Status: 29 July 2019
With the following data protection policy, we would like to inform you which types of your personal data (hereinafter also referred to as “data” for short) we process, for what purposes and to what extent. The data protection policy applies to all personal data we process, both in the context of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences such as our social media profiles (hereinafter collectively referred to as “online offer”).
Herr Rechtsanwalt (Solicitor) Ronald Schmidt
c/o tekit Consult Bonn GmbH
TÜV Saarland e.V. – Gruppe
Rosenstraße 2
10178 Berlin
Email address: berlin@tekit.de
The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.
Here we wish to inform you about the legal framework of the General Data Protection Regulation (GDPR), which is the basis on which we process personal data. Please note that, in addition to the GDPR regulations, the national data protection regulations in your or our country of residence and domicile may apply.
Consent (Art. 6 (1)(1)(a) GDPR) - The data subject has given his/her consent to the processing of personal data relating to him/her for one or more specific purposes.
Performance of a contract and pre-contractual enquiries (Art. 6 (1)(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject's request.
Rechtliche Verpflichtung (Art. 6 Abs. 1 S. 1 lit. c. DSGVO) - Die Verarbeitung ist zur Erfüllung einer rechtlichen Verpflichtung erforderlich, der der Verantwortliche unterliegt. Legal obligation (Art. 6 (1)(1)(c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f. DSGVO) - Die Verarbeitung ist zur Wahrung der berechtigten Interessen des Verantwortlichen oder eines Dritten erforderlich, sofern nicht die Interessen oder Grundrechte und Grundfreiheiten der betroffenen Person, die den Schutz personenbezogener Daten erfordern, überwiegen. Legitimate interests (Art. 6 (1)(1)(f) GDPR) - Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
Art. 9 (1)(1)(b) GDPR (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 (1) of the GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants in the context of the application procedure so that the controller or the data subject can exercise the rights accruing to him or her under labour law and social security and social protection law and fulfil his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2)(b) GDPR, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 (2)(c) GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 (2)(h) GDPR. In the case of a communication of specific categories of data based on voluntary consent, their processing is based on Art. 9 (2)(a) GDPR. In the case of processing of applicant data in Germany, §§ 22, 26 of the German Federal Data Protection Act (BDSG) specifically apply).
National data protection regulations in Germany: in addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. These include, in particular, the German Federal Data Protection Act (Bundesdatenschutzgesetz - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, processing of specific categories of personal data, processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.
We take appropriate technical and organisational measures to ensure an appropriate level of risk protection in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, entry into, disclosure of, guaranteed availability of and separation of the data. We also have procedures in place to ensure that data subjects’ rights can be exercised, that data can be deleted and that any compromise to data security is dealt with. Furthermore, we take the protection of personal data into account in the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
In the course of our processing of personal data, it may happen that data are transferred or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of these data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within our group of companies: We may transfer personal data to other companies within our group of companies or grant them access to these data. Insofar as this transfer is for administrative purposes, the transfer of the data is based on our legitimate corporate and business interests or takes place if is necessary for the fulfilment of our contract-related obligations or if the consent of the data subjects or a legal permission exists.
Datenübermittlung innerhalb der Organisation: Wir können personenbezogene Daten an andere Stellen innerhalb unserer Organisation übermitteln oder ihnen den Zugriff auf diese Daten gewähren. Sofern diese Weitergabe zu administrativen Zwecken erfolgt, beruht die Weitergabe der Daten auf unseren berechtigten unternehmerischen und betriebswirtschaftlichen Interessen oder erfolgt, sofern sie Erfüllung unserer vertragsbezogenen Verpflichtungen erforderlich ist oder wenn eine Einwilligung der Betroffenen oder eine gesetzliche Erlaubnis vorliegt. Transfer of data within the organisation: We may transfer or provide access to personal data to other entities within our organisation. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate corporate and business interests or is made where it is necessary for the performance of our contract-related obligations or where consent from the data subjects or legal permission has been granted.
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or data processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, which includes US processors certified under the “Privacy Shield”, or on the basis of special guarantees, such as contractual obligation through the EU Commission’s “standard contractual clauses”, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).
