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Data Policy

This data policy declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) as part of the provision of my services and within my online offer and the websites, functions and content associated with it as well as external online presences, such as e.g . B. my social media profiles (hereinafter jointly referred to as "online offer"). With regard to the terms used, such as B. "Processing" or "Responsible" I refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).


Julian Berengar Sölter Photography

Julian Berengar Solter
Lüner Damm 7
21337 Lueneburg


Types of data processed:

- Inventory data (e.g. personal master data, names or addresses)
- Contact details (e.g. e-mail, telephone numbers)
- Content data (e.g. text input, photographs, videos)
- Usage data (e.g. websites visited, interest in content, access times)
- Meta/communication data (e.g. device information, IP addresses).​

Categories of data subjects:

Visitors and users of the online offer (hereinafter the persons concerned are also collectively referred to as "users").

Purpose of processing:

- Provision of the online offer, its functions and  content
- Answering contact requests and communicating with users
- Safety measures
- Reach measurement/marketing.

Terms used:​

"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 means of assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special features, are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Processing" is any process or series of processes carried out with or without the aid of automated processes in connection with personal data. The term is broad and encompasses practically every handling of data.
"Pseudonymization" means 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 stored separately and is subject to technical and organizational measures that ensure that the personal data not assigned to an identified or identifiable natural person.
"Profiling" 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 related to work performance, economic situation, health, personal Analyze or predict that natural person’s preferences, interests, reliability, behavior, whereabouts or relocation.
The "responsible person" 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.
"Processor" means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the person responsible.

Relevant legal bases:​

In accordance with Art. 13 GDPR, I will inform you of the legal basis for my data processing.  For users from the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies if the legal basis is not mentioned in the data protection declaration:
The legal basis for obtaining consent is Article 6(1)(a) and Article 7 GDPR;
The legal basis for processing to fulfill our services and carry out contractual measures as well as answering inquiries is Article 6 Paragraph 1 Letter b GDPR;
The legal basis for processing to fulfill our legal obligations is Article 6 (1) (c) GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 Paragraph 1 lit. d GDPR serves as the legal basis.
The legal basis for the processing required to perform a task that is in the public interest or in the exercise of official authority that has been transferred to the person responsible is Article 6 Paragraph 1 lit. e GDPR.
The legal basis for processing to protect our legitimate interests is Article 6 Paragraph 1 Letter f GDPR.
The processing of data for purposes other than those for which it was collected is determined by the provisions of Article 6 (4) GDPR.
The processing of special categories of data (according to Art. 9 Para. 1 GDPR) is determined according to the specifications of Art. 9 Para. 2 GDPR.

Safety measures:

In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk for the rights and freedoms of natural persons, suitable technical and organizational measures are taken Measures to ensure a level of protection appropriate to the risk.
The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, transfer, securing availability and their separation. Furthermore, I have set up procedures that ensure the exercise of data subject rights, deletion of data and reaction to data threats. Furthermore, I already take into account the protection of personal data during the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Cooperation with processors, joint controllers and third parties:

If, as part of my processing, I disclose data to other people and companies (processors, jointly responsible persons or third parties), transmit it to them or otherwise grant them access to the data, this is only done on the basis of legal permission (e.g. if a Transmission of the data to third parties, such as payment service providers, is required to fulfill the contract), users have consented, a legal obligation provides for this or on the basis of my legitimate interests (e.g. when using agents, web hosts, etc.).
If I disclose or transmit data to other companies in my group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, moreover, on a basis that corresponds to the legal requirements.

Transfers to third countries:

If I process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or this in the context of using third-party services or disclosure or transmission of data to other people or companies happens, this only happens if it is to fulfill my (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of my legitimate interests. Subject to express consent or contractually required transmission, I only process or leave the data in third countries with a recognized level of data protection, which include US processors certified under the "Privacy Shield" or on the basis of special guarantees, such as B. contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO," (EU Commission information page).​

Rights of data subjects:

Right to information:  You have the right to request confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with legal requirements.
Right to rectification: you have accordingly. In accordance with legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
Right to deletion and restriction of processing:   You have the right to demand that the data in question be deleted immediately in accordance with the legal requirements, or alternatively to restrict the processing of the data in accordance with the legal requirements demand.
Right to data portability: You have the right to receive the data that you have provided to us in accordance with the legal requirements in a structured, common and machine-readable format or to request that it be transmitted to another person responsible.
Complaint to the supervisory authority:   You also have the right, in accordance with the statutory provisions, to lodge a complaint with the competent supervisory authority.


Right of withdrawal:

You have the right to revoke your consent with effect for the future.

You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is based on Article 6 Paragraph 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed in order to operate direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising.


Cookies and right to object to direct advertising:

"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the content of a shopping cart in an online shop or a login status can be saved. "Permanent" or "persistent" refers to cookies that remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users can also be stored in such a cookie, which are used for range measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only their cookies, they are referred to as "first-party cookies").
I can use temporary and permanent cookies and explain this in my data protection declaration.
If I ask the user to consent to the use of cookies (e.g. as part of a cookie consent), the legal basis for this processing is Article 6 Paragraph 1 lit. GDPR. Otherwise, the user's personal cookies are processed in accordance with the following explanations within the framework of this data protection declaration on the basis of my legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. DSGVO) or if the use of cookies is necessary to provide my contract-related services, in accordance with Article 6 Paragraph 1 Letter b. DSGVO, or if the use of cookies is necessary for the performance of a task that is in the public interest or in the exercise of official authority, in accordance with Article 6 Paragraph 1 lit. GDPR, processed.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the US website or the EU website Furthermore, the storage of cookies can be achieved by switching them off in the browser settings. Please note that it may then not be possible to use all the functions of this online offer.​

Deletion of data:

The data processed by me will be deleted in accordance with the legal requirements or their processing will be restricted. Unless expressly stated in this data protection declaration, the data stored by me will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations.
If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. i.e. the data will be blocked and not processed for other purposes. This applies e.g. B. for data that must be kept for commercial or tax reasons.​

Changes and updates to the privacy policy:

I ask you to inform yourself regularly about the content of my data protection declaration. I will adapt the data protection declaration as soon as the changes in the data processing I have carried out make this necessary. I will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.​


When contacting me (e.g. via contact form, e-mail, telephone or via social media), the information provided by the user for processing the contact request and its processing in accordance with Article 6 Paragraph 1 lit. b. (in the context of contractual/pre-contractual relationships),  Art. 6 Paragraph 1 lit. f. (other requests) GDPR processed. User information can be stored in a customer relationship management system ("CRM system") or comparable inquiry organization.
I delete the requests if they are no longer necessary. I review necessity every two years; Furthermore, the statutory archiving obligations apply.

Hosting and email delivery:

The hosting services I use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services that I use to operate this online offer.
In doing so, I or my hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data from customers, interested parties and visitors to this online offer on the basis of my legitimate interests in making this online offer available efficiently and securely in accordance with Art. 6 Para. 1 lit. f GDPR i. V. m. Art. 28 GDPR (conclusion of order processing contract).

Online presence in social media​:

I maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to be able to inform them about my services there.
I would like to point out that user data can be processed outside of the European Union. This can result in risks for users, because e.g. B. the enforcement of user rights could be made more difficult. With regard to US providers who are certified under the Privacy Shield, I would like to point out that they undertake to comply with the data protection standards of the EU.
Furthermore, user data is usually processed for market research and advertising purposes. So e.g. B. from the usage behavior and the resulting interests of the user usage profiles are created. The usage profiles can in turn be used, e.g. B. to place advertisements inside and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and the interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of the personal data of the users takes place on the basis of our legitimate interests in effective information for the users and communication with the users in accordance with Article 6 Paragraph 1 lit. f GDPR. If the users are asked by the respective providers of the platforms for their consent to the data processing described above, the legal basis for the processing is Article 6 Paragraph 1 Letter a., Article 7 GDPR.
For a detailed description of the respective processing and the possibility of objection (opt-out), I refer to the following linked information from the providers.
Also in the case of requests for information and the assertion of user rights, I would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. If you still need help, you can contact me.

Facebook, pages, groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) based on an agreement on joint processing of personal data (

Privacy Policy:, specific for pages:, Opt-Out: and, Privacy Shield:
Google/YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland)

Privacy Policy:,, Privacy Shield:
Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA)

Privacy Policy/Opt-Out:
Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA)

Privacy Policy:, Opt-Out:, Privacy Shield:
Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA)

Privacy Policy/Opt-Out:
LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland)

Privacy Policy:, Opt-Out:, Privacy Shield:
Xing (XING AG, Dammtorstrasse 29-32, 20354 Hamburg, Germany)

Privacy Policy/Opt-Out:
Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom)

Privacy Policy/Opt-Out:
Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany)

Privacy Policy/Opt-Out:

Integration of third-party services and content:

I use content or service offers from third-party providers within the online offer on the basis of my legitimate interests (ie interest in the analysis, optimization and economic operation of my online offer within the meaning of Art. 6 Para. 1 lit. f. DSGVO) in order to improve their content and Services such as B. to include videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. I try to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, visiting times and other information on the use of our online offer, as well as being linked to such information from other sources._d04a07d8- 9cd1-3239-9149-20813d6c673b_

Google Maps​:

I embed the maps of the “Google Maps” service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The processed data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually as part of the settings on their mobile devices). The data can be processed in the USA.

Privacy Policy:,


Functions and content of the Instagram service offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, can be integrated into the online offer. For this z. B. Content such as images, videos or texts and buttons with which users can share content of this online offer within Instagram. If the users are members of the Instagram platform, Instagram can assign the above-mentioned content and functions to the user profiles there.

Instagram Privacy Policy:

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