Privacy policy
1. Data privacy at a glance
General notes
In the following, please find a clear overview of what happens with your personal data when you visit this website. Personal data means all data which can be used to identify you personally. For detailed information on data protection, please refer to the data protection declaration set out below this section.
Data collection on this website
Who is responsible for the collection of data on this website?
The data processing on this website is handled by the website operator. The contact details of the operator can be found in the section “Information on the controller” of this privacy policy.
How do we collect your data?
Your data can be collected when you provide us with it. This may for instance involve data which you enter into a contact form.
Other data are automatically collected by our IT systems when you visit our website, either automatically or with your consent. These are in particular technical data (e.g. Internet browser, operating system or time of access). Such data is collected automatically whenever you access this website.
What do we use your data for?
Some of the data is collected to ensure a smooth provision and functioning of the website. Other data can be used to analyse your user behaviour.
What rights do you have with regard to your data?
You have the right to request information on the origin, recipient and purpose of your personal data stored by us at any time and free of charge. Furthermore, you have the right to request the rectification or erasure of such data. If you have given your consent to data processing, you can withdraw this consent at any time with effect for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. In addition, you have the right to lodge and appeal at the competent supervisory authority.
If you have any questions on data privacy issues, you can contact us at any time.
Analytics tools and third-party tools
When you visit this website, your surfing behaviour can be statistically evaluated. This is mainly carried out using so-called analytics programs.
Detailed information on these analytics programs can be found in the following privacy policy.
2. Hosting
We use the following provider to host the content of our website:
External hosting
This website is hosted externally. The personal data collected on this website are stored on the servers of the host(s). This may include IP addresses, contact requests, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.
External hosting is carried out for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 (1) (b) GDPR) and in the interest of a secure, fast and efficient provision of our web services by a professional provider (Art. 6 (1) lit. f GDPR). If a consent has been requested in this respect, the processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR and Section 25 (1) of the Act on Data Protection and the Protection of Privacy in Telecommunications and Telemedia (TTDSG), insofar as the consent includes the installation of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.
Our host(s) will only process your data to the extent necessary to fulfil their performance obligations and follow our instructions with regard to this data.
We use the following host(s):
WorNet Aktiengesellschaft Bürgermeister-Graf-Ring 28
82538 Geretsried-Gelting
Order processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract prescribed by data protection law, which guarantees that it processes the personal data of the visitors to our website solely in accordance with our instructions and in compliance with the GDPR.
3. General notes and mandatory information
Data privacy
The operators of this website take the protection of your personal data very seriously. We handle your personal data confidentially and in accordance with the statutory data protection regulations and this data protection declaration.
When using this website, various personal data is collected. Personal data means data which can be used to identify you personally. This data protection declaration explains which data we collect and for what we use them. It also specifies how and for what purpose this occurs.
We would like to point out that the transmission of data on the Internet (e.g. within the scope of email communication) may be subject to security loopholes. A complete protection of the data from the third-party access is not possible.
Information on the controller
The controller for the processing of data on this website is:
DATA MODUL Aktiengesellschaft Produktion und Vertrieb von elektronischen Systemen Landsberger Str. 322
80687 Munich
Telephone: +49 (0) 89 56017 0
Email: info@data-modul.com
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 (e.g. names, email addresses, etc.).
Storage period
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain stored with us until the purpose for data processing no longer applies. If you assert a justified request for erasure or withdraw your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your
personal data (e.g. retention periods under tax or commercial law); in the latter case, the erasure shall be carried out after these reasons cease to apply.
General information on the legal bases for data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR and insofar as special categories of data are processed in accordance with Art. 9 (1) GDPR. In the event of the express granting consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 (1) lit. a GDPR. If you have consented to the storage of cookies or access to information in your end device (e.g. via device fingerprinting), the data processing is also carried out on the basis of Section 25 (1) GDPR. Consent can be withdrawn at any time. If your data is required for the fulfilment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 (1) lit. b GDPR. Furthermore, we process your data if this is necessary to fulfil a legal obligation on the basis of Art. 6 (1) lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest in accordance with Art. 6 (1) lit. f GDPR. In the following paragraphs, this privacy policy provides information on the relevant legal bases in each individual case is provided.