Als "Cookies“ werden kleine Dateien bezeichnet, die auf Geräten der Nutzer gespeichert werden. Mittels Cookies können unterschiedliche Angaben gespeichert werden. Zu den Angaben können z.B. die Spracheinstellungen auf einer Webseite, der Login-Status, ein Warenkorb oder die Stelle, an der ein Video geschaut wurde, gehören. “Cookies” are small files that are stored on users’ devices. Cookies can be used to store different types of information. The information can include, for example, the language settings on a website, a login status, a shopping cart or the place where a video was watched.
Cookies are usually also used when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking users’ potential interests. “Cookies” also include other technologies that fulfil the same functions as cookies (e.g. when user details are stored using pseudonymous online identifiers, also known as “user IDs”).
Insofar as we use cookies or “tracking” technologies, we will inform you separately in our data protection policy.
Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies are processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or if the use of cookies is necessary to fulfil our contractual obligations.
Revocation and objection (opt-out): Regardless of whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”).
Firstly, you can declare your objection by changing your browser settings, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online offer).
An objection to the use of cookies for online marketing purposes can be declared by means of a variety of services, especially in the case of tracking, via the US-American site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ or generally on http://optout.aboutads.info.
Processing of cookie data on the basis of consent: before we process or have data processed in the context of the use of cookies, we ask users for consent that can be revoked at any time. Before consent has been given, cookies are only used if they are necessary for the operation of our online offer. Their use is based on our interest and the interest of users in the expected functionality of our online offer.
Types of data processed: usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
Data subjects: users (website visitors, users of online services).
Legal basis: Consent (Art. 6(1)(1)(a) GDPR), Legitimate Interests (Art. 6 (1)(1)(f)).
We process the data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual (or pre-contractual) partners, e.g. to answer enquiries.
We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as the entrepreneurial organisation. We only pass on contractual partners’ data to third parties within the framework of the applicable law, to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection policy.
We inform contractual partners about which data are required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of legal warranty and comparable obligations, i.e. generally after four years, unless the data are stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes this is generally ten years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, in principle after the end of the order.
If we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Offer of software and platform services: we process the data of our users, registered users and any test users (hereinafter uniformly referred to as “users”) in order to be able to provide our contractual services to them and on the basis of legitimate interests in order to be able to guarantee the security of our offer and to be able to develop it further. The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations.
Further information on commercial services: we process the data of our customers and clients (hereinafter uniformly referred to as “customers”) in order to enable them to select, purchase or commission the selected services or works and associated activities as well as their payment and delivery or execution or performance.
The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations.
Types of data processed: basic data (names, addresses, etc.), payment data (bank details, invoices, payment history), contact data (email, telephone numbers), contract data (subject matter of contract, term, customer category).
Data subjects: interested parties, business and contractual partners.
Purposes of processing: contractual performance and service, contact requests and communication, office and organisational procedures, administration and response to requests.
Legal basis: contractual performance and pre-contractual enquiries (Art. 6 (1)(1)(b) GDPR), legal obligation (Art. 6 (1)(1)(c) GDPR), legitimate interests (Art. 6 (1)(1)(f) GDPR).
When contacting us (e.g. via contact form, email, telephone or via social media), the information provided by the inquiring person is processed to the extent necessary to respond to the contact requests and take any actions requested.
Responding to contact requests in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre)contractual requests and otherwise on the basis of the legitimate interests in responding to the requests.
Chat function: for the purpose of communication and answering enquiries, we offer a chat function within our online offer. Users’ entries within the chat are processed in order to answer their enquiries.
Types of data processed: basic data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text entries, photographs, videos), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
Data subjects: communication partners, interested parties.
Purposes of processing: contact requests and communication, managing and responding to requests.
Legal basis: contract performance and pre-contractual enquiries (Art. 6 (1)(1)(b) GDPR), legitimate Interests (Art. 6 (1)(1)(f) GDPR).
We use messenger services for communication purposes and therefore ask you to take note of the following information on the functionality of the messenger, on encryption, on the use of the metadata of the communication and on your objection options.
You can also contact us by alternative means, e.g. via telephone or email. Please use the contact options provided to you or the contact options provided within our online offer.
For end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure that the message content is encrypted.
However, we would also like to point out to our communication partners that although the messenger providers cannot view the content, they can find out if and when communication partners communicate with us, as well as technical information on the device used by the communication partners and, depending on the settings of their device, location information (“metadata”) is also processed.
