Privacy policy
Preamble
With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
Status: September 25, 2024
Table of contents
- Preamble
- Person responsible
- Contact data protection officer
- Overview of processing
- Relevant legal bases
- Security measures
- Transmission of personal data
- Internationale Datentransfers
- General information on data storage and deletion
- Rights of the data subjects
- Business processes and procedures
- Providers and services used in the course of business activities
- Credit check
- Provision of the online offer and web hosting
- Use of cookies
- Blogs and publication media
- Contact and request management
- Artificial intelligence (AI)
- Video conferences, online meetings, webinars and screen sharing
- Cloud Service
- Newsletter and electronic notifications
- Advertising communication via e-mail, post, fax or telephone
- Web analysis, monitoring and optimization
- Onlinemarketing
- Presence in social networks (social media)
- Plug-ins and embedded functions and content
- Management, organization and support tools
- Processing of data in the context of employment relationships
- Application procedure
- Change and update
- Definitions of terms
Person responsible
ReiCat GmbH
To the waiting tower 7
63571 Gelnhausen
Persons authorized to represent the company: Sophia Höfling
E-mail address: legal@reicat.de
Imprint: www.reicat.com/en/imprint
Contact data protection officer
Dipl.-Ing. Michael Höfling
legal@reicat.de
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of data processed
- File dates.
- Employee data.
- Payment data.
- Contact details.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and process data.
- Social data.
- Applicant data.
- Image and/or video recordings.
- Sound recordings.
- Contact information (Facebook).
- Event data (Facebook).
- Protocol data.
- Performance and behavior data.
- Working time data.
- Creditworthiness data.
- Salary data.
Special categories of data
- Health data.
- Religious or ideological beliefs.
- Trade union membership.
Categories of affected persons
- Beneficiary and client.
- Employees.
- Interested parties.
- Communication partner.
- Users.
- Applicants.
- Business and contractual partners.
- Persons depicted.
- Third parties.
- Customers.
Purposes of the processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Safety measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organizational procedures.
- Remarketing.
- Conversion measurement.
- Target group formation.
- Organizational and administrative procedures.
- Application procedure.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online services and user-friendliness.
- Assessment of creditworthiness and credit standing.
- Establishment and implementation of employment relationships.
- Information technology infrastructure.
- Financial and payment management.
- Public relations.
- Sales promotion.
- Business processes and business management procedures.
- Artificial intelligence (AI).
Automated decisions in individual cases
- Credit report.
Relevant legal bases
Relevant legal bases according to the GDPR:Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR)– The data subject has given their consent to the processing of their personal data for one or more specific purposes.
- Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)– Processing is necessary for the 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.
- Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR)– The processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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.
- Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR)– Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application procedure so that the controller or the data subject can exercise the rights arising from labor law and social security and social protection law and fulfill their obligations in this regard, their processing is carried out in accordance with Art. 9 para. 2 lit. b. GDPR. GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. 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 diagnosis, health or social care or treatment or for the management of health or social care systems and services in accordance with Art. 9 para. 2 lit. h. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 para. 2 lit. a. GDPR.
- Processing of special categories of personal data relating to healthcare, employment and social security (Art. 9 (2) (h) GDPR)– Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of an employee’s fitness for work, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care systems and services on the basis of Union or Member State law or on the basis of a contract with a health professional.
National data protection regulations in Germany:In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases, including profiling. The data protection laws of the individual federal states may also apply.Relevant legal basis according to the Swiss Data Protection Act:If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (“Swiss FADP” for short). Unlike the GDPR, for example, the Swiss FADP does not generally require that a legal basis for the processing of personal data be specified and that the processing of personal data be carried out in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss FADP). In addition, personal data will only be obtained by us for a specific purpose that is recognizable to the data subject and will only be processed in a manner that is compatible with this purpose (Art. 6 para. 3 of the Swiss FADP).Reference to validity of GDPR and Swiss DPA:This data protection notice serves to provide information in accordance with both the Swiss Data Protection Act (DSG) and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “sensitive personal data” used in the Swiss DPA, the terms “processing” of “personal data”, “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.
Security measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection 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, input, disclosure, safeguarding availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.
Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not required, the IP address is truncated (also known as “IP masking”). The last two digits or the last part of the IP address after a dot are removed or replaced by placeholders. The purpose of shortening the IP address is to prevent or make it significantly more difficult to identify a person by their IP address.
Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.
Transmission of personal data
As part of our processing of personal data, it may be transmitted to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the group of companies: Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to it. This data transfer takes place on the basis of our legitimate business and commercial interests. This includes, for example, improving business processes, ensuring efficient and effective internal communication, optimizing the use of our human and technological resources and enabling us to make informed business decisions. In certain cases, the transfer of data may also be necessary in order to fulfill our contractual obligations, or it may be based on the consent of the data subject or legal permission.
Internationale Datentransfers
Data processing in third countries: 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 the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de. As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection for certain companies from the USA as secure within the framework of the adequacy decision of 10.07.2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.
Disclosure of personal data abroad: In accordance with the Swiss FADP, we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss FADP). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international contracts, specific safeguards, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations recognized in advance by the FDPIC or a competent data protection authority in another country. According to Art. 16 of the Swiss DPA, exceptions may be made for the disclosure of data abroad if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements. As part of the so-called “Data Privacy Framework” (DPF), the Swiss have recognized the level of data protection for certain companies from the USA as secure as part of the adequacy decision of 07.06.2024. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.
General information on data storage and deletion
We delete personal data that we process in accordance with the statutory provisions as soon as the underlying consents are revoked or there is no further legal basis for the processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.
In particular, data that must be stored for commercial or tax law reasons or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons must be archived accordingly.
Our data protection information contains additional information on the retention and deletion of data that applies specifically to certain processing operations.
If there is more than one information on the retention period or deletion period of a date, the longest period is always decisive.
If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in the context of which data is stored, the event triggering the deadline is the date on which the termination or other termination of the legal relationship takes effect.
We only process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, for the reasons that justify its storage.Further information on processing operations, procedures and services:
- Storage and deletion of data:The following general time limits apply to storage and archiving in accordance with German law:
- 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organizational documents, accounting documents and invoices required for their understanding (§ 147 para. 3 in conjunction with para. 1 no. 1, 4 and 4a AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 and 4, para. 4 HGB).
- 6 years – Other business documents: commercial or business letters received, reproductions of commercial or business letters sent, other documents insofar as they are of significance for taxation, e.g. Hourly wage slips, company accounting sheets, calculation documents, price markings, but also payroll accounting documents, insofar as they are not already accounting documents and cash register strips (§ 147 para. 3 in conjunction with para. 1 no. 2, 3, 5 AO, § 257 para. 1 no. 2 and 3, para. 4 HGB).
- 3 years – Data required to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries based on past business experience and standard industry practices will be stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
- Storage and deletion of data:The following general time limits apply to storage and archiving in accordance with Swiss law:
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- 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheets, accounting vouchers and invoices as well as all necessary work instructions and other organizational documents (Art. 958f of the Swiss Code of Obligations (CO)).
