Privacy policy

We are pleased that you are visiting our website. The protection and security of your personal information when using our website is very important to us. We would therefore like to take this opportunity to inform you which of your personal data we collect when you visit our website and for what purposes it is used. Personal data is individual information about the personal or factual circumstances of a specific or identifiable natural person (data subject), e.g. name, address, email addresses, user behaviour. This is therefore data with which we can identify you. In addition, you will occasionally also find information on data processing processes outside of this website (e.g. video conferences or newsletters).

Person responsible for data processing

Person responsible

for the processing of personal data within the meaning of the EU General Data Protection Regulation (GDPR)

Art and Auction House Wilhelm M. Döbritz
Braubachstrasse 10-12
60311 Frankfurt am Main
0049 – (0)69 – 28 77 33

Data Protection Officer

exkulpa gmbh
Waldfeuchter Str. 266
52525 Heinsberg
Phone: 02452 / 99 33 11

General information

This privacy policy fulfils the legal requirements for transparency in the processing of personal data. This is any information relating to an identified or identifiable natural person. This includes, for example, information such as your name, age, address, telephone number, date of birth, email address, IP address or user behaviour when visiting a website. Information for which we cannot (or only with disproportionate effort) establish a connection to your person, e.g. through anonymisation, is not personal data. The processing of personal data (e.g. the collection, retrieval, use, storage or transmission) always requires a legal basis and a defined purpose.

Stored personal data will be deleted as soon as the purpose of the processing has been achieved and there are no legitimate reasons for further storage of the data. We will inform you of the specific storage periods or criteria for storage in the individual processing operations. Irrespective of this, we store your personal data in individual cases for the assertion, exercise or defence of legal claims and in the event of statutory retention obligations.

Information according to Art. 13 GDPR

This information is intended for customers, interested parties, suppliers and employees. Your personal data will be processed by us for the following purposes:

  • To fulfil our contractual obligations to you (Art. 6 para. 1 lit. b GDPR).
  • For the fulfilment of pre-contractual obligations (Art. 6 para. 1 lit. b GDPR).
  • To respond to enquiries (Art. 6 para. 1 lit. b GDPR).
  • If you have given us your consent to process your personal data for specific purposes (e.g. to receive our newsletter), the data processing takes place on the basis of your consent (Art. 6 para. 1 lit. a GDPR).
  • To fulfil legal obligations to which our company is subject (Art. 6 para. 1 lit. c GDPR).
  • Where necessary, we also process your data to safeguard our legitimate interests, in particular to assert legal claims and defend ourselves in legal disputes or to ensure IT security, to consult and exchange data with credit agencies to determine creditworthiness and default risks, for direct advertising and market research unless you have objected to the use of your data for this purpose, for measures for business management and further development of services and products, for measures to optimise products and sales, for risk management measures, for the prevention or investigation of criminal offences (Art. 6 para. 1 lit. f GDPR).

Categories of recipients of the personal data

Within our company, only those employees have access to the data who absolutely need it to fulfil their tasks (need-to-know principle). Individual processes and services are carried out by carefully selected service providers based within the EEA and commissioned in accordance with data protection regulations. If service providers commissioned by us are given access to personal data when carrying out your services, order processing contracts have been concluded with them in accordance with Art. 28 para. 3 GDPR.

Duration of data storage

The data processed by us is stored for the duration of the existence and processing of the contractual relationship and in compliance with statutory retention periods. These are in particular commercial and tax retention obligations under the German Commercial Code (HGB) and the German Fiscal Code (AO). The regular retention and documentation periods are up to ten years. If there is no contractual relationship, we only process the data for as long as required for the specific purpose.

Your rights as a data subject

As a data subject, you have the following rights vis-à-vis us with regard to your personal data:

  • Right to information about your personal data processed by us.
  • Right to rectification or erasure if they are incorrect, out of date or unlawfully collected by us.
  • Right to restriction of processing if complete erasure is not possible, e.g. because we have to comply with statutory retention obligations.
  • Right to object to the processing if the data processing is based on a balancing of interests (the so-called legitimate interest), as described above under „Purpose of the processing“. This is the case if, in particular, the processing is not necessary for the fulfilment of a contract with you. When asserting your right to object, we ask you to explain the reasons why we should not process your data as we have done.

Of course, you can also object to the processing of your personal data for advertising purposes at any time. Please send your objection to our address given in the legal notice or send us an e-mail to the address given in the legal notice.

  • Right of revocation if you have given us your consent to process your data. You can assert your revocation against our company at any time without giving reasons. To do so, please contact the address given in the legal notice.
  • In addition, you have the right to complain to a data protection supervisory authority about the processing of your personal data by our company.

If you have any questions about data protection, please send an e-mail to the address given in the legal notice.

