Privacy policy

Foreword

We, Schröder & Busse GbR, represented by retired solicitor and notary Dieter Busse, solicitor and notary Dr Dennis Eifert, solicitor Milkica Romic (hereinafter collectively referred to as “the organisation”, “we” or “us”), take the protection of your personal data seriously and would like to take this opportunity to inform you about data protection in our organisation.

The EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: “GDPR”), there are obligations to ensure the protection of personal data of the data subject affected by processing (we also refer to you as the data subject hereinafter as “customer”, “user”, “you” or “data subject”).

Insofar as we decide, either alone or jointly with others, on the purposes and means of data processing, this includes, in particular, the obligation to inform you transparently about the nature, scope, purpose, duration and legal basis of the processing (cf. Articles 13 and 14 GDPR). With this declaration (hereinafter: “data protection information”), we inform you about how we process your personal data.

A. General

1. Definitions

Based on Art. 4 GDPR, this data protection information is based on the following definitions:

“Personal data” (Art. 4 No. 1 GDPR) is any information relating to an identified or identifiable natural person (“data subject”). A person is identifiable if they can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, an online identifier, location data or by reference to information about their physical, physiological, genetic, mental, economic, cultural or social identity. Identifiability may also be established by linking such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photos, video or audio recordings may also contain personal data).
“Processing” (Art. 4 No. 2 GDPR) is any operation involving personal data, whether or not with the aid of automated (i.e. technology-based) procedures. This includes, in particular, the collection (i.e. procurement), recording, organising, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, disseminating or otherwise making available, aligning, combining, restricting, erasing or destroying personal data, as well as changing the purpose or scope of data processing originally intended.
“Controller” (Art. 4 No. 7 GDPR) is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Third party” (Art. 4 No. 10 GDPR) is any natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or processor, are authorised to process personal data; this also includes other legal entities belonging to the group.
“Processor” (Art. 4 No. 8 GDPR) is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, in particular in accordance with its instructions (e.g. IT service providers). In terms of data protection law, a processor is not a third party.
“Consent” (Art. 4 No. 11 GDPR) 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 a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the controller

We are the controller responsible for the processing of your personal data within the meaning of Art. 4 No. 7 GDPR:

Schröder & Busse GbR

Mainzer Landstraße 69 – 71
60329 Frankfurt am Main
Germany

Telephone: 069 75608750

Email: legal[at]schroederbusse.de

For further information about our organisation, please refer to the legal notice on our website.

3. Contact details of the data protection officer

Our company data protection officer is available at any time to answer any questions you may have and to act as your contact person for data protection issues. His contact details are:

R2Data GmbH
Scanbox 18556
Ehrenbergstraße 16a
10245 Berlin

datenschutz[at]r2data.de
T +49 (0)30 2332 6315 0
https://www.r2data.de

4. Legal basis for data processing

By law, any processing of personal data is prohibited in principle and is only permitted if the data processing falls under one of the following justifications:

6 (1) (a) GDPR (“Consent”): Where the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes in an informed and unambiguous manner, by means of a statement or other unequivocal affirmative action;
6(1)(b) GDPR: Where processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
6(1)(c) GDPR: Where processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a statutory retention obligation);
6(1)(d) GDPR: If processing is necessary to protect the vital interests of the data subject or another natural person;
6(1)(e) GDPR: If processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or
6 (1) (f) GDPR (“legitimate interests”): If processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which are likely to result in the protection of personal data (especially where the data subject is a child).

We indicate the applicable legal basis for each of the processing operations we carry out below. Processing may also be based on several legal bases.

General information on the legal bases for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, if special categories of data are processed in accordance with Art. 9(1) GDPR. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your end device (e.g. via device fingerprinting), data processing is also carried out on the basis of Section 25(1) TDDDG. Consent can be revoked at any time. If your data is necessary for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 (1) lit. b GDPR. Furthermore, we process your data if it is necessary to fulfil a legal obligation on the basis of Art. 6 (1) lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. The relevant legal basis in each individual case is explained in the following paragraphs of this privacy policy.