Note on legal bases: if we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use messenger in relation to our contractual partners as well as in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communicating via messengers. Furthermore, we would like to point out that when your data are first provided to us we do not pass these onto the messengers without your consent.
Revocation, objection and deletion: You can revoke consent given and object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion guidelines (i.e. e.g. as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.
Reservation of reference to other communication channels: finally, we would like to point out that, for your security, we reserve the right not to answer enquiries via messenger. We may do this, for example, if contractual internals require special confidentiality or an answer via messenger does not meet formal requirements. In such cases we will refer you to more adequate communication channels.
Skype: the end-to-end encryption of Skype requires activation (if it is not activated by default).
Types of data processed: contact data (email, telephone numbers), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses), content data (text input, photographs, videos).
Data subjects: communication partners.
Purposes of processing: contact requests and communication, direct marketing (by email or post).
Legal basis: consent (Art. 6 (1)(1)(a) GDPR), legitimate interests (Art. 6 (1)(1)(f) GDPR).
Services used and service providers:
Facebook Messenger: Facebook Messenger with end-to-end encryption (Facebook Messenger’s end-to-end encryption requires activation if it is not activated by default); Service provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Data Protection Policy: https://www.facebook.com/about/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-Out: https://www.facebook.com/settings?tab=ads.
Microsoft Teams: Microsoft Teams - Messenger; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: https://products.office.com; Data protection policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active.
Skype: Skype Messenger with end-to-end encryption; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; website: https://www.skype.com/de/; data protection policy: https://privacy.microsoft.com/de-de/privacystatement, security information: https://www.microsoft.com/de-de/trustcenter; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active.
Snapchat: Snapchat Messenger with end-to-end encryption; service provider: Snap Inc, 63 Market Street Venice, CA 90291 USA; Website: https://www.snapchat.com/l/de-de/; Data protection policy: https://www.snap.com/de-DE/privacy/privacy-policy/; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TNPxAAO&status=Active.
Telegram Broadcasts: Telegram Broadcasts - Messenger with end-to-end encryption; Service provider: Telegram, Dubai; website: https://telegram.org/; data protection policy: https://telegram.org/privacy.
WhatsApp: WhatsApp Messenger with end-to-end encryption; service provider: WhatsApp Inc. WhatsApp Legal 1601 Willow Road Menlo Park, California 94025, USA; Website: https://www.whatsapp.com/; Data protection policy: https://www.whatsapp.com/legal; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TSnwAAG&status=Active.
We use platforms and applications from other providers (hereinafter referred to as “third party providers”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting the third-party providers and their services, we observe the legal requirements.
In this context, communication participants’ data are processed and stored on the third-party providers’ servers, insofar as these data are part of communication processes with us. These data may include, in particular, registration and contact data, visual and vocal contributions as well as entries in chats and shared screen contents.
Where users are referred to third-party providers or their software or platforms in the course of communications, business or other dealings with us, the third-party providers may process usage data and metadata for security, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
Note on legal bases: if we ask users for their consent to involve third-party providers, the legal basis for the processing is consent. Furthermore, their involvement may be a component of our (pre-)contractual services, provided that the involvement of the third-party providers was agreed within this framework. Otherwise, user data are processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this data protection policy.
Types of data processed: basic data (names, addresses etc.), contact data (email, telephone numbers), content data (text entries, photographs, videos), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
Data subjects: communication partners, users (website visitors, users of online services).
Purposes of processing: contractual performance and service, contact requests and communication, office and organisational procedures.
Legal grounds: consent (Art. 6 (1)(1)(a) GDPR), contractual performance and pre-contractual enquiries (Art. 6 (1)(1)(b) GDPR), legitimate interests (Art. 6 (1)(1)(f) GDPR).
Services used and service providers:
Microsoft Teams: messenger and conferencing software; service providers: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: https://products.office.com/en-EN/microsoft-teams/group-chat-software; Data protection policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active.
Skype: messenger and conferencing software; service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: https://www.skype.com/de/; Data protection policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active.
In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed as part of the provision of the hosting service may include all information relating to the users of our online service that accrues over the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
Email dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of emails. For these purposes, the addresses of the recipients and senders as well as further information regarding the email dispatch (e.g. the providers involved) and the contents of the respective emails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that emails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but (unless an end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the emails between the sender and the reception by our server.
