We are pleased that you want to know more about our company. The management of STP Informationstechnologie GmbH accords great importance to data protection. It is generally possible to use of the internet pages of STP Informationstechnologie GmbH without providing any personal data. However, if the data subject wishes to make use of special services offered by our company via our website, it may be necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we generally obtain the consent of the data subject.
STP Informationstechnologie GmbH, as the data controller, has implemented numerous technical and organisational measures to ensure that the personal data processed via this website is protected as completely as possible. This notwithstanding, internet-based data transmissions may have security gaps, such that it is not possible to guarantee absolute protection. For this reason, every data subject is free to transmit personal data to us by alternative means, including but not limited to by telephone.
a) Personal data
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 reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
b) Data subject
Data subject means any identified or identifiable natural person whose personal data are processed by the controller.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
d) Restriction of processing
Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future
Profiling is any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, conduct, location or change of location.
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
Controller means 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller
Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients
j) Third party
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, is authorised to process personal data
Consent 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
The controller within the meaning of GDPR, other data privacy laws applicable in the Member States of the European Union and other provisions of a data privacy nature is:
STP Informationstechnologie GmbH
Phone +49 721 828 15-0
Fax +49 721 828 15-555
3. Name and address of the Data Protection Officer
The controller’s Data Protection Officer is:
STP Informationstechnologie GmbH
Phone +49 721 828 15-0
Fax +49 721 828 15-555
All data subjects can contact our Data Protection Officer directly at any time with any questions and suggestions regarding data protection.
By means of a cookie it is possible to optimise the information and offers on our website in the user’s interest. As already mentioned, cookies enable us to recognise repeated users of our website. The purpose of this recognition is to make it easier for users to use our website.
5. Collection of general data and information
STP Informationstechnologie GmbH’s website collects a range of general data and information upon each visit to the website by a data subject or an automated system. Such general data and information are stored in the server’s log files and may include (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (known as “referrer”), (4) the sub-websites of our website that are accessed via an accessing system, (5) the date and time of an access to the website, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information that serve to prevent risks in the event of attacks on our information technology systems.
In its use of such general data and information, STP Informationstechnologie GmbH does not make inferences about the data subject. Instead, this information is required to (1) deliver the content of our website correctly, (2) optimise the content of our website as well as the advertising for it, (3) ensure the permanent functionality of our information technology systems and the technology of our website as well as (4) to provide law enforcement agencies with the information necessary for prosecution in the event of a cyberattack. Such anonymously collected data and information are therefore evaluated by STP Informationstechnologie GmbH on the one hand for statistical purposes and additionally with the aim to increase data protection and data security in our company in order to ultimately ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
6. Registering on our website
The data subject has the option of registering on the website (http://stp-online.de) of the controller, which involves providing personal data. The personal data transmitted to the data controller are those entered in the respective input mask used for registration. The personal data entered by the data subject are collected and stored solely for internal use by the controller and for its own purposes. The controller may arrange for the transfer to one or more processors, such as a parcel service provider, who will likewise use the personal data exclusively for an internal use attributable to the controller.
When registering on the website of the data controller, the data subject’s IP address assigned by the internet service provider (ISP) and the date and time of registration are also saved. These data are stored as it is the only way to prevent the misuse of our services and, if necessary, to enable the clarification of any criminal offences committed. In this respect, the storage of these data is necessary to protect the data controller. These data will not be transferred to third parties unless there is a legal obligation to do so or the data are transferred for the purpose of criminal prosecution.
The registration of the data subject, with the voluntary provision of personal data, enables the controller to offer the data subject content or services that, by their very nature, can only be provided to registered users. Registered persons are free to modify the personal data provided during registration at any time or to have them completely deleted from the controller’s data set.
The controller shall on request provide any data subject with information on what personal data relating to the data subject are stored at any time. Furthermore, the controller shall correct or delete personal data at the request or instruction of the data subject unless otherwise required by law.
7. Subscribing to our newsletter
On STP Informationstechnologie GmbH’s website, users are given the opportunity to subscribe to our company’s newsletter. Which personal data are transmitted to the data controller when subscribing to the newsletter can be seen from the input mask used for this purpose.
STP Informationstechnologie GmbH informs its customers at regular intervals about the company’s offers by means of a newsletter. The data subject can only receive our company’s newsletter if (1) the data subject has a valid email address and (2) the data subject registers to receive the newsletter. For legal reasons, a double opt-in procedure is used under which a confirmation email is sent to the email address first entered by the data subject for the newsletter dispatch. The purpose of this confirmation email is to check whether the holder of the email address as the data subject has authorised the newsletter’s receipt.
During registration for the newsletter we also save the IP address assigned by the internet service provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. It is necessary to collect these data to enable tracing any (potential) subsequent misuse of a data subject’s email address, thus serving to provide legal protection for the data controller.
The personal data collected during registration for the newsletter are used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter may receive information by email if necessary for the operation of the newsletter service or for registration, as could be the case if there are changes to the newsletter service or in the event of changes in technical conditions. Personal data collected within the scope of the newsletter service will not be transferred to third parties. Data subjects may unsubscribe from our newsletter at any time. The data subject can withdraw consent to the storage of personal data given us for the newsletter dispatch at any time. A corresponding link is included in every newsletter with which the consent can be withdrawn. It is also possible at any time to unsubscribe from the newsletter mailing list directly on the website of the controller or to inform the controller by any other means.
8. Newsletter tracking
STP Informationstechnologie GmbH’s newsletters contain what are referred to as tracking pixels. A tracking pixel is a thumbnail image embedded in HTML emails to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. By means of the embedded tracking pixels, STP Informationstechnologie GmbH can recognise whether an email was opened by a data subject and which links in the email the data subject clicked on.
Such personal data collected via the tracking pixels contained in the newsletters are stored and evaluated by the data controller in order to optimise the newsletter dispatch and to adapt the content of future newsletters even better to the interests of the data subject. These personal data are not transferred to third parties. Data subjects are entitled to revoke the associated separate declaration of consent submitted via the double opt-in procedure at any time. If consent is withdrawn these personal data will be deleted by the data controller. Unsubscribing from the newsletter is automatically interpreted by STP Informationstechnologie GmbH as a withdrawal of consent.
9. Contact options via the website
Due to legal regulations, STP Informationstechnologie GmbH’s website contains information that enables making quick electronic contact with our company as well as direct communication with us, which also includes a general address for what is referred to as electronic mail (email address). When a data subject contacts the controller by email or by using a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for processing purposes or for contacting the data subject. These personal data are not transferred to third parties.
10. Blog comment functionality on website
STP Informationstechnologie GmbH offers users of the blog (http://stp-online.de) located on the data controller’s website the opportunity to leave individual comments relating to specific blog posts. A blog is a portal operated on a website that is usually publicly accessible and on which one or more people, referred to as bloggers or web-bloggers, can post articles or share their thoughts in what are referred to as blog posts. Third parties can typically post comments about the blog posts.
If a data subject leaves a comment in the blog published on this website, information on the time of the comment and the user name (pseudonym) chosen by the data subject will be stored and published in addition to the comments left by the data subject. Furthermore, the IP address assigned to the data subject by the internet service provider (ISP) is also logged. The IP address is stored for security reasons and in case the data subject violates the rights of third parties through the comment he or she posts or posts illegal content. The storage of such personal data is therefore in the interest of the data controller in order that the data controller may be exculpated in the event of any infringement of the law. These personal data collected will not be transferred to third parties, unless such a transfer is required by law or serves the legal defence of the data controller.
11. Routine deletion and blocking of personal data
The data controller processes and stores personal data relating to the data subject only for the time necessary to achieve the purpose for which the data are stored unless prescribed otherwise by the European legislator or any other laws or regulations to which the controller is subject.
If the purpose of storage ceases to apply or if a storage period prescribed by the European legislator or any other competent legislator expires, the personal data will be blocked or deleted as a matter of routine and in accordance with the statutory provisions.
12. Rights of the data subject
a) Right to confirmation
The data subject is granted by the European legislator the right to obtain confirmation from the controller as to whether personal data relating to him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may at any time contact an employee of the controller.
b) Right to information
The data subject is granted by the European legislator the right to obtain at any time and free of charge from the controller information on the personal data stored in relation to him or her and a copy thereof. In addition, the European legislator grants the data subject access to the following information:
- The purpose of the processing
- The categories of personal data processed
- The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations
- Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
- The existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
- The existence of a right to lodge a complaint with a supervisory authority
- Where the personal data are not collected from the data subject, any available information as to their source
- The existence of automated decision-making, including profiling, in accordance with Article 22 (1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject
In addition, the data subject has the right to obtain information as to whether personal data have been transferred to a third country or to an international organisation. Where this is the case, the data subject also has the right to obtain information on the appropriate safeguards in connection with the transfer.
If a data subject wishes to exercise this right to information, the data subject may at any time contact an employee of the controller.
c) Right to rectification
The data subject is granted by the European legislator the right to obtain without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right of rectification, he or she may at any time contact an employee of the controller.
d) Right to erasure (right to be forgotten)
The data subject is granted by the European legislator the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller has the obligation to erase personal data without undue delay where one of the following grounds applies and processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent on which the processing was based according to point (a) of Article 6 (1), or point (a) of Article 9 (2) GDPR and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21 (2) GDPR.
- The personal data have been unlawfully processed.
- The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8 (1) GDPR.
If one of the above-mentioned reasons applies and a data subject wishes to have personal data stored by STP Informationstechnologie GmbH erased, the data subject may contact an employee of the data controller at any time. The employee of STP Informationstechnologie GmbH will arrange for the request for erasure to be complied with immediately.
Where STP Informationstechnologie GmbH has made the personal data public and our company as controller is obliged pursuant to Article 17 (1) GDPR to erase the personal data, STP Informationstechnologie GmbH, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers which are processing the published personal data that the data subject has requested the erasure by such other controllers of any links to, or copy or replication of, those personal data to the extent that processing is not necessary. The STP Informationstechnologie GmbH employee will make all necessary arrangements in each case.
e) Right to restriction of processing
The data subject is granted by the European legislator the right to demand from the controller restriction of processing where one of the following conditions applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
- The controller no longer needs the personal data for processing purposes, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21 (1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the above-mentioned reasons applies and a data subject wishes to have the personal data stored by STP Informationstechnologie GmbH restricted, the data subject may contact an employee of the data controller at any time. The STP Informationstechnologie GmbH employee will arrange for the restriction of processing.
f) Right to data portability
The data subject is granted by the European legislator the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to point (a) of Article 6 (1) or point (a) of Article 9 (2) GDPR or on a contract pursuant to point (b) of Article 6 (1) GDPR; and the processing is carried out by automated means, unless the 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.
Furthermore, in exercising their right to data portability pursuant to Article 20 (1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may contact an employee of STP Informationstechnologie GmbH at any time.
g) Right to object
The data subject is granted by the European legislator the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6 (1) GDPR.
Where the data subject objects, STP Informationstechnologie GmbH shall no longer process the personal data unless we are able to demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Where STP Informationstechnologie GmbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. Where the data subject objects vis-à-vis STP Informationstechnologie GmbH to processing for direct marketing purposes, STP Informationstechnologie GmbH shall no longer process the personal data for such purposes.
Where STP Informationstechnologie GmbH processes personal data for scientific or historical research purposes or statistical purposes pursuant to Article 89 (1) GDPR, the data subject, on grounds relating to his or her particular situation, further has the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of STP Informationstechnologie GmbH directly or another employee. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
The data subject is granted by the European legislator the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, unless the decision (1) is necessary for entering into, or performance of, a contract between the data subject and the data controller or (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests or (3) is based on the data subject’s explicit consent.
If the decision is necessary (1) for entering into, or performance of, a contract between the data subject and the data controller or (2) is based on the data subject’s explicit consent, STP Informationstechnologie GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
If a data subject wishes to assert this right with respect to automated decisions, he or she may at any time contact an employee of the controller
i) Right to withdraw consent with regard to data privacy
The data subject is granted by the European legislator the right to withdraw his or her consent to the processing of personal data at any time. If a data subject wishes to assert this right with respect to withdrawal of consent, he or she may at any time contact an employee of the controller.
The controller collects and processes the personal data of applicants for the purpose of processing under the application procedure. Processing may also be carried out by electronic means. This is in particular the case when an applicant submits relevant application documents to the controller by electronic means, such as email or a web form available on the website. If the data controller concludes an employment contract with an applicant, the transmitted data are stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application file shall be automatically erased two months after notification of the decision to reject the application, unless erasure conflicts with any other legitimate interests of the controller. Other legitimate interests in this sense include but are not limited to a duty to provide evidence in proceedings under the German General Act on Equal Treatment (Allgemeines Gleichbehandlungsgesetz – AGG).
The data controller has integrated links to Facebook on this website. Facebook is a social network. By using such a link (not a plug-in), the data subject leaves the controller’s website and is redirected to the destination address.
A social network is a social meeting place operated on the internet, an online community, that generally allows users to communicate with each other and interact in virtual space. A social network can serve as a platform for the exchange of opinions and experiences or enable the internet community to provide personal or company-related information. Facebook enables social network users to create private profiles, upload photos and network via friend requests, among other things.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. For any data subject residing outside the USA or Canada, the data controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
The data controller has integrated the Google Analytics component (with anonymisation function) on this website. Google Analytics is a web analysis service. Web analysis refers to the compilation, collection and evaluation of data on the behaviour of visitors to websites. Among other things, a web analysis service compiles data on the internet page from which a data subject came to an internet page (so-called referrers), which sub-pages of the internet page were accessed or how often and for how long a subpage was viewed. A web analysis primarily serves a website’s optimisation and the cost-benefit analysis of internet advertising.
The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
The data controller uses the add-on “_gat._anonymizeIp” for web analysis via Google Analytics. By means of this add-on, the IP address of the internet connection of the data subject is truncated and anonymised by Google if our internet pages are accessed from a Member State of the European Union or from another state that is a party to the Agreement on the European Economic Area.
The Google Analytics component is used for the purpose of analysing visitor traffic on our website. Google uses the data and information obtained to evaluate how our website is used, among other things, to compile online reports that show us the activities on our website, and to provide other services related to the use of our website.
Google Analytics sets a cookie on the data subject’s information technology system. See above for an explanation of cookies. By setting the cookie, Google is able to analyse the use of our website. Each time one of the individual pages of this website, which is operated by the data controller and on which a Google Analytics component has been integrated, is accessed, the internet browser on the data subject’s information technology system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. By means of this technical method, Google receives knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to trace the origin of visitors and clicks and permit invoicing related commission on that basis.
The cookie is used to store personal information, such as the time of access, the location from which access was made and the frequency of visits to our website by the data subject. Every time our website is visited, this personal data, including the IP address of the internet connection used by the data subject, is transmitted to Google in the United States of America, where Google stores it. Google may pass on such personal data collected via the technical method to third parties.
The data controller has integrated links to LinkedIn on this website (no plug-in). LinkedIn is an internet-based social network that allows users to connect with current business contacts and to make new business contacts. Over 400 million registered users use LinkedIn in more than 200 countries. This makes LinkedIn currently the largest platform for business contacts and one of the most visited websites in the world.
The data controller has integrated links to Twitter on this website (no plug-in). Twitter is a multilingual publicly accessible microblogging service on which users can post and distribute what are known as tweets, i.e. short messages with a maximum of 140 characters. Everyone, including people who are not registered on Twitter, can view these short messages. The tweets are also displayed to what are referred to as the followers of the respective user. Followers are other Twitter users who follow the tweets of a user. Furthermore, with Twitter it is possible to address a wide audience using hashtags, links or retweets.
The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.
The data controller has integrated links to Xing on this website (no plug-in). Xing is an internet-based social network that allows users to connect with current business contacts and to make new business contacts. Individual users can create a personal profile on Xing. For example, companies can create company profiles or publish job offers on Xing.
The operating company of Xing is XING SE, Dammtorstrasse 30, 20354 Hamburg, Germany.
19. Legal basis of the processing
Point (a) of Article 6 I GDPR serves our company as a legal basis for processing operations in which we obtain consent for a specific processing purpose. Where it is necessary to process personal data for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the provision of a service, such processing is based on point (b) of Article 6 I GDPR. The same applies to such processing operations that are necessary to carry out pre-contractual measures, for example in cases of enquiries about our products or services. If our company is subject to a legal obligation which makes it necessary to process personal data, for example to fulfil tax obligations, the processing is based on point (c) of Article 6 I GDPR. Ultimately, processing operations could be based on point (f) of Article 6 I GDPR. Unless covered by any of the aforementioned legal bases, processing operations are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or of a third party that is not overridden by the interests, fundamental rights and freedoms of the data subject. Such processing operations are allowed in particular because they have been specifically mentioned by the European legislator. In this respect, the legislator took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47 sentence 2 GDPR).
20. Legitimate interests in the processing by the controller or a third party
If the processing of personal data is based on point (f) of Article 6 I GDPR, it is our legitimate interest to carry out our business activities in the interest of the well-being of all our employees and our shareholders.
21. Duration for which the personal data are stored
The criterion for the duration of storage of personal data is the respective legal retention period. After expiry of the period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfilment or the initiation of a contract.
22. Legal or contractual provisions on making personal data available; necessity for the conclusion of the contract; obligation of the data subject to provide personal data; possible consequences of failure to provide personal data
We hereby inform you that the provision of personal data is required by law (e.g. tax regulations) in some cases or can also result from contractual regulations (e.g. information on the contractual partner). Concluding a contract may in some cases require that a data subject provides us with personal data that we must then process. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject cannot be concluded. Before a data subject provides personal data, the data subject must contact one of our employees. Our employee shall inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract or is necessary for the conclusion of a contract, whether there is an obligation to provide the personal data and as to any consequences of failure to provide such personal data.