legitimate interest of us or third parties (Art. 6 para. 1 f DSGVO)

Beyond the actual performance of the contract or preliminary contract, we may process your data if it is necessary to protect legitimate interests of us or third parties, in particular for purposes:

  • advertising or market and opinion research, insofar as you have not objected to the use of your data;
  • obtaining information and exchanging data with credit agencies, insofar as this exceeds our economic risk;
  • the testing and optimization of demand analysis procedures;
  • the further development of services and products as well as existing systems and processes;
  • the disclosure of personal data as part of due diligence in company sale negotiations;
  • for comparison with European and international anti-terrorist lists, insofar as this goes beyond the legal obligations;
  • the enrichment of our data, including through the use or research of publicly available data;
  • statistical evaluations or market analysis;
  • of benchmarking;
  • the assertion of legal claims and defense in legal disputes that are not directly attributable to the contractual relationship;
  • the limited storage of the data, if deletion is not possible or only possible with disproportionate effort due to the special type of storage;
  • the development of scoring systems or automated decision-making processes;
  • the prevention and investigation of criminal offenses, insofar as not exclusively for the fulfillment of legal requirements;
  • building and plant security (e.g. through access controls and video surveillance), insofar as this goes beyond the general duties of care;
  • internal and external investigations, safety reviews;
  • the possible listening in or recording of telephone conversations for quality control and training purposes;
  • of obtaining and maintaining certifications of a private or regulatory nature;
  • safeguarding and exercising domestic authority through appropriate measures, such as video surveillance to protect our customers and employees, and to secure evidence in the event of criminal acts and prevent them from occurring.

2.3. purposes within the scope of your consent (Art. 6 para. 1 a DSGVO)

Processing of your personal data for certain purposes (e.g. use of your e-mail address for marketing purposes) may also be based on your consent. As a rule, you can revoke this at any time. This also applies to the revocation of declarations of consent given to us prior to the application of the GDPR, i.e. prior to May 25, 2018. You will be informed separately about the purposes and consequences of revoking or not granting consent in the relevant text of the consent. As a general rule, the revocation of consent only takes effect for the future. Processing that took place before the revocation is not affected by this and remains lawful.


2.4. purposes to comply with legal requirements (Art. 6 para. 1 c DSGVO) or in the public interest (Art. 6 para. 1 e DSGVO).

Like everyone involved in business, we are subject to a wide range of legal obligations. Primarily, these are legal requirements (e.g., commercial and tax laws), but also regulatory or other official requirements where applicable. The purposes of processing may include identity and age verification, fraud and money laundering prevention, the prevention, combating and investigation of terrorist financing and asset-threatening crimes, comparisons with European and international anti-terror lists, the fulfillment of control and reporting obligations under tax law, and the archiving of data for data protection and data security purposes as well as audits by tax and other authorities. In addition, the disclosure of personal data may become necessary in the context of official/court measures for the purposes of gathering evidence, criminal prosecution or enforcement of civil claims.


3. the categories of data we process, insofar as we do not receive data directly from you, and their origin

Insofar as this is necessary for the provision of our services, we process personal data permissibly received from other companies or other third parties (e.g. credit agencies, address publishers). In addition, we process personal data that we have permissibly taken, received or acquired from publicly accessible sources (such as telephone directories, commercial and association registers, civil registers, debtor directories, land registers, the press, the Internet and other media) and may process. Relevant personal data categories may include in particular:

  • Personal data (name, date of birth, place of birth, nationality, marital status, profession/industry and comparable data)
  • Contact details (address, e-mail address, telephone number and similar data)
  • Address data (registration data and comparable data)
  • Confirmation of payment/coverage in the case of bank and credit cards - Information about your financial situation (creditworthiness data including scoring, i.e. data for assessing the economic risk)
  • Customer history
  • Data about your use of the telemedia offered by us (e.g. time of calling up our websites, apps or newsletters, pages/links clicked on by us or entries and comparable data).
  • Video and audio data

4. recipients or categories of recipients of your data

Within our company, those internal departments or organizational units receive your data that they need  to fulfill our contractual and legal obligations or in the context of processing and implementing our legitimate interests. Your data will only be passed on to external bodies