- 10 years – Data necessary for the consideration of potential claims for damages or similar contractual claims and rights, as well as for the processing of related inquiries based on past business experience and standard industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Art. 127, 130 CO). Claims for rent, lease and capital interest as well as other periodic services, from the supply of food, for catering and for debts to landlords, as well as from handicraft work, retail sale of goods, medical care, professional work of lawyers, legal agents, procurators and notaries and from the employment relationship of employees expire after five years (Art. 128 CO).
Rights of the data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent:You have the right to withdraw your consent at any time.
- Right to information:You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
- Right to rectification:In accordance with the legal requirements, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
- Right to erasure and restriction of processing:In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.
- Right to data portability:You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
- Complaint to the supervisory authority:In accordance with the statutory provisions and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you are habitually resident, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.
Rights of data subjects under the Swiss DPA:
As a data subject, you are entitled to the following rights in accordance with the provisions of the Swiss DPA:
- Right to information:You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to exercise your rights under this law and to ensure transparent data processing.
- Right to data output or transfer:You have the right to request that the personal data you have provided to us be made available to you in a commonly used electronic format.
- Right to rectification:You have the right to request the correction of incorrect personal data concerning you.
- Right to object, erasure and destruction:You have the right to object to the processing of your data and to request that the personal data concerning you be deleted or destroyed.
Business processes and procedures
Personal data of service recipients and clients – including customers, clients or, in special cases, clients, patients or business partners as well as other third parties – are processed within the scope of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting and project management.
The data collected is used to fulfill contractual obligations and efficiently design operational processes. This includes the processing of business transactions, the management of customer relationships, the optimization of sales strategies and the guarantee of internal accounting and financial processes. In addition, the data supports the protection of the rights of the controller and promotes administrative tasks and the organization of the company.
Personal data may be passed on to third parties if this is necessary to fulfill the stated purposes or legal obligations. The data will be deleted after expiry of statutory retention periods or if the purpose of the processing no longer applies. This also includes data that must be stored for a longer period of time due to tax and legal obligations to provide evidence.
- Processed data types:Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. text or image messages and contributions and the information relating to them, such as information on authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); log data (e.g. log files relating to logins or data retrieval or access times); usage data (e.g. page views and e-mail addresses, clicks, usage intensity and frequency, devices used or access times). log files relating to logins or the retrieval of data or access times); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); creditworthiness data (e.g. credit score received, estimated probability of default, risk classification based on this, historical payment behavior); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Employee data (information on employees and other persons in an employment relationship).
- Persons concerned:Service recipients and clients; interested parties; communication partners; business and contractual partners; third parties; users (e.g. website visitors, users of online services); employees (e.g. employees, applicants, temporary staff and other employees). Customers.
- Purposes of the processing:Provision of contractual services and fulfilment of contractual obligations; office and organizational procedures; business processes and business management procedures; communication; marketing; sales promotion; public relations; assessment of creditworthiness and credit standing; financial and payment management; security measures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Storage and deletion:Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
Further information on processing operations, procedures and services:
- Kundenmanagement und Customer-Relationship-Management (CRM):Procedures required as part of customer management and customer relationship management (CRM) (e.g. customer acquisition in compliance with data protection requirements, measures to promote customer retention and loyalty, effective customer communication, complaint management and customer service with consideration of data protection, data management and analysis to support the customer relationship, administration of CRM systems, secure account management, customer segmentation and target group formation);Legal basis:Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Contact management and contact maintenance:Procedures required as part of organizing, maintaining and securing contact information (e.g. setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restores of contact information, training employees in the effective use of contact management software, regularly reviewing communication history and adjusting contact strategies);Legal basis:Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- General payment transactions:Procedures required for carrying out payment transactions, monitoring bank accounts and controlling payment flows (e.g. creating and checking transfers, processing direct debits, checking account statements, monitoring incoming and outgoing payments, return debit management, account reconciliation, cash management);Legal basis:Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Accounting, accounts payable, accounts receivable:Procedures required for the recording, processing and control of business transactions in the area of accounts payable and accounts receivable (e.g. creation and checking of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, processing of dunning procedures, account reconciliation in the context of receivables and payables, accounts payable and accounts receivable);Legal basis:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Financial accounting and taxes:Procedures required for the recording, administration and control of financially relevant business transactions as well as for the calculation, reporting and payment of taxes (e.g. account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning procedures, account reconciliation, tax advice, preparation and submission of tax returns, processing of tax matters);Legal basis:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Purchasing:Procedures required in the procurement of goods, raw materials or services (e.g. supplier selection and evaluation, price negotiations, order placement and monitoring, verification and control of deliveries, invoice verification, administration of orders, inventory management, creation and maintenance of purchasing guidelines);Legal basis:Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Distribution:Procedures required for the planning, implementation and control of measures for the marketing and sale of products or services (e.g. customer acquisition, quotation preparation and tracking, order processing, customer advice and support, sales promotion, product training, sales controlling and analysis, management of sales channels);Legal basis:Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Marketing, advertising and sales promotion:Procedures required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group identification, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programs, sales promotion measures, performance measurement and optimization of marketing activities, budget management and cost control);Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Public relations:Procedures required in the context of public relations (e.g. development and implementation of communication strategies, planning and execution of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organization of press conferences and public events, crisis communication, creation of content for social media and company websites, support of corporate branding);Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Guest Wi-Fi:Procedures required when setting up, operating, maintaining and monitoring a wireless network for guests (e.g. installing and configuring Wi-Fi access points, creating and managing guest access, monitoring network connectivity, ensuring network security, troubleshooting connectivity issues, updating network software, complying with data protection regulations);Legal basis:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Providers and services used in the course of business activities
As part of our business activities, we use additional services, platforms, interfaces or plug-ins from third-party providers (“services” for short) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organization.
- Processed data types:Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Contract data (e.g. subject matter of the contract, term, customer category).
- Persons concerned:Service recipients and clients; interested parties; business and contractual partners. Employees (e.g. employees, applicants, temporary staff and other employees).
- Purposes of the processing:Provision of contractual services and fulfilment of contractual obligations; office and organizational procedures. Business processes and business management procedures.
- Storage and deletion:Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- DATEV:Software for accounting, communication with tax consultants and authorities and with document storage;Service provider:DATEV eG, Paumgartnerstr. 6 – 14, 90429 Nuremberg, Germany;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);Website: https://www.datev.de/web/de/mydatev/datev-cloud-anwendungen/; Privacy policy: https://www.datev.de/web/de/m/ueber-datev/datenschutz/; Order processing contract: Provided by the service provider. Basis for third country transfers: Switzerland – Adequacy decision (Germany).
Credit check
If we make advance payments or enter into comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from specialized service companies (credit agencies) in order to safeguard our legitimate interests.
We process the information received from the credit agencies on the statistical probability of a payment default as part of an appropriate discretionary decision on the establishment, execution and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.
The decision as to whether we make advance payment is made in accordance with the legal requirements solely on the basis of an automated decision in individual cases, which our software makes on the basis of the information provided by the credit agency.
If we obtain express consent from contractual partners, the legal basis for the credit report and the transmission of the customer’s data to the credit agencies is consent. If no consent is obtained, the credit report is based on our legitimate interests in the security of our payment claims.