Collection of access data and log files: we ourselves (or our web hosting provider) collect data on every access to the server (called “server log files”). The server log files may include the addresses and names of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files may be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks – “DDoS attacks”) and to ensure the capacity and stability of the servers.
Content delivery network: We use a “content delivery network” (CDN). A CDN is a service that helps the content of an online offer, in particular large media files such as graphics or programme scripts, to be delivered more quickly and securely using regionally distributed servers that are connected via the Internet.
Types of data processed: content data (text input, photographs, videos), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
Data subjects: users (website visitors, users of online services).
Purposes of processing: content delivery network (CDN).
Legal grounds: legitimate interests (Art. 6 (1)(1)(f) GDPR).
Services used and service providers:
Amazon Web Services (AWS): web hosting and infrastructural services; service provider: Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA; Website: https://aws.amazon.com/de/; Data protection policy: https://aws.amazon.com/de/privacy/?nc1=f_pr; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TOWQAA4&status=Active.
Our application procedure requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the details provided there.
In principle, the required information includes personal information such as name, address, contact details and proof of the qualifications required for a position. Upon request, we will gladly provide additional information about which details are required.
If an online form is provided, applicants can submit their applications to us using this. The data are transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by email. Please note, however, that emails sent via the Internet are generally not encrypted. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received. We cannot, therefore, assume any responsibility for the transmission path of the application between the sender and the reception by our server.
For the purposes of candidate search, submission of applications and selection of applicants, we may use third party applicant management or recruitment software and platforms and services, subject to legal requirements.
Applicants are welcome to contact us regarding the method of application submission or to send us the application by post.
Processing of specific categories of data: if specific categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants in the context of the application procedure in order to enable the controller or the data subject to exercise the rights accruing to him or her under labour law and social security and social protection law, and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2)(b) GDPR, for the protection of the vital interests of the applicants or other persons pursuant to Art. 9 (2)(c) GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, for care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9(2)(h) GDPR. If, based on voluntary consent, these specific categories of data are communicated, their processing is based on Art. 9 (2)(a) GDPR.
Deletion of data: data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion will take place, subject to a justified withdrawal by the applicants, at the latest after the expiry of a period of six months to enable us to answer any follow-up questions about the application and to comply with our obligations to provide evidence under the regulations on the equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.
Inclusion in an applicant pool: inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, that their consent has no influence on the current application process and that they can revoke their consent at any time for the future.
Types of data processed: applicant data (personal details, postal and contact addresses and the documents belonging to the application and the information contained therein, e.g. covering letter, CV, certificates and other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
Data subjects: applicants.
Purposes of processing: application procedure (establishment and possible later implementation as well as possible later termination of the employment relationship).
Legal basis: Art. 9 (1)(1)(b) GDPR (application procedure as a pre-contractual or contractual relationship) (Insofar as specific categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data, e.g. severe disability or ethnic origin) are requested from applicants in order for the data controller or the data subject to exercise the rights accruing to him or her under employment law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2)(b) GDPR, for the protection of vital interests of the applicants or other persons according to Art. 9(2)(c) GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 (2)(h) GDPR. If, based on voluntary consent, these specific categories of data are communicated, their processing is based on Art. 9 (2)(a) GDPR. If applicant data are processed in Germany specifically, §§ 22, 26 BDSG also apply.)
Services used and service providers:
Xing: Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.com; Data protection policy: https://privacy.xing.com/de/datenschutzerklaerung.
We use software services that are accessible via the Internet and run on the servers of their providers (called “cloud services”, also referred to as “software as a service”) for the following purposes: storing and managing documents; managing calendars; sending emails, spreadsheets and presentations; exchanging documents, content and information with specific recipients; publishing web pages, forms or other content and information; and chats and participation in audio and video conferences.
In this context, personal data may be processed and stored on the servers of the providers to the extent that these are part of communication processes with us or are otherwise processed by us as set out in the context of this data protection policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimisation.
If we use cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on the users’ devices for the purpose of web analysis or to remember the users’ settings (e.g. in the case of media control).
Note on legal bases: where we ask for consent to use cloud services, the legal basis for processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, user data are processed on the basis of our legitimate interests (i.e. interest in efficient and secure management and collaboration processes).
Types of data processed: basic data (names, addresses, etc.), contact data (email, telephone numbers), content data (text entries, photographs, videos), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
Data subjects: customers, employees (staff, applicants, former staff), interested parties, communication partners.