Data protection officer
We have appointed a data protection officer.
PRIOLAN GmbH
Steinsfeldstr. 46
74626 Bretzfeld
Phone 07946 9893516
Email: datenschutz(at)data-modul.com
(Please use this email address only for data privacy related questions and concerns)
Note on the transfer of data to third countries that are not regarded as safe under data protection law and the transfer to US companies that are not DPF-certified.
Among other things, we use tools from companies based in third countries that are not secure under data protection law and US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). If these tools are active, your personal data may be transferred to these countries and processed there. We would like to point out that no level of data protection comparable to that in the EU can be guaranteed in third countries that are unsafe under data protection law.
We would like to point out that the USA, as a safe third country, generally has a level of data protection comparable to that of the EU. Data transfer to the USA is therefore permitted if the recipient is certified under the “EU-US Data Privacy Framework” (DPF) or is equipped with appropriate additional guarantees. Information on transfers to third countries, including the data recipients, can be found in this privacy policy.
Recipients of personal data
As part of our business activities, we work together with various external organisations. In some cases, it is also necessary to transfer personal data to these external organisations.
We only pass on personal data to external bodies if this is necessary for the fulfilment of a contract, if we are legally obligated to do so (e.g. passing on data to tax authorities), if we have a legitimate interest in the transfer in accordance with Art. 6 (1) lit. f GDPR or if another legal basis permits the transfer of data. When working with processors, we only pass on the personal data of our customers on the basis of a valid contract for order processing. In the case of joint processing, a joint processing agreement is concluded.
Withdrawal of your consent regarding data processing
Many data processing operations may only be carried out with your express consent. You can withdraw any already granted content at any time This shall however not affect the lawfulness of any data processed before the withdrawal.
Right to object to the collection of data in special cases and to direct marketing (Art. 21 GDPR)
IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ARTICLE 6 (1) LIT. (E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME ON GROUNDS RELATING TO YOUR SPECIFIC SITUATION; THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS OR FOR THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION UNDER ARTICLE (21) (1) GDPR).
IF YOUR PERSONAL DATA 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. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. (21) (2) GDPR).
Right to appeal at the competent supervisory authority
In the event of non-compliance with the provisions of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged non-compliance. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.
Right to data portability
You shall have the right to have the personal data, processed by us on the basis of your consent or automatically for the purpose of contract fulfilment submitted to you or a third party in a commonly used and machine-readable format. If you request the direct transfer of the data to another controller, this shall only occur where technically feasible.
Access, rectification and erasure
Within the scope of the applicable statutory provisions, you may request information on the personal data stored on you as well as their original, recipient, the purpose of their processing and where applicable the rectification or erasure of such data free of charge and at any time. If you have any further questions on data privacy issues, you can contact us at any time.
Right to restriction of processing
In addition, you have the right to request the restriction of the processing of your personal data . To exercise this right, you can contact us at any time. The right to restriction of processing exists in the following cases:
If you contest the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the review, you have the right to request that the processing of your personal data be restricted.
If your personal data were/are being unlawful processed, you can request the restriction of data processing instead of erasure.
If we no longer require your personal data, but you need them for the exercise, defence or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of its erasure.
If you have lodged an objection in accordance with Art. 21 (1) GDPR, a your interests and ours must be weighed up against each other. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data - with the exception of its storage - may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.
SSL or TLS encryption
This website uses a SSL or TLS encryption for security-related reasons and the protection of the transmission of confidential content such as orders or requests sent by you to us as website operator. You can recognise an encrypted connection as the
“http://” in the address bar of your browser will change to “https://” and a padlock will appear.
When the SSL or TLS encryption is activated, the data you are transmitting to us cannot be read by third parties.
