Protection des données
Pronorm Einbauküchen GmbH Protection des données
Preamble
With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as ” data”) we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online services”).
The terms used are not gender-specific.
Last Update: 27nd April 2020
Table of contents
- Preamble
- Controller
- Overview of processing operations
- Legal Bases for the Processing
- Security Precautions
- Transmission and Disclosure of Personal Data
- Data Processing in Third Countries
- Use of Cookies
- Commercial Services
- Contacting us
- Job Application Process
- Cloud Services
- Onlinemarketing
- Profiles in Social Networks
- Plugins and embedded functions and content
- Erasure of data
- Changes and Updates to the Privacy Policy
- Rights of Data Subjects
- Terminology and Definitions
Controller
pronorm Einbauküchen GmbH
Höferfeld 5-7
32602 Vlotho
Authorised representatives: represented by managing directors Thorsten Gösling and Roger Klinkenberg
E-Mail address: info@pronorm.de
Tel.: +49 (0)5733 - 979-0
Overview of processing operations
The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.
Categories of Processed Data
- Inventory data (e.g. names, addresses).
- Job applicant details (e.g. Personal data, postal and contact addresses and the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, etc., as well as other information on the person or qualifications of applicants provided with regard to a specific job or voluntarily by applicants).
- Content data (e.g. text input, photographs, videos).
- Contact data (e.g. e‑mail, telephone numbers).
- Meta/communication data (e.g. device information, IP addresses).
- Usage data (e.g. websites visited, interest in content, access times).
- Contract data (e.g. contract object, duration, customer category).
- Payment Data (e.g. bank details, invoices, payment history).
Categories of Data Subjects
- Employees (e.g. Employees, job applicants).
- Job applicants.
- Business and contractual partners.
- Prospective customers.
- Communication partner (Recipients of e‑mails, letters, etc.).
- Customers.
- Users (e.g. website visitors, users of online services).
Purposes of Processing
- Provision of our online services and usability.
- Conversion Tracking.
- Job Application Process (Establishment and possible later execution as well as possible later termination of the employment relationship.).
- Office and organisational procedures.
- Direct marketing (e.g. by e‑mail or postal).
- Feedback (e.g. collecting feedback via online form).
- Interest-based and behavioral marketing.
- contact requests and communication.
- Conversion tracking (Measurement of the effectiveness of marketing activities).
- Profiling (Creating user profiles).
- Remarketing.
- Web Analytics (e.g. access statistics, recognition of returning visitors).
- Security measures.
- Targeting (e.g. profiling based on interests and behaviour, use of cookies).
- Contractual services and support.
- Managing and responding to inquiries.
Legal Bases for the Processing
In the following we inform you about the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that, in addition to the regulations of the GDPR, the national data protection regulations may apply in your country or in our country of residence or domicile.
- Consent (Article 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
- Performance of a contract and prior requests (Article 6 (1) (b) GDPR) – Performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Compliance with a legal obligation (Article 6 (1) © GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
- Legitimate Interests (Article 6 (1) (f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
- Article 9 (1)(b) GDPR (job application process as a pre-contractual or contractual relationship) (If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can carry out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, their processing shall be carried out in accordance with Article 9 (2)(b) GDPR , in the case of the protection of vital interests of applicants or other persons on the basis of Article 9 (1)© GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 (1)(d) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (1)(a) GDPR.) – .
Security Precautions
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.
SSL encryption (https): In order to protect your data transmitted via our online services in the best possible way, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
Transmission and Disclosure of Personal Data
In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, payment institutions within the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such a case, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data.
Data 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 disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.
Subject to express consent or transfer required by contract or law, we process or have processed the data only in third countries with a recognised level of data protection, which includes US processors certified under the “Privacy Shield” or on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Article 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).
Use of Cookies
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online service. The information stored can include, for example, the language settings on a website, the login status, a shopping basket or the location where a video was viewed. The term “cookies” also includes other technologies that fulfil the same functions as cookies (e.g. if user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).
The following types and functions of cookies are distinguished:
- Temporary cookies (also : session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed his browser.
- Permanent cookies : Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users who are used for range measurement or marketing purposes can also be stored in such a cookie.
- First-Party-Cookies : First-Party-Cookies are set by ourselves.
- Third party cookies : Third party cookies are mainly used by advertisers (so-called third parties) to process user information.
- Necessary (also : essential) cookies : Cookies can be necessary for the operation of a website (e.g. to save logins or other user inputs or for security reasons).
- Statistics, marketing and personalisation cookies : Cookies are also generally used to measure a website’s reach and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) are stored on individual websites in a user profile. Such profiles are used, for example, to display content to users that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. . If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.
Information on legal basis: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for your consent. If this applies and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in a business operation of our online service and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.
General information on Withdrawal of consent and objection (Opt-Out): Respective of whether processing is based on consent or legal permission, you have the option at any time to object to the processing of your data using cookie technologies or to revoke consent (collectively referred to as “opt-out”). You can initially explain your objection using the settings of your browser, e.g. by deactivating the use of cookies (which may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com. In addition, you can receive further information on objections in the context of the information on the used service providers and cookies.
Processing Cookie Data on the Basis of Consent: Before we process or have processed data within the context of the usage of cookies, we ask the users for their consent, which can be revoked at any time. Before the consent has not been given, we may use cookies that are necessary for the operation of our online services. Their use is based on our interest and the user’s interest in the expected functionality of our online services.
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- Processed data types : Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects : Users (e.g. website visitors, users of online services).
- Legal Basis : Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Google Analytics: Google Analytics est un service d’analyse de site internet fourni par Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94034, USA. Il s'agit d'un traitement commun de données au sens de l'article 26 du RGPD (Règlement général sur la protection des données), le traitement des données étant principalement effectué par Google.
Les données générées par les cookies concernant votre utilisation du site sont généralement transmises et stockées par Google sur des serveurs situés aux États-Unis. Google et les agences gouvernementales des États-Unis ont donc accès à vos données personnelles. Google peut utiliser les données à ses propres fins, telles que le profilage, et peut les combiner avec vos autres informations disponibles.- Votre adresse IP est toutefois préalablement raccourcie au sein des États membres de l’Union européenne ou dans d’autres États parties à l’accord sur l’Espace économique européen. Seulement dans des cas exceptionnels, l’adresse IP complète est transmise à un serveur de Google aux États-Unis où elle est raccourcie. Pour notre compte, Google utilisera les informations générées dans le but d’évaluer votre utilisation du site, de compiler des rapports sur les activités du site et nous fournir d’autres services relatifs à l’utilisation du site et d'Internet. Vous pouvez empêcher la sauvegarde du cookie en effectuant le réglage approprié sur le site web ou dans votre logiciel de navigation. Toutefois, notez que si vous choisissez de refuser les cookies, vous ne pourrez peut-être pas utiliser toutes les fonctionnalités de ce site. En outre, vous pouvez empêcher la collecte des données générées par le cookie et relatives à votre utilisation du site (y compris votre adresse IP) par Google ainsi que le traitement de ces données par Google en téléchargeant et en installant le plug-in de navigateur disponible au lien suivant : https://tools.google.com/dlpage/gaoptout?hl=fr.
Facebook Pixel: Le site web utilise la fonction de remarketing « Custom Audiences » de Facebook Inc. („Facebook“). Ainsi, les utilisateurs du site web peuvent voir des publicités liées à leurs centres d’intérêt (« publicités Facebook ») lorsqu'ils se rendent sur le réseau social Facebook ou sur d'autres sites web qui utilisent également ce procédé. Ainsi, nous suivons la pertinence d'afficher des publicités qui vous intéressent afin de rendre notre site web plus intéressant pour vous.
A l’aide des outils de marketing utilisés, votre navigateur établit automatiquement une connexion directe avec le serveur de Facebook. Nous n'avons aucune influence sur l’ampleur et l'utilisation ultérieure des données collectées par Facebook grâce à cet outil et nous vous informons donc en fonction de l'état de nos connaissances : Grâce à l'intégration de Facebook Custom Audiences, Facebook est informé que vous avez consulté le site web correspondant à notre présence sur Internet ou cliqué sur une de nos publicités. Si vous êtes inscrit à un service Facebook, Facebook peut associer la visite à votre compte. Même si vous n'êtes pas inscrit sur Facebook ou si vous ne vous êtes pas connecté, il est possible que le fournisseur découvre et enregistre votre adresse IP et d'autres éléments d'identification.
Commercial Services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the context of contractual and comparable legal relationships as well as associated actions and communication with the contractual partners or pre-contractually, e.g. to answer inquiries.
We process this data in order to fulfil our contractual obligations, safeguard our rights and for the purposes of the administrative tasks associated with this data and the business-related organisation. We will only pass on the data of the contractual partners within the scope of the applicable law to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g. telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further processing, e.g. for marketing purposes, as part of this privacy policy.
Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in on-line forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.
We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons of archiving (e.g., as a rule 10 years for tax purposes). In the case of data disclosed to us by the contractual partner within the context of an assignment, we delete the data in accordance with the specifications of the assignment, in general after the end of the assignment.
If we use third-party providers or platforms to provide our services, the terms and conditions and privacy policies of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.
Consulting: We process the data of our clients, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to provide them with our consulting services. The data processed, the type, scope and purpose of the processing and the necessity of its processing are determined by the underlying contractual and client relationship.
Insofar as it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or with the consent of the client, we disclose or transfer the client’s data to third parties or agents, such as authorities, courts, subcontractors or in the field of IT, office or comparable services, taking into account the professional requirements.
- Processed data types : Inventory data (e.g. names, addresses), Payment Data (e.g. bank details, invoices, payment history), Contact data (e.g. e‑mail, telephone numbers), Contract data (e.g. contract object, duration, customer category).
- Data subjects : Prospective customers, Business and contractual partners.
- Purposes of Processing : Contractual services and support, contact requests and communication, Office and organisational procedures, Managing and responding to inquiries.
- Legal Basis : Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Compliance with a legal obligation (Article 6 (1) © GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Contacting us
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the inquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested activities.
The response to contact enquiries within the framework of contractual or pre-contractual relationships is made in order to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of the legitimate interests in responding to the enquiries.
- Processed data types : Inventory data (e.g. names, addresses), Contact data (e.g. e‑mail, telephone numbers), Content data (e.g. text input, photographs, videos).
- Data subjects : Communication partner (Recipients of e‑mails, letters, etc.).
- Purposes of Processing : contact requests and communication.
- Legal Basis : Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Job Application Process
The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information contained therein.
In principle, the required information includes personal information such as name, address, a contact option and proof of the qualifications required for a particular employment. Upon request, we will be happy to provide you with additional information.
If provided, applicants can send us their applications using an online form. Applicants can also send us their applications via email. However, please note that emails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and the reception on our server.
For the purposes of searching for applicants, submitting applications and selecting applicants, we may make use of the applicant management and recruitment software, platforms and services of third-party providers in compliance with legal requirements. Applicants are welcome to contact us about how to submit their application or send it to us by regular mail.
Processing of special categories of data: If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can exercise his/her rights arising from labour law and social security and social protection law and fulfil his/her duties in this regard, their processing shall be carried out in accordance with Article 9 (1)(b) GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Article 9 (1)(c) GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 (1)(h) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (1)(a) GDPR.
Erasure of data: In the event of a successful application, the data provided by the applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, to which applicants are entitled at any time. Subject to a justified revocation by the applicant, the deletion will take place at the latest after the expiry of a period of six months, so that we can answer any follow-up questions regarding the application and comply with our duty of proof under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.
- Processed data types : Job applicant details (e.g. Personal data, postal and contact addresses and the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, etc., as well as other information on the person or qualifications of applicants provided with regard to a specific job or voluntarily by applicants).
- Data subjects : Job applicants.
- Purposes of Processing : Job Application Process (Establishment and possible later execution as well as possible later termination of the employment relationship.).
- Legal Basis : Article 9 (1)(b) GDPR (job application process as a pre-contractual or contractual relationship) (If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can carry out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, their processing shall be carried out in accordance with Article 9 (2)(b) GDPR , in the case of the protection of vital interests of applicants or other persons on the basis of Article 9 (1)© GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 (1)(d) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (1)(a) GDPR.).
Cloud Services
We use Internet-accessible software services (so-called “cloud services”, also referred to as “Software as a Service”) provided on the servers of its providers for the following purposes: document storage and administration, calendar management, e-mail delivery, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of websites, forms or other content and information, as well as chats and participation in audio and video conferences.
Within this framework, personal data may be processed and stored on the provider’s servers insofar as this data is part of communication processes with us or is otherwise processed by us in accordance with this privacy policy. This data may include in particular master data and contact data of data subjects, data on processes, contracts, other proceedings and their contents. Cloud service providers also process usage data and metadata that they use for security and service optimization purposes.
If we use cloud services to provide documents and content to other users or publicly accessible websites, forms, etc., providers may store cookies on users’ devices for web analysis or to remember user settings (e.g. in the case of media control).
Information on legal basis – If we ask for permission to use cloud services, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre)contractual services, provided that the use of cloud services has been agreed in this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient and secure administrative and collaboration processes).
- Processed data types : Inventory data (e.g. names, addresses), Contact data (e.g. e‑mail, telephone numbers), Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects : Customers, Employees (e.g. Employees, job applicants), Prospective customers, Communication partner (Recipients of e‑mails, letters, etc.).
- Purposes of Processing : Office and organisational procedures.
- Legal Basis : Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Services and service providers being used:
- Microsoft Cloud Services : Cloud Services ; Service provider : Microsoft Corporation, One Microsoft Way, Redmond, WA 98052–6399 USA ; Website : http://microsoft.com ; Privacy Policy : https://privacy.microsoft.com/de-de/privacystatement, Security information : https://www.microsoft.com/de-de/trustcenter ; Privacy Shield (Safeguarding the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active.
Onlinemarketing
We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedure in which the relevant user information for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, computer system used and information on usage times. If users have consented to the collection of their sideline data, these can also be processed.
The information in the profiles is usually stored in the cookies or similar memorizing procedures. These cookies can later, generally also on other websites that use the same online marketing technology, be read and analyzed for purposes of content display, as well as supplemented with other data and stored on the server of the online marketing technology provider.
Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process.
As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities.
Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.
Information on legal basis: If we ask users for their consent (e.g. in the context of a so-called “cookie banner consent”), the legal basis for processing data for online marketing purposes is this consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online services. In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
- Processed data types : Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects : Users (e.g. website visitors, users of online services), Prospective customers.
- Purposes of Processing : Targeting (e.g. profiling based on interests and behaviour, use of cookies), Remarketing, Conversion Tracking, Interest-based and behavioral marketing, Profiling (Creating user profiles), Conversion tracking (Measurement of the effectiveness of marketing activities), Web Analytics (e.g. access statistics, recognition of returning visitors).
- Security measures : IP Masking (Pseudonymization of the IP address).
- Legal Basis : Consent (Article 6 (1) (a) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
- Opt-Out : We refer to the privacy policies of the respective service providers and the possibilities for objection (so-called “opt-out”). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered collectively for each area : a) Europe : https://www.youronlinechoices.eu. b) Canada : https://www.youradchoices.ca/choices. c) USA : https://www.aboutads.info/choices. d) Cross-regional : http://optout.aboutads.info.
Services and service providers being used:
- Google Analytics : Online marketing and web analytics ; Service provider : Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company : Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ; Website : https://marketingplatform.google.com/intl/en/about/analytics/; Privacy Policy : https://policies.google.com/privacy ; Privacy Shield (Safeguarding the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ; Opt-Out : Opt-Out-Plugin : http://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements : https://adssettings.google.com/authenticated.
Profiles in Social Networks
We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.
We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users’ rights. With regard to US providers certified under the Privacy Shield or offering comparable guarantees of a secure level of data protection, we would like to point out that they thereby commit themselves to comply with EU data protection standards.
In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behavior and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).
For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.
Also, in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.
- Processed data types : Inventory data (e.g. names, addresses), Contact data (e.g. e‑mail, telephone numbers), Content data (e.g. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
- Data subjects : Users (e.g. website visitors, users of online services).
- Purposes of Processing : contact requests and communication, Targeting (e.g. profiling based on interests and behaviour, use of cookies), Remarketing, Web Analytics (e.g. access statistics, recognition of returning visitors).
- Legal Basis : Legitimate Interests (Article 6 (1) (f) GDPR).
Services and service providers being used:
- Instagram : Social network ; Service provider : Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA ; Website : https://www.instagram.com ; Privacy Policy : http://instagram.com/about/legal/privacy.
- Facebook : Social network ; Service provider : Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland, parent company : Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA ; Website : https://www.facebook.com ; Privacy Policy : https://www.facebook.com/about/privacy ; Privacy Shield (Safeguarding the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ; Opt-Out : Settings for advertisements : https://www.facebook.com/settings?tab=ads ; Additional information on data protection : Agreement on the joint controll of processing of personal data on Facebook pages : https://www.facebook.com/legal/terms/page_controller_addendum, privacy policy for Facebook pages : https://www.facebook.com/legal/terms/information_about_page_insights_data.
- LinkedIn : Social network ; Service provider : LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ; Website : https://www.linkedin.com ; Privacy Policy : https://www.linkedin.com/legal/privacy-policy ; Privacy Shield (Safeguarding the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active ; Opt-Out : https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- YouTube : Social network ; Service provider : Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company : Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ; Privacy Policy : https://policies.google.com/privacy ; Privacy Shield (Safeguarding the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ; Opt-Out : https://adssettings.google.com/authenticated.
- Xing : Social network ; Service provider : XING AG, Dammtorstraße 29–32, 20354 Hamburg, Germany ; Website : https://www.xing.com ; Privacy Policy : https://privacy.xing.com/en.
Plugins and embedded functions and content
Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may, for example, be graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as “Content”).
The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.
Information on legal basis: If we ask users for their consent (e.g. in the context of a so-called “cookie banner consent”), the legal basis for processing is this consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online services. We refer you to the note on the use of cookies in this privacy policy.
- Processed data types : Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Contact data (e.g. e‑mail, telephone numbers), Content data (e.g. text input, photographs, videos), Inventory data (e.g. names, addresses).
- Data subjects : Users (e.g. website visitors, users of online services), Communication partner (Recipients of e‑mails, letters, etc.).
- Purposes of Processing : Provision of our online services and usability, Contractual services and support, contact requests and communication, Direct marketing (e.g. by e‑mail or postal), Targeting (e.g. profiling based on interests and behaviour, use of cookies), Interest-based and behavioral marketing, Profiling (