5. Data deletion and storage period

For the processing operations we carry out, we specify below how long the data is stored by us and when it is deleted or blocked. Unless an explicit storage period is specified below, your personal data will be deleted or blocked as soon as the purpose or legal basis for storage no longer applies. Your data will only be stored on our servers in the European Economic Area (EEA), subject to any transfer in accordance with the provisions set out below on “Cooperation with processors” and “Requirements for the transfer of personal data to third countries”.

However, storage may continue beyond the specified period in the event of a (threatened) legal dispute with you or other legal proceedings, or if storage is required by legal provisions to which we are subject as the controller (e.g. Section 257 of the German Commercial Code (HGB), Section 147 of the German Fiscal Code (AO)). When the storage period prescribed by law expires, the personal data will be blocked or deleted, unless further storage by us is necessary and there is a legal basis for this.

6. Data security

We use appropriate technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorised access by third parties (e.g. TSL encryption for our website), taking into account the state of the art, the implementation costs and the nature, scope, context and purpose of the processing as well as the existing risks of a data breach (including its likelihood and impact) for the data subject. Our security measures are continuously improved in line with technological developments.

7. Recipients of personal data

We work with various external parties in the course of our business activities. In some cases, this requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary for the fulfilment of a contract, if we are legally obliged to do so (e.g. disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1) lit. f GDPR, or if another legal basis permits the disclosure of data. When using processors, we only pass on our customers’ personal data on the basis of a valid contract for data processing. In the case of joint processing, a contract for joint processing is concluded.

8. Cooperation with processors

We use external domestic and foreign service providers to handle our business transactions (e.g. in the areas of IT, logistics, telecommunications and marketing). These service providers only act on our instructions and are contractually obliged to comply with data protection regulations within the meaning of Art. 28 GDPR.

If personal data about you is passed on by us to our subsidiaries or passed on to us by our subsidiaries (e.g. for advertising purposes), this is done on the basis of existing data processing agreements.

9. Conditions for the transfer of personal data to third countries

Within the scope of our business relationships, your personal data may be transferred or disclosed to third-party companies. These may also be located outside the EEA, i.e. in third countries. Such processing is carried out exclusively for the purpose of fulfilling contractual and business obligations and maintaining your business relationship with us. We will inform you of the respective details of the transfer below in the relevant sections.

The European Commission certifies that some third countries have data protection standards comparable to those of the EEA through so-called adequacy decisions (a list of these countries and a copy of the adequacy decisions are available on the European Commission’s website). In other third countries to which personal data may be transferred, however, there may not be a consistently high level of data protection due to a lack of legal provisions. Where this is the case, we ensure that data protection is adequately guaranteed. This is possible through binding corporate rules, standard contractual clauses of the European Commission for the protection of personal data, certificates or recognised codes of conduct.

10. No automated decision-making (including profiling)

We do not intend to use personal data collected from you for automated decision-making (including profiling).

11. No obligation to provide personal data

We do not make the conclusion of contracts with us dependent on you providing us with personal data in advance. As a customer, you are generally under no legal or contractual obligation to provide us with your personal data; however, we may only be able to provide certain offers to a limited extent or not at all if you do not provide the necessary data. If this should exceptionally be the case in relation to the products we offer, as presented below, you will be notified separately.

12. Your rights

You can assert your rights as a data subject with regard to your processed personal data at any time using the contact details provided in A.(2) above. As a data subject, you have the right to:

