Privacy policy
Introduction
KALWEIT ITS GmbH takes the protection of your data very seriously. This is precisely why we would like to explain to you 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, in mobile applications 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: December 10, 2020
Table of contents
- Introduction
- Person responsible
- Overview of processing
- Relevant legal bases
- Security measures
- Transfer and disclosure of personal data
- Data processing in third countries
- Use of cookies
- Commercial and business services
- Provision of the online offer and web hosting
- Blogs and publication media
- Communication via Messenger
- Video conferences, online meetings, webinars and screen sharing
- Application procedure
- Cloud services
- Presence in social networks (social media)
- Planning, organization and auxiliary tools
- Amendment and updating of the privacy policy
- Rights of the data subjects
Person responsible
KALWEIT ITS GmbH
Rathausstr. 3
20095 Hamburg
E-mail address: datenschutz@kalwe.it
Phone: +49 40 285 301 250
A data protection officer is not appointed, as there is no legal obligation to appoint one in accordance with Art. 37 GDPR and Section 38 BDSG. Responsibility under data protection law lies with the controller.
Imprint: https://kalweit-its.de/impressum/
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
- Inventory data (e.g. names, addresses).
- 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, curriculum vitae, certificates and other personal or qualification information provided with regard to a specific position or voluntarily by applicants).
- Content data (e.g. entries in online forms).
- Contact details (e.g. e-mail, telephone numbers).
- Meta/communication data (e.g. device information, IP addresses).
- Usage data (e.g. websites visited, interest in content, access times).
- Contract data (e.g. subject matter of the contract, term, customer category).
- Payment data (e.g. bank details, invoices, payment history).
Categories of affected persons
- Employees (e.g. employees, applicants, former employees).
- Applicants.
- Business and contractual partners.
- Interested parties.
- Communication partner.
- Customers.
- Users (e.g. website visitors, users of online services).
Purposes of the processing
- Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
- Office and organizational procedures.
- Direct marketing (e.g. by e-mail or post).
- Feedback (e.g. collecting feedback via online form).
- Contact requests and communication.
- Remarketing.
- Safety measures.
- Tracking (e.g. interest/behavioral profiling, use of cookies).
- Provision of contractual services and customer service.
- Managing and responding to inquiries.
Relevant legal bases
In the following, we inform you of the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. 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.
- Performance of a contract 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) – 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. 9 para. 2 lit. b GDPR) – Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application procedure (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise their rights under 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, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 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.
National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. These include, in particular, the Act on 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. It also regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. The data protection laws of the individual federal states may also apply.
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 the access, input, disclosure, safeguarding of availability and its separation. 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.
SSL encryption (https): We use SSL encryption to protect your data transmitted via our online offering. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Transfer and disclosure of personal data
As part of our processing of personal data, the data 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, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the organization: We may transfer personal data to other departments within our organization or grant them access to this data. If this transfer is for administrative purposes, the transfer of the data is based on our legitimate business and commercial interests or takes place if it is necessary to fulfill our contractual obligations or if the consent of the data subjects or a legal permission exists.
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 if 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.
Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Use of cookies
Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after their visit to an online service. The information stored may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also known as “user IDs”)
A distinction is made between the following cookie types and functions:
- Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their browser.
- Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users that are used for reach measurement or marketing purposes can also be stored in such a cookie.
- First-party cookies: First-party cookies are set by us.
- Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
- Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user input or for security reasons).
- Statistical, marketing and personalization cookies: Cookies are also generally used to measure reach and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also referred to as “tracking”, i.e. tracking the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or when obtaining consent.
Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offering and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.
Storage period: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.
General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection using your browser settings, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online offering). You can also object to the use of cookies for online marketing purposes by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained. You can also receive further information on how to object in the context of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies or the processing and providers mentioned in the cookie consent management procedure can be obtained, managed and revoked by users. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: Consent may be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.
- Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Commercial and business services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships and associated measures and in the context of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.
We process this data to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. We only pass on the data of contractual partners to third parties within the framework of the applicable law insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, as part of this privacy policy.
We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.
Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Consulting: We process the data of our clients, customers, interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide them with our consulting services. The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship.
If it is necessary for the performance of our contract, for the protection of vital interests or by law, or if the client’s consent has been obtained, we disclose or transfer the client’s data to third parties or agents, such as authorities, subcontractors or in the field of IT, office or comparable services, in compliance with the requirements of professional law.
Project and development services: We process the data of our customers and clients (hereinafter uniformly referred to as “customers”) in order to enable them to select, purchase or commission the selected services or works and related activities as well as their payment and provision or execution or performance.
The required information is marked as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to hold any consultations. Insofar as we receive access to information from end customers, employees or other persons, we process this in accordance with legal and contractual requirements.