- Processed data types:Inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); contract data (e.g. subject matter of the contract, term, customer category); creditworthiness data (e.g. credit score received, estimated probability of default, risk classification based on this, historical payment behavior). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
- Persons concerned:Service recipients and clients; interested parties. Business and contractual partners.
- Purposes of the processing:Assessment of creditworthiness and credit standing.
- Storage and deletion:Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis:Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Automated decisions in individual cases:Credit report (decision based on a credit check).
Further information on processing operations, procedures and services:
- Verband der Vereine Creditreform e.V.:Credit agency;Service provider:Verband der Vereine Creditreform e.V., Hellersbergstraße 12, D-41460 Neuss, Germany;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);Website: https://www.creditreform.de/; Privacy policy: https://www.creditreform.de/datenschutz. Basis for third country transfers:Switzerland – Adequacy decision (Germany).
Provision of the online offer and web hosting
We process users’ data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device.
- Processed data types:Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved); log data (e.g. log files relating to logins or the retrieval of data or access times). Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Persons concerned:Users (e.g. website visitors, users of online services).
- Purposes of the processing:Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures. Provision of contractual services and fulfillment of contractual obligations.
- Storage and deletion:Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a “web host”); Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks), and also to ensure the utilization of the servers and their stability;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
- E-mail dispatch and hosting: The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and receipt on our server; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Kinsta: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: Kinsta Inc, 8605 Santa Monica Blvd #92581, West Hollywood, CA 90069, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://kinsta.com/de/; Privacy Policy: https://kinsta.com/de/legal/datenschutzpolitik/; Data processing agreement: https://kinsta.com/legal/data-processing-addendum/.
- QualityHosting: Services in the area of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity);Service provider:QualityHosting AG, Uferweg 40-42, 63571 Gelnhausen, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);Website: https://www.qualityhosting.de;Privacy policy: https://www.qualityhosting.de/agb-datenschutz/datenschutzerklaerung.html; Order processing contract: Provided by the service provider. Basis for third country transfers: Switzerland – Adequacy decision (Germany).
Use of cookies
Cookies are small text files or other storage notes that store information on end devices and read it from them. For example, to store the log-in status in a user account, the contents of a shopping cart in an e-shop, the content accessed or the functions used in an online offering. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online services and to analyze visitor flows. Notes on consent:We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide users with a telemedia service they have expressly requested (i.e. our online offering). The revocable consent is clearly communicated to you and contains the information on the respective use of cookies. Information on the legal basis for data protection: The legal basis under data protection law on which we process users’ personal data using cookies depends on whether we ask for their consent. If the users accept, the legal basis for the processing of their data is their declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and the improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we use cookies in the course of this privacy policy or as part of our consent and processing procedures. Storage duration: A distinction is made between the following types of cookies with regard to the storage period:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
- Permanente Cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are permanent and that they may be stored for up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also object to processing in accordance with the legal requirements, also by means of the privacy settings of their browser.
- Processed data types: Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- BorlabsCookie: Consent management: Procedures for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users’ end devices and their processing;Service provider:Execution on servers and/or computers under own data protection responsibility; Website: https://de.borlabs.io/borlabs-cookie/. Further information:An individual user ID, language and types of consent and the time they were given are stored on the server and in the cookie on the user’s device.
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Contact and request management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the inquiring persons are processed insofar as this is necessary to answer the contact inquiries and any requested measures.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other personal or qualification information provided by applicants with regard to a specific position or voluntarily).
- Persons concerned: Communication partner. Applicants.
- Purposes of the processing: Communication; organizational and administrative procedures; feedback (e.g. collecting feedback via online form); provision of our online services and user-friendliness. Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Bitrix24: The CRM system Bitrix24 generates our contact form, which is integrated on the website, to register contact requests; Service provider:Bitrix24 Limited
Frema House, office 102, No. 9
Constantinou Paparigopoulou Str.
3106, Limassol, Cyprus; Website: https://www.bitrix24.de/; Privacy policy: https://www.bitrix24.de/privacy/. Basis for third country transfers:Switzerland – Adequacy decision (Cyprus). - Personio:Recruitment platform and applicant management services (job advertisements, applicant search and application process);Service provider:Personio SE & Co. KG, Seidlstraße 3, 80335 Munich, Germany;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);Website: https://www.personio.de/; Privacy policy: https://www.personio.de/datenschutzerklaerung/. Basis for third country transfers:Switzerland – Adequacy decision (Germany).
Artificial intelligence (AI)
We use artificial intelligence (AI), whereby personal data is processed. The specific purposes and our interest in using AI are set out below. By AI we mean, in accordance with the term “AI system” in Article 3 No. 1 of the AI Regulation, a machine-based system that is designed to operate autonomously to varying degrees, can be adaptable after its introduction and produces results such as predictions, content, recommendations or decisions from the input received, which can influence physical or virtual environments.
Our AI systems are deployed in strict compliance with legal requirements. These include both specific regulations for artificial intelligence and data protection requirements. In particular, we adhere to the principles of legality, transparency, fairness, human control, purpose limitation, data minimization, integrity and confidentiality. We ensure that the processing of personal data always takes place on a legal basis. This can be either the consent of the data subject or legal permission.
When using external AI systems, we carefully select their providers (hereinafter “AI providers”). In accordance with our legal obligations, we ensure that the AI providers comply with the applicable provisions. We also observe the obligations incumbent on us when using or operating the purchased AI services. The processing of personal data by us and the AI providers takes place exclusively on the basis of consent or legal authorization. We attach particular importance to transparency, fairness and the preservation of human control over AI-supported decision-making processes.
We implement appropriate and robust technical and organizational measures to protect the processed data. These ensure the integrity and confidentiality of the processed data and minimize potential risks. By regularly reviewing AI providers and their services, we ensure ongoing compliance with current legal and ethical standards.
- Processed data types:Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Persons concerned:Users (e.g. website visitors, users of online services). Third parties.
- Purposes of the processing:Artificial intelligence (AI).
- Storage and deletion:Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal bases:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- DeepL:Translation of texts into different languages and provision of synonyms and context examples. Support with the correction and improvement of texts in different languages; Service provider:DeepL SE, Maarweg 165, 50825 Cologne, Germany; Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.deepl.com; Privacy policy: https://www.deepl.com/de/privacy; Order processing contract:Provided by the service provider. Basis for third country transfers:Switzerland – Adequacy decision (Germany).
Video conferences, online meetings, webinars and screen sharing
We use platforms and applications of other providers (hereinafter referred to as “conference platforms”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as “conference”). When selecting the conference platforms and their services, we observe the legal requirements. As part of participation in a conference, the conference platforms process the participants’ personal data listed below. The scope of the processing depends on which data is required in the context of a specific conference (e.g. specification of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of holding the conference, the conference platforms may also process participants’ data for security purposes or service optimization. The processed data includes personal data (first name, surname), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants’ end devices, their operating system, the browser and its technical and language settings, information on the content of communication processes, i.e. entries in chats as well as audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If the participants are registered as users with the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider. Logging and recordings: If text entries, participation results (e.g. from surveys) and video or audio recordings are logged, this will be communicated transparently to the participants in advance and – if necessary – they will be asked for their consent. Data protection measures of the participants: For details on the processing of your data by the conferencing platforms, please refer to their data protection notices and select the optimum security and data protection settings for you in the settings of the conferencing platforms. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by informing roommates, locking doors and, if technically possible, using the function to make the background unrecognizable). Links to the conference rooms and access data must not be passed on to unauthorized third parties. Notes on legal bases: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to the recording of conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g. in participant lists, in the case of processing of conference results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); image and/or video recordings (e.g. photographs or video recordings of a person); sound recordings. Log data (e.g. log files relating to logins or the retrieval of data or access times).