Objection to advertising emails
The use of contact details published within the scope of the obligation to provide a legal notice to forward advertising and information material not expressly requested is hereby objected to. The operators of the website expressly reserve the right to take legal action in case of the unrequested forwarding of advertising material, for instance in form of spam emails.
4. Data collection on this website
Cookies
Our webpages use so-called “cookies”. Cookies are small data packets and do not cause any damage to your end device. They are stored on your device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or they are automatically deleted by your web browser.
Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g. cookies for processing payment services).
Cookies have various functions. Many cookies are required for technical reasons, as certain website functions would not work without them (e.g. the shopping basket function or the display of videos). Other cookies can be used to analyse user behaviour or for advertising purposes.
Cookies that are required to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping basket function) or to optimise the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 (1) lit. f GDPR, unless another legal basis is specified. The website operator has a legitimate interest in the storage of necessary cookies, which is the technically flawless and optimised provision of services. If consent to the storage of cookies and comparable recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6 (1) lit. a GDPR and Section 25 (1) TTDSG); such consent can be withdrawn at any time.
You can set your browser to inform you about the placement of cookies on your device and allow the placement of cookies only in individual cases; furthermore, you can allow the placement of cookies only for specific cases or generally reject their placement and also activate the automatic deletion of cookies when closing the browser. The deactivation of cookies may restrict the function of this website.
The privacy policy provides information on which cookies and services are used on this website.
Consent with Usercentrics
This website uses the consent technology of Usercentrics to obtain your consent to the storage of certain cookies on your end device or to the use of certain technologies and to document these in compliance with data protection regulations. The provider of this technology is Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich, Germany, homepage:
https://usercentrics.com/de/ (hereinafter referred to as “Usercentrics”).
When you visit our website, the following personal data are transmitted to Usercentrics:
Your consent(s) or the withdrawal of your consent(s) Your IP address
Information about your browser
Information about your end device
Time of your visit to the website
Geolocation
Furthermore, Usercentrics stores a cookie in your browser in order to be able to assign the granted consents or their revocation to you. The data collected in this way is stored until you ask us to delete it, you delete the Usercentrics cookie yourself or the purpose for storing the data ceases to apply. Mandatory statutory retention obligations remain unaffected.
Usercentrics is used to obtain the legally required consent for the use of certain technologies. The legal basis for this is Art. 6 (1) lit. c GDPR.
Order processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract prescribed by data protection law, which guarantees that it processes the personal data of the visitors to our website solely in accordance with our instructions and in compliance with the GDPR.
Contact form
When using the contact form for sending us requests, we will store your data entered in the contact form including the specified contact details for the purposes of processing your request and for the case of follow-up queries. We will not forward this data without your consent.
This data is processed on the basis of Art. 6 (1) lit. b GDPR if your enquiry is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the enquiries addressed to us (Art. 6 (1) lit. f GDPR) or on your consent (Art. 6 (1) lit. a GDPR) if this has been requested; consent can be withdrawn at any time.
We will keep the data entered by you in the contact form until you request us to delete it, withdraw your consent to the storage of the data or when the purpose for which the data is stored ceases to exist (e.g. once your request has been completed). Mandatory statutory provisions – in particular retention periods – shall remain unaffected of this.
Enquiry by email, telephone or fax
If you contact us by email, telephone or fax, your enquiry including all personal data (name, reason for enquiry) will be stored and processed by us for the purpose of processing your request. We will not forward this data without your consent.
This data is processed on the basis of Art. 6 (1) lit. b GDPR if your enquiry is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the enquiries addressed to us (Art. 6 (1) lit. f GDPR) or on your consent (Art. 6 (1) lit. a GDPR) if this has been requested; consent can be withdrawn at any time.
We will keep the data submitted to us via the contact form until you request us to delete it, withdraw your consent to the storage of the data or when the purpose for which the data is stored ceases to exist (e.g. once your request has been completed). Mandatory statutory provisions – in particular retention periods – shall remain unaffected of this.
