With the following privacy policy we would like to inform you which
types of your personal data (hereinafter also abbreviated as "data")
we process for which purposes and in which scope. The privacy
statement applies to all processing of personal data carried out by
us, both in the context of providing 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 services"). The terms used are not
gender-specific.
Last Update: 9. December 2020
Table of contents
• Preamble
• Controller
• Overview of processing operations
• Legal Bases for the Processing
• Security Precautions
• Transmission and Disclosure of Personal Data
• Data Processing in Third Countries
• Use of Cookies
• Commercial Services
• Provision of online services and web hosting
• Contacting us
• Communication via Messenger
• Video Conferences, Online Meetings, Webinars and Screen-Sharing
• Job Application Process
• Cloud Services
• Newsletter and Electronic Communications
• Commercial communication by E-Mail, Postal Mail, Fax or Telephone
• Surveys and Questionnaires
• Onlinemarketing
• Rating Platforms
• Profiles in Social Networks (Social Media)
• Plugins and embedded functions and content
• Planning, Organization and Utilities
• Erasure of data
• Changes and Updates to the Privacy Policy
• Rights of Data Subjects
• Terminology and Definitions
Cultural Lights GmbH
Bergstr. 93,
12169 Berlin
Germany
Authorised Representatives: Hedi Blödorn (Managing Director) &
Abdulhamid Douedari (Managing Director)
E-mail address:
info@cultural-lights.com
Phone: +4930991910000
Legal Notice:
http://cultural-lights.com/legal-notice-en.html
The following table summarises the types of data processed, the
purposes for which they are processed and the concerned data subjects.
Categories of Processed Data
• Event Data (Facebook) ("Event Data" is data that can be transmitted
from us to Facebook, e.g. via Facebook pixels (via apps or other
means) and relates to persons or their actions; the data includes, for
example, information about visits to websites, interactions with
content, functions, installations of apps, purchases of products,
etc.; Event data is processed for the purpose of creating target
groups for content and advertising information (Custom Audiences);
Event Data does not include the actual content (such as written
comments), login information, and Contact Information (such as names,
email addresses, and phone numbers). Event Data is deleted by Facebook
after a maximum of two years, the Custom Audiences created from them
with the deletion of our Facebook account).
• Inventory data (e.g. names, addresses).
• Job applicant details (e.g. Personal data, postal and contact
addresses and the documents pertaining to the application and the
information contained therein, such as cover letter, curriculum vitae,
certificates, etc., as well as other information on the person or
qualifications of applicants provided with regard to a specific job or
voluntarily by applicants).
• Content data (e.g. text input, photographs, videos).
• Contact data (e.g. e-mail, telephone numbers).
• Meta/communication data (e.g. device information, IP addresses).
• Usage data (e.g. websites visited, interest in content, access
times).
• Location data (Information on the geographical position of a device
or person).
• Contract data (e.g. contract object, duration, customer category).
• Payment Data (e.g. bank details, invoices, payment history).
Categories of Data Subjects
• Employees (e.g. Employees, job applicants).
• Job applicants.
• Business and contractual partners.
• Prospective customers.
• Communication partner (Recipients of e-mails, letters, etc.).
• Customers.
• Users (e.g. website visitors, users of online services).
Purposes of Processing
• Provision of our online services and usability.
• Conversion tracking (Measurement of the effectiveness of marketing
activities).
• Job Application Process (Establishment and possible later execution
as well as possible later termination of the employment relationship).
• Office and organisational procedures.
• Direct marketing (e.g. by e-mail or postal).
• Feedback (e.g. collecting feedback via online form).
• Interest-based and behavioral marketing.
• Contact requests and communication.
• Profiling (Creating user profiles).
• Remarketing.
• Web Analytics (e.g. access statistics, recognition of returning
visitors).
• Security measures.
• Targeting (e.g. profiling based on interests and behaviour, use of
cookies).
• Provision of contractual services and customer support.
• Managing and responding to inquiries.
In the following we inform you about the legal basis of the General
Data Protection Regulation (GDPR), on the basis of which we process
personal data. Please note that, in addition to the regulations of the
GDPR, the national data protection regulations may apply in your
country or in our country of residence or domicile. If, in addition,
more specific legal bases are applicable in individual cases, we will
inform you of these in the data protection declaration.
• Consent (Article 6 (1) (a) GDPR) - The data subject has given
consent to the processing of his or her personal data for one or more
specific purposes.
• Performance of a contract and prior requests (Article 6 (1) (b)
GDPR) - Performance of a contract to which the data subject is party
or in order to take steps at the request of the data subject prior to
entering into a contract.
• Compliance with a legal obligation (Article 6 (1) (c) GDPR) -
Processing is necessary for compliance with a legal obligation to
which the controller is subject.
• Legitimate Interests (Article 6 (1) (f) GDPR) - Processing is
necessary for the purposes of the legitimate interests pursued by the
controller or by a third party, except where such interests are
overridden by the interests or fundamental rights and freedoms of the
data subject which require protection of personal data.
• Job application process as a pre-contractual or contractual
relationship (Article 9 (2)(b) GDPR) - If special categories of
personal data within the meaning of Article 9 (1) GDPR (e.g. health
data, such as severely handicapped status or ethnic origin) are
requested from applicants within the framework of the application
procedure, so that the responsible person or the person concerned can
carry out the obligations and exercising specific rights of the
controller or of the data subject in the field of employment and
social security and social protection law, their processing shall be
carried out in accordance with Article 9 (2)(b) GDPR , in the case of
the protection of vital interests of applicants or other persons on
the basis of Article 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 administration of systems
and services in the health or social sector in accordance with Article
9 (2)(d) GDPR. In the case of a communication of special categories of
data based on voluntary consent, their processing is carried out on
the basis of Article 9 (2)(a) GDPR.
National data protection regulations in Germany: In addition to the
data protection regulations of the General Data Protection Regulation,
national regulations apply to data protection in Germany. This
includes in particular the Law on Protection against Misuse of
Personal Data in Data Processing (Federal Data Protection Act - BDSG).
In particular, the BDSG contains special provisions on the right to
access, the right to erase, the right to object, the processing of
special categories of personal data, processing for other purposes and
transmission as well as automated individual decision-making,
including profiling. Furthermore, it regulates data processing for the
purposes of the employment relationship (§ 26 BDSG), in particular
with regard to the establishment, execution 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 in
accordance with the legal requirements, taking into account the state
of the art, the costs of implementation and the nature, scope, context
and purposes of processing as well as the risk of varying likelihood
and severity for the rights and freedoms of natural persons, in order
to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality,
integrity and availability of data by controlling physical and
electronic access to the data as well as access to, input,
transmission, securing and separation of the data. In addition, we
have established procedures to ensure that data subjects' rights are
respected, that data is erased, and that we are prepared to respond to
data threats rapidly. Furthermore, we take the protection of personal
data into account as early as the development or selection of
hardware, software and service providers, in accordance with the
principle of privacy by design and privacy by default.
Masking of the IP address: If it is possible for us or the storage of
the IP address is not necessary, we shorten or have your IP address
shortened. When the IP address is shortened, also known as "IP
masking", the last octet, i.e. the last two numbers of an IP address,
is deleted (the IP address in this context is an identifier
individually assigned to an Internet connection by the online access
provider). With the shortening of the IP address, the identification
of a person on the basis of their IP address is to be prevented or
made considerably more difficult.
SSL encryption (https): In order to protect your data transmitted via
our online services in the best possible way, we use SSL encryption.
You can recognize such encrypted connections by the prefix https:// in
the address bar of your browser.
In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, payment institutions within the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such a case, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data. Data Transfer within the Organization: We may transfer or otherwise provide access to personal information to other locations within our organization. Insofar as this disclosure is for administrative purposes, the disclosure of the data is based on our legitimate business and economic interests or otherwise, if it is necessary to fulfill our contractual obligations or if the consent of those concerned or otherwise a legal permission is present.