- Persons concerned: Communication partners; users (e.g. website visitors, users of online services). Persons depicted.
- Purposes of the processing: Provision of contractual services and fulfillment of contractual obligations; communication. Office and organizational procedures.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Microsoft Teams:Audio and video conferencing, chat, file sharing, integration with Office 365 applications, real-time collaboration on documents, calendar functions, task management, screen sharing, optional recording; Service provider: Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Irland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement
Safety instructions:https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
Cloud Service
We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients or publication of content and information).
In this context, personal data may be processed and stored on the servers of the providers, insofar as these are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content. Cloud service providers also process usage data and metadata that they use for security purposes and to optimize their services.
If we use the cloud services to provide other users or publicly accessible websites with forms or other documents and content, the providers may store cookies on users’ devices for the purposes of web analysis or to remember user settings (e.g. in the case of media control).
- Processed data types:Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Persons concerned:Interested parties; communication partners. Business and contractual partners.
- Purposes of the processing:Office and organizational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
- Storage and deletion:Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Microsoft Cloud Services: Cloud storage, cloud infrastructure services and cloud-based application software;Service provider:Microsoft Irland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Irland;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);Website: https://microsoft.com/de-de; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement
Safety instructions:https://www.microsoft.com/de-de/trustcenter; Order processing contract: https://www.microsoft.com/licensing/docs/view/Microsoft-Products-and-Services-Data-Protection-Addendum-DPA. Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
Newsletter and electronic notifications
We send newsletters, emails and other electronic notifications (hereinafter “newsletter”) exclusively with the consent of the recipient or on the basis of a legal basis. If the contents of the newsletter are mentioned in the context of a registration for the newsletter, these contents are decisive for the consent of the users. To subscribe to our newsletter, it is normally sufficient to provide your e-mail address. However, in order to be able to offer you a personalized service, we may ask you to provide your name so that we can address you personally in the newsletter or to provide further information if this is necessary for the purpose of the newsletter.
Deletion and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a potential defense against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.
The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system. Contents: Information about us, our services, promotions and offers.
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Persons concerned: Communication partner.
- Purposes of the processing: Direct marketing (e.g. by e-mail or post).
- Storage and deletion: 3 years – Contractual claims (AT) (Data necessary to consider potential warranty claims and claims for damages or similar contractual claims and rights, as well as to process related inquiries, based on past business experience and standard industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 1478, 1480 ABGB)). 10 years – Contractual claims (CH) (Data necessary for the consideration of potential claims for damages or similar contractual claims and rights, as well as for the processing of related inquiries, based on past business experience and standard industry practice, will be stored for the statutory limitation period of ten years, unless a shorter period of 5 years applies, which is relevant in certain cases (Art. 127, 130 CO)).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Possibility of objection (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 unsubscribe from the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.
Further information on processing operations, procedures and services:
- Measurement of opening and click rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server or its server, if we use a mailing service provider, when the newsletter is opened. As part of this retrieval, technical information, such as details of the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked on. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The evaluations are used to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening and click rates as well as the storage of the measurement results in the user profiles and their further processing are based on the user’s consent. Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the stored profile information will be deleted; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Bitrix24: CRM system Bitrix24 is used to send emails to our customers and interested parties;Service provider:Bitrix24 Limited
Frema House, office 102, No. 9
Constantinou Paparigopoulou Str.
3106, Limassol, Cyprus; Website: https://www.bitrix24.de/; Privacy policy: https://www.bitrix24.de/privacy/. Basis for third country transfers: Switzerland – Adequacy decision (Cyprus).
Advertising communication via e-mail, post, fax or telephone
We process personal data for the purposes of advertising communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.
Recipients have the right to withdraw their consent at any time or to object to advertising communication at any time.
After revocation or objection, we store the data required to prove the previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the user, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).
- Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers). Content data (e.g. textual or pictorial messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
- Persons concerned: Communication partner.
- Purposes of the processing: Direct marketing (e.g. by e-mail or post); marketing. Sales promotion.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Web analysis, monitoring and optimization
Web analysis (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offer or its functions or content are most frequently used, or invite visitors to reuse them. It also enables us to understand which areas require optimization.
In addition to web analysis, we can also use test procedures, for example to test and optimize different versions of our online offering or its components.
Unless otherwise stated below, profiles, i.e. data summarized for a usage process, may be created for these purposes and information may be stored in a browser or end device and then read out. The information collected includes, in particular, websites visited and the elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data from us or from the providers of the services we use, it is also possible to process location data.
In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective process.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned: Users (e.g. website visitors, users of online services).
- Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); provision of our online offer and user-friendliness; remarketing; conversion measurement (measurement of the effectiveness of marketing measures). Marketing.
- Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Safety measures: IP masking (pseudonymization of the IP address).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Google Analytics: We use Google Analytics to measure and analyze the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognize which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offering and technical aspects of their end devices and browsers.
Pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city’s inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. They are not logged, are not accessible and are not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing;Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland;Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);Website: https://marketingplatform.google.com/intl/de/about/analytics/; Safety measures:IP masking (pseudonymization of the IP address); Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Possibility of objection (opt-out):Opt-Out-Plugin:https://tools.google.com/dlpage/gaoptout?hl=de Settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/(Types of processing and data processed). - Information on consent recipients and cookie-free analysis: Notes on consent recipients: The consent given by users in the context of a consent dialog (also known as “cookie opt-in/consent”, ‘cookie banner’, etc.) serves several purposes. On the one hand, it serves to fulfill our obligation to obtain consent to the storage and reading of information on and from the user’s end device (in accordance with ePrivacy guidelines). Secondly, it covers the processing of users’ personal data in accordance with data protection regulations. In addition, this consent also applies to Google, as the company is obliged under the Digital Markets Act to obtain consent for personalized services. We therefore share the status of the consents given by users with Google. Our consent management software informs Google whether consent has been granted or not. The aim is to ensure that the consents given or not given by users are taken into account when using Google Analytics and when integrating functions and external services. In this way, user consents and their revocation in the context of Google Analytics and other Google services can be dynamically adapted in our online offering depending on the user selection.
Cookie-less analysis: We use the extended implementation of the consent mode of Google Analytics. This means that if users do not give their consent to the storage and reading of information on their end devices – especially with regard to cookies – no cookies or comparable information will be stored on the users’ devices. Likewise, no user profiles are created.
In this case, the Google code generates a random identification number on the user’s device and transmits it to Google (so-called “ping”). The identification number is not stored in the user’s browser, apps or other devices. This identification number is unique for each website visit, so that the behavior or interests of users are not recorded across devices or pages. Only a minimum of information on user activity is sent. This includes information on consent status and information for conversion measurement, i.e. whether a user was directed to our online offering by a Google ad.