Purposes of processing: office and organisational procedures.
Legal grounds: consent (Art. 6 (1)(1)(a) GDPR), contract performance and pre-contractual enquiries (Art. 6 (1)(1)(b) GDPR), legitimate interests (Art. 6 (1)(1)(f) GDPR).
Services used and service providers:
Microsoft OneDrive: cloud storage services (e.g. Office 365); service providers: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: http://microsoft.com/de-de; Data protection policy: https://privacy.microsoft.com/de-de/privacystatement, Security notices: https://www.microsoft.com/de-de/trustcenter; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active.
We only send newsletters, emails and other electronic notifications (hereinafter “newsletters”) with the consent of the recipients or with legal permission. If, when a user is registering for a newsletter, its contents are specifically outlined, they are relevant for the consent of the users. In addition, our newsletters contain information about our services and us.
In order to subscribe to our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further details if these are necessary for the purposes of the newsletter.
Double opt-in procedure: registration for our newsletter is always carried out as a “double opt-in procedure”. This means that after registration you will receive an email in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other people’s email addresses. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.
Deletion and restriction of processing: we may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent previously given. The processing of these data will be limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. If there is an obligation to permanently observe objections, we reserve the right to store the email address in a blacklist for this sole purpose.
The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.
Note on legal bases: the newsletter is sent on the basis of the recipients’ consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. if there is existing customer advertising. Insofar as we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.
Content: information about us, our services, promotions and offers.
Performance measurement: the newsletters contain a “web beacon”, i.e. a pixel-sized file that is retrieved from our server or, if we use a shipping service provider, from their server when the newsletter is opened. Within the scope of this retrieval, technical information is initially collected such as information on the browser and your system, as well as your IP address and the time of the retrieval.
This information serves to further the technical improvement of our newsletter, using technical data or target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. Rather, the evaluations allow us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves both our business interests and meets the expectations of the users.
Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled, or it must be revoked.
Types of data processed: basic data (names, addresses, etc.), contact data (email, telephone numbers), meta/communication data (device information, IP addresses), usage data (websites visited, interest in content, access times).
Data subjects: Communication partners.
Purposes of processing: direct marketing (by email or post).
Legal basis: consent (Art. 6 (1)(1)(a) GDPR), legitimate interests (Art. 6 (1)(1)(f) GDPR).
Opt-out: you can choose to stop receiving our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably email, for this purpose.
Services used and service providers:
Newsletter2Go: email marketing platform; service provider: Newsletter2Go GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Website: https://www.newsletter2go.com; Data protection policy: https://www.newsletter2go.de/datenschutz/.
Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. We may use reach analysis to, for example, determine what time our online offer or its functions or content are most frequently visited or revisited. Likewise, we can understand which areas need optimisation.
In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offer or its components.
For these purposes, user profiles may be created and stored in a file (“cookie”) or similar procedures may be used with the same purpose. This information may include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms are used instead. This means that neither we nor the software providers have access to the actual identity of the users, but only to the information stored in their profiles for the purpose of the respective procedures.
Note on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, users’ data are processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this data protection policy.
Types of data processed: usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses), contact data (email, telephone numbers), content data (text input, photographs, videos).
Data subjects: users (website visitors, users of online services).
Purposes of processing: reach measurement (access statistics, recognition of returning visitors), tracking (interest/behavioural profiling, cookies), conversion tracking, profiling (creating profiles of users), remarketing, interest-based and behavioural marketing, feedback (collecting feedback, e.g. via form), server monitoring and error detection.
Security measures: IP masking (pseudonymisation of the IP address).
Legal basis: consent (Art. 6 (1)(1)(a) GDPR); legitimate interests (Art. 6 (1)(1)(f) GDPR).
Services used and service providers:
Adobe Analytics: Adobe Analytics; Service provider: Adobe Systems Software Ireland Companies, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Ireland, Parent Company: ; Website: https://www.adobe.com/de/analytics/adobe-analytics.html; Data protection policy: https://www.adobe.com/de/privacy.html; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TNo9AAG&status=Active; Opt-Out: https://www.adobe.com/privacy/marketing.html#online-advertising.