5. Social media
Elements of the social network Facebook are integrated on this website. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, according to Facebook, the data collected are also transferred to the USA and other third countries.
An overview of the Facebook social media elements can be found here: https://developers.facebook.com/docs/plugins/?locale=de_DE.
When the social media element is active, a direct connection is established between your end device and the Facebook server. Facebook receives the information that you have visited this website with your IP address. If you click on the “Like” button of Facebook while you are logged into your Facebook account, you can link the content of this website to your Facebook profile.
This allows Facebook to associate your visit to this website with your user account. We would like to point out that, as the provider of the website, we have no knowledge of the content of the transmitted data or its use by Facebook. Further information on this can be found in Facebook’s privacy policy at https://de-de.facebook.com/privacy/explanation.
If consent has been obtained, the above-mentioned service is used on the basis of Art. 6 (1) lit. a GDPR and Section 25 TTDSG. Consent can be withdrawn at any time. If no consent has been obtained, the service is used on the basis of our legitimate interest in the widest possible visibility on social media.
If personal data are collected on our website with the aid of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its transfer to Facebook. The processing carried out by Facebook after forwarding is not part of the joint responsibility. The obligations jointly incumbent on us have been set out in an agreement on joint processing. You can find the wording of the agreement at
https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing data privacy information when using the Facebook tool as well as for the secure implementation of the tool on our website in accordance with data protection law. Facebook is responsible for the data security of Facebook products. You can assert your data subject rights (e.g. right of access) regarding the data processed by Facebook directly with Facebook. If you assert your data subject rights with us, we are obliged to forward them to Facebook.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. For details on this, visit:
https://www.facebook.com/legal/EU_data_transfer_addendum, https://de-de.facebook.com/help/566994660333381 and https://www.facebook.com/policy.php.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt0000000GnywAAC&status=Active
This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Each time you access a page on this website that contains elements of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is then informed that you have visited this website with your IP address. If you click on the “Recommend” button of LinkedIn and are logged into your LinkedIn account, LinkedIn will be able to associate your visit to this website with you and your user account. We would like to point out that, as the provider of the pages, we have no knowledge of the content of the transmitted data or its use by LinkedIn.
If consent has been obtained, the above-mentioned service is used on the basis of Art. 6 (1) lit. a GDPR and Section 25 TTDSG. Consent can be withdrawn at any time. If no consent has been obtained, the service is used on the basis of our legitimate interest in the widest possible visibility on social media.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. For details on this, visit: https://www.linkedin.com/help/linkedin/answer/a1343190/datenubertragung-aus-der-eu-dem-ewr-und-der-%20schweiz?lang=en-US
Further information on this can be found in LinkedIn’ privacy policy at: https://www.linkedin.com/legal/privacy-policy.
This website uses elements of the XING network. The provider is New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany.
Each time you access a page on this website that contains elements of XING, a connection to XING’s servers is established. To the best of our knowledge, no personal data is stored in the process. In particular, no IP addresses are stored, and usage behaviour is not evaluated.
If consent has been obtained, the above-mentioned service is used on the basis of Art. 6 (1) lit. a GDPR and Section 25 TTDSG. Consent can be withdrawn at any time. If no consent has been obtained, the service is used on the basis of our legitimate interest in the widest possible visibility on social media.
Further information on data privacy and the XING Share button can be found in XING’s privacy policy at:
https://www.xing.com/app/share?op=data_protection.
6. Analytics tools and advertising
Google Analytics
This website uses functions of the web analytics service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyse the behaviour of visitors to the website. In doing so, the website operator receives various usage data, such as page views, length of visit, operating systems used and origin of the user. This data is summarised in a user ID and assigned to the respective end device of the website visitor.
We can also use Google Analytics to record your mouse and scroll movements and clicks, among other things. Google Analytics also uses various modelling methods to supplement the data records collected and uses machine learning technologies for data analysis.
Google Analytics uses technologies that enable the recognition of the user for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). The information collected by Google concerning the use of this website is generally transmitted to a Google server in the USA and stored there.