  • for the execution of the contract;
  • for the purpose of fulfilling legal requirements according to which we are obliged to provide information, report or pass on data or the passing on of data is in the public interest (see section 2.4);
  • to the extent that external service providers process data on our behalf as order processors or function transferees (e.g. external data centers, support/maintenance of EDP/IT applications, archiving, document processing, call center services, compliance services, controlling, data screening for anti-money laundering purposes, data validation, or
  • plausibility check, data destruction, purchasing/procurement, customer management, lettershops, marketing, media technology, research, risk controlling, billing, telephony, website management, auditing services, credit institutions, printing companies or companies for data disposal, courier services, logistics);
  • on the basis of our legitimate interest or the legitimate interest of the third party for the purposes stated in section 2.2 (e.g. to authorities, credit agencies, debt collection, lawyers, courts, appraisers, affiliated companies and committees and supervisory bodies);
  • if you have given us consent to transfer the data to third parties.

We will not pass on your data to third parties beyond this. Insofar as we commission service providers to process your data, they are subject to the same security standards as we are. In other cases, the recipients may only use the data for the purposes for which it was transmitted to them.


5. online product advisor / appointment setting

Type and purpose of processing:
When using the online product advisors or the online appointment system provided, the personal data entered by the user is used to recommend a product adapted to the user's needs and circumstances or to offer him suitable advice. This is the only way that the online product advisors or the online appointment system can display the desired results (product or consulting service) to the user. For this purpose, the data is stored on the user's device by means of cookies during the use of the generator. A transfer to the responsible party or to third parties only takes place if further steps are initiated after completion (e.g. a product is ordered or an individual consultation is arranged).
If further steps are initiated, the processing is carried out in parts under joint responsibility between

smartlab Innovationsgesellschaft mbH Krefelder Strasse 195
52070 Aachen

Privacy policy smartlab


Smart Living Hub GmbH Nordstraße 10
83253 Rimsting

Privacy policy SLH

The companies address different needs of potential customers. Data collection, storage, and qualification of the data gathered during inquiries are carried out in a shared database environment (Salesforce) to ensure that the most suitable provider can always offer an individualized offer tailored to the needs of the interested party. Both companies are independently responsible for the lawful processing of personal data and the provision of data subjects' rights, including the provision of mandatory information. They support each other as needed. The joint responsibility is governed by an agreement between the companies.

Legal basis:
The processing of the data entered in takes place for the implementation of pre-contractual measures at the request of the data subject (Art. 6 para. 1 lit. b DSGVO).

Recipients of the data may be order processors, such as technical service providers who are active for the operation and maintenance of our website or providers of tools used for contract initiation and processing, such as Salesforce.

Storage period:
Data will only be processed in this context as long as this is necessary for the purposes stated above.
If a contractual relationship arises, we are subject to the statutory retention periods under the German Commercial Code (HGB) and delete your data the expiration of these periods.

Provision required or necessary:
The provision of your personal data is neither required by law nor by contract. However, without the provision of your personal data, we cannot offer you individual advice or product recommendations via the configurator tools.


6. duration of the storage of your data

We process and store your data for the duration of our business relationship. This also includes the initiation of a contract (pre-contractual legal relationship) and the processing of a contract.

In addition, we are subject to various storage and documentation obligations arising from the German Commercial Code (HGB) and the German Fiscal Code (AO), among other things. The retention and documentation periods specified there are up to ten years beyond the end of the business relationship or the pre-contractual legal relationship.

Furthermore, special statutory provisions may require a longer retention period, such as the preservation of evidence within the scope of statutory limitation provisions. According to Sections 195 et seq. of the German Civil Code (BGB), the regular limitation period is three years; however, limitation periods of up to 30 years may also be applicable.

If the data are no longer required for the fulfillment of contractual or legal obligations and rights, they are regularly deleted, unless their - temporary - further processing is necessary for the fulfillment of the purposes listed under section 2.2 due to an overriding legitimate interest. Such an overriding legitimate interest also exists, for example, if deletion is not possible or only possible with disproportionate effort due to the special nature of the storage and processing for other purposes is precluded by appropriate technical and organizational measures.


7. processing of your data in a third country or by an international organization

A transfer of data to countries outside the European Union (EU) or the European Economic Area (EEA) (so-called third countries) takes place if it is necessary for the execution of an order/contract from or with you, if it is required by law (e.g. tax reporting obligations), if it is in the legitimate interest of us or a third party or if you have given us your consent. In this context, the processing of your data in a third country may also take place in connection with the involvement of service providers as part of commissioned processing. If there is no EU Commission decision on an adequate level of data protection for the country in question, we will ensure that your rights and freedoms are adequately protected and guaranteed in accordance with EU data protection requirements by means of appropriate contracts. We will provide you with corresponding detailed information upon request. Information on the appropriate or adequate guarantees and on the possibility of obtaining a copy from you can be obtained from the company data protection officer upon request.


