Data Protection

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “Data”) within our online offering and the related websites, features and content, as well as external online presence, e.g. our social media profiles on. (collectively referred to as “online offer”). With regard to the terminology used, e.g. “Personal data” or their “processing”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).


Company: 21st Real Estate GmbH
Street house number: Bouchéstraße 12
Postcode, City, Country: 12435, Berlin, Germany
Commercial Register Number: HRB 174711
Managing Director: Petr Bradatsch, Dr. Nicolai Wendland
Telephone number: +49 (30) 403 676 300
E-mail address:

Data Protection Officer

Contact our Data Protection Officer via e-mail:

Types of processed data

  • Inventory data (e.g., names, addresses).
  • Contact information (e.g., e-mail, phone numbers).
  • Content data (e.g., text input, photographs, videos).
  • Contract data (e.g., contract, term, customer category).
  • Payment details (e.g., bank details, payment history).
  • Usage data (e.g., websites visited, interest in content, access times).

Processing of special categories of data (Article 9 (1) GDPR)

In principle, no special categories of data are processed unless they are sent by the users to the processing, e.g. entered in online forms.

Categories of data subjects

  • Customers / prospects / suppliers.
  • Visitors and users of the online offer.

In the following, we also refer to the persons concerned as “users”.

Purpose of processing

  • Provision of the online offer, its contents and functions.
  • Provision of contractual services, service and customer care.
  • Answering contact requests and communicating with users.
  • Marketing, advertising and market research.
  • Safety measures.

  • As of: 18.05.2018 *

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Art. 7 DSGVO, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO.

2. Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adjust the privacy policy as soon as the changes to the data processing we make require it. We will notify you as soon as the changes require your participation (eg consent) or other individual notification.

3. Security Measures

We comply with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, extent, causes and purposes of the processing, as well as the different likelihood and severity of the risk Rights and freedoms of natural persons, appropriate technical and organizational measures to ensure a level of protection appropriate to the risk. In particular, assurance of the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, security of availability, has been among the measures taken and their separation. We have also set up procedures to ensure perceptions of data subject rights, data leaching, and response to data harassment. Furthermore, we consider the protection of personal data already in the development or selection of hardware and software. Procedures are implemented according to the principle of data protection by technology design and privacy-friendly default settings (Art. 25 GDPR). The security measures involved in particular the encrypted transfer of data between your browser and our server.

4. Collaboration with processors and third parties

If, in the course of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise give them access to the data, this will only be done on the basis of a legal permit (eg if a Transferring the data to third parties, such as to payment service providers, in accordance with Article 6 (1) (b) GDPR is necessary for the performance of the contract), you have consented to a legal obligation or on the basis of our legitimate interests (eg Use of agents, webhosters, etc.).

Unless we third parties process data on the basis of a so-called " contract processing contract " This is done on the basis of Art. 28 GDPR.

5. Transfers to third countries

If we process data in a third country (ie outside of the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transfer of data Third parties, this only occurs if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. DSGVO. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (eg for the US through the Privacy Shield) or compliance with officially recognized specific contractual obligations (so-called “standard contractual clauses”).

6. Rights of data subjects

You have the right to ask for confirmation of the processing of the data in question and to provide information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.

You have accordingly. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with Article 17 of the GDPR, they have the right to demand that the data in question be immediately deleted or, alternatively, to require the processing of the data to be restricted in accordance with Art. 18 GDPR.

You have the right to demand that the data relating to you which you have provided to us be obtained in accordance with Art. 20 GDPR and to request their disclosure to other persons responsible.

You have acc. to Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.

7. Right of withdrawal

You have the right to grant consent in accordance with. Art. 7 para. 3 GDPR with effect for the future.

8. Right to object

You may object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.

9. Cookies

We use temporary and persistent cookies, i. E. small files stored on the users’ devices (explanation of the term and function, see last section of this privacy policy). In part, the cookies are used for security or to operate our online offer (e.g., for the presentation of the website) or to save the user’s decision when confirming the cookie banner. In addition, we or our technology partners use cookies for measuring reach and marketing purposes, which users are informed about in the course of the privacy policy. A general objection to the use of cookies used for online marketing purposes can be found in a variety of services, especially in the case of tracking, via the US website or the EU Page be explained. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all features of this online offer may be used.

10. Deleting data

The data processed by us will be deleted or restricted in accordance with the provisions of Articles 17 and 18 GDPR. Unless expressly stated in this privacy statement, the data we store will be deleted as soon as they are no longer required for their intended purpose and the lease does not conflict with statutory retention requirements. Unless the data are deleted because they are necessary for other and legally permissible purposes, their processing will be restricted. That the data is blocked and not processed for other purposes. This applies, for example for data held for commercial or tax law reasons.

According to legal requirements, the storage takes place in particular for 6 years in each case. & Sect; 257 (1) HGB (Handelsbüu cher, inventories, opening balance sheets, annual accounts, trade letters, accounting records, etc.) as well as for 10 years. & Sect; 147 (1) SO (books, records, management reports, accounting records, trade and business letters, documents relevant to taxation, etc.).

11. Provision of contractual services

We process inventory data (e.g., names and addresses and contact information of users), contract data (e.g., services used, names of contacts, invoice information) to fulfill our contractual obligations and services in accordance with Art. Art. 6 para. 1 lit b. DSGVO. The entries marked as mandatory in online forms are required for the conclusion of the contract.