The use of this service is based on your consent in accordance with Art. 6 (1) lit. a GDPR and Section 25 (1) TTDSG. Consent can be withdrawn at any time.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. For details on this, visit:
https://privacy.google.com/businesses/controllerterms/mccs/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt000000001L5AAI&status=Active
Browser plug-in
You can prevent the collection and processing of your data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
You can find more information on how Google Analytics handles user data in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.
Order processing
We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
Hotjar
This website uses Hotjar. The provider is Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe (homepage: https://www.hotjar.com).
Hotjar is a tool for analysing your user behaviour on this website. With Hotjar we can among other things record your mouse and scroll movements and clicks. Hotjar can also determine how long you remain in a certain place with the mouse pointer. Hotjar uses this information to create so-called heat maps, which can be used to determine which website areas are favoured by the visitors.
We can also determine how long you stayed on a page and when you left it. And we can determine at which point you cancelled entering data into a contact form (so-called conversion funnels).
In addition, Hotjar can be used to obtain direct feedback from website visitors. This function serves to improve the online services of the website operator.
Hotjar uses technologies that enable the recognition of the user for the purpose of analysing user behaviour (e.g. cookies or the use of device fingerprinting).
If consent has been obtained, the above-mentioned service is used on the basis of Art. 6 (1) lit. a GDPR and Section 25 TTDSG. Consent can be withdrawn at any time. If no consent has been obtained, this service is used on the basis of Art. 6 (1) lit. f GDPR; the website operator has a legitimate interest to analyse user behaviour, in order to optimise their web services and advertising.
Deactivating Hotjar
If you wish to deactivate data collection by Hotjar, click on the following link and follow the instructions there:
https://www.hotjar.com/policies/do-not-track/
Please note that Hotjar must be deactivated separately for each browser or end device.
For more information about Hotjar and the data collected, please consult Hotjar’s privacy policy at the following link:
https://www.hotjar.com/privacy
7. Newsletter
Newsletter data
If you would like to receive the newsletter offered on the website, you will need to provide an email address as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. No further data is collected, or if so, only on a voluntary basis. We use the newsletter service providers described below to process the newsletter.
CleverReach
This website uses CleverReach to send newsletters. The provider is CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany (hereinafter referred to as “CleverReach”). CleverReach is a service that can be used to organise and analyse the sending of newsletters. The data you enter for the purpose of receiving the newsletter (e.g. email address) is stored on the servers of CleverReach in Germany or Ireland.
Our newsletters sent with CleverReach enable us to analyse the behaviour of newsletter recipients. Among other things, we can analyse how many recipients have opened the newsletter message and how often which link in the newsletter was clicked on. Conversion tracking can also be used to analyse whether a predefined action (e.g. purchase of a product on this website)
has taken place after clicking on the link in the newsletter. Further information on data analysis by CleverReach newsletters can be found at: https://www.cleverreach.com/en-de/newsletter-tool/newsletter-reporting/.
The data processing is carried out on the basis of your consent (Art. 6 (1) lit. a GDPR). You can withdraw this consent at any time by unsubscribing from the newsletter. The lawfulness of the data processing operations that have already taken place remains unaffected by the revocation.
If you do not want CleverReach to analyse your data, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter.
The data you provide us with for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored by us for other purposes remains unaffected by this.
After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist if this is necessary to prevent future mailings. The data from the blacklist will be used for this purpose only and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 (1) lit. f GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.
You can find more details on this in CleverReach’s privacy policy at: https://www.cleverreach.com/en-de/privacy-policy/.
Order processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract prescribed by data protection law, which guarantees that it processes the personal data of the visitors to our website solely in accordance with our instructions and in compliance with the GDPR.
8. Plug-ins and tools
YouTube
This website embeds videos from the YouTube website. The operator of the website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
When you visit one of our websites on which YouTube is integrated, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited.
Furthermore, YouTube can store various cookies on your end device or use comparable technologies to recognise you (e.g. device fingerprinting). This way, YouTube can obtain information about visitors to this website. This information is then used, among other things, to record video statistics, improve user-friendliness and prevent fraud attempts.