In addition, if available, the following information may be transmitted: a) Function-related information such as headers (technical details transmitted by the browser), b) Timestamp (date and time of access), c) User agent (information about the browser and device used, only on the web), d) Referrer URL (the URL of the page from which the user came), e) Summarized/pseudonymous information: This includes an indication of whether the current or a previous page in the user’s navigation history contains ad click information in the URL (e.g. GCLID/DCLID, special tracking codes from Google), a random number generated on each page load, and information about the consent management platform used by the website owner (e.g. developer ID);Service provider:Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://support.google.com/analytics/answer/9976101?hl=de; Privacy policy: https://policies.google.com/privacy. Basis for third country transfers: Switzerland – Adequacy decision (Ireland). - Google Tag Manager: We use Google Tag Manager, a software from Google that enables us to manage so-called website tags centrally via a user interface. Tags are small code elements on our website that are used to record and analyze visitor activity. This technology helps us to improve our website and the content offered on it. The Google Tag Manager itself does not create any user profiles, does not store any cookies with user profiles and does not carry out any independent analyses. Its function is limited to simplifying the integration and management of tools and services that we use on our website and making them more efficient. Nevertheless, when using the Google Tag Manager, the user’s IP address is transmitted to Google, which is necessary for technical reasons in order to implement the services we use. Cookies may also be set in the process. However, this data processing only takes place if services are integrated via the Tag Manager. For more detailed information on these services and their data processing, please refer to the further sections of this privacy policy; Service provider:Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis:Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing contract:
https://business.safety.google/adsprocessorterms. Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
Onlinemarketing
We process personal data for the purpose of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (the so-called “cookie”) or similar procedures are used, by means of which the user information relevant for the presentation of the aforementioned content is stored. This may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) for user protection. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.
The statements in the profiles are generally stored in cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing process and analyzed for the purpose of displaying content and supplemented with further data and stored on the server of the online marketing process provider.
In exceptional cases, it is possible to assign clear data to the profiles, primarily if, for example, the users are members of a social network whose online marketing process we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, for example by giving their consent during registration.
In principle, we only receive access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, 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, for example. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that the cookies used are stored for a period of two years. Notes on legal bases:If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.Information on revocation and objection:We refer to the data protection notices of the respective providers and the opt-out options provided by the providers. If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are summarized for the respective areas:
- (a) Europe:https://www.youronlinechoices.eu.
- b) Canada:https://www.youradchoices.ca/choices.
- c) USA:https://www.aboutads.info/choices.
- d) Cross-territory:https://optout.aboutads.info.
- Processed data types:Content data (e.g. text or image messages and posts and the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved); event data (Facebook) (“event data” is information, for example via meta pixels (whether via apps or other channels). (e.g. IP addresses, time data, identification numbers, persons involved); event data (Facebook) (“event data” is information that is sent to the provider Meta via Meta pixels (whether via apps or other channels) and relates to persons or their actions. This data includes, for example, details of website visits, interactions with content and functions, app installations and product purchases. Event data is processed with the aim of creating target groups for content and advertising messages (custom audiences). It is important to note that event data does not include actual content such as comments written, login information or contact information such as names, email addresses or telephone numbers. “Event data” is deleted by Meta after a maximum of two years, and the target groups created from it disappear when our Meta user accounts are deleted); contact information (Facebook) (“contact information” is data that (clearly) identifies data subjects, such as names, e-mail addresses and telephone numbers, which can be transmitted to Facebook, e.g. via Facebook pixels or uploads for matching purposes in order to create custom audiences. The contact information is deleted after matching for the purpose of creating target groups).
- Persons concerned:Users (e.g. website visitors, users of online services).
- Purposes of the processing:Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavioral profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.
- Storage and deletion:Deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Safety measures:IP masking (pseudonymization of the IP address).
- Legal basis:Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing operations, procedures and services:
- Meta pixel and target group formation (custom audiences):With the help of the meta pixel (or comparable functions, for the transmission of event data or contact information via interfaces in apps), Meta is able to determine the visitors of our online offer as a target group for the display of advertisements (so-called “meta ads”). Accordingly, we use the meta pixel to display the meta ads placed by us only to those users on Meta platforms and within the services of partners cooperating with Meta (so-called “audience network”). https://www.facebook.com/audiencenetwork/) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited), which we transmit to Meta (so-called “custom audiences”). With the help of the meta pixel, we also want to ensure that our meta ads correspond to the potential interest of users and are not annoying. With the help of the meta pixel, we can also track the effectiveness of the meta ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a meta ad (so-called “conversion measurement”); Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland;Legal basis:Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Order processing contract: https://www.facebook.com/legal/terms/dataprocessing; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Further information:Event user data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and target group formation on the basis of the agreement on joint responsibility (“Addendum for Responsible Parties”,https://www.facebook.com/legal/controller_addendum) is processed. The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
- Extended adjustment for the meta pixel:In addition to the processing of event data in the context of the use of the Meta pixel (or comparable functions, e.g. in apps), contact information (data identifying individual persons, such as names, e-mail addresses and telephone numbers) is also collected by Meta within our online offering or transmitted to Meta. The processing of contact information is used to create target groups (so-called “custom audiences”) for the display of content and advertising information based on the presumed interests of users. The collection, transmission and comparison with data available at Meta is not carried out in plain text, but as so-called “hash values”, i.e. mathematical representations of the data (this method is used, for example, to store passwords). After the comparison for the purpose of creating target groups, the contact information is deleted;Legal basis:Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);Privacy policy:Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland;Order processing contract: https://www.facebook.com/legal/terms/dataprocessing; Basis for third country transfers:EU/EWR – Data Privacy Framework (DPF), Schweiz – Data Privacy Framework (DPF).Further information: https://www.facebook.com/legal/terms/data_security_terms.
- Meta – target group education via data upload:Creation of target groups for marketing purposes – We transmit contact information (names, e-mail addresses and telephone numbers) in list form to Meta for the purpose of creating target groups (so-called “custom audiences”) for the display of content and advertising information based on the presumed interests of users. The transmission and comparison with data available at Meta does not take place in plain text, but as so-called “hash values”, i.e. mathematical representations of the data (this method is used, for example, to store passwords). After the comparison for the purpose of creating target groups, the contact information is deleted;Service provider:Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland;Legal basis:Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR);Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/;Order processing contract: https://www.facebook.com/legal/terms/dataprocessing. Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Instagram ads:Placement of advertisements within the Instagram platform and evaluation of the advertising results; Service provider:Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland; Legal basis:Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/; Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Possibility of objection (opt-out):We refer to the data protection and advertising settings in the user’s profile on the Instagram platform as well as in the context of Instagram’s consent procedure and Instagram’s contact options for exercising information and other data subject rights in Instagram’s privacy policy; Further information:Event user data, i.e. behavioral and interest data, is processed for the purposes of targeted advertising and target group formation on the basis of the agreement on joint responsibility (“Addendum for Responsible Parties”,https://www.facebook.com/legal/controller_addendum) is processed. The joint controllership is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.)