If we process data in a third country (i.e. outside the European Union
(EU), the European Economic Area (EEA)) or the processing takes place
in the context of the use of third party services or disclosure or
transfer of data to other persons, bodies or companies, this will only
take place in accordance with the legal requirements.
Subject to express consent or transfer required by contract or law, we
process or have processed the data only in third countries with a
recognised level of data protection, on the basis of special
guarantees, such as a contractual obligation through so-called
standard protection clauses of the EU Commission or if certifications
or binding internal data protection regulations justify the processing
(Article 44 to 49 GDPR, information page of the EU Commission:
https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en
).
Cookies are text files that contain data from visited websites or
domains and are stored by a browser on the user's computer. A cookie
is primarily used to store information about a user during or after
his visit within an online service. The information stored can
include, for example, the language settings on a website, the login
status, a shopping basket or the location where a video was viewed.
The term "cookies" also includes other technologies that fulfil the
same functions as cookies (e.g. if user information is stored using
pseudonymous online identifiers, also referred to as "user IDs").
The following types and functions of cookies are distinguished:
• Temporary cookies (also: session cookies): Temporary cookies are
deleted at the latest after a user has left an online service and
closed his browser.
• Permanent cookies: Permanent cookies remain stored even after
closing the browser. For example, the login status can be saved or
preferred content can be displayed directly when the user visits a
website again. The interests of users who are used for range
measurement or marketing purposes can also be stored in such a cookie.
• First-Party-Cookies: First-Party-Cookies are set by ourselves.
• Third party cookies: Third party cookies are mainly used by
advertisers (so-called third parties) to process user information.
• Necessary (also: essential) cookies: Cookies can be necessary for
the operation of a website (e.g. to save logins or other user inputs
or for security reasons).
• Statistics, marketing and personalisation cookies: Cookies are also
generally used to measure a website's reach and when a user's
interests or behaviour (e.g. viewing certain content, using functions,
etc.) are stored on individual websites in a user profile. Such
profiles are used, for example, to display content to users that
corresponds to their potential interests. This procedure is also
referred to as "tracking", i.e. tracking the potential interests of
users. If we use cookies or "tracking" technologies, we will inform
you separately in our privacy policy or in the context of obtaining
consent.
Information on legal basis: The legal basis on which we process your
personal data with the help of cookies depends on whether we ask you
for your consent. If this applies 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 will
be processed on the basis of our legitimate interests (e.g. in a
business operation of our online service and its improvement) or, if
the use of cookies is necessary to fulfill our contractual
obligations.
Retention period: Unless we provide you with explicit information on
the retention period of permanent cookies (e.g. within the scope of a
so-called cookie opt-in), please assume that the retention period can
be as long as two years.
General information on Withdrawal of consent and objection (Opt-Out):
Respective of whether processing is based on consent or legal
permission, you have the option at any time to object to the
processing of your data using cookie technologies or to revoke consent
(collectively referred to as "opt-out"). You can initially explain
your objection using the settings of your browser, e.g. by
deactivating the use of cookies (which may also restrict the
functionality of our online services). An objection to the use of
cookies for online marketing purposes can be raised for a large number
of services, especially in the case of tracking, via the websites
https://www.aboutads.info/choices/
and
https://www.youronlinechoices.com. In addition, you can receive further information on objections in
the context of the information on the used service providers and
cookies.
Processing Cookie Data on the Basis of Consent: We use a cookie
management solution in which users' consent to the use of cookies, or
the procedures and providers mentioned in the cookie management
solution, can be obtained, managed and revoked by the users. The
declaration of consent is stored so that it does not have to be
retrieved again and the consent can be proven in accordance with the
legal obligation. Storage can take place server-sided and/or in a
cookie (so-called opt-out cookie or with the aid of comparable
technologies) in order to be able to assign the consent to a user or
and/or his/her device.Subject to individual details of the providers
of cookie management services, the following information applies: The
duration of the storage of the consent can be up to two years. In this
case, a pseudonymous user identifier is formed and stored with the
date/time of consent, information on the scope of the consent (e.g.
which categories of cookies and/or service providers) as well as the
browser, system and used end device.
• Processed data types: Usage data (e.g. websites visited, interest in
content, access times), Meta/communication data (e.g. device
information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online
services).
• Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests
(Article 6 (1) (f) GDPR).
We process data of our contractual and business partners, e.g.
customers and interested parties (collectively referred to as
"contractual partners") within the context of contractual and
comparable legal relationships as well as associated actions and
communication with the contractual partners or pre-contractually, e.g.
to answer inquiries.
We process this data in order to fulfil our contractual obligations,
safeguard our rights and for the purposes of the administrative tasks
associated with this data and the business-related organisation. We
will only pass on the data of the contractual partners within the
scope of the applicable law to third parties insofar as this is
necessary for the aforementioned purposes or for the fulfilment of
legal obligations or with the consent of data subjects concerned (e.g.
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 processing, e.g. for marketing purposes, as
part of this privacy policy.
Which data are necessary for the aforementioned purposes, we inform
the contracting partners before or in the context of the data
collection, e.g. in online forms by special marking (e.g. colors),
and/or symbols (e.g. asterisks or the like), or personally.
We delete the data after expiry of statutory warranty and comparable
obligations, i.e. in principle after expiry of 4 years, unless the
data is stored in a customer account or must be kept for legal reasons
of archiving (e.g., as a rule 10 years for tax purposes). In the case
of data disclosed to us by the contractual partner within the context
of an assignment, we delete the data in accordance with the
specifications of the assignment, in general after the end of the
assignment.
If we use third-party providers or platforms to provide our services,
the terms and conditions and privacy policies of the respective
third-party providers or platforms shall apply in the relationship
between the users and the providers.
Economic Analyses and Market Research: For economic reasons and in
order to be able to recognise market trends, wishes of contractual
partners and users, we analyse the data available to us on business
transactions, contracts, enquiries, etc., whereby the persons
concerned may include contractual partners, interested parties,
customers, visitors and users of our online service.
The analyses
are carried out for the purpose of business evaluations, marketing and
market research (for example, to determine customer groups with
different characteristics). If available, we can take into account the
profiles of registered users with information, e.g. on the services
they have used. The analyses serve us alone and are not disclosed
externally unless they are anonymous analyses with summarised, i.e.
anonymised values. Furthermore, we respect the privacy of the users
and process the data for analysis purposes as pseudonymously as
possible and if possible anonymously (e.g. as summarized data).
Education and Training Services: We process the data of the
participants of our education and training programmes (uniformly
referred to as " students") in order to provide them with our
educational and training services. The data processed, the type, scope
and purpose of the processing and the necessity of its processing are
determined by the underlying contractual and educational relationship.
The processing also includes the performance evaluation and evaluation
of our services and the teachers and instructors.
As part of our activities, we may also process special categories of
data, in particular information on the health of persons undergoing
training or further training and data revealing ethnic origin,
political opinions, religious or philosophical convictions. To this
end, we obtain, if necessary, the express consent of the students to
be trained and further educated and process the special categories of
data otherwise only if it is necessary for the provision of training
services, for purposes of health care, social protection or protection
of vital interests of the students to be trained and further educated.
Insofar as it is necessary for the fulfilment of our contract,
for the protection of vital interests or by law, or with the consent
of the trainees, we disclose or transfer the data of the students to
third parties or agents, e.g. public authorities or in the field of
IT, office or comparable services, in compliance with the requirements
of professional law.
Coaching: We process the data of our clients and interested parties
and other clients or contractual partners (uniformly referred to as
"clients") in order to provide them with our services. The data
processed, the type, scope and purpose of their processing and the
necessity of their processing are determined by the underlying
contractual and client relationship.