Data processing in accordance with the Money Laundering Prevention Act

In accordance with Section 2 (1) of the German Money Laundering Prevention Act (GwG), we are obliged to comply with measures to prevent money laundering and terrorist financing. The measures prescribed by law include the identification of contractual partners (Section 11 GwG) if a certain transaction amount is exceeded. Under certain circumstances, we are also obliged to report suspicious transactions or transaction intentions (Sections 43 et seq. GwG). As part of the prescribed identification and/or reporting, we collect personal data and, if necessary, pass it on to the Financial Intelligence Unit (FIU). The legal basis for the collection and forwarding of data is Art. 6 para. 1 lit. c) GDPR in conjunction with the respective statutory provisions of the GwG. Unless other statutory provisions on recording and retention obligations provide for a longer period in individual cases, we are obliged to retain the data for five years. Once the retention period has expired, the data will be destroyed in accordance with data protection regulations without the need for a separate request to do so.


Cookies are small text files that are sent by us to the browser of your end device and stored there when you visit our website. As an alternative to the use of cookies, information can also be stored in the local storage of your browser. Some functions of our website cannot be offered without the use of cookies or local storage (technically necessary cookies). Other cookies, on the other hand, enable us to carry out various analyses so that we are able, for example, to recognise the browser you are using when you visit our website again and to transmit various information to us (non-essential cookies). With the help of cookies, we can, among other things, make our website more user-friendly and effective for you, for example by tracking your use of our website and determining your preferred settings (e.g. country and language settings). If third parties process information via cookies, they collect the information directly via your browser. Cookies do not cause any damage to your end device. They cannot execute programmes or contain viruses.

We provide information about the respective services for which we use cookies in the individual processing operations. Detailed information on the cookies used can be found in the cookie settings or in the Consent Manager of this website.

Consent with Borlabs Cookie

Our website uses Borlabs Cookie consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document them in accordance with data protection regulations. The provider is Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg (hereinafter referred to as Borlabs).

A cookie is set in your browser in order to be able to assign and document your consent or cancellation. This data is stored until you delete the cookie, ask us to delete the data or the purpose for the data processing no longer applies. Statutory retention obligations remain unaffected. This data is not passed on to the provider of Borlabs Cookie.

Details on the data processing of Borlabs Cookie can be found at

Borlabs cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c GDPR.

Your rights

Under the conditions of the statutory provisions of the General Data Protection Regulation (GDPR), you have the following rights as a data subject:

  • Information in accordance with Art. 15 GDPR about the data stored about you in the form of meaningful information on the details of the processing as well as a copy of your data;
  • Correction in accordance with Art. 16 GDPR of incorrect or incomplete data stored by us;
  • erasure pursuant to Art. 17 GDPR of the data stored by us, 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;
  • restriction of processing pursuant to Art. 18 GDPR if the accuracy of the data is contested, the processing is unlawful, we no longer need the data and you oppose the erasure of the data because you need it for the establishment, exercise or defence of legal claims or you have objected to processing pursuant to Art. 21 GDPR.
  • Data portability pursuant to Art. 20 GDPR, insofar as you have provided us with personal data on the basis of consent pursuant to Art. 6 para. 1 lit. a GDPR or on the basis of a contract pursuant to Art. 6 para. 1 lit. b GDPR and these have been processed by us using automated procedures. You will receive your data in a structured, commonly used and machine-readable format or we will transmit the data directly to another controller if this is technically feasible.
  • Objection pursuant to Art. 21 GDPR to the processing of your personal data, insofar as this is carried out on the basis of Art. 6 para. 1 lit. e, f GDPR and there are reasons for this arising from your particular situation or the objection is directed against direct advertising. The right to object does not exist if overriding, compelling legitimate grounds for the processing can be demonstrated or the processing is carried out for the establishment, exercise or defence of legal claims. If the right to object does not exist for individual processing operations, this is indicated there.
  • Revocation pursuant to Art. 7 para. 3 GDPR of your consent with effect for the future.
  • Complaint to a supervisory authority pursuant to Art. 77 GDPR if you believe that the processing of your personal data violates the GDPR. As a rule, you can contact the supervisory authority of your usual place of residence, your workplace or our company headquarters.

Data processing in detail

Below we inform you about the individual processing operations, the scope and purpose of the data processing, the legal basis, the obligation to provide your data and the respective storage period. Automated decision-making in individual cases, including profiling, does not take place.

Provision of the website

When you access and use our website, we collect the personal data that your browser automatically transmits to our server. The following information is temporarily stored in a so-called log file:

  • IP address of the requesting computer
  • Date and time of access
  • Name and URL of the retrieved file
  • Website from which the access is made (referrer URL)
  • Browser used and, if applicable, the operating system of your computer, as well as the name of your access provider

Our website is not hosted by us, but by a service provider who processes the aforementioned data on our behalf in accordance with Art. 28 GDPR for the purpose of providing the website.

The hoster is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f GDPR).

We use the following hoster:

Elgendorfer Str. 57
56410 Montabaur

Contact form

Type and scope of processing

If you send us enquiries (e.g. via contact form, e-mail or telephone), we store all the data that results from this (e.g. name, e-mail address, subject of the enquiry, etc.). We need this data to process your enquiry and to be able to answer any follow-up questions. We will not pass on this data without your consent.

Purpose and legal basis

This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your enquiry is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. Otherwise, the processing is based on our legitimate interest in the effective processing of the enquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if you have previously given it.