Presence in social networks (social media)
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 result in risks for users because, for example, it could make it more difficult to enforce user rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. The latter may in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. Cookies are therefore generally stored on the user’s computer, in which the user’s usage behavior and interests are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the privacy policies and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the latter have access to the user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Processed data types:Contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions).
- Persons concerned:Users (e.g. website visitors, users of online services).
- Purposes of the processing:Communication; feedback (e.g. collecting feedback via online form). Public relations.
- Storage and deletion:Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Instagram:Social network, allows you to share photos and videos, comment on and favorite posts, send messages, subscribe to profiles and pages;Service provider:Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);Website: https://www.instagram.com;Privacy policy: https://privacycenter.instagram.com/policy/.Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Facebook pages:Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy:https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in the Facebook Data Policy:https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, known as “Page Insights”, to Page owners to help them understand how people interact with their Pages and the content associated with them. We have concluded a special agreement with Facebook (“Information on Page Insights”,https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transfer of data to the parent company Meta Platforms, Inc. in the USA; Service provider:Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com;Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Facebook groups: We use the “Groups” function of the Facebook platform to create interest groups within which Facebook users can get in touch with each other or with us and exchange information. In doing so, we process personal data of the users of our groups insofar as this is necessary for the purpose of group use and moderation. Our guidelines within the groups may contain further specifications and information on the use of the respective group. This data includes information on first and last names, as well as published or privately shared content, as well as values on the status of group membership or group-related activities, such as joining or leaving, as well as the time details for the aforementioned data. We also refer to the processing of user data by Facebook itself. This data includes information about the types of content that users view or interact with, or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, known as “insights”, to group operators to help them understand how people interact with their groups and the content associated with them; Service provider:Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland; Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Facebook events: Event profiles within the Facebook social network – We use the “Events” function of the Facebook platform to draw attention to events and dates and to get in touch with users (participants and interested parties) and to exchange information. In doing so, we process personal data of the users of our event pages, insofar as this is necessary for the purpose of the event page and its moderation. This data includes information on first and last names, as well as published or privately shared content, as well as values on the status of participation and the time details for the aforementioned data. We also refer to the processing of user data by Facebook itself. This data includes information about the types of content that users view or interact with, or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy:https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device information” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, known as “Insights”, to event providers to help them understand how people interact with their event pages and the content associated with them;Service provider:Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland; Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR);Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitors’ data generated for the purpose of creating the “page insights” (statistics) of our LinkedIn profiles.
This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data) and information from users’ profiles, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy:https://www.linkedin.com/legal/privacy-policy We have entered into a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum (the ‘Addendum’)”, https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of data by and transfer to Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of Ireland Unlimited Company, which relates in particular to the transfer of data to the parent company LinkedIn Corporation in the USA;Service provider:LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. - YouTube:Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy policy: https://policies.google.com/privacy; Basis for third country transfers:EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).Possibility of objection (opt-out): https://myadcenter.google.com/personalizationoff.
Plug-ins and embedded functions and content
We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).
The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyze 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 contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, but may also be linked to such information from other sources. Notes on legal bases:If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.
- Processed data types:Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned:Users (e.g. website visitors, users of online services).
- Purposes of the processing:Provision of our online services and user-friendliness.
- Storage and deletion:Deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
- Legal basis:Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- MyFonts:Fonts; data processed as part of the font retrieval process the identification number of the web font project (anonymized), the URL of the licensed website linked to a customer number to identify the licensee and the licensed web fonts, and the referrer URL; the anonymized web font project identification number is stored in encrypted log files with such data for 30 days to determine the monthly number of page views; after such extraction and storage of the number of page views, the log files are deleted; Service provider:Monotype Imaging Holdings Inc., 600 Unicorn Park Drive, Woburn, Massachusetts 01801, USA; Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.myfonts.co. Privacy policy: https://www.myfonts.com/info/legal/#Privacy.
Management, organization and support tools
We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.
In this context, personal data may be processed and stored on the servers of the third-party providers. This may affect 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 transactions, contracts, other processes and their content.
If users are referred to third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.
- Processed data types:Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Persons concerned:Communication partner. Users (e.g. website visitors, users of online services).
- Purposes of the processing:Provision of contractual services and fulfillment of contractual obligations. Office and organizational procedures.
- Storage and deletion:Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- Trello:Project management tool;Service provider:Trello Inc., 55 Broadway New York, NY 10006, USA, Mutterunternehmen: Atlassian Inc. (San Francisco, Harrison Street Location), 1098 Harrison Street, San Francisco, California 94103, USA;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://trello.com/; Privacy policy: https://trello.com/privacy; Basis for third country transfers:EU/EWR – Data Privacy Framework (DPF), Schweiz – Data Privacy Framework (DPF). Further information:Data transfer impact assessment: https://www.atlassian.com/legal/data-transfer-impact-assessment.
Processing of data in the context of employment relationships
In the context of employment relationships, personal data is processed with the aim of effectively managing the establishment, implementation and termination of such relationships. This data processing supports various operational and administrative functions that are necessary for the management of employee relations.
The data processing covers various aspects ranging from contract initiation to contract termination. This includes the organization and administration of daily working hours, the administration of access rights and authorizations as well as the handling of personnel development measures and employee appraisals. The processing is also used for payroll accounting and the administration of wage and salary payments, which are critical aspects of contract implementation.
In addition, data processing takes into account the legitimate interests of the responsible employer, such as ensuring safety in the workplace or collecting performance data to evaluate and optimize operational processes. Data processing also includes the disclosure of employee data as part of external communication and publication processes, where this is necessary for operational or legal purposes.
The processing of this data always takes place in compliance with the applicable legal framework, whereby the aim is always to create and maintain a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, the anonymization or deletion of data after the purpose of processing has been fulfilled or in accordance with statutory retention periods.
- Processed data types:Employee data (information on employees and other persons in an employment relationship); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and e-mail addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as information relating to them, such as information on authorship or time of creation); social data (data subject to social confidentiality, e.g. from social security organizations). content data (e.g. text or image messages and contributions and the information relating to them, such as details of authorship or time of creation); social data (data subject to social confidentiality and processed, for example, by social insurance providers, social welfare providers or pension authorities); log data (e.g. log files relating to logins or the retrieval of data or access times.); performance and behavioral data (e.g. performance and behavioral aspects such as performance evaluations, feedback from superiors, training participation, compliance with company guidelines, self-assessments and behavioral assessments); working time data (e.g. start of working hours, end of working hours, actual working hours, target working hours, break times, overtime, vacation days, special leave days, sick days, absences, home office days, business trips); salary data (e.g. basic salary, bonus payments, sick days, absences, home office days, business trips).salary data (e.g. basic salary, bonus payments, premiums, tax class information, supplements for night work/overtime, tax deductions, social security contributions, net payment amount); usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
- Special categories of personal data:Health data; Religious or philosophical beliefs. Trade union membership.
- Persons concerned:Employees (e.g. salaried employees, applicants, temporary staff and other employees).
- Purposes of the processing:Establishment and implementation of employment relationships (processing of employee data in the context of the establishment and implementation of employment relationships); business processes and business management procedures; provision of contractual services and fulfillment of contractual obligations; security measures. Office and organizational procedures.