Amazon Personalize: Amazon Personalize is a machine learning service that makes it easier for developers to create individualised recommendations for customers using their apps; service provider: Amazon Europe Core S.à.r.l., Amazon EU S.à.r.l, Amazon Services Europe S.à.r.l. and Amazon Media EU S.à.r.l., all four located at 38, avenue John F. Kennedy, L-1855 Luxembourg, and Amazon Instant Video Germany GmbH, Domagkstr. 28, 80807 Munich, Germany (collectively \"Amazon Europe\"), parent company: Amazon.com, Inc., 2021 Seventh Ave, Seattle, Washington 98121, USA; Website: https://aws.amazon.com/de/personalize/; Data protection policy: https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TOWQAA4&status=Active.
Firebase: Google Firebase is a platform for developers of applications ("apps" for short) for mobile devices and websites. Google Firebase offers a variety of functions for testing apps, monitoring their functionality and optimising them (which are presented on the following overview page: https://firebase.google.com/products). The functions include, among other things, the storage of apps including personal data of the app users, such as content created by them or information regarding their interaction with the apps (this is called “cloud computing”). Google Firebase also provides interfaces that allow interaction between app users and other services, e.g. authentication via services such as Facebook, Twitter or via an email password combination. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://firebase.google.com; Data protection policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out: Opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https://adssettings.google.com/authenticated.
Mixpanel: Various tools, including machine learning based tools, used to analyse user behaviour, develop and improve services, applications and websites, usability, provide contractual services, support customers and communicate with customers, and web analytics. Service Provider: Mixpanel, Inc, 405 Howard Street, Floor 2, San Francisco, CA 94105, USA; Website: https://mixpanel.com/; Data protection policy: https://mixpanel.com/legal/privacy-policy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TOacAAG&status=Active; Opt-Out: https://mixpanel.com/legal/privacy-overview.
We process personal data for online marketing purposes, which include in particular the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of its effectiveness.
For these purposes, user profiles are created and stored in a file (“cookie”) or similar procedures are used, by means of which information about the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, information about communication partners and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed.
The IP addresses of users are also stored. However, we use IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of the users (such as e-mail addresses or names) are stored within the scope of the online marketing procedure, but pseudonyms. This means that neither we nor the providers of the online marketing procedures have access to the actual identity of the users, but only to the information stored in their profiles.
The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analysed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.
Exceptionally, clear data can be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use, and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the providers, e.g. by giving their consent as part of the registration process.
In principle, we only receive access to summarised information about the success of our advertisements. However, within the framework of conversion measurement we can check which of our online marketing procedures have led to a “conversion”, i.e. for example, to the conclusion of a contract with us. Conversion measurement is used solely to analyse the success of our marketing measures.
Note on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users’ data are processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this data protection policy.
Facebook pixel: using the Facebook pixel it is possible for Facebook to establish visitors to our online offer as a target group for the display of advertisements (“Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the websites visited) that we transmit to Facebook (“Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of the users and do not have a harassing effect. Furthermore, we can use the Facebook pixel to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (this is called “conversion measurement”).
Advanced matching for the Facebook pixel: when using the Facebook pixel, the additional function “advanced matching” is used. In this context, data such as email addresses or Facebook IDs of the users are transmitted (encrypted) to Facebook to form target groups.
Types of data processed: usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses), location data, social data (data that is subject to social secrecy (§ 35 SGB I) and is processed, for example, by social insurance agencies, social welfare agencies or pension authorities).
Data subjects: users (website visitors, users of online services), interested parties, customers, employees (staff, applicants, former staff), communication partners.
Purposes of processing: tracking (interest/behavioural profiling, cookies), remarketing, visit action evaluation, interest-based and behavioural marketing, profiling (creating profiles of users), conversion measurement (measuring the effectiveness of marketing measures), reach measurement (access statistics, recognition of returning visitors), cross-device tracking (cross-device processing of user data for marketing purposes), targeting (determining relevant target groups for marketing purposes or other content output), click tracking.
Security measures: IP masking (pseudonymisation of the IP address).
Legal basis: consent (Art. 6 (1)(1)(a) GDPR; legitimate interests (Art. 6(1)(1)(f) GDPR).
Opt-out option: we refer to the data protection information of the respective providers and the opt-out options given for the providers ("opt-out"). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-territory: http://optout.aboutads.info.