Within the scope of our
services, we may also process special categories of data, here in
particular information on the health of clients, possibly with
reference to their sexual life or sexual orientation and data
revealing ethnic origin, political opinions, religious or
philosophical beliefs. To this end, we obtain the express consent of
clients where necessary and process the special categories of data
otherwise for the purposes of health care, if the data is public or
wit an other legal permission.
Insofar as it is necessary for the fulfilment of our contractual
obligations, the protection of vital interests or by law, or with
theclients's consent, we disclose or transfer the clients's data to
third parties or agents, such as public authorities, accounting
offices and in the field of IT, office or comparable services, in
compliance with professional regulations.
Consulting: We process the data of our clients, clients as well as
interested parties and other clients or contractual partners
(uniformly referred to as "clients") in order to provide them with our
consulting services. The data processed, the type, scope and purpose
of the processing and the necessity of its processing are determined
by the underlying contractual and client relationship.
Insofar as it is necessary for the fulfilment of our contract, for the
protection of vital interests or by law, or with the consent of the
client, we disclose or transfer the client's data to third parties or
agents, such as authorities, courts, subcontractors or in the field of
IT, office or comparable services, taking into account the
professional requirements.
Recruiting Services: As part of our services, which include in
particular the search for, contacting and placement of potential job
candidates, we process the data of the job candidates and the personal
data of potential employers or their employees.
We process the information and contact data provided by the job
candidates for the purposes of establishing, implementing and, if
necessary, terminating a job placement contract. In addition, we can
ask interested parties questions about the success of our recruiting
services at a later date, in accordance with legal requirements.
We process the data of the job candidates, as well as of the
employers, in order to fulfil our contractual obligations, in order to
process the requests we receive for the placement of jobs to the
satisfaction of the parties involved.
We can record the recruiting processes in order to be able to prove
the existence of the contractual relationship and the consent of the
interested parties in accordance with the statutory accountability
obligations (Article 5 (2) GDPR). This information will be stored for
a period of three to four years if we need to prove the original
request (e.g. to prove eligibility to contact the job candidates).
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, acquire or commission
the selected services or works and related tasks, as well as their
payment and delivery, or execution or provision.
The required details are identified as such within the framework of
the conclusion of the order, order or comparable contract and include
the details required for service provision and invoicing as well as
contact information in order to be able to hold any consultations.
• Processed data types: Inventory data (e.g. names, addresses),
Payment Data (e.g. bank details, invoices, payment history), Contact
data (e.g. e-mail, telephone numbers), Contract data (e.g. contract
object, duration, customer category), Usage data (e.g. websites
visited, interest in content, access times), Meta/communication data
(e.g. device information, IP addresses), Job applicant details (e.g.
Personal data, postal and contact addresses and the documents
pertaining to the application and the information contained therein,
such as cover letter, curriculum vitae, certificates, etc., as well as
other information on the person or qualifications of applicants
provided with regard to a specific job or voluntarily by applicants).
• Special categories of personal data: Health Data (Article 9 (1)
GDPR), Data related to sexual preferences, sex life, and/or sexual
orientation (Article 9 (1) GDPR), Rreligious or philosophical beliefs
(Article 9 (1) GDPR), Data revealing ethnic origin.
• Data subjects: Prospective customers, Business and contractual
partners, Customers, Job applicants.
• Purposes of Processing: Provision of contractual services and
customer support, Contact requests and communication, Office and
organisational procedures, Managing and responding to inquiries,
Conversion tracking (Measurement of the effectiveness of marketing
activities), Interest-based and behavioral marketing, Profiling
(Creating user profiles).
• Legal Basis: Performance of a contract and prior requests (Article 6
(1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) (c)
GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
In order to provide our online services securely and efficiently, we
use the services of one or more web hosting providers from whose
servers (or servers they manage) the online services can be accessed.
For these purposes, we may use infrastructure and platform services,
computing capacity, storage space and database services, as well as
security and technical maintenance services.
The data processed within the framework of the provision of the
hosting services may include all information relating to the users of
our online services that is collected in the course of use and
communication. This regularly includes the IP address, which is
necessary to be able to deliver the contents of online services to
browsers, and all entries made within our online services or from
websites.
Collection of Access Data and Log Files: We, ourselves or our web
hosting provider, collect data on the basis of each access to the
server (so-called server log files). Server log files may include the
address and name of the web pages and files accessed, the date and
time of access, data volumes transferred, notification of successful
access, browser type and version, the user's operating system,
referrer URL (the previously visited page) and, as a general rule, IP
addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid
overloading the servers (especially in the case of abusive attacks,
so-called DDoS attacks) and to ensure the stability and optimal load
balancing of the servers.
• Processed data types: Content data (e.g. text input, photographs,
videos), Usage data (e.g. websites visited, interest in content,
access times), Meta/communication data (e.g. device information, IP
addresses).
• Data subjects: Users (e.g. website visitors, users of online
services).
• Purposes of Processing: Provision of contractual services and
customer support.
• Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Services and service providers being used:
• 1&1 IONOS: Hosting platform for E-Commerce / websites; Service
provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany;
Website: https://www.ionos.com;
Privacy Policy:
https://www.ionos.com/terms-gtc/terms-privacy/.
When contacting us (e.g. by contact form, e-mail, telephone or via
social media), the data of the inquiring persons are processed insofar
as this is necessary to answer the contact enquiries and any requested
activities.
The response to contact enquiries within the framework of contractual
or pre-contractual relationships is made in order to fulfil our
contractual obligations or to respond to (pre)contractual enquiries
and otherwise on the basis of the legitimate interests in responding
to the enquiries.
• Processed data types: Inventory data (e.g. names, addresses),
Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text
input, photographs, videos), Usage data (e.g. websites visited,
interest in content, access times), Meta/communication data (e.g.
device information, IP addresses).
• Data subjects: Communication partner (Recipients of e-mails,
letters, etc.).
• Purposes of Processing: Contact requests and communication, Managing
and responding to inquiries.
• Legal Basis: Performance of a contract and prior requests (Article 6
(1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Services and service providers being used:
• Zoho Desk: Management of contact requests and communication; Service
provider: Zoho Corporation Pvt. Ltd., Chengalpattu, Tamil Nadu, India;
Website: https://www.zoho.com;
Privacy Policy:
https://www.zoho.com/privacy.html; Standard Contractual Clauses (Safeguarding the level of data
protection when processing data in third countries): On request from
the service provider.
We use messenger services for communication purposes and therefore ask
you to observe the following information regarding the functionality
of the messenger services, encryption, use of the metadata of the
communication and your objection options.
You can also contact us by alternative means, e.g. telephone or
e-mail. Please use the contact options provided to you or use the
contact options provided within our online services.
In the case of encryption of content (i.e. the content of your message
and attachments), we point out that the communication content (i.e.
the content of the message and attachments) is encrypted end-to-end.
This means that the content of the messages is not visible, not even
by the messenger service providers themselves. You should always use a
current version of the messenger service with activated encryption, so
that the encryption of the message contents is guaranteed.
However, we would like to point out to our communication partners that
although messenger service providers do not see the content, they can
find out that and when communication partners communicate with us and
process technical information on the communication partner's device
used and, depending on the settings of their device, also location
information (so-called metadata).
Information on Legal basis: If we ask communication partners for
permission before communicating with them via messenger services, the
legal basis of our processing of their data is their consent.
Otherwise, if we do not request consent and you contact us, for
example, voluntarily, we use messenger services in our dealings with
our contractual partners and as part of the contract initiation
process 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 for communication via messenger services.
We would also like to point out that we do not transmit the contact
data provided to us to the messenger service providers for the first
time without your consent.