- Legal basis:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Processing of special categories of personal data relating to health care, employment and social security (Art. 9 para. 2 lit. h) GDPR).
Further information on processing operations, procedures and services:
- Working time recording:Procedures for recording employees’ working hours include both manual and automated methods, such as the use of time clocks, time recording software or mobile apps. This involves activities such as entering clock-in and clock-out times, break times, overtime and absences. Checking and validating the recorded working times includes comparing them with shift schedules, checking absences and approving overtime by supervisors. Reports and analyses are created based on the recorded working times to provide timesheets, overtime reports and absence statistics for management and the HR department;Legal basis:Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Authorization management:Procedures required in the definition, management and control of access rights and user roles within a system or organization (e.g. creation of permission profiles, role and access-based control, review and approval of access requests, regular review of access rights, tracking and auditing of user activity, creation of security policies and procedures);Legal bases:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Special categories of personal data:Special categories of personal data are processed in the context of the employment relationship or to fulfill legal obligations. The special categories of personal data processed include data relating to the health, trade union membership or religious affiliation of employees. This data may, for example, be passed on to health insurance companies or processed to assess employees’ ability to work or for occupational health management or for information to the tax office;Legal basis:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Sources of the processed data:Personal data is processed that was obtained as part of the employee’s application and/or employment relationship. In addition, if required by law, personal data is collected from other sources. These may be tax authorities for tax-relevant information, the respective health insurance company for information on incapacity for work, third parties such as employment agencies or publicly accessible sources such as professional social networks in the context of application procedures;Legal basis:Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Purposes of data processing:The personal data of employees is primarily processed to establish, implement and terminate the employment relationship. In addition, the processing of this data is necessary to fulfill legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to comply with regulatory and supervisory requirements, to optimize electronic data processing processes and to compile internal or cross-company data, possibly including statistical data. Furthermore, employee data may be processed for the assertion of legal claims and for defense in legal disputes;Legal basis:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Transmission of employee data:Employee data is only processed internally by those departments that require it to fulfill operational, contractual and legal obligations.
Data is only passed on to external recipients if this is required by law or if the employees concerned have given their consent. Possible scenarios for this could be requests for information from authorities or in the case of capital formation benefits. Furthermore, the controller may forward personal data to other recipients if this is necessary to fulfill its contractual and legal obligations as an employer. These recipients may include: a) Banks b) Health insurance funds, pension insurance providers, pension providers and other social insurance providers c) Authorities, courts (e.g. tax authorities, labor courts, other supervisory authorities as part of the fulfillment of reporting and information obligations) d) Tax and legal advisors e) Third-party debtors in the event of wage and salary garnishment f) Other bodies to which legally binding declarations must be made.
In addition, data may be passed on to third parties if this is necessary for communication with business partners, suppliers or other service providers. Examples of this are details in the sender area of e-mails or letterhead and the creation of profiles on external platforms;Legal basis:Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). - Business trips and travel expense accounting:Procedures required for the planning, execution and accounting of business trips (e.g. booking trips, organizing accommodation and transport, managing travel expense advances, submitting and checking travel expense reports, checking and accounting for expenses incurred, complying with travel guidelines, handling travel expense management);Legal basis:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, professional and social security (Art. 9 para. 2 lit. h) GDPR).
- Payroll accounting and payroll accounting:Procedures required for the calculation, payment and documentation of wages, salaries and other remuneration of employees (e.g. recording of working hours, calculation of deductions and bonuses, payment of taxes and social security contributions, preparation of wage and salary statements, management of payroll accounts, reporting to the tax office and social security institutions);Legal basis:Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
- Deletion of employee data:Employee data is deleted in accordance with German law if it is not required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or due to the interests of the employer. The following retention and archiving obligations are observed:Legal basis:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, professional and social security (Art. 9 para. 2 lit. h) GDPR).
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- General personnel documents – General personnel documents (such as employment contract, reference letter, supplementary agreements) are kept for up to three years after termination of the employment relationship (Section 195 BGB).
Tax-relevant documents – Tax-relevant documents in the personnel file are kept for six years (§ 147 AO, § 257 HGB).
Information on wages and hours worked – Information on wages and hours worked for (accident) insured persons with wage statements is kept for five years (§ 165 I 1, IV 2 SGB VII). - Salary lists including lists for special payments – Salary lists including lists for special payments, if an accounting document is available, are kept for ten years (§ 147 AO, § 257 HGB).
- Payroll lists for interim, final and special payments – Payroll lists for interim, final and special payments are kept for six years (§ 147 AO, § 257 HGB).
- Employee insurance documents – Employee insurance documents, if accounting records are available, are kept for ten years (§ 147 AO, § 257 HGB).
- Contribution statements to social insurance institutions – Contribution statements to social insurance institutions are kept for ten years (§ 165 SGB VII).
Payroll accounts – Payroll accounts are kept for six years (§ 41 I 9 EStG). - Applicant data – Retained for a maximum of six months from receipt of the rejection.
- Working time records (for more than 8 hours on working days) – Are kept for two years (§ 16 II Working Hours Act (ArbZG)).
- Application documents (after online job advertisement) – Will be kept for three to a maximum of six months after receipt of the rejection (§ 26
- Federal Data Protection Act (BDSG) new version, Section 15 IV General Equal Treatment Act (AGG)).
- Certificates of incapacity for work (AU) – Are kept for up to five years (Section 6 I of the Act on the Equalization of Expenses (AAG)).
- Documents relating to company pension schemes – are kept for 30 years (Section 18a of the German Act on the Improvement of Company Pension Schemes (BetrAVG)).
- Employee sickness data – Retained for twelve months after the start of the illness if the absences do not exceed six weeks in a year.
- Maternity protection documents – are kept for two years (§ 27 para. 5 MuSchG).
- General personnel documents – General personnel documents (such as employment contract, reference letter, supplementary agreements) are kept for up to three years after termination of the employment relationship (Section 195 BGB).
- Personnel file management:Procedures required for organizing, updating and managing employee data and documents (e.g. recording personnel master data, storing employment contracts, references and certificates, updating data in the event of changes, compiling documents for employee interviews, archiving personnel files, complying with data protection regulations);Legal basis:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, professional and social security (Art. 9 para. 2 lit. h) GDPR).
- Personnel development, performance evaluation and performance reviews:Procedures required in the area of employee promotion and development, performance appraisal and performance reviews (e.g. needs analysis for further training, planning and implementation of training measures, preparation of performance evaluations, implementation of target agreement and feedback meetings, career planning and talent management, succession planning);Legal basis:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR), Processing of special categories of personal data relating to health, professional and social security (Art. 9 para. 2 lit. h) GDPR).
- Obligation to provide data:The controller informs employees that it is necessary to provide their data. This is generally the case if the data is required for the establishment and performance of the employment relationship or if its collection is required by law. It may also be necessary to provide data if employees assert claims or if employees are entitled to claims. The implementation of these measures or fulfillment of benefits is dependent on the provision of this data (for example, the provision of data for the purpose of receiving wages);Legal bases:Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Application procedure
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 details provided there.
In principle, the required information includes personal details such as name, address, contact details and proof of the qualifications required for the position. On request, we will be happy to provide additional information on what details are required.