Users of our software must create a user account. As part of the registration, the necessary mandatory information is communicated to the users. The user accounts are not public and can not be indexed by search engines. If users have terminated their user account, their data will be deleted with respect to the user account, subject to their retention being for commercial or tax law reasons according to Art. 6 para. 1 lit. c DSGVO necessary. It is the responsibility of the users to secure their data upon termination prior to the end of the contract. We are entitled to irretrievably delete all data stored by the user during the term of the contract.

As part of the registration and re-registration and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A transfer of these data to third parties is basically not, except that it is necessary for the prosecution of our claims or there is a legal obligation in accordance with this. Art. 6 para. 1 lit. c DSGVO.

Liability is granted after expiration of statutory warranty and similar obligations, the necessity of keeping the data is reviewed every three years; in the case of legal archiving obligations, the leasing takes place after its expiration (end of commercial law (6 years) and tax law (10 years) retention obligation); Information in the customer’s account remains until it has been leased.

12. Contact

When contacting us (via contact form or e-mail), the information provided by the user to process the contact request and its processing acc. Art. 6 para. 1 lit. b) DSGVO processed.

User information may be stored in our Customer Relationship Management System (“CRM System”) or equivalent request organization.

We use the CRM system Pipedrive of the supplier Pipedrive OÜ based on our legitimate interests (efficient and fast processing of user inquiries, existing customer management, new customer business), a private limited company established under the laws of the Republic of Estonia, with the address Paldiski mnt 80, Tallinn, 10617, Estonia, registered in the Estonian Commercial Register under the code 11958539, and a subsidiary of Pipedrive US. For this purpose, we have entered into a contract with Pipedrive with so-called standard contractual clauses, in which Pipedrive undertakes to process user data only in accordance with our instructions and to comply with the EU data protection standard. Pipedrive US is also certified under the Privacy Shield Agreement, providing an additional guarantee to comply with European data protection law. Privacy Statement of Pipedrive:

We will delete the requests if they are no longer required. We check the necessity every two years; Inquiries from customers who have a customer account, we store permanently and refer to the information on the customer account for the purpose of leasing. In the case of legal archiving obligations, leasing takes place after its expiration (end of commercial law (6 years) and tax law (10 years) retention obligation).

13. Collection of access data and logfiles

Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO Data on any access to the server on which this service is located (so-called server log files). Access data includes the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, user’s operating system, referrer URL (previously visited page), IP Address and the requesting provider.

Logfile information is stored for security reasons (for example, to expose abuse or fraudulent activity) for a maximum of seven days and then deleted. Data whose further storage is required for evidential purposes shall be exempted from the lease until the final occurrence of the incident.

14. Online Presences in Social Media

Based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO Onlineprivalences within social networks and platforms in order to communicate with the customers, prospects and users active there and to inform them about our services. When calling the respective networks and platforms, the business conditions and the data processing guidelines apply to their respective operators.

Unless otherwise stated in our Privacy Policy, we will process users’ data as far as they communicate with us within social networks and platforms, e.g. Contribute to our online presences or send us messages.

15. Cookies & Audience measurement

Cookies are information that is transferred from our web server or third-party web servers to the users’ web browsers and stored there for later retrieval. Cookies can be small files or other types of information storage.

We use “session cookies”, which are only stored for the duration of the current visit on our online presence (eg the storage of your login status or the language setting on the website and thus the use of our online offer at all to be able to). In a session cookie a randomly generated unique identification number is stored, a so-called session ID. In addition, a cookie contains the indication of its origin and storage period. These cookies can not save any other data. Session cookies will be deleted if you have finished using our online offer and you have e.g. log out or close the browser.

About the use of cookies in the context of pseudonymous range measurement, the users are informed in the context of this privacy policy.

If users do not want cookies stored on their computer, they will be asked to disable the 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.

You may opt for the use of cookies for metering and promotional purposes through the Network Advertising Initiative’s opt-out page ( and, in addition, the US website   (  or the European website   (

16. Google Analytics

Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), we use Google Analytics, a web analytics service provided by Google LLC (“ Google “) , Google uses cookies. The information generated by the cookie about the users’ use of the online offer is usually transmitted to and stored by Google on servers in the USA.

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide other services related to the use of this online offer and the internet usage, against us ü to provide. Pseudonymous usage profiles of the users can be created from the processed data.

We use Google Analytics to display advertisements displayed within Google and its affiliate advertising services, only those users who have shown an interest in our online offering or who have certain characteristics (eg interests in specific topics or products visited by them) Web pages) that we submit to Google (so-called " Remarketing & quot ;, or > Google Analytics Audiences “). Remarketing Audiences also seek to ensure that our ads are in line with users’ potential interest and are not offensive.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the users is abridged by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the United States and will be blacklisted.

The IP address transmitted by the user’s browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; In addition, users can prevent the collection by Google of the data generated by the cookie and related to their use of the online offer as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link : hl = en.

For more information about Google’s data usage, hiring and opt-out opportunities, please visit Google’s websites:  (  Google Data Use   Your use of our partners’ websites or apps  (      for data processing ()   manage information that Google uses to show you advertising “).

Otherwise, the personal data will be anonymised or deleted after 14 months have elapsed

17 Integration of services and content of third parties

Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), we make use of content or services offered by third-party providers in order to provide their content and services Services, such as To include videos or fonts (collectively referred to as " content "). This always presupposes that the third-party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the presentation of this content. We endeavor to use only those content whose respective providers use the IP address only for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. Through the " pixel tags " Information on how visitor traffic is evaluated on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and, among other things, technical information about the browser and operating system, referring web pages