Withdrawal, objection and deletion: You can withdraw your consent or
object to communication with us via messenger services at any time.In
the case of communication via messenger services, we delete the
messages in accordance with our general data retention policy (i.e. as
described above after the end of contractual relationships, 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 there
are no legal obligations to store the messages to prevent their
deletion.
Reservation of reference to other means of communication: Finally, we
would like to point out that we reserve the right, for reasons of your
safety, not to answer inquiries about messenger services. This is the
case if, for example, internal contractual matters require special
secrecy or if an answer via the messenger services does not meet the
formal requirements. In such cases we refer you to more appropriate
communication channels.
Skype: The end-to-end encryption of Skype requires its activation
(unless it is enabled by default).
• Processed data types: Contact data (e.g. e-mail, telephone numbers),
Usage data (e.g. websites visited, interest in content, access times),
Meta/communication data (e.g. device information, IP addresses),
Content data (e.g. text input, photographs, videos).
• Data subjects: Communication partner (Recipients of e-mails,
letters, etc.).
• Purposes of Processing: Contact requests and communication, Direct
marketing (e.g. by e-mail or postal).
• Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests
(Article 6 (1) (f) GDPR).
Services and service providers being used:
• Facebook-Messenger: Facebook-Messenger with end-to-end encryption
(the end-to-end Facebook Messenger encryption requires activation,
unless enabled by default); Service provider:
https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square,
Grand Canal Harbour, Dublin 2, Irland, Mutterunternehmen: Facebook, 1
Hacker Way, Menlo Park, CA 94025, USA; Website:
https://www.facebook.com; Privacy Policy:
https://www.facebook.com/about/privacy; Opt-Out:
https://www.facebook.com/settings?tab=ads.
• 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; Privacy Policy:
https://privacy.microsoft.com/de-de/privacystatement, Security
information: https://www.microsoft.com/de-de/trustcenter.
• Threema: Threema Messenger with end-to-end encryption; Service
provider: Threema GmbH, Churerstrasse 82, 8808 Pfäffikon SZ,
Switzerland; Website: https://threema.ch/de; Privacy Policy:
https://threema.ch/en/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/; Privacy
Policy: https://www.whatsapp.com/legal.
We use third-party platforms and applications (hereinafter referred to
as "third party providers") for the purposes of conducting video and
audio conferences, webinars and other types of video and audio
meetings. When selecting third-party providers and their services, we
observe the legal requirements.
In this context, data of the communication participants will be
processed and stored on the servers of third parties, as far as these
are part of communication processes with us. This data may include,
but is not limited to, registration and contact details, visual and
voice contributions, chat entries and shared screen content.
If users are referred to the third-party providers or their software
or platforms in the context of communication, business or other
relationships with us, the third-party provider processing may process
usage data and metadata that can be processed by them for security
purposes, service optimisation or marketing purposes. We therefore ask
you to observe the data protection information of the respective third
party providers.
Information on legal basis: If we ask the users for their consent to
the use of third party providers or certain functions (e.g. permission
to record conversations), the legal basis of the processing is
consent. Furthermore, the processing can be a component of our
(pre)contractual services, provided that the use of the third party
was agreed within this context. Otherwise, user data will be processed
on the basis of our legitimate interest in efficient and secure
communication with our communication partners. In this context, we
would also like to refer you to the information on the use of cookies
in this privacy policy.
• Processed data types: Inventory data (e.g. names, addresses),
Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text
input, photographs, videos), Usage data (e.g. websites visited,
interest in content, access times), Meta/communication data (e.g.
device information, IP addresses).
• Data subjects: Communication partner (Recipients of e-mails,
letters, etc.), Users (e.g. website visitors, users of online
services).
• Purposes of Processing: Provision of contractual services and
customer support, Contact requests and communication, Office and
organisational procedures, Direct marketing (e.g. by e-mail or
postal).
• Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a
contract and prior requests (Article 6 (1) (b) GDPR), Legitimate
Interests (Article 6 (1) (f) GDPR).
Services and service providers being used:
• Skype: Messenger and conference software; Service provider:
Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA;
Website: https://www.skype.com; Privacy Policy:
https://privacy.microsoft.com/de-de/privacystatement, Security
information: https://www.microsoft.com/de-de/trustcenter.
• TeamViewer: Conference Software; Service provider: TeamViewer GmbH,
Jahnstr. 30, 73037 Göppingen, Germany; Website:
https://www.teamviewer.com/en/; Privacy Policy:
https://www.teamviewer.com/en/privacy-policy/.
• Zoom: Video Conferencing, Web Conferencing and Webinars; Service
provider: Zoom Video Communications, Inc., 55 Almaden Blvd., Suite
600, San Jose, CA 95113, USA; Website: https://zoom.us; Privacy
Policy: https://zoom.us/docs/de-de/privacy-and-legal.html; Standard
Contractual Clauses (Safeguarding the level of data protection when
processing data in third countries):
https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as
Global DPA).
The application process 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 information contained therein.
In principle, the required information includes personal information
such as name, address, a contact option and proof of the
qualifications required for a particular employment. Upon request, we
will be happy to provide you with additional information.
If made available, applicants can submit their applications via an
online form. The data will be transmitted to us encrypted according to
the state of the art. Applicants can also send us their applications
by e-mail. Please note, however, that e-mails on the Internet are
generally not sent in encrypted form. As a rule, e-mails are encrypted
during transport, but not on the servers from which they are sent and
received. We can therefore accept no responsibility for the
transmission path of the application between the sender and the
reception on our server. For the purposes of searching for applicants,
submitting applications and selecting applicants, we may make use of
the applicant management and recruitment software, platforms and
services of third-party providers in compliance with legal
requirements.
Applicants are welcome to contact us about how to submit their
application or send it to us by regular mail.
Processing of special categories of data: If special categories of
personal data within the meaning of Article 9 (1) GDPR (e.g. health
data, such as severely handicapped status or ethnic origin) are
requested from applicants within the framework of the application
procedure, so that the responsible person or the person concerned can
exercise his/her rights arising from labour law and social security
and social protection law and fulfil his/her duties in this regard,
their processing shall be carried out in accordance with Article 9
(1)(b) GDPR, in the case of the protection of vital interests of
applicants or other persons pursuant to Article 9 (1)(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 administration of systems and services in the health or social
sector in accordance with Article 9 (1)(h) GDPR. In the case of a
communication of special categories of data based on voluntary
consent, their processing is carried out on the basis of Article 9
(1)(a) GDPR.
Ereasure of data: In the event of a successful application, the data
provided by the applicants may be further processed by us for the
purposes of the employment relationship. Otherwise, if the application
for a job offer is not successful, the applicant's data will be
deleted. Applicants' data will also be deleted if an application is
withdrawn, to which applicants are entitled at any time. Subject to a
justified revocation by the applicant, the deletion will take place at
the latest after the expiry of a period of six months, so that we can
answer any follow-up questions regarding the application and comply
with our duty of proof under the regulations on equal treatment of
applicants. Invoices for any reimbursement of travel expenses are
archived in accordance with tax regulations.
Admission to a talent pool - Admission to an talent pool, if offered,
is based on consent. Applicants are informed that their consent to be
included in the talent pool is voluntary, has no influence on the
current application process and that they can revoke their consent at
any time for the future.
• Processed data types: Job applicant details (e.g. Personal data,
postal and contact addresses and the documents pertaining to the
application and the information contained therein, such as cover
letter, curriculum vitae, certificates, etc., as well as other
information on the person or qualifications of applicants provided
with regard to a specific job or voluntarily by applicants).
• Data subjects: Job applicants.
• Purposes of Processing: Job Application Process (Establishment and
possible later execution as well as possible later termination of the
employment relationship).
• Legal Basis: Job application process as a pre-contractual or
contractual relationship (Article 9 (2)(b) GDPR).