Technical services: We process the data of our customers and clients (hereinafter uniformly referred to as “customers”) in order to enable them to select, purchase or commission the selected services or works and related activities as well as their payment and provision or execution or performance.
The required information is marked as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to hold any consultations. Insofar as we receive access to information from end customers, employees or other persons, we process this in accordance with legal and contractual requirements.
- Processed data types: Inventory data (e.g. names, addresses), Payment data (e.g. bank details, invoices, payment history), Contact data (e.g. email, telephone numbers), Contract data (e.g. subject matter of contract, duration, customer category).
- Affected persons: Interested parties, business and contractual partners.
- Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, administration and response to inquiries.
- Legal basis: Fulfillment of 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).
Provision of the online offer and web hosting
In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.
The data processed as part of the provision of the hosting service may include all information relating to the users of our online service that is generated during use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the utilization of the servers and their stability.
- Processed data types: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
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. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Provision of contractual services and customer support, Feedback (e.g. collecting feedback via online form), Security measures.
- 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).
Services used and service providers:
- Wordfence: Firewall and security and error detection functions; Service provider: Defiant, Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA; Website: https://www.wordfence.com; Privacy Policy: https://www.wordfence.com/privacy-policy/; Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://www.wordfence.com/gdpr/dpa.pdf.
Communication via Messenger
We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of communication metadata and on your options to object.
You can also contact us by alternative means, e.g. by telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.
In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure that the message content is encrypted.
However, we would also like to point out to our communication partners that although the providers of the messengers cannot view the content, they can find out that and when communication partners communicate with us and process technical information about the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata).
Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and you contact us, for example, on your own initiative, we use Messenger in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. We would also like to point out that we will not transmit the contact data provided to us to Messenger for the first time without your consent.
Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.
Reservation of reference to other communication channels: Finally, we would like to point out that we reserve the right not to answer inquiries via Messenger for reasons of your security. This is the case if, for example, internal contractual information requires special confidentiality or a reply via Messenger does not meet the formal requirements. In such cases, we will refer you to more appropriate communication channels.
- Processed data types: Contact data (e.g. e-mail, telephone numbers), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Content data (e.g. entries in online forms).
- Affected persons: Communication partner.
- Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or post).
- Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Video conferences, online meetings, webinars and screen sharing
We use platforms and applications from other providers (hereinafter referred to as “third-party providers”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting third-party providers and their services, we observe the legal requirements.
In this context, data of the communication participants are processed and stored on the servers of the third-party providers, insofar as these are part of communication processes with us. This data may include, in particular, registration and contact data, visual and vocal contributions as well as entries in chats and shared screen content.
If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party 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.
Notes on legal bases: If we ask users for their consent to the use of third-party providers or certain functions (e.g. consent to the recording of conversations), the legal basis for processing is consent. Furthermore, their use may be part of our (pre-)contractual services, provided that the use of third-party providers has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners. In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
- Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Communication partners, users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures.
- Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 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 provided, applicants can send us their applications using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and receipt on 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 it to us by post.
Processing of special categories of data: 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 person responsible or the person concerned can exercise the rights arising from labor law and social security and social protection law and fulfill his or her 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 fitness for work, for medical diagnostics, for the provision of 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.
Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is unsuccessful, 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: 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 processing: Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
- Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR).
Cloud services
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 following purposes: document storage and management, calendar management, sending e-mails, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information as well as chats and participation in audio and video conferences.
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 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).
Notes on legal bases: If we ask for consent to the use of cloud services, the legal basis for processing is consent. Furthermore, their use may be part of our (pre)contractual services, provided that the use of cloud services has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient and secure administrative and collaboration processes)
- Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Affected persons: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
- Purposes of processing: Office and organizational procedures.
- Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
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 users’ 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 user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user’s data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
- Processed data types: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of Processing: Contact requests and communication, Tracking (e.g. profiling based on interests and behavior, use of cookies), Remarketing.
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Services used and service providers:
- LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung.
Planning, organization and auxiliary 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 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 the 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.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be part of our (pre)contractual services, provided that the use of third-party providers has been agreed in this context. 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: Inventory data (e.g. names, addresses), Contact data (e.g. e-mail, telephone numbers), Content data (e.g. entries in online forms), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects: Communication partners, users (e.g. website visitors, users of online services), business and contractual partners.
- Purposes of processing: Provision of contractual services and customer service.
- Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
Amendment and updating of the privacy policy
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 an act of cooperation on your part (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.
Rights of the data subjects
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 of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain access to this data and further information and a copy of the data in accordance with legal requirements.
- Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability: You have the right to receive 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: You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.