pursuant to Art. 15 GDPR, to request information about your data processed by us. In particular, you may request information about the purposes of processing, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, deletion, restriction of processing or objection, the existence of a right of appeal, the origin of your data, if it was not collected by us, and the existence of automated decision-making, including profiling and, if applicable, meaningful information about its details;
to request the immediate correction of inaccurate data or the completion of your data stored by us in accordance with Art. 16 GDPR;
to request the erasure of your data stored by us in accordance with Art. 17 GDPR, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims;
to request the restriction of the processing of your data in accordance with Art. 18 GDPR, unless the accuracy of the data is disputed by you or the processing is unlawful;
pursuant to Art. 20 GDPR, to receive your data that you have provided to us in a structured, commonly used and machine-readable format or to request its transfer to another controller (“data portability”);
pursuant to Art. 21 GDPR, to object to data collection in specific cases and to direct marketing (Art. 21 GDPR), provided that the processing is based on Art. 6(1)(e) or (f) GDPR. This is particularly the case if the processing is not necessary for the performance of a contract with you. Unless it is an objection to direct marketing, we ask you to explain the reasons why we should not process your data as we have done when exercising such an objection. In the event of your justified objection, we will examine the situation and either stop or adjust the data processing or point out to you our compelling legitimate grounds on the basis of which we will continue the processing;
In accordance with Art. 7 (3) GDPR, you may revoke your consent – i.e. your voluntary, informed and unambiguous declaration of intent, made clear by means of a statement or other unequivocal affirmative action, that you agree to the processing of the personal data concerned for one or more specific purposes – at any time, if you have given such consent. As a result, we will no longer be permitted to continue processing the data based on this consent in the future; and
pursuant to Art. 77 GDPR, to lodge a complaint with a data protection supervisory authority about the processing of your personal data in our organisation and
pursuant to Art. 79 GDPR, to obtain legal protection before the ordinary courts and labour courts, in particular if we refuse to act on the request of the data subject pursuant to Art. 12(5) GDPR.

13. Objection to advertising emails

The use of contact data published within the scope of the imprint obligation for sending unsolicited advertising and information material by third parties is hereby expressly objected to. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, for example through spam emails.

14. Changes to the data protection information

In the context of the further development of data protection law and technological or organisational changes, our data protection information is regularly reviewed at to determine whether adjustments or additions are necessary. You will be informed of any changes in particular on our website. This data protection information is current as of January 2026.

B. Visiting the websites

When you visit our websites, your personal data may be processed. When you use the websites, we may collect, store and further process the following categories of personal data:

1. Data processing, purpose and legal basis

Server log files (“log data”)

When you visit our websites, a so-called log data record (so-called server log files) is stored temporarily and anonymously on our web server. This consists of:

the page from which the page was requested (so-called referrer URL)
the name and URL of the requested page
the date and time of the request
the description of the type, language and version of the web browser used
the IP address of the requesting computer, which is shortened so that it can no longer be traced back to a specific person
the amount of data transferred
the operating system
a message indicating whether the request was successful (access status/HTTP status code)
the GMT time zone difference

The processing of log data serves statistical purposes and improves the quality of our website, in particular the stability and security of the connection (legal basis is Art. 6(1)(f) GDPR). The stored information is deleted after seven days, unless there is a justified suspicion of illegal use, which requires further investigation. It is not possible for us to identify you based on the stored information. Therefore, Articles 15 to 22 GDPR do not apply in accordance with Art. 11(2) GDPR, unless you provide further information that enables your identification.

Enquiries by email, telephone or fax

If you contact us by e-mail, telephone or fax, your enquiry, including all resulting personal data (name, enquiry), will be stored and processed by us for the purpose of processing your request.

This data is processed on the basis of Art. 6(1)(b) GDPR, provided that your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if this has been requested.

Contact form data

If you send us enquiries via the contact form, your details from the enquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We will not pass on this data without your consent.

2. Duration of data processing

Your data will only be processed until you request us to delete it, revoke your consent to its storage or as necessary to achieve the above-mentioned processing purposes; the legal bases specified in the context of the processing purposes apply here. With regard to the use and storage period of cookies, please note the points mentioned there and the cookie declaration.

Third parties employed by us will store your data on their system for as long as is necessary in connection with the provision of services for us in accordance with the respective order.

3. Transfer of personal data to third parties; legal basis

The following categories of recipients, who are usually processors, may have access to your personal data:

Service providers for the operation of our website and the processing of data stored or transmitted by the systems (e.g. for data centre services, payment processing, IT security). The legal basis for the transfer is then Art. 6 (1) (b) or (f) GDPR, unless they are processors;
Government agencies/authorities, insofar as this is necessary to fulfil a legal obligation. The legal basis for the transfer is then Art. 6 (1) (c) GDPR;
Persons employed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors or supervisory authorities). The legal basis for the transfer is then Art. 6 (1) (b) or (f) GDPR.