Services used and service providers:
Google Analytics: online marketing and web analytics; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Data protection policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out: Opt-out plugin: http://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https://adssettings.google.com/authenticated.
Facebook pixel: Facebook Pixel; service provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Data protection policy: https://www.facebook.com/about/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-Out: https://www.facebook.com/settings?tab=ads.
We maintain online presences within social networks in order to communicate with users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users’ rights. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we point out that they thereby undertake to comply with EU data protection standards.
Furthermore, user data are usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of and logged into the respective platforms).
For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Types of data processed: basic data (names, addresses, etc.), contact data (email, telephone numbers), content data (text entries, photographs, videos), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
Data subjects: users (website visitors, users of online services) and haters.
Purposes of processing: contact requests and communication, tracking (interest/behavioural profiling, cookies), remarketing, reach measurement (access statistics, recognition of returning visitors).
Legal basis: legitimate interests (Art. 6 (1)(1)(f) GDPR).
Services used and service providers:
Instagram: Social network; service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Data protection policy: http://instagram.com/about/legal/privacy.
Facebook: Social network; service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Data protection declaration: https://www.facebook.com/about/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-out option: Settings for advertisements: https://www.facebook.com/settings?tab=ads; Additional information on data protection: Agreement on joint processing of personal data on Facebook pages: https://www.facebook.com/legal/terms/page_controller_addendum, Data protection information for Facebook pages: https://www.facebook.com/legal/terms/information_about_page_insights_data.
LinkedIn: Social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Data protection policy: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Twitter: Social network; service provider: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Data protection policy: https://twitter.com/de/privacy, (settings) https://twitter.com/personalization; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
YouTube: Social network; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Data protection policy: https://policies.google.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out: https://adssettings.google.com/authenticated.
Xing: Social network; service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; website: https://www.xing.de; data protection policy: https://privacy.xing.com/de/datenschutzerklaerung.
We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). Examples of these are graphics, videos or social media buttons and posts (hereinafter uniformly referred to as “content”).
The integration always requires third-party content providers to process the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is thus required for the display of this content or function. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.
Note on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users’ data are processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this data protection policy.
Types of data processed: usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses), contact data (email, telephone numbers), content data (text input, photographs, videos).
Data subjects: users (website visitors, users of online services), communication partners.
Purposes of processing: provision of our online offer and user-friendliness, contractual performance and service, contact requests and communication, direct marketing (by email or post), tracking (interest/behavioural profiling, cookies), interest-based and behavioural marketing, profiling (creating profiles of users).
Legal basis: legitimate interests (Art. 6 (1)(1)(f) GDPR); consent (Art. 6 (1)(1)(a) GDPR).
Services used and service providers:
Facebook Social Plugins: Facebook Social Plugins - this may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/; Service provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Data protection policy: https://www.facebook.com/about/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active; Opt-Out: Settings for advertisements: https://www.facebook.com/settings?tab=ads.
LinkedIn plugins and buttons: LinkedIn plugins and buttons - This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within LinkedIn. Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.instagram.com; Data protection policy: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
We use services, platforms and software of other providers (hereinafter referred to as “third-party providers”) for the purposes of organisation, administration, planning and provision of our services. When selecting the third-party providers and their services, we observe the legal requirements.
In this context, personal data may be processed and stored on the servers of the third-party providers. This may involve various data which we process in accordance with this data protection declaration. This data may include, in particular, master data and users’ contact data, data on transactions, contracts, other processes and their contents.
If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
Note on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers was agreed within this framework. Otherwise, user data are processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this data protection policy.
Types of data processed: basic data (names, addresses, etc.), contact data (email, telephone numbers), content data (text entries, photographs, videos), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
Data subjects: communication partners, users (website visitors, users of online services).
Legal basis: consent (Art. 6 (1)(1)(a) GDPR); contract performance and pre-contractual requests (Art. 6 (1)(1)(b) GDPR), legitimate interests (Art. 6 (1)(1)(f) GDPR).
Services used and service providers:
Jira: web application for error management, problem handling and operational project management; service provider: Atlassian Inc. (San Francisco, Harrison Street Location), 1098 Harrison Street, San Francisco, California 94103, USA; Website: https://www.atlassian.com/software/confluence; Data protection policy: https://www.atlassian.com/legal/privacy-policy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt00000008RdQAAU&status=Active.