Services and service providers being used:
• LinkedIn Recruiter: Recruiting platform and services; Service
provider: https://www.linkedin.com, LinkedIn Ireland Unlimited
Company, Wilton Place, Dublin 2, Ireland; Website:
https://www.linkedin.com; Privacy Policy:
https://www.linkedin.com/legal/privacy-policy.
We use Internet-accessible software services (so-called "cloud
services", also referred to as "Software as a Service") provided on
the servers of its providers for the following purposes: document
storage and administration, calendar management, e-mail delivery,
spreadsheets and presentations, exchange of documents, content and
information with specific recipients or publication of websites, forms
or other content and information, as well as chats and participation
in audio and video conferences.
Within this framework, personal data may be processed and stored on
the provider's servers insofar as this data is part of communication
processes with us or is otherwise processed by us in accordance with
this privacy policy. This data may include in particular master data
and contact data of data subjects, data on processes, contracts, other
proceedings and their contents. Cloud service providers also process
usage data and metadata that they use for security and service
optimization purposes.
If we use cloud services to provide documents and content to other
users or publicly accessible websites, forms, etc., providers may
store cookies on users' devices for web analysis or to remember user
settings (e.g. in the case of media control).
Information on legal basis - If we ask for permission to use cloud
services, the legal basis for processing data is consent. Furthermore,
their use can be a component of our (pre)contractual services,
provided that the use of cloud services has been agreed in this
context. Otherwise, user data will be processed on the basis of our
legitimate interests (i.e. interest in efficient and secure
administrative and collaboration processes).
• Processed data types: Inventory data (e.g. names, addresses),
Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text
input, photographs, videos), Usage data (e.g. websites visited,
interest in content, access times), Meta/communication data (e.g.
device information, IP addresses).
• Data subjects: Customers, Employees (e.g. Employees, job
applicants), Prospective customers, Communication partner (Recipients
of e-mails, letters, etc.).
• Purposes of Processing: Office and organisational procedures.
• Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a
contract and prior requests (Article 6 (1) (b) GDPR), Legitimate
Interests (Article 6 (1) (f) GDPR).
Services and service providers being used:
• Dropbox: Cloud storage services; Service provider: Dropbox, Inc.,
333 Brannan Street, San Francisco, California 94107, USA; Website:
https://www.dropbox.com; Privacy Policy:
https://www.dropbox.com/privacy; Standard Contractual Clauses
(Safeguarding the level of data protection when processing data in
third countries):
https://assets.dropbox.com/documents/en/legal/data-processing-agreement-dfb-013118.pdf.
• Google Cloud Services: Cloud storage services; 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://cloud.google.com/;
Privacy Policy: https://www.google.com/policies/privacy, Security
information: https://cloud.google.com/security/privacy.
We send newsletters, e-mails and other electronic communications
(hereinafter referred to as "newsletters") only with the consent of
the recipient or a legal permission. Insofar as the contents of the
newsletter are specifically described within the framework of
registration, they are decisive for the consent of the user.
Otherwise, our newsletters contain information about our services and
us.
In order to subscribe to our newsletters, it is generally sufficient
to enter your e-mail address. We may, however, ask you to provide a
name for the purpose of contacting you personally in the newsletter or
to provide further information if this is required for the purposes of
the newsletter.
Double opt-in procedure: The registration to our newsletter takes
place in general in a so-called Double-Opt-In procedure. This means
that you will receive an e-mail after registration asking you to
confirm your registration. This confirmation is necessary so that no
one can register with external e-mail addresses.
The registrations for the newsletter are logged in order to be able to
prove the registration process according to the legal requirements.
This includes storing the login and confirmation times as well as the
IP address. Likewise the changes of your data stored with the dispatch
service provider are logged.
Deletion and restriction of processing: We may store the unsubscribed
email addresses for up to three years based on our legitimate
interests before deleting them to provide evidence of prior consent.
The processing of these data is limited to the purpose of a possible
defense against claims. An individual deletion request is possible at
any time, provided that the former existence of a consent is confirmed
at the same time. In the case of an obligation to permanently observe
an objection, we reserve the right to store the e-mail address solely
for this purpose in a blocklist.
Information on legal bases: The sending of the newsletter is based on
the consent of the recipients or, if consent is not required, on the
basis of our legitimate interests in direct marketing. Insofar as we
engage a service provider for sending e-mails, this is done on the
basis of our legitimate interests. The registration procedure is
recorded on the basis of our legitimate interests for the purpose of
demonstrating that it has been conducted in accordance with the law.
Contents: Information about us, our services, promotions and offers.
Sending via text messages: The electronic communications can also be
sent via text messages (or are sent exclusively via text messages, if
the sending authorization, e.g., consent, only includes sending via
SMS).
• Processed data types: Inventory data (e.g. names, addresses),
Contact data (e.g. e-mail, telephone numbers), Meta/communication data
(e.g. device information, IP addresses).
• Data subjects: Communication partner (Recipients of e-mails,
letters, etc.).
• Purposes of Processing: Direct marketing (e.g. by e-mail or postal).
• Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests
(Article 6 (1) (f) GDPR).
• Opt-Out: You can cancel the receipt of 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 otherwise use one of the contact options listed above,
preferably e-mail.
We process personal data for the purposes of promotional
communication, which may be carried out via various channels, such as
e-mail, telephone, post or fax, in accordance with the legal
requirements.
The recipients have the right to withdraw their consent at any time or
to object to the advertising communication at any time.
After withdrawal or objection, we may store the data required to prove
consent for up to three years on the basis of our legitimate interests
before we delete them. The processing of these data is limited to the
purpose of a possible defense against claims. An individual deletion
request is possible at any time, provided that the former existence of
a consent is affirmed.
• Processed data types: Inventory data (e.g. names, addresses),
Contact data (e.g. e-mail, telephone numbers).
• Data subjects: Communication partner (Recipients of e-mails,
letters, etc.).
• Purposes of Processing: Direct marketing (e.g. by e-mail or postal).
• Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests
(Article 6 (1) (f) GDPR).
The surveys and questionnaires ("surveys") carried out by us are
evaluated anonymously. Personal data is only processed insofar as this
is necessary for the provision and technical execution of the survey
(e.g. processing the IP address to display the survey in the user's
browser or to enable a resumption of the survey with the aid of a
temporary cookie (session cookie)) or participants have consented.
Information on legal basis: If we ask the participants for their
consent to the processing of their data, this is the legal basis for
the processing, otherwise the processing of the participants' data is
based on our legitimate interests in conducting an objective survey.
• Processed data types: Contact data (e.g. e-mail, telephone numbers),
Content data (e.g. text input, photographs, videos), Usage data (e.g.
websites visited, interest in content, access times),
Meta/communication data (e.g. device information, IP addresses).
• Data subjects: Communication partner (Recipients of e-mails,
letters, etc.).
• Purposes of Processing: Contact requests and communication, Direct
marketing (e.g. by e-mail or postal).
• Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests
(Article 6 (1) (f) GDPR).
We process personal data for the purposes of online marketing, which
may include in particular the marketing of advertising space or the
display of advertising and other content (collectively referred to as
"Content") based on the potential interests of users and the
measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in
a file (so-called "cookie") or similar procedure in which the relevant
user information for the display of the aforementioned content is
stored. This information may include, for example, content viewed,
websites visited, online networks used, communication partners and
technical information such as the browser used, computer system used
and information on usage times. If users have consented to the
collection of their sideline data, these can also be processed.
The IP addresses of the users are also stored. However, we use
provided IP masking procedures (i.e. pseudonymisation by shortening
the IP address) to ensure the protection of the user's by using a
pseudonym. In general, within the framework of the online marketing
process, no clear user data (such as e-mail addresses or names) is
secured, but pseudonyms. This means that we, as well as the providers
of online marketing procedures, do not know the actual identity of the
users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or
similar memorizing procedures. These cookies can later, generally also
on other websites that use the same online marketing technology, be
read and analyzed for purposes of content display, as well as
supplemented with other data and stored on the server of the online
marketing technology provider.
