Information on the processing of personal data in connection with the taking and publication of photographs and film footage


With this data protection information, we would like to inform you about the processing of your personal data by us in connection with the production and publication of photographs and film recordings and about your rights. 


1. name and contact details of the responsible person and the data protection officer 


The person responsible for the processing of personal data is 


Elliana Jensen-Abieva


50672 Köln

Telefon: +49 (0)1632427519



2. categories of personal data 


We process photo and film recordings and, where applicable, names and first names that we make and collect on various occasions: 

  1. a) Internal events attended exclusively by employees and guests of the Circular Valley Foundation

b ) Open events in which external parties also participate, e.g. actions for external parties (e.g. company presentations, information events, award ceremonies, trade fairs), If we wish to honor and/or highlight individuals, additional personal data (your first and last name) will be collected and processed in addition to the photographs and film footage. Insofar as photo or movie recordings reveal indications of your ethnic origin, religion or health (e.g. skin color, headgear, glasses), we also process these. The photos are taken in the context of the events and occasions. They are taken either by employees of the Marketing & Communications department or by external photographers who are, of course, involved in accordance with data protection law and whom we prohibit from using the photographs for their own purposes. 


3. aim and purpose of the processing of the personal data

We take photographs and film footage of various events and occasions to document our activities and information about our company. In addition, we use the photographs and film footage to report on our events and to make the content of the events accessible to a wider public: 

  1. a) Internal events 

The photographs and film footage of internal events may be published on our intranet and used in internal presentations. On request, we will also be happy to make them available to you, insofar as this is permissible under data protection law. 

  1. b) Open events

The pictures of the open events will be published if necessary:

 – on the homepage of our company 

– on the following social media channels of our company: Xing, Youtube, Facebook, Instagram, LinkedIn and Twitter 

– in flyers 

– in the annual report 

– on the intranet 

– in internal and external presentations

– Press (print) and their online editions 

– TV stations (ARD, WDR, ZDF) including the stations’ homepages and social media channels) 


4. legal basis for the processing of personal data 

The production of photographs and film recordings as well as their publication is based on the following regulations: 

  1. a) Consent

If you have given us your consent for the production and publication of photographs and films, your personal data will be processed on the basis of Art. 6 (1) a DSGVO. You can revoke your consent at any time. Consent that has been given can be revoked at any time. Please note that the revocation is only effective for the future. Processing that took place before the revocation is not affected by this (more on this below): We obtain your consent for the production of photographs and films when we produce portraits and close-ups of individuals, as well as for the production of images of children. Furthermore, we always ask for your consent – in addition to the legal permission explained below – if this is possible for us with reasonable effort. Unfortunately, this is not possible for large events. 

  1. b) Balancing of interests to protect our legitimate interests

The production and publication of overview and group shots (photo and film) of events, which do not specifically show or depict individual persons in portrait/close-up or children and which are aimed at showing only the character of the event, is in our overriding legitimate interests in documenting our activities, reporting on our activities and preserving memories. In this case, the processing of your personal data is based on Art. 6 (1) p. 1 letter f DS-GVO. According to Art. 9 (2) e DS-GVO, this also applies to indications of your ethnic origin, religion or health (e.g. skin color, headgear, glasses) resulting from the photo and film recordings. 

5. recipients of the data or categories of recipients

 Your data (photographs and film footage) will be viewed internally by the Marketing and Communications department in our company for the aforementioned purposes. We do not publish any photos or movie footage without first reviewing them. In the case of publications on the intranet, the data will be passed on to the IT department in our company. If we have used the services of external photographers, we receive the digital photo files from them. The internal route of the photographs is then as described above. If we publish photo and film recordings on social media channels, the data will be transmitted there and also processed by the operators of the social media platforms. We cannot influence how they handle your data; you can view the relevant information of these third-party providers here: 


  1. a) Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, Privacy statements:  Terms of use: there also Instagram, additionally: 


  1. b) Youtube Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland Terms of use: . Privacy Policy:
  2. c) Xing XING SE, Dammtorstraße 30, 20354 Hamburg, Germany Privacy Policy: . T&C:


  1. d) LinkedIn LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland Privacy Policy: . User Agreement:


6. duration of storage and criteria for determining the duration of storage Personal data 

(photographs and film footage) are generally stored indefinitely, as this is the only way we can achieve permanent documentation of our activities and events, also in the historical interest. Only employees of the Marketing & Communications and IT departments have access to personal data (photos and film footage).


7. data subject rights and right of appeal

 In accordance with Art. 15 DS-GVO, you have the right to receive information about the data stored about you. If incorrect personal data has been processed, you have the right to rectification in accordance with Art. 16 DSGVO. If the legal requirements are met, you can request the deletion or restriction of processing, as well as object to data processing (Art. 17, 18 and 21 DSGVO). According to Article 20 of the GDPR, you can assert the right to data portability for data that is processed automatically on the basis of your consent or a contract with you. These rights can be asserted against our company at the address stated above in the section “Name and contact details of the controller”. If you believe that data processing violates data protection law, you have the right to complain to a data protection supervisory authority of your choice (Art. 77 DS-GVO in conjunction with § 19 BDSG). This also includes the data protection supervisory authority responsible for us, which you can reach at the following contact details: State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia Kavalleriestr. 2-4, 40213 Düsseldorf, Tel: 0211/384240, telefax: 0211/38424-10, E-Mail: 


8. voluntariness or obligation to provide the data

 You do not have to allow yourself to be photographed and/or filmed by us and/or provide us with your first and last name, if applicable. You also do not have to give us your consent to take and publish photographs/film footage. If you do not wish to be photographed/filmed, please inform the photographer immediately. This will not cause you any disadvantages. If you do not want to be photographed/filmed but notice a camera pointing in your direction, please turn away. 

You also have the option of informing us at that you do not wish to be photographed/filmed.  

In addition, you can also inform us if you agree to be photographed but not to all or some forms of the specified publication. If, despite all the aforementioned measures, there are photo and/or film recordings of you and you have informed us directly at the event or afterwards about your lack of consent, we will delete these images unless there is legal permission for further processing. If you have informed us of your lack of consent for publication, we will ensure that no publication takes place. 


9. Transfer of data to a third country

Our data processing takes place in Germany and in the EU, a transfer of data to a third country or an international organization does not take place. However, a transfer of photo and film recordings to a third country outside the EU may occur if the recordings are published on a social media channel and the operator of the social media platform is located outside the EU. The parent companies of Google, Facebook, Instagram and Twitter are located in the USA, so your data may also be transferred there. Circular Valley has agreed with Google, Facebook, Instagram and Twitter that the European companies of Google, Facebook, Instagram and Twitter are responsible for fulfilling data subjects’ rights under Articles 15-20 of the GDPR with respect to personal data stored by Google, Facebook, Instagram and Twitter after joint processing. 

Information on standard contract clauses:


10. Information about your right to object according to Art. 21 DSGVO

 You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6 (1) sentence 1 letter f DS-GVO (data processing on the basis of a balance of interests). This also applies to advertising purposes based on this provision. If you object, our company will no longer process your personal data, unless our company can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the Processing serves the assertion, exercise or defense of legal claims. The objection can be made without any formalities and should preferably be addressed to the responsible person indicated in point 1.