Trello: Project management tool; service provider: Trello Inc, 55 Broadway New York, NY 10006, USA; parent company: Atlassian Inc. (San Francisco, Harrison Street Location), 1098 Harrison Street, San Francisco, California 94103, USA; website: https://trello.com/; data protection declaration: https://trello.com/privacy; Privacy Shield (guaranteeing the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt00000008RdQAAU&status=Active.
Data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing these data has ceased to apply or is not necessary for the purpose).
If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection policy.
We ask you to regularly inform yourself about the content of our data protection policy. We adapt the data protection policy as and when changes to the data processing carried out by us require it. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or another individual notification.
Rights of the data subjects
As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 18 and 21 of the GDPR:
Right to object: 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 Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
Right to withdraw consent: you have the right to revoke any consent given at any time.
Right to information: you have the right to request confirmation as to whether data in question are being processed, and to information about these data as well as further information and a copy of the data in accordance with the legal requirements.
Right to rectification: you have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
Right to erasure and restriction of processing: you have the right, in accordance with the law, to request that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with the law.
Right to data portability: you have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that they be transferred to another person.
Complaint to the supervisory authority: you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, in accordance with the law, if you consider that the processing of personal data concerning you infringes the GDPR.
This section provides you with an overview of the terms used in this data protection policy. Many of the terms are taken from the law and defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
Conversion tracking: conversion tracking refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on users’ devices within the websites on which the marketing measures take place and then retrieved again on the target website (e.g. we can then track whether the ads we placed on other websites were successful).
Click tracking: click tracking allows us to keep track of users’ movements within an entire online offering. Since the results of these tests are more accurate if the interaction of the users can be tracked over a certain period of time (e.g. so that we can see whether a user likes to return), cookies are usually stored on the users’ computers for these testing purposes.
Content Delivery Network (CDN): A content delivery network is a service with the help of which the content of an online offer, in particular large media files such as graphics or programme scripts, can be delivered more quickly and securely with the help of regionally distributed servers connected via the Internet.
Cross-device tracking: cross-device tracking is a form of tracking in which users’ behavioural and interest information is recorded across devices in profiles by assigning an online identifier to the users. This allows user information to be analysed independently of the browsers or devices used (e.g. mobile phones or desktop computers), usually for marketing purposes. For most providers, the online identifier is not linked to clear data such as names, postal addresses or email addresses.
IP masking: IP masking is a method in which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymising processing procedures, especially in online marketing.
Interest-based and behavioural marketing: Interest-based and/or behavioural marketing is when potential user interest in ads and other content is predetermined as accurately as possible. This is done on the basis of information about a user’s previous behaviour (e.g. visiting and staying on certain websites, buying behaviour or interaction with other users), which is stored in a profile. Cookies are generally used for these purposes.
Conversion measurement: Conversion measurement is a procedure with which the effectiveness of marketing measures can be determined. For this, a cookie is usually stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the target website (e.g. we can then track whether the ads we have placed on other websites have been successful).
Profiling: “Profiling” is any form of automated processing of personal data that involves using that personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
Reach measurement: reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of web pages. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better optimise the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
Remarketing: "remarketing" or "retargeting" is when, for example, for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
Server monitoring and error detection: with the help of server monitoring and error detection, we ensure the availability and integrity of our online offer and use the data processed in the process to technically optimise our online offer. For this purpose, performance, utilisation and comparable technical values are processed, which provide information about the stability and any anomalies of our online offer. In the event of errors and conspicuousness, individual enquiries from the users of our online offering are recorded in order to identify and rectify sources of problems.
Location data: data indicating the location of an end user’s device.
Tracking: We refer to “tracking” when the behaviour of users can be traced across several online offers. As a rule, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (“profiling”). This information can then be used, for example, to display advertisements to users that presumably correspond to their interests.
Processing: “processing” means any operation or set of operations which is performed upon personal data, whether by automatic means or not. The term is broad and includes virtually any handling of data, be it collection, analysis, storage, transmission or deletion.
Target group formation: target group formation (or “custom audiences”) is when target groups are determined for advertising purposes, e.g. display of advertisements. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop in which the user viewed the products. In turn, we refer to “lookalike audiences” (or similar target groups) when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences. Target groups can be created by processing visitors to an online offer or can be uploaded to the provider of an online marketing procedure (which is usually done pseudonymously).