Exceptionally, clear data can be assigned to the profiles. This is the
case, for example, if the users are members of a social network whose
online marketing technology 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 social network providers or
other service providers, e.g. by consenting as part of a registration
process.
As a matter of principle, we only gain access to summarised
information about the performance of our advertisements. However,
within the framework of so-called conversion measurement, we can check
which of our online marketing processes have led to a so-called
conversion, i.e. to the conclusion of a contract with us. The
conversion measurement is used alone for the performance analysis of
our marketing activities.
Unless otherwise stated, we kindly ask you to consider that cookies
used will be stored for a period of two years.
Information on legal basis: If we ask users for their consent (e.g. in
the context of a so-called "cookie banner consent"), the legal basis
for processing data for online marketing purposes is this consent.
Otherwise, user data will be processed on the basis of our legitimate
interests (i.e. interest in the analysis, optimisation and economic
operation of our online services. In this context, we would also like
to refer you to the information on the use of cookies in this privacy
policy.
• Processed data types: Usage data (e.g. websites visited, interest in
content, access times), Meta/communication data (e.g. device
information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online
services).
• Purposes of Processing: Targeting (e.g. profiling based on interests
and behaviour, use of cookies), Remarketing, Conversion tracking
(Measurement of the effectiveness of marketing activities),
Interest-based and behavioral marketing, Profiling (Creating user
profiles).
• Security measures: IP Masking (Pseudonymization of the IP address).
• Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests
(Article 6 (1) (f) GDPR).
• Opt-Out: We refer to the privacy policies of the respective service
providers and the possibilities for objection (so-called "opt-out").
If no explicit opt-out option has been specified, it is possible to
deactivate cookies in the settings of your browser. However, this may
restrict the functions of our online offer. We therefore recommend the
following additional opt-out options, which are offered collectively
for each area:a) Europe: https://www.youronlinechoices.eu. b) Canada:
https://www.youradchoices.ca/choices. c) USA:
https://www.aboutads.info/choices. d) Cross-regional:
https://optout.aboutads.info.
Services and service providers being used:
• Google Tag Manager: Google Tag Manager is a solution with which we
can manage so-called website tags via an interface and thus integrate
other services into our online services (please refer to further
details in this privacy policy). With the Tag Manager itself (which
implements the tags), for example, no user profiles are created or
cookies are stored. Google only receives the IP address of the user,
which is necessary to run the Google Tag Manager. 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; Privacy Policy:
https://policies.google.com/privacy.
We participate in rating procedures to evaluate, optimise and
advertise our performance. If users rate us via the participating
rating platforms or methods or otherwise provide feedback, the General
Terms and Conditions of Business or Use and the data protection
information of the providers also apply. As a rule, the rating also
requires registration with the respective provider.
In order to ensure that the evaluators have actually made use of our
services, we transmit, with the consent of the customer, the necessary
data relating to the customer and the service or products used to the
respective rating platform (this includes the name, e-mail address,
order number or article number). This data is used solely to verify
the authenticity of the user.
• Processed data types: Contract data (e.g. contract object, duration,
customer category), Usage data (e.g. websites visited, interest in
content, access times), Meta/communication data (e.g. device
information, IP addresses).
• Data subjects: Customers, Users (e.g. website visitors, users of
online services).
• Purposes of Processing: Feedback (e.g. collecting feedback via
online form).
• Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests
(Article 6 (1) (f) GDPR).
We maintain online presences within social networks and process user
data in this context in order to communicate with the 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 entail risks for users, e.g. by making it
more difficult to enforce users' rights.
In addition, user data is usually processed within social networks for
market research and advertising purposes. For example, user profiles
can be created on the basis of user behaviour and the associated
interests of users. The user profiles can then be used, for example,
to place advertisements within and outside the networks which are
presumed to correspond to the interests of the users. For these
purposes, cookies are usually stored on the user's computer, in which
the user's usage behaviour and interests are stored. Furthermore, data
can be stored in the user profiles independently of the devices used
by the users (especially if the users are members of the respective
networs or will become members later on).
For a detailed description of the respective processing operations and
the opt-out options, please refer to the respective data protection
declarations and information provided by the providers of the
respective networks.
Also in the case of requests for information and the exercise of
rights of data subjects, we point out that these can be most
effectively pursued with the providers. Only the providers have access
to the data of the users and can directly take appropriate measures
and provide information. If you still need help, please do not
hesitate to contact us.
Facebook: We are jointly responsible (so called "joint controller")
with Facebook Ireland Ltd. for the collection (but not the further
processing) of data of visitors to our Facebook page. This data
includes information about the types of content users view or interact
with, or the actions they take (see "Things that you and others do and
provide" in the Facebook Data Policy:
https://www.facebook.com/policy), and information about the devices
used by users (e.g., IP addresses, operating system, browser type,
language settings, cookie information; see "Device Information" in the
Facebook Data Policy: https://www.facebook.com/policy). As explained
in the Facebook Data Policy under "How we use this information?"
Facebook also collects and uses information to provide analytics
services, known as "page insights," to site operators to help them
understand how people interact with their pages and with content
associated with them. We have concluded a special agreement with
Facebook ("Information about Page-Insights",
https://www.facebook.com/legal/terms/page_controller_addendum), which
regulates in particular the security measures that Facebook must
observe and in which Facebook has agreed to fulfill the rights of the
persons concerned (i.e. users can send information access or deletion
requests directly to Facebook). The rights of users (in particular to
access to information, erasure, objection and complaint to the
competent supervisory authority) are not restricted by the agreements
with Facebook. Further information can be found in the "Information
about Page Insights"
(https://www.facebook.com/legal/terms/information_about_page_insights_data).
• Processed data types: Inventory data (e.g. names, addresses),
Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text
input, photographs, videos), Usage data (e.g. websites visited,
interest in content, access times), Meta/communication data (e.g.
device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online
services).
• Purposes of Processing: Contact requests and communication,
Targeting (e.g. profiling based on interests and behaviour, use of
cookies), Remarketing, Web Analytics (e.g. access statistics,
recognition of returning visitors).
• Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
Services and service providers being used:
• Instagram: Social network; Service provider: Instagram Inc., 1601
Willow Road, Menlo Park, CA, 94025, USA, , Mutterunternehmen:
Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website:
https://www.instagram.com; Privacy Policy:
https://instagram.com/about/legal/privacy.
• Facebook: Social network; Service provider: Facebook Ireland Ltd., 4
Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland, parent
company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website:
https://www.facebook.com; Privacy Policy:
https://www.facebook.com/about/privacy; Opt-Out: Settings for
advertisements: https://www.facebook.com/settings?tab=ads.
• LinkedIn: Social network; Service provider: LinkedIn Ireland
Unlimited Company, Wilton Place, Dublin 2, Ireland; Website:
https://www.linkedin.com; Privacy Policy:
https://www.linkedin.com/legal/privacy-policy; Opt-Out:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Twitter: Social network; Service provider: Twitter International
Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07,
Ireland, parent company: Twitter Inc., 1355 Market Street, Suite 900,
San Francisco, CA 94103, USA; Privacy Policy:
https://twitter.com/de/privacy, (Settings)
https://twitter.com/personalization.
• YouTube: Social network and video platform; Service provider: Google
Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland,
parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View,
CA 94043, USA; Privacy Policy: https://policies.google.com/privacy;
Opt-Out: https://adssettings.google.com/authenticated.
Within our online services, we integrate functional and content
elements that are obtained from the servers of their respective
providers (hereinafter referred to as "third-party providers"). These
may, for example, be graphics, videos or social media buttons as well
as contributions (hereinafter uniformly referred to as "Content").
The integration always presupposes that the third-party providers of
this content process the IP address of the user, since they could not
send the content to their browser without the IP address. The IP
address is therefore required for the presentation of these contents
or functions. We strive to use only those contents, whose respective
offerers use the IP address only for the distribution of the contents.
Third parties may also use so-called pixel tags (invisible graphics,
also known as "web beacons") for statistical or marketing purposes.
The "pixel tags" can be used to evaluate 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 include
technical information about the browser and operating system,
referring websites, visit times and other information about the use of
our website, as well as may be linked to such information from other
sources.
Information on legal basis: If we ask users for their consent (e.g. in
the context of a so-called "cookie banner consent"), the legal basis
for processing is this consent. Otherwise, user data will be processed
on the basis of our legitimate interests (i.e. interest in the
analysis, optimisation and economic operation of our online services.
We refer you to the note on the use of cookies in this privacy policy.
Facebook plugins and contents: We are jointly responsible (so-called
"joint-controllership") with Facebook Ireland Ltd. for the collection
or transmission (but not further processing) of "Event Data" that
Facebook collects or receives as part of a transmission using the
Facebook Social Plugins that run on our website for the following
purposes: a) displaying content advertising information that matches
users' presumed interests; b) delivering commercial and transactional
messages (e.g. b) delivering commercial and transactional messages
(e.g., addressing users via Facebook Messenger); c) improving ad
delivery and personalizing features and content (e.g., improving
recognition of which content or advertising information is believed to
be of interest to users). We have entered into a special agreement
with Facebook ("Controller Addendum",
https://www.facebook.com/legal/controller_addendum), which
specifically addresses the security measures that Facebook must take
(https://www.facebook.com/legal/terms/data_security_terms) and in
which Facebook has agreed to comply with the rights of data subjects
(i.e., users can, for example, submit information access or deletion
requests directly to Facebook). Note: If Facebook provides us with
measurements, analyses and reports (which are aggregated, i.e. do not
contain information on individual users and are anonymous to us), then
this processing is not carried out within the scope of joint
responsibility, but on the basis of a DPA ("Data Processing Terms",
https://www.facebook.com/legal/terms/dataprocessing/update), the "Data
Security Conditions"
(https://www.facebook.com/legal/terms/data_security_terms) and, with
regard to processing in the USA, on the basis of Standard Contractual
Clauses ("Facebook EU Data Transfer Addendum,
https://www.facebook.com/legal/EU_data_transfer_addendum). The rights
of users (in particular to access to information, erasure, objection
and complaint to the competent supervisory authority) are not
restricted by the agreements with Facebook.
Instagram plugins and contents: We are jointly responsible (so-called
"joint-controllership") with Facebook Ireland Ltd. for the collection
or transmission (but not further processing) of "Event Data" that
Facebook collects or receives as part of a transmission using
Instagram functions that run on our website for the following
purposes: a) displaying content advertising information that matches
users' presumed interests; b) delivering commercial and transactional
messages (e.g. b) delivering commercial and transactional messages
(e.g., addressing users via Facebook Messenger); c) improving ad
delivery and personalizing features and content (e.g., improving
recognition of which content or advertising information is believed to
be of interest to users). We have entered into a special agreement
with Facebook ("Controller Addendum",
https://www.facebook.com/legal/controller_addendum), which
specifically addresses the security measures that Facebook must take
(https://www.facebook.com/legal/terms/data_security_terms) and in
which Facebook has agreed to comply with the rights of data subjects
(i.e., users can, for example, submit information access or deletion
requests directly to Facebook). Note: If Facebook provides us with
measurements, analyses and reports (which are aggregated, i.e. do not
contain information on individual users and are anonymous to us), then
this processing is not carried out within the scope of joint
responsibility, but on the basis of a DPA ("Data Processing Terms",
https://www.facebook.com/legal/terms/dataprocessing/update), the "Data
Security Conditions"
(https://www.facebook.com/legal/terms/data_security_terms) and, with
regard to processing in the USA, on the basis of Standard Contractual
Clauses ("Facebook EU Data Transfer Addendum,
https://www.facebook.com/legal/EU_data_transfer_addendum). The rights
of users (in particular to access to information, erasure, objection
and complaint to the competent supervisory authority) are not
restricted by the agreements with Facebook.
• Processed data types: Usage data (e.g. websites visited, interest in
content, access times), Meta/communication data (e.g. device
information, IP addresses), Event Data (Facebook) ("Event Data" is
data that can be transmitted from us to Facebook, e.g. via Facebook
pixels (via apps or other means) and relates to persons or their
actions; the data includes, for example, information about visits to
websites, interactions with content, functions, installations of apps,
purchases of products, etc.; Event data is processed for the purpose
of creating target groups for content and advertising information
(Custom Audiences); Event Data does not include the actual content
(such as written comments), login information, and Contact Information
(such as names, email addresses, and phone numbers). Event Data is
deleted by Facebook after a maximum of two years, the Custom Audiences
created from them with the deletion of our Facebook account), Location
data (Information on the geographical position of a device or person),
Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text
input, photographs, videos), Inventory data (e.g. names, addresses).
• Data subjects: Users (e.g. website visitors, users of online
services), Communication partner (Recipients of e-mails, letters,
etc.).
• Purposes of Processing: Provision of our online services and
usability, Provision of contractual services and customer support,
Contact requests and communication, Direct marketing (e.g. by e-mail
or postal), Targeting (e.g. profiling based on interests and
behaviour, use of cookies), Interest-based and behavioral marketing,
Profiling (Creating user profiles), Security measures, Managing and
responding to inquiries.
• Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR), Consent
(Article 6 (1) (a) GDPR), Performance of a contract and prior requests
(Article 6 (1) (b) GDPR).
Services and service providers being used:
• Facebook plugins and contents: Facebook Social Plugins and contents
- This can include content such as images, videos or text and buttons
with which users can share content from this online service within
Facebook. The list and appearance of the Facebook Social Plugins can
be viewed here: https://developers.facebook.com/docs/plugins/; Service
provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal
Harbour, Dublin 2, Irland, Mutterunternehmen: Facebook, 1 Hacker Way,
Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy
Policy: https://www.facebook.com/about/privacy; Opt-Out: Settings for
advertisements: https://www.facebook.com/settings?tab=ads.
• Google Fonts: We integrate the fonts ("Google Fonts") of the
provider Google, whereby the data of the users are used solely for
purposes of the representation of the fonts in the browser of the
users. The integration takes place on the basis of our legitimate
interests in a technically secure, maintenance-free and efficient use
of fonts, their uniform presentation and consideration of possible
licensing restrictions for their integration. 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://fonts.google.com/; Privacy Policy:
https://policies.google.com/privacy.
• Google Maps: We integrate the maps of the service "Google Maps" from
the provider Google. The data processed may include, in particular, IP
addresses and location data of users, which are not collected without
their consent (usually within the framework of the settings of their
mobile devices); 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://cloud.google.com/maps-platform; Privacy Policy:
https://policies.google.com/privacy; Opt-Out: Opt-Out-Plugin:
https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the
Display of Advertisements:
https://adssettings.google.com/authenticated.
• Instagram plugins and contents: Instagram plugins and contents -
This can include content such as images, videos or text and buttons
with which users can share content from this online service within
Instagram . Service provider: https://www.instagram.com, Instagram
Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website:
https://www.instagram.com; Privacy Policy:
https://instagram.com/about/legal/privacy.
• LinkedIn plugins and contents: LinkedIn plugins and contents - This
can include content such as images, videos or text and buttons with
which users can share content from this online service within
LinkedIn. Service provider: LinkedIn Ireland Unlimited Company, Wilton
Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy
Policy: https://www.linkedin.com/legal/privacy-policy; Opt-Out:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• Twitter plugins and contents: Twitter plugins and buttons - This can
include content such as images, videos or text and buttons with which
users can share content from this online service within Twitter.