If available, applicants are welcome to submit their applications via our online form, which is encrypted using state-of-the-art technology. Alternatively, it is also possible to send us applications by e-mail. However, we would like to point out that e-mails sent via the Internet are generally not encrypted. Although e-mails are generally encrypted in transit, this is not done on the servers from which they are sent and received. We can therefore accept no responsibility for the security of the application during transmission between the sender and our server.
For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management or recruitment software and platforms and services from third-party providers in compliance with legal requirements.
Applicants are welcome to contact us about how to submit their application or send us their application by post.Processing of special categories of data:Insofar as special categories of personal data (Art. 9 para. 1 GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants or communicated by them as part of the application procedure, their processing is carried out so that the controller or the data subject can exercise the rights arising from labor law and social security and social protection law and fulfill his or her obligations in this regard. In the case of the protection of vital interests of applicants or other persons or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care systems and services.Deletion of data:The data provided by applicants may be processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified withdrawal by the applicant, the deletion will take place after a period of six months at the latest, so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax regulations.Inclusion in an applicant pool:Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the ongoing application process and that they can revoke their consent at any time for the future.
- Processed data types:Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other personal or qualification information provided by applicants with regard to a specific position or voluntarily).
- Persons concerned:Applicants.
- Purposes of the processing:Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
- Storage and deletion:Deletion in accordance with the information in the section “General information on data storage and deletion”.
- Legal basis:Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing operations, procedures and services:
- LinkedIn Recruiter:Job search and application-related services within the LinkedIn platform;Service provider:LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; AGB: https://legal.linkedin.com/dpa; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing contract: https://legal.linkedin.com/dpa. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
- Personio:Recruitment platform and applicant management services (job advertisements, applicant search and application process); Service provider:Personio SE & Co. KG, Seidlstraße 3, 80335 Munich, Germany;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.personio.de/; Privacy policy: https://www.personio.de/datenschutzerklaerung/. Basis for third country transfers:Switzerland – Adequacy decision (Germany).
- Indeed:Services in connection with employee acquisition/recruitment (search for employees, communication, application process, contract negotiations);Service provider:Indeed Ireland Operations Limited, 124 St. Stephen’s Green, Dublin 2, Irland;Legal basis:Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://indeed.com/; Privacy policy: https://de.indeed.com/legal?hl=de#privacypolicy. Basis for third country transfers:Switzerland – Adequacy decision (Ireland).
Change and update
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing carried out by us 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, please note that the addresses may change over time and please check the information before contacting us.
Definitions of terms
This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.
- Employees:Employees are defined as persons who are in an employment relationship, whether as staff, employees or in similar positions. An employment relationship is a legal relationship between an employer and an employee that is defined by an employment contract or agreement. It involves the employer’s obligation to pay remuneration to the employee while the employee performs work. The employment relationship comprises various phases, including the establishment, in which the employment contract is concluded, the performance, in which the employee performs his or her work activities, and the termination, when the employment relationship ends, whether by notice, termination agreement or otherwise. Employee data is all information relating to these persons and in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, vacation entitlements, health data and performance appraisals.
- File dates:Inventory data includes essential information that is necessary for the identification and management of contractual partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, e-mail addresses), dates of birth and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities or systems by enabling clear assignment and communication.
- Credit report:Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention). According to Art. 22 GDPR, such automated decisions are only permitted if the data subject consents, if they are necessary for the performance of a contract or if national laws permit these decisions.
- Content data:Content data includes information generated in the course of creating, editing and publishing content of all kinds. This category of data can include text, images, videos, audio files and other multimedia content published on various platforms and media. Content data is not limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information and publication dates
- Contact details:Contact data is essential information that enables communication with people or organizations. It includes telephone numbers, postal addresses and email addresses, as well as communication tools such as social media handles and instant messaging identifiers.
- Conversion measurement:Conversion measurement (also known as “visit action evaluation”) is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
- Artificial intelligence (AI):The purpose of processing data using artificial intelligence (AI) includes the automated analysis and processing of user data in order to recognize patterns, make predictions and improve the efficiency and quality of our services. This includes the collection, cleansing and structuring of data, the training and application of AI models as well as the continuous review and optimization of the results and is carried out exclusively with the consent of the users or on the basis of legal permission.
- Performance and behavior data:Performance and behavioral data refers to information related to how people perform tasks or behave in a particular context, such as an educational, work or social environment. This data can include metrics such as productivity, efficiency, quality of work, attendance and compliance with policies or procedures. Behavioral data could include interactions with colleagues, communication styles, decision-making processes and reactions to different situations. These types of data are often used for performance evaluations, training and development, and decision making within organizations.
- Meta, communication and process data:Meta, communication and procedural data are categories that contain information about the way in which data is processed, transmitted and managed. Meta data, also known as data about data, includes information that describes the context, origin and structure of other data. It can include information on file size, creation date, the author of a document and change histories. Communication data records the exchange of information between users via various channels, such as e-mail traffic, call logs, messages in social networks and chat histories, including the persons involved, time stamps and transmission paths. Procedural data describes the processes and procedures within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used to track and review operations.
- Usage data:Usage data refers to information that captures how users interact with digital products, services or platforms. This data includes a wide range of information that shows how users use applications, which functions they prefer, how long they stay on certain pages and which paths they navigate through an application. Usage data can also include frequency of use, timestamps of activities, IP addresses, device information and location data. It is particularly valuable for analysing user behaviour, optimizing user experiences, personalizing content and improving products or services. In addition, usage data plays a crucial role in identifying trends, preferences and potential problem areas within digital offerings
- Personal data:“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Profiles with user-related information:The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists of using this personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
- Protocol data:Log data is information about events or activities that have been logged in a system or network. This data typically contains information such as timestamps, IP addresses, user actions, error messages and other details about the use or operation of a system. Log data is often used to analyze system problems, for security monitoring or to create performance reports.
- Reach measurement:Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online offers can, for example, recognize at what time users visit their websites and what content they are interested in. This allows them to better adapt the content of their websites to the needs of their visitors, for example. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
- Remarketing:Remarketing” or “retargeting” is when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Tracking:The term “tracking” is used when the behavior of users can be tracked across several online offerings. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
- Responsible person:The “controller” is 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.
- Processing:“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.
- Contract data:Contract data is specific information that relates to the formalization of an agreement between two or more parties. It documents the conditions under which services or products are provided, exchanged or sold. This category of data is essential for the management and fulfillment of contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data may include start and end dates of the contract, the type of services or products agreed, price agreements, payment terms, termination rights, renewal options and special terms or clauses. They serve as the legal basis for the relationship between the parties and are crucial for the clarification of rights and obligations, the enforcement of claims and the resolution of disputes.
- Payment data:Payment data includes all information needed to process payment transactions between buyers and sellers. This data is crucial for e-commerce, online banking and any other form of financial transaction. It includes details such as credit card numbers, bank details, payment amounts, transaction dates, verification numbers and billing information. Payment data can also include information about payment status, chargebacks, authorizations and fees.
- Target group formation:Custom audiences are defined as target groups for advertising purposes, e.g. the display of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online store in which they viewed the products. In turn, “lookalike audiences” (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.