Furthermore, we only disclose your personal data to third parties if you have given your express consent in accordance with Art. 6 (1) (a) GDPR or if it is necessary on the basis of the contract with you in accordance with Art. 6 (1) (b) GDPR.

4. Hosting and content delivery networks (CDN)

We host the content of our website with the following providers:

webgo

The provider is webgo GmbH, Heidenkampsweg 81, 20097, Hamburg (hereinafter “webgo”). When you visit our website, webgo collects various log files, including your IP addresses.

For details, please refer to webgo’s privacy policy: https://www.webgo.de/datenschutz/.

The use of webgo is based on Art. 6 (1) lit. f GDPR. We have a legitimate interest in ensuring that our website is displayed as reliably as possible. If consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR and § 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s terminal device (e.g. for device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Order processing

We have concluded a contract for order processing (AVV) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that the personal data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.

C. Other services

NotarNow online forms

Our website has a button for online data entry, which allows you to send us data via an online form. If you use this online service from NotarNow (LegalNow GmbH, Lena-Christ-Straße 2, 82031 Grünwald), your details, including the contact details you provide there, will be automatically stored on the NotarNow servers for a short period of time for the purpose of processing your enquiry and in case of follow-up questions, and will then be forwarded to us. The data is transmitted in encrypted form using transport encryption via Secure Socket Layer (SSL/TLS).

The data is stored solely for the purpose of processing or contacting the data subject. The data will not be passed on to other third parties. The legal basis for the processing of the data is Art. 6 (1) lit. b GDPR, provided that your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective processing of enquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), if this has been requested.

The data you enter in the online form will remain with us until you request us to delete it, revoke your consent to its storage, or the purpose for data storage no longer applies (e.g. after your enquiry has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.

When using the “cache” function, your online form entries are encrypted and stored anonymously for 30 days. If the online form is not submitted to us within these 30 days, the form entries will be automatically deleted in their entirety. In this case, it is not necessary for you to request deletion.

Digital mandate acceptance via the client portal of the Federal Chamber of Notaries

For digital mandate acceptance, we use the corresponding service of the Federal Chamber of Notaries, a public-law corporation, Anton-Wilhelm-Amo-Straße 34, 10117 Berlin (“Federal Chamber of Notaries”). The Federal Chamber of Notaries offers us a modern system for accepting mandates and also gives you the opportunity to send us the necessary mandate-related information as easily as possible. The Federal Chamber of Notaries acts as a processor for us in this regard.

Depending on the form and case, a wide variety of data and information visible in the respective fields will be requested. This includes, but is not necessarily limited to: surname, first name, date of birth, address and other contact and case-specific data. Your data, including the contact details you provide there for the purpose of processing the enquiry and in the event of follow-up questions, will be stored automatically for a short period of time in the Microsoft Azure Cloud used by the Federal Chamber of Notaries and then forwarded to us.

The Federal Chamber of Notaries is obliged to maintain confidentiality with regard to the data to be processed (in accordance with Sections 69a BNotO in conjunction with 81a BNotO). The Federal Chamber of Notaries processes the data exclusively on our instructions and for the aforementioned purposes. Microsoft and the Federal Chamber of Notaries have also concluded an agreement on order processing and an obligation of confidentiality on the part of Microsoft within the meaning of Section 26a BNotO. Data relating to digital mandate acceptance is only processed by Microsoft on this basis and only within the European Economic Area. Data is transmitted in encrypted form using transport encryption via Secure Socket Layer (SSL/TLS).

Your data is collected and processed for the purposes of client processing, as was and is the case with us outside of digital client acceptance. The legal basis for the processing of your data is generally Art. 6 (1) (b) GDPR, according to which processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. The data you enter in the form will remain with us in accordance with the mandatory legal provisions, in particular retention periods. When using the “Save/share form” function, your online form entries will be encrypted and stored anonymously for 30 days. If the online form is not submitted to us within these 30 days, the form entries will be automatically deleted in their entirety. In this case, it is not necessary for you to request deletion.