Storage duration

We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Contact form for applicants

Type and scope of processing

You have the opportunity to apply to us on our website (e.g. by e-mail, post or online application form).

Purpose and legal basis

We process the personal data of applicants in accordance with the legal requirements for the purpose of processing the application procedure and for the implementation of pre-contractual measures within the meaning of Art. 6 para. 1 lit. b. GDPR and § 26 BDSG according to German law (initiation of an employment relationship) and – if you have given your consent – Art. 6 para. 1 lit. a GDPR. Consent can be revoked at any time. Your personal data will only be passed on within our company to persons who are involved in processing your application.

If the application is successful, the data submitted by you will be stored in our data processing systems on the basis of § 26 BDSG and Art. 6 para. 1 lit. b GDPR for the purpose of implementing the employment relationship.

Storage duration

Your data will be stored for a period of 6 months after the end of the application process. This is usually done to fulfil legal obligations or to defend against any claims arising from legal regulations. We are then obliged to delete or anonymise your data. In this case, the data will only be available to us as so-called metadata without direct personal reference for statistical analyses (e.g. proportion of women or men in applications, number of applications per period, etc.).

If it is evident that the data will be required after the expiry of the 6-month period (e.g. due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Inclusion in the applicant pool

As part of the application process, we offer applicants the opportunity to be included in our „talent pool“ for a period of 12 months on the basis of consent within the meaning of Art. 6 para. 1 lit. a. GDPR to be included.

The application documents in the talent pool will only be processed in the context of future job advertisements and employee searches and will be destroyed after the deadline at the latest. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke this consent at any time for the future.

If you receive an offer of employment with us during the application process and accept it, we will store the personal data collected during the application process for at least the duration of the employment relationship.

Video conferencing

Data processing

We use online conferencing tools to communicate with our customers. The tools we use in detail are listed below. If you communicate with us via video or audio conference, your personal data will be collected and processed by us and the provider of the respective tool.

The tools collect the data you provide, including your email address and telephone number. They also process the duration of the conference, when you attended the conference, number of participants and other metadata.

In addition, the provider of the tool processes all technical data required to organise the conference. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

If you share content on this service, it will be stored on the provider’s servers. This includes cloud recordings, chat messages, voice messages, photos and videos that you have shared while using this service.

Please note that we do not have full control over the data processing procedures of the tools used. For more detailed information on data processing by the conference tools, please refer to the privacy policies of the tools used.

Purpose and legal basis

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 lit. b GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). If you have previously given your consent to data processing, your data will be processed solely on the basis of Art. 6 para. 1 lit. a GDPR; consent can be withdrawn at any time.

Storage duration

The data collected directly by us via the video and conference tools will be deleted from our systems as soon as you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Stored cookies remain on your end device until you delete them. Mandatory statutory retention periods remain unaffected.

We have no influence on the storage period of your data, which is stored by the operators of the conference tools for their own purposes. For details, please contact the operators of the conference tools directly.

Comply Privacy Policy Sync

Type and scope of processing

We use Comply Privacy Policy Sync to properly deliver the content of our website. Comply Privacy Policy Sync is a service provided by Hendrik Paulo Gaffo & Alexander Riegert GbR, which acts as a content delivery network (CDN) on our website.

A CDN helps to provide the content of our online offer, in particular files such as graphics or scripts, more quickly with the help of regionally or internationally distributed servers. When you access this content, you establish a connection to the servers of Hendrik Paulo Gaffo & Alexander Riegert GbR, Carl-Bremer-Ring 13, 22179 Hamburg, Germany, whereby your IP address and possibly browser data such as your user agent are transmitted. This data is processed exclusively for the above-mentioned purposes and to maintain the security and functionality of Comply Privacy Policy Sync.

Purpose and legal basis

The use of the Content Delivery Network is based on our legitimate interests, i.e. interest in the secure and efficient provision and optimisation of our online offer in accordance with Art. 6 para. 1 lit. f. GDPR. GDPR.

Storage duration

The specific storage period of the processed data cannot be influenced by us, but is determined by Hendrik Paulo Gaffo & Alexander Riegert GbR. Further information can be found in the privacy policy for Comply Privacy Policy Sync:


Type and scope of processing

This website uses the services of MailChimp to send newsletters. The provider is Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

MailChimp is a service that can be used to organise the sending of newsletters, among other things. If you enter data for the purpose of subscribing to the newsletter (e.g. email address), this data is stored on MailChimp’s servers in the USA. We have deactivated performance measurement at Mailchimp so that Mailchimp will not evaluate your behaviour when you open our newsletter.

If you do not want your data to be transferred to Mailchimp, you must unsubscribe from the newsletter. We provide a link for this purpose in every newsletter message. You can also unsubscribe from the newsletter directly on the website.

We have concluded a so-called „Data Processing Agreement“ with MailChimp, in which we oblige MailChimp to protect our customers‘ data and not to pass it on to third parties.

Purpose and legal basis

The data processing takes place on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You can revoke this consent at any time by unsubscribing from the newsletter. The legality of the data processing operations that have already taken place remains unaffected by the cancellation.

Storage duration

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

For more information, please refer to MailChimp’s privacy policy at: