3. DATA PROTECTION OFFICER (DSB) AND PERSON RESPONSIBLE FOR DATA PROTECTION

5. RAISING AWARENESS AMONG EMPLOYEES / SERVICE PROVIDERS

6. DATA PROCESSING / DATA PROCESSING PURPOSES

8. DESCRIPTION OF THE TECHNICAL-ORGANISATIONAL MEASURES (TOMS)

8.4.1. Confidentiality (Art. 32 para. 1 lit. b DS-GVO)

8.4.5. Pseudonymisation (Art. 32 para. 1 lit. a DS.-GVO; Art. 25 para. 1 DS-GVO)

8.5. Integrity (An. 32 para. 1 lit. .b DS-GVO)

9. TALENT AUTHENTICATION AND QUALITY ASSURANCE

9.1. Control measures to authenticate the actual user (talent)

11.1. Data subjects' rights: Process chains

11.2. Data breach notification: Process chain

12. CHECKLIST FOR THE ANNUAL CONTROL AND IMPROVEMENT PROCESS

This data protection concept is based on the principles formulated in Article 5(1) of the GDPR, such as purpose limitation, data minimisation, storage limitation, integrity, the right to be forgotten and confidentiality, and is lawful (Article 6 of the GDPR). The compliance with the Regulation as required by the GDPR (Art. 5(2); Art. 24(1)), the compliance with the rights of the data subjects (Art. 13-20), the obligation to report data breaches (Art. 33-34), the obligation to provide evidence and the obligation to be accountable (Art. 5(2), Art. 24(1)) is guaranteed. A control and improvement process is carried out at least once a year (Article 32, line 1), based on the checklist contained in the last chapter of this data protection concept.

We process personal data of natural persons over the age of 18 (Art 8 GDPR) in whole or in part by automated means and have our place of business in the EU:

Yoummday GmbH, Infanteriestraße 11a, House E, 80797 Munich,

3. DATA PROTECTION OFFICER (DSB) AND RESPONSIBLE FOR DATA PROTECTION

If one of the following criteria applies, an external or internal DPO is necessary and must be appointed:

Processing of the data by a public authority or a public body, with the exception of the courts
YES ( )
NO (X)

Processing of personal data processing of personal data is a core activity of the organisation and/or requires extensive regular and systematic monitoring of the person concerned.
YES (X )
NO ( )

Processing of categories of personal data requiring special protection (Art. 9(1) of the GDPR) such as z. e.g. health data, ethical background, genetic or biometric data, trade union membership, etc.) is a core activity of the organisation.
YES ( )
NO (X)

Data Protection Officer:
Björn Barthelmes Karl-Frank-Straße 35
12587 Berlin
E-mail: datenschutz@yoummday.com

Data Protection Coordinator:
Jörg Hoffmann
Phone: +49 89 230 236 03
E-mail: joerg.hoffmann@yoummday.com

Activities
- Information and training events

Organiser
- Webinars, for example at datenschutzguru.de or gruenderszene.de

It is particularly important to raise the awareness of all relevant employees, which we naturally do. Only with informed and attentive employees can security measures be implemented effectively and possible security incidents be recognised in good time.

Once the cause of a security incident has been identified, measures must be taken to address it. It is often necessary to isolate the affected IT systems or sites to contain the impact of the security incident.

The resolution of security incidents must be documented in detail.

An example of an awareness-raising/commitment to compliance with the GDPR for employees can be found in the appendix. Also in the appendix: A sample contract for commissioned data processing.

6. DATA PROCESSING/DATA PROCESSING PURPOSES

Purposes and description of the data processing operations:

1. Accounting and business processing: Processing and transmission of data within the scope of business relationships with customers, talents and suppliers, as well as third parties and business partners involved in the business processing, including their respective contact persons, including automatically generated and archived text documents (such as invoices, correspondence or contracts) in these matters.

2. Customer care and marketing: Service-oriented information and care of categorised customers, suppliers and third parties or business partners involved in the business process, including their respective contact persons and interested parties, including automatically created and archived text documents (e.g. correspondence) as well as the transmission of newsletters, form letters and information material.

3. Operation of websites: Transmission of data within the framework of the job market (company name, contact person, telephone number, website address, job description, CV, address, user name, password); Newsletter dispatch: Information to interested parties and customers on the subject of social media. Regularly updated information about new job offers

4. Website analysis: Analysis of anonymised visitor behaviour on the website for optimisation and traceability of page visits (e.g. entry and exit pages, length of stay...).

5. Contact form: Contact request via the website for interested parties and customers to answer specific enquiries / Talent area: Users can log in to the website to visit a talent area

To the extent that the DPO determines that the intended processing is subject to a data protection impact assessment, the DPO shall notify this immediately. The procedure may only be carried out after approval by the DPO. In case of doubt, the management shall decide.

8. DESCRIPTION OF THE TECHNICAL ORGANISATIONAL MEASURES (TOMS)

As the responsible body, suitable technical and organisational measures have been taken to ensure compliance with the principles of the European Data Protection Regulation. This ensures and provides evidence that the processing is carried out in accordance with the provisions of the EU Data Protection Regulation.



The following measures serve to ensure the confidentiality of the systems and serve the:

Ensuring the confidentiality of systems and services

Ensuring the integrity of systems and services

Ensuring the availability of systems and services

Ensuring the resilience of systems and services

Restoring the availability of and access to personal data after a physical and technical incident. Procedures for regular review, 

assessment, evaluation of the effectiveness of the above measures.



The technical and organisational measures to be taken are based on:

DATA PROTECTION CONCEPT

What are business and trade secrets?
What is not a secret?
What are your duties of confidentiality and return?
What are the consequences of violations?

Today you will be instructed about your duty to maintain business and trade secrets. This leaflet gives you the opportunity to read the most important information again. If you have any questions, do not hesitate to ask your supervisor.

What are business and trade secrets?
Business and trade secrets are facts, circumstances and processes related to Yoummday that are not public knowledge but are only accessible to a limited group of people and which Yoummday has a legitimate interest in not disclosing.

Business secrets relate more to commercial issues. Examples: individual business transactions, offer and contract documents, customer and supplier data, market data, market strategies, calculations, prices, conditions, balance sheets, employees, organisation.

Trade secrets tend to relate to the organisational or technical area. Examples: Design plans and ideas, recipes, control procedures and results, property and performance analyses, modes of operation, production methods, process sequences, plans for new products or modifications, developments including the intended task solution, development steps, design or programming methods.

A trade secret can also be information that a company uses a process or computer programme that is actually obvious. A trade secret is also a service invention, for example, even if you made the invention yourself and no one but you knows about it.

Before disclosing or using for your own purposes any information you have received in the course of your work at Yoummday, please check with your manager to make sure there are no objections. This also applies after your employment with Yoummday has ended.

What is not a secret?
If a fact is public, it is no longer a business or trade secret. A fact is public if it is accessible at will, for example through publication in a newspaper.

It is not sufficient for a product to be disclosed if, for example, its composition and method of manufacture can be discovered through detailed investigations and considerations. The secret may also be made known to employees without losing its character as a secret, since employees are subject to a legal duty of confidentiality. The disclosure to external persons is harmless if the need for confidentiality is explicit or arises from the circumstances. This is assumed by case law even without an agreement if, for example, another company is to carry out plans or external experts are called in. Even if a secret is betrayed, this does not necessarily eliminate the confidential character.

What confidentiality and return obligations do you have?
You may not disclose business and trade secrets to third parties during or after your employment with Yoummday. A third party is anyone to whom the secret is not accessible. This does not only apply to competitors, but also to Yoummday employees who do not know the secret, family members, etc. As an employee, you may not use business and trade secrets for your own purposes.

You may only take documents, materials, equipment, etc. containing business or trade secrets out of the company if you have the permission of your supervisor. If you work in a home or mobile office, the Home Office/Mobile Office (Teleworking) Guideline also applies to you. Other confidentiality obligations - such as your data protection confidentiality obligations - also apply.

All business documents, regardless of whether you received them from Yoummday or from third parties or whether you created them yourself, must be returned without being asked at the end of the employment relationship. You must also return or delete any notes (e.g. files) that you have created yourself. Your supervisor can also ask you to return or delete them at any time during the employment relationship.

What are the consequences of violations?
If you obtain or secure business and trade secrets without authorisation (e.g. copy a secret or write it down from memory - even if you are legally aware of the secret), communicate them to third parties or exploit them, you can be punished with up to five years' imprisonment under Section 17 UWG.

Other possible consequences are obligations to pay damages and injunctions (if necessary also against the new employer) and (during the existence of the employment relationship) dismissal with or without notice.


* The masculine form chosen here always refers to female, male and diverse persons at the same time.

NOTE ON BUSINESS AND TRADE SECRETS

The secrecy of telecommunications
Your duty to maintain the secrecy of telecommunications
Requests for information
Consequences of violations Wording of the laws

Today, you have been informed about the secrecy of telecommunications. At the same time, you will receive a briefing on the obligations that arise for you from the secrecy of telecommunications. This leaflet gives you the opportunity to read the most important information again. If you have any questions, do not hesitate to ask your supervisor or the company data protection officer.

The telecommunications secret
The secrecy of telecommunications protects not only telephones and faxes, but also modern forms of communication such as e-mail. It is therefore also called telecommunication secrecy. It is a fundamental right (Article 10 of the Basic Law - GG), which is regulated in more detail in § 88 of the Telecommunications Act (TKG) and § 206 of the Criminal Code (StGB). §§ Sections 91 ff. TKG regulate data protection in telecommunications. In special cases, the General Data Protection Regulation (DS-GVO) or, if applicable, the Federal Data Protection Act (BDSG) may also be applicable instead of the TKG.

On the one hand, the secrecy of telecommunications protects the content of the communication: What was discussed during the telephone conversation? What data was transmitted? What is in the email or chat message? And also: What is in the subject of the email?

On the other hand, the secrecy of telecommunications also protects the "closer circumstances of the telecommunication": Who telephoned or emailed with whom and when? Which internet pages were called up? Who actually tried to establish a telephone connection?

Not only Yoummday, but also you personally must observe the secrecy of telecommunications. This obligation already results from the law (§ 88 TKG,

§ 206 StGB). Your formal commitment today to the secrecy of telecommunications only serves to make clear to you how important this duty is.

The secrecy of telecommunications applies for an unlimited period of time, even if you are no longer working for us (this is expressly stated in § 88 para. 1 sentence 2 TKG; however, this also applies to § 206 StGB). It applies to all

People who are not responsible for the matter in question - i.e. also towards all other colleagues, your family and the press.

Your duty to preserve the secrecy of telecommunications
You must treat information that is subject to telecommunications secrecy with absolute confidentiality. You may not, for example, evaluate individual connection records or log files on telecommunication connections, view e-mail boxes or similar, unless this is permitted by law as an exception. The most important permission is contained in section 88, paragraph 3, sentence 1 of the TKG: If we can only provide the telecommunication service or protect our telecommunication systems if we have knowledge of certain information subject to telecommunications secrecy, we are permitted to take such knowledge. §§ Sections 96 and 97 of the Telecommunications Act allow us to store and use connection data to the extent necessary for billing purposes. For the purpose of combating interference and fraud, we are permitted to

§ 100 TKG in certain cases to use connection data. (In special cases, the DS-GVO, possibly the BDSG, may also be applicable instead of the TKG). Your supervisor will explain to you what data may be stored and used for what purpose in a specific case.

Please note that these permissions only exist to the extent that knowledge, storage or use is absolutely necessary for the respective purpose. If, for example, you have to look into a mailbox to correct a technical error, you may only do so to the extent that this cannot be avoided: If it is sufficient to evaluate the header of an email, you are not allowed to read the message text itself. Of course, you are not allowed to pass on things that are subject to the secrecy of telecommunications, even if you have obtained legal knowledge of them for administrative purposes - not even to your superior. Exception: If you accidentally learn that a serious offence mentioned in § 138 StGB is being planned.



Request for information
You may be approached by the police or other authorities and asked for certain information, for example about users or details that are subject to telecommunications secrecy. Please forward such requests immediately to the internal data protection coordinator. You yourself are not allowed to

Provide information if this is not specifically part of your job description.

If you violate the secrecy of telecommunications, you may face up to five years in prison.

§ Section 206 of the Criminal Code makes it a criminal offence (among other things) to pass on information that is subject to telecommunications secrecy. It is also a criminal offence to suppress confidential transmissions (especially e-mails) without authorisation, for example, to delete them or to withhold them for a longer period of time.

Certain violations of the TKG may also result in a fine, e.g. if data is collected or not deleted without authorisation (§ 149 TKG). Under certain circumstances, further fines and criminal offences may be considered, such as violations of data protection law (Art. 83 DS-GVO, §§ 42, 43 BDSG), betrayal of business and trade secrets (§ 17 UWG), spying on data (§ 202 a StGB), computer fraud (§ 263 a StGB).

It can cause serious damage to Yoummday if a so-called data breach becomes public knowledge. Customers lose trust and stop using our services if they cannot be sure that their data is in good hands with us. In addition, we may be obliged under the GDPR to notify all data subjects of a data breach and may also have to inform the public. Please help us to ensure that the secrecy of telecommunications is always maintained.

If damage is caused by breaches of telecommunications secrecy, we and you personally may have to pay compensation. You personally may also face consequences under labour law if you violate the secrecy of telecommunications.

Depending on the severity of the misconduct, a warning, termination with notice or even termination without notice without prior warning are conceivable.

Wording of the laws Telecommunications Act (TKG)
§ Section 88 Secrecy of telecommunications

(1) The secrecy of telecommunications shall apply to the content of telecommunications and the details thereof, in particular the fact whether a person is connected to a

telecommunications process is or was involved. The secrecy of telecommunications also extends to the detailed circumstances of unsuccessful connection attempts.

(2) Every service provider is obliged to maintain the secrecy of telecommunications. The obligation to maintain secrecy shall continue even after the end of the activity which gave rise to it.

(3) Those obliged under paragraph 2 shall be prohibited from obtaining knowledge of the content or the detailed circumstances of telecommunications for themselves or others beyond what is necessary for the provision of the telecommunications services in accordance with the business, including the protection of their technical systems. They may use knowledge of facts subject to telecommunications secrecy only for the purpose stated in sentence 1. The use of this knowledge for other purposes, in particular the disclosure to others, shall only be permissible if this Act or another statutory provision so provides and expressly refers to telecommunications processes. The obligation to report under Section 138 of the Criminal Code shall take precedence.

(4) If the telecommunications installation is on board a watercraft or aircraft, the duty to maintain secrecy does not apply to the person driving the vehicle or to his or her representative.

§ Section 206 Violation of postal or telecommunications secrecy

(1) Any person who without authorisation informs another person of facts which are subject to postal or telecommunications secrecy and which have become known to him or her as the owner or employee of an undertaking which provides postal or telecommunications services on a commercial basis shall be liable to a custodial sentence not exceeding five years or to a monetary penalty.

(2) It shall also be a punishable offence for any person who, as owner or employee of an undertaking referred to in paragraph 1, unauthorisedly

1. opens a consignment which has been entrusted to such an undertaking for transmission and which has been sealed, or obtains knowledge of its contents by technical means without opening the seal,

2. suppresses a consignment entrusted to such an undertaking for transmission; or

3. permits or encourages any of the acts referred to in paragraph 1 or in points 1 or 2.

(3) Paragraphs 1 and 2 shall also apply to persons who are

1. perform supervisory tasks over an undertaking referred to in paragraph 1,

2. are entrusted by or with the authorisation of such an undertaking with the provision of postal or telecommunications services; or

3. are entrusted with the manufacture of or work on a plant serving the operation of such an enterprise.

4. Any person who without authorisation informs another person of facts which have become known to him or her as a public official working outside the postal or telecommunications sector on the basis of an authorised or unauthorised interference with postal or telecommunications secrecy shall be liable to a custodial sentence not exceeding two years or to a monetary penalty.

5. Postal secrecy applies to the details of the postal traffic of certain persons as well as to the contents of postal items. The secrecy of telecommunications applies to the content of telecommunications and the circumstances surrounding them, in particular the fact whether someone is or was involved in a telecommunications process. The secrecy of telecommunications also extends to the details of unsuccessful attempts to make a connection.

NOTICE ON THE SECRECY OF TELECOMMUNICATIONS

What does "unfair" mean?
What is prohibited?
"Black List" (Annex to Section 3 (3) UWG)
What are the legal consequences of unfair conduct?
Annex to the instruction on the obligation not to infringe the Unfair Competition Act (UWG)

INSTRUCTION ON THE OBLIGATION NOT TO VIOLATE THE LAW AGAINST UNFAIR COMPETITION (UWG)

Employees shall be instructed not to engage in any unfair commercial activities within the scope of their telephone activity:

What does "unfair" mean?
Business acts are unfair, in particular towards consumers, and therefore unlawful, if they are capable of influencing the personal decision-making capacity in such a way that the ability to decide on the basis of information is noticeably impaired. This is intended to prevent business decisions from being brought about which the persons concerned would probably not have taken otherwise.

In this respect, the legal provisions include various rules of conduct that must be observed in all telephone contact.

What is forbidden?
The freedom of personal decision-making can be impaired by various types of telephone conduct. The most important prohibitions for business communication by telephone are described below:


Unreasonable harassment (§ 7 UWG)
Unsolicited calls for advertising purposes are considered intrusive and harassing advertising. Calls for cold calling in order to gain new customers are therefore generally prohibited due to customer trapping by harassment.

Exceptions apply only if
– a consumer has expressly declared consent before the advertising call. For this purpose, it is not sufficient if the first question asked by the caller is "Do you agree with this telephone advertising?

– in the case of traders, presumed consent is to be assumed. However, this can only be safely assumed if the call is made in connection with an existing business relationship and does not go beyond the nature of the existing business.

– the person contacted has made contact himself/herself and has expressly requested a callback on a specific matter.

Aggressive sales methods (§ 4 a UWG)
It is important not to exert any pressure or influence - either legal or psychological - on a contract decision made by telephone and to maintain a friendly tone at all times.

Blackening of competitors or commercial defamation, disparagement and disparagement (section 4 no. 1 and 2 UWG)
Competitors are to be protected from untrue factual allegations that are detrimental to business. Negative claims are only permissible if they are demonstrably true. This means that the utmost caution must be exercised in telephone contact when making negative statements about competitors. Here, the area of criminal law (e.g. defamation) can also be touched very quickly.

Misleading commercial acts pursuant to § 5 UWG
In addition, no misleading statements may be made in telephone contact which are suitable for influencing a business decision. In particular, the following are inadmissible:

– Untrue advertising statements or information about goods or services,

– true advertising statements, if they are misunderstood by the target audience,

– Advertising with self-evident statements such as: "With us you get a two-year warranty/guarantee", since the legally prescribed warranty is two years,

– incomplete or omitted information, such as concealment of the fact that the goods are second choice or a discontinued model.

Comparative advertising (Section 6 UWG)
Often, comparisons to the goods or services of the competitor or to the competitor itself are made when initiating a contract by telephone. Comparative advertising is permissible in principle, but can quickly become unlawful if it falls under the prohibition catalogue of Section 6 (2) UWG. Apart from many individual cases, the principle applies here that a comparison is only permissible if it is based on demonstrably true facts.

– Therefore, caution is advised with unique selling propositions such as: "The biggest...", "The best...", "Leading company in the sector...", "Number 1". Advertising with a

Top position is only permissible if this position can be proven on the basis of objectively verifiable criteria and the advertiser has a clear lead over his competitors with a certain consistency.

Statements that consist of a mere value judgement, such as "I personally find the product worse or better" do not constitute a factual claim and are therefore not covered by the regulations on comparative advertising.

Violation of business secrets (please refer to the separate instruction on this subject).

"Black List" (Annex to Section 3 (3) UWG)
To supplement this, the appendix to Section 3 (3) of the Unfair Competition Act (UWG) is attached in Annex 1. This so-called "black list" contains 30 explicit offences of unfair conduct which are inadmissible in any case. Even if these offences only partially affect telephone contact, it is obligatory to review them as part of the training.

What are the legal consequences of unfair conduct?
A violation of the prohibitions of conduct establishes the immorality of his actions. Contracts that come into being through immoral conduct are thus null and void according to § 138 BGB.

In particular, there is a risk of claims for injunctive relief and damages, which can also be asserted against the employer.

Violations of the prohibition of unlawful telephone advertising to consumers are also administrative offences and can be punished with a fine of up to 300,000 euros (Section 20 (2) UWG).

Under labour law, such behaviour often constitutes grounds for termination of the employment relationship with notice or, if necessary, without notice.

Annex to the instruction on the obligation not to infringe the Unfair Competition Act (UWG)

Unlawful business acts are according to the Annex to Section 3 (3) UWG:

"Adorning oneself with borrowed plumes"
1. the untruthful statement of an entrepreneur to be one of the signatories of a code of conduct;

2. the use of quality marks, quality labels or similar without the necessary authorisation; example: organic seal or "Blue Angel";

3. making an untrue statement that a code of conduct has been endorsed by a public or other body;

4. the untruthful statement that an entrepreneur, a business act carried out by him or a product or service has been confirmed, endorsed or approved by a public or private body, or the untruthful statement that the conditions for the confirmation, endorsement or approval are met. Example: "TÜF tested/certified/ state recognised/state approved/...";

"Promises you can't keep"
5. offers of goods or services at a specified price if the trader does not disclose that he has reasonable grounds for believing that he will not be able to provide or cause to be provided those goods or services or similar goods or services for a reasonable period of time and in reasonable quantities at the specified price (bait and switch offers). If the stockpiling is shorter than two days, it is up to the trader to prove the reasonableness;

"Promises you don't want to keep"
6. Offers of goods or services at a certain price if the trader then, with the intention of selling another good or service instead, performs something defective or refuses to show what he has advertised or refuses to accept orders for it or to provide the advertised service within a reasonable time;

"Putting consumers under time pressure"
7. Untruthfully stating that certain goods or services are only available generally or under certain conditions for a very limited period of time in order to induce the consumer to make an immediate commercial decision without having the time and opportunity to decide on the basis of information. Example: "Today only", "Today and then never again", or similar;

"Confronting consumers with foreign languages"
8. After-sales services in a language other than that in which the negotiations were conducted before the conclusion of the transaction, if the language originally used is not an official language of the Member State in which the trader is established; this does not apply if consumers are informed before the conclusion of the transaction that these services will be provided in a language other than the language originally used; example: After conclusion of the contract, everything only in English;

"Deceiving consumers"
9. making a false statement or creating the false impression that a product or service is marketable;

"Advertise with self-evident facts"
10. making a false statement or creating the false impression that legal rights are a special feature of the offer; example: "Two-year warranty on new goods";

"Camouflaged advertising"
11. the use of editorial content financed by the entrepreneur for the purpose of sales promotion without this connection being clearly evident from the content or the type of visual or acoustic presentation (advertising disguised as information); example: fake newspaper articles;

"Fear advertising"
12. untruthful statements about the nature and extent of a risk to the personal safety of the consumer or his family in the event that he does not purchase the offered goods or does not make use of the offered service;

"Free-riding"
13. Advertising a good or service that is similar to a competitor's good or service if this is done with the intention of deceiving as to the commercial origin of the advertised good or service;

"Snowball or pyramid schemes"
14. the introduction, operation or promotion of a sales promotion system which gives the impression that remuneration can be obtained solely or mainly through the introduction of further participants into the system (snowball or pyramid scheme);

"Untruths, exaggerations and inaccuracies".
15. making an untrue statement that the trader is about to go out of business or move premises;

16. a claim that a particular good or service will increase the chances of winning a game of chance;

17. making a false statement or creating the false impression that the consumer has already won or will win a prize or will obtain a prize or other advantage by taking a certain action, when in fact there is no such prize or advantage, or when in any case the possibility of obtaining a prize or other advantage is made dependent on the payment of a sum of money or the assumption of costs;

18. the untrue statement that a good or service can cure illnesses, dysfunctions or deformities;

19. an untruthful statement about market conditions or sources of supply in order to induce the consumer to purchase or use a good or service at less favourable conditions than the general market conditions; example: "Made in Germany", "we produce in Germany" although this is not true;

20. the offer of a competition or a prize competition, if neither the prospective. The following is not true of the prices awarded, nor of an appropriate equivalent;

21. the offer of a good or service as "free", "free of charge", "free of costs" or similar, if costs are nevertheless to be borne for this; this does not apply to costs which are unavoidable in connection with the acceptance of the offer of goods or services or for the collection or delivery of the goods or the use of the service; example: Undisclosed basic charges, handling fees or minimum purchases;

22. the transmission of advertising material accompanied by a request for payment if this conveys the false impression that the advertised goods or services have already been ordered; example: subscription fraud;

23. making a false statement or creating an inaccurate impression that the trader is a consumer or is not acting for the purposes of his business, trade, craft or profession; example: many eBay traders are to be classified as commercial because of the scale of their activity;

24. misrepresenting or creating the false impression that after-sales service is available in relation to goods or services in a Member State of the European Union other than that in which the goods are sold or the service is provided;

"Take them by surprise and build up pressure"
25. creating the impression that the consumer cannot leave certain premises without first entering into a contract;

26. in the case of a personal visit to the home, failure to comply with a request by the person visited to leave or not to return to the home, unless the visit is justified for the lawful enforcement of a contractual obligation;

"Run down consumers"
27. Measures intended to prevent the consumer from enforcing his contractual rights arising out of an insurance relationship by requiring him to produce a copy of the insurance policy when making a claim.

of documents that are not necessary to prove this claim or that letters asserting such a claim are systematically not answered;

"When children are addressed"
28. the direct invitation to children included in an advertisement to purchase the advertised goods or services themselves or to induce their parents or other adults to do so;

INFORMATION

TEACHINGS AND FACT SHEETS FOR TALENTS

Index