Service provider: Twitter International Company, One Cumberland Place,
Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter
Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA;
Website: https://twitter.com; Privacy Policy:
https://twitter.com/en/privacy.
• YouTube videos: Video contents; 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://www.youtube.com; Privacy Policy:
https://policies.google.com/privacy; Opt-Out: Opt-Out-Plugin:
https://tools.google.com/dlpage/gaoptout?hl=en, Settings for the
Display of Advertisements:
https://adssettings.google.com/authenticated.
We use services, platforms and software from other providers
(hereinafter referred to as " third-party providers") for the purposes
of organizing, administering, planning and providing our services.
When selecting third-party providers and their services, we comply
with the legal requirements.
Within this context, personal data may be processed and stored on the
servers of third-party providers. This may include various data that
we process in accordance with this privacy policy. This data may
include in particular master data and contact data of users, data on
processes, contracts, other processes and their contents.
If users are referred to the third-party providers or their software
or platforms in the context of communication, business or other
relationships with us, the third-party provider processing may process
usage data and metadata that can be processed by them for security
purposes, service optimisation or marketing purposes. We therefore ask
you to read the data protection notices of the respective third party
providers.
Information on legal basis: If we ask the users for their consent to
the use of third party providers, the legal basis of the processing is
consent. Furthermore, the processing can be a component of our
(pre)contractual services, provided that the use of the third party
was agreed within this context. Otherwise, user data will be 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 privacy policy.
• Processed data types: Inventory data (e.g. names, addresses),
Contact data (e.g. e-mail, telephone numbers), Content data (e.g. text
input, photographs, videos), Usage data (e.g. websites visited,
interest in content, access times), Meta/communication data (e.g.
device information, IP addresses).
• Data subjects: Communication partner (Recipients of e-mails,
letters, etc.), Users (e.g. website visitors, users of online
services).
• Legal Basis: Consent (Article 6 (1) (a) GDPR), Performance of a
contract and prior requests (Article 6 (1) (b) GDPR), Legitimate
Interests (Article 6 (1) (f) GDPR).
The data processed by us will be erased in accordance with the
statutory provisions as soon as their processing is revoked or other
permissions no longer apply (e.g. if the purpose of processing this
data no longer applies or they are not required for the purpose).
If the data is not deleted because they are required for other and
legally permissible purposes, their processing is limited to these
purposes. This means that the data will be restricted and not
processed for other purposes. This applies, for example, to data that
must be stored for commercial or tax reasons or for which storage is
necessary to assert, exercise or defend legal claims or to protect the
rights of another natural or legal person.
Further information on the erasure of personal data can also be found
in the individual data protection notices of this privacy policy.
We kindly ask you to inform yourself regularly about the contents of
our data protection declaration. We will adjust the privacy policy as
changes in our data processing practices make this necessary. We will
inform you as soon as the changes require your cooperation (e.g.
consent) or other individual notification.
If we provide addresses and contact information of companies and
organizations in this privacy policy, we ask you to note that
addresses may change over time and to verify the information before
contacting us.
As data subject, you are entitled to various rights under the GDPR,
which arise in particular from Articles 15 to 21 of the GDPR:
• Right to Object: You have the right, on grounds arising from your
particular situation, to object at any time to the processing of your
personal data which is based on letter (e) or (f) of Article 6(1) GDPR
, including profiling based on those provisions.Where personal data
are processed for direct marketing purposes, you have the right to
object at any time to the processing of the personal data concerning
you for the purpose of such marketing, which includes profiling to the
extent that it is related to such direct marketing.
• Right of withdrawal for consents: You have the right to revoke
consents at any time.
• Right of access: You have the right to request confirmation as to
whether the data in question will be processed and to be informed of
this data and to receive further information and a copy of the data in
accordance with the provisions of the law.
• Right to rectification: You have the right, in accordance with the
law, to request the completion of the data concerning you or the
rectification of the incorrect data concerning you.
• Right to Erasure and Right to Restriction of Processing: In
accordance with the statutory provisions, you have the right to demand
that the relevant data be erased immediately or, alternatively, to
demand that the processing of the data be restricted in accordance
with the statutory provisions.
• 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 request its transmission to another controller.
• Complaint to the supervisory authority: You also have the right,
under the conditions laid down by law, 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
if you consider that the processing of personal data relating to you
infringes the GDPR.
This section provides an overview of the terms used in this privacy
policy. Many of the terms are drawn from the law and defined mainly in
Article 4 GDPR. The legal definitions are binding. The following
explanations, on the other hand, are intended above all for the
purpose of comprehension. The terms are sorted alphabetically.
• Controller: "Controller" means the natural or legal person, public
authority, agency or other body which, alone or jointly with others,
determines the purposes and means of the processing of personal data.
• Conversion tracking: Conversion tracking is a method used to
evaluate the effectiveness of marketing measures. For this purpose, a
cookie is usually stored on the devices of the users within the
websites on which the marketing measures take place and then called up
again on the target website (e.g. we can thus trace whether the
advertisements placed by us on other websites were successful).
• IP Masking: IP masking is a method by which the last octet, i.e. the
last two numbers of an IP address, are deleted so that the IP address
alone can no longer be used to uniquely identify a person. IP masking
is therefore a means of pseudonymising processing methods,
particularly in online marketing.
• Interest-based and behavioral marketing: Interest-related and/or
behaviour-related marketing is the term used when potential user
interest in advertisements and other content is predicted if possible.
This is done on the basis of information on the previous behaviour of
users (e.g. visiting and staying on certain websites, purchasing
behaviour or interaction with other users), which is stored in a
so-called profile. For these purposes cookies are usually used.
• Location data: Location data is created when a mobile device (or
another device with the technical requirements for a location
determination) connects to a radio cell, a WLAN or similar technical
means and functions of location determination. Location data serve to
indicate the geographically determinable position of the earth at
which the respective device is located. Location data can be used, for
example, to display map functions or other information dependent on a
location.
• Personal Data: "personal data" means any information relating to an
identified or identifiable natural person ("data subject"); an
identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a
name, an identification number, location data, an online identifier or
to one or more factors specific to the physical, physiological,
genetic, mental, economic, cultural or social identity of that natural
person.
• Processing: The term "processing" covers a wide range and
practically every handling of data, be it collection, evaluation,
storage, transmission or erasure.
• Profiling: "Profiling" means any automated processing of personal
data consisting in the use of such personal data to analyse, evaluate
or predict certain personal aspects relating to a natural person
(depending on the type of profiling, this includes information
regarding age, gender, location and movement data, interaction with
websites and their contents, shopping behaviour, social interactions
with other people) (e.g. interests in certain contents or products,
click behaviour on a website or the location). Cookies and web beacons
are often used for profiling purposes.
• Remarketing: Remarketing" or "retargeting" is the term used, for
example, to indicate for advertising purposes which products a user is
interested in on a website in order to remind the user of these
products on other websites, e.g. in advertisements.
• Targeting: Tracking" is the term used when the behaviour of users
can be traced across several websites. As a rule, behavior and
interest information with regard to the websites used is stored in
cookies or on the servers of the tracking technology providers
(so-called profiling). This information can then be used, for example,
to display advertisements to users presumably corresponding to their
interests.
• Web Analytics: Web Analytics serves the evaluation of visitor
traffic of online services and can determine their behavior or
interests in certain information, such as content of websites. With
the help of web analytics, website owners, for example, can recognize
at what time visitors visit their website and what content they are
interested in. This allows them, for example, to optimize the content
of the website to better meet the needs of their visitors. For
purposes of web analytics, pseudonymous cookies and web beacons are
frequently used in order to recognise returning visitors and thus
obtain more precise analyses of the use of an online service.