8. your data protection rights

Under certain conditions, you can assert your data protection rights against us

  • Thus, you have the right to receive information from us about your data stored by us according to the rules of Art. 15 DSGVO (if necessary with restrictions according to § 34 BDSG).
  • Upon your request, we will correct the data stored about you in accordance with Art. 16 DSGVO if it is inaccurate or incorrect.
  • If you wish, we will delete your data in accordance with the principles of Art. 17 DSGVO, provided that other legal regulations (e.g. statutory retention obligations or the restrictions under Section 35 BDSG) or an overriding interest on our part (e.g. for the defense of our rights and claims) do not prevent this.
  • Taking into account the requirements of Art. 18 DSGVO, you may request us to restrict the processing of your data.
  • Furthermore, you may object to the processing of your data pursuant to Art. 21 DSGVO, on the basis of which we must terminate the processing of your data. However, this right of objection only applies in very special circumstances of your personal situation, whereby rights of our company may conflict with your right of objection.
  • You also have the right to receive your data under the conditions of Art. 20 DSGVO in a structured, common and machine-readable format or to transfer it to a third party.
  • In addition, you have the right to revoke your consent to the processing of personal data at any time with effect for the future (see section 2.3).
  • Furthermore, you have the right to lodge a complaint with a data protection supervisory authority (Art. 77 DSGVO). However, we recommend that you always first address a complaint to our data protection officer.

Your requests to exercise your rights should be addressed in writing, if possible, to the address above or directly to our Data Protection Officer.


9. scope of your obligations to provide us with your data

You only need to provide the data that is required for the establishment and implementation of a business relationship or for a pre-contractual relationship with us, or which we are required to collect by law. Without this data, we will generally not be able to conclude or execute the contract. This may also refer to data required later in the course of the business relationship. If we request additional data from you, you will be informed separately of the voluntary nature of the information.


10. existence of automated decision-making in individual cases (including profiling).

We do not use any purely automated decision-making processes pursuant to Article 22 of the GDPR. If we do use such a procedure in individual cases in the future, we will inform you separately, provided this is required by law.


In some circumstances, we process your data partly with the aim of evaluating certain personal aspects (profiling).


In order to be able to provide you with targeted information and advice on products, we may use evaluation tools. These enable needs-based product design, communication and advertising, including market and opinion research.


Such procedures can also be used to assess your creditworthiness and credit standing and to combat money laundering and fraud. So-called "score values" can be used to assess your creditworthiness and credit standing. Scoring involves calculating the probability, using mathematical methods, that a customer will meet his or her payment obligations in accordance with the contract. Such score values thus support us, for example, in assessing creditworthiness, in decision-making in connection with product transactions, and are incorporated into our risk management. The calculation is based on mathematically and statistically recognized and proven methods and is carried out on the basis of your data, in particular income situation, expenses, existing liabilities, occupation, employer, length of employment, experience from the previous business relationship, contractual repayment of previous loans and information from credit agencies.


Information on nationality and special categories of personal data pursuant to Art. 9 of the GDPR are not processed.


Information about your right to object Art. 21 DSGVO1.

1. you have the right to object at any time to the processing of your data which is carried out on the basis of Art. 6 (1) f DSGVO (data processing on the basis of a balance of interests) or Art. 6 (1) e DSGVO (data processing in the public interest), if there are grounds for doing so which arise from your particular situation. This also applies to profiling based on this provision within the meaning of Art. 4 No. 4 DSGVO.


If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.


2. we may also process your personal data for the purpose of direct marketing. If you do not wish to receive advertising, you have the right to object to this at any time; this also applies to profiling, insofar as it is associated with such direct advertising. We will observe this objection for the future.


We will no longer process your data for direct marketing purposes if you object to processing for these purposes.

The objection can be made without formalities and should preferably be addressed to


smartlab Innovationsgesellschaft mbH
Data Protection Coordinator Pascal Beckers
Krefelder Straße 195
52070 Aachen

E-mail address:


Our privacy policy as well as the information on data protection regarding our data processing pursuant to Articles (Art.) 13, 14 and 21 DSGVO may change from time to time. We will publish all changes on this page. We provide older versions for you to view in an archive.

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