If you are logged into your YouTube account, you enable YouTube to assign your surfing behaviour directly to your personal profile. You can prevent this by logging out of your YouTube account.
The use of YouTube is in the interest of an appealing presentation of our online services. This qualifies as a legitimate interest as defined by Art. 6 (1) lit. f GDPR. If a consent has been requested in this respect, the processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR and Section 25 (1) of the Act on Data Protection and the Protection of Privacy in Telecommunications and Telemedia (TTDSG), insofar as the consent includes the installation of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.
More information on the handling of user data can be found in YouTube’s privacy policy at:
https://policies.google.com/privacy?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt000000001L5AAI&status=Active
Adobe Fonts
This website uses Adobe web fonts for the standardised display of specific fonts. The provider is Adobe Systems Incorporated, 345 Park Avenue, San Jose, CA 95110-2704, USA (Adobe).
When you access this website, your browser loads the required fonts directly from Adobe in order to display them correctly on your device. In doing so, your browser establishes a connection to Adobe’s servers in the USA. This informs Adobe that this website has been accessed via your IP address. According to Adobe, no cookies are stored when the fonts are provided. Consent is generated by the Consent Tool.
The data are stored and analysed on the basis of Art. 6 (1) lit. f GDPR. The website operator has a legitimate interest in the uniform presentation of the typeface on its website. If a consent has been requested in this respect, the processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR and Section 25 (1) of the Act on Data Protection and the Protection of Privacy in Telecommunications and Telemedia (TTDSG), insofar as the consent includes the installation of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. For details on this, visit:
https://www.adobe.com/privacy/eudatatransfers.html.
You can find more information about Adobe Fonts at: https://www.adobe.com/privacy/policies/adobe-fonts.html.
You can find Adobe’s privacy policy at: https://www.adobe.com/privacy/policy.html
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt0000000TNo9AAG&status=Active
Google Maps
This website uses the map service Google Maps. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
To use the functions of Google Maps it is necessary to adapt your IP address. This information is generally transmitted to a Google server in the USA, where it is stored. The operator of this website has not influence on the transmission of this data. If Google Maps is activated, Google may use Google Fonts for the purpose of uniform representation of fonts. When calling up Google Maps, your browser will load the required web fonts into the cache of your browser to correctly display the texts and font types.
The use of Google Maps is in the interest of an appealing presentation of our online services and enables it to easily find the sites specified on our website. This qualifies as a legitimate interest as defined by Art. 6 (1) lit. f GDPR. If a consent has been requested in this respect, the processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR and Section 25 (1) of the Act on Data Protection and the Protection of Privacy in Telecommunications and Telemedia (TTDSG), insofar as the consent includes the installation of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be withdrawn at any time.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. For details on this, visit:
https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.
More information on the handling of user data can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt000000001L5AAI&status=Active
9. Audio and video conferencing
Data processing
We use online conferencing tools, among others, to communicate with our customers. The individual tools we use are listed below. If you communicate with us by video or audio conference via the Internet, your personal data will be collected and processed by us and the provider of the respective conferencing tool.
The conferencing tools collect all data that you provide/enter to use the tools (email address and/or your telephone number). The conferencing tools also process the duration of the conference, the start and end (time) of participation in the conference, the number of participants and other
“contextual information” related to the communication process (meta data).
Furthermore, the provider of the tool processes all technical data required for the processing of online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.
If content is exchanged, uploaded or provided in any other way within the tool, this is also stored on the servers of the tool provider. Such content in particular includes cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared while using the service.
Please note that we do not have full control over the data processing operations of the tools used. Our options are largely determined by the company policy of the respective provider. More information on data processing by the conferencing tools can be found in the privacy policies of the tools used, which we have listed below this section.
Purpose and legal bases
The conferencing tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 (1) lit. b GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6 (1) lit. f GDPR). If consent has been requested, the relevant tools are used on the basis of this consent; consent can be withdrawn at any time with effect for the future.
Storage period
The data collected directly by us via the video and conferencing tools will be deleted from our systems as soon as you ask us to delete it, withdraw your consent to storage or the purpose for data storage no longer applies. Stored cookies remain on your end device until you delete them. Mandatory statutory retention periods remain unaffected.
We have no influence on the storage period of your data stored by the operators of the conferencing tools for their own purposes. For details, please contact the operators of the conference tools directly.
Conferencing tools used
We use the following conferencing tools:
Microsoft Teams
We use Microsoft Teams. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Details on data processing can be
found in the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt0000000KzNaAAK&status=Active
Order processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract prescribed by data protection law, which guarantees that it processes the personal data of the visitors to our website solely in accordance with our instructions and in compliance with the GDPR.
10. Own services
Handling of job applicant data
We offer you the opportunity to send us job applications (e.g. by email, post or via the online application form). Below, we have put together some information about the scope, purpose and use of your personal data collected as part of the application process. We assure you that your data will be collected, processed and used in accordance with applicable data protection law and all other statutory provisions and that your data will be treated as strict confidential.
Scope and purpose of data collection
If you send us an application, we will process your associated personal data (e.g. contact and communication data, application documents, notes taken during interviews, etc.) to the extent necessary to decide on the conclusion of an employment relationship. The legal basis for this is Section 26 of the Federal Data Protection Act (BDSG) under German law (Initiation of an employment relationship), Art. 6 (1) lit. b GDPR (general contract initiation) and - if you have given your consent - Art. 6 (1) lit. a GDPR. Consent can be withdrawn at any time. Your personal data will only be passed on within our company to persons who are involved in processing your application.
If the application is successful, the data submitted by you will be stored in our data processing systems on the basis of Section 26 BDSG and Art. 6 (1) lit. b GDPR for the purpose of implementing the employment relationship.
Retention period of application data
If we are unable to make you a job offer, you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the grounds of our legitimate interests (Art. 6 para. 1 (f) GDPR) for up to 6 months from the end of the application process (rejection or withdrawal of the application).
The data will then be erased and the physical application documents destroyed. The retention serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be still be needed after expiry of the 6-month period (e.g. due to an impending or pending legal dispute), the data will only be erased after the purpose for further storage no longer applies.
Longer storage may also occur if you have given your consent (Art. 6 (1) lit. a GDPR) or if statutory retention obligations prevent deletion.
Entry in the applicant pool
If we do not make you a job offer, there is the option of entering you in our applicant pool. If you are accepted, all documents and details from your application will be entered into the applicant pool in order to contact you in the event of suitable vacancies.
Entry in the applicant pool is based exclusively on your express consent (Art. 6 (1) lit. a GDPR). Giving your consent is voluntary and in no way related to the current application process. The data subject can withdraw their consent at any time. In this case, the data will be irrevocably erased from the applicant pool, provided there are no legal grounds for retention.
The data from the applicant pool will be irrevocably erased no later than two years after consent has been granted.
The data transmitted as part of your application will be transferred via TLS encryption and stored in a database. This database is operated by Personio GmbH, which offers personnel administration and applicant management software (https://www.personio.com/legal-notice/). In this context, Personio is our processor in accordance with Art. 28 GDPR. The basis for the processing is an order processing contract between us as the controller and Personio.
Rights of data subjects
If personal data are processed by us as the controller, you as the data subject have certain rights under Chapter III of the EU General Data Protection Regulation (GDPR), depending on the legal basis and purpose of the processing, in particular the right of access (Art. 15 GDPR), the right to rectification (Art. 16 GDPR), the right to erasure (Art. 17 GDPR), the right to restriction of processing (Art. 20 GDPR) and the right to object (Art. 21 GDPR). If the processing of personal data is based on your consent, you have the right to withdraw this consent in accordance with Art. 7 III GDPR. To assert your rights as a data subject in relation to the data processed in this online application procedure, please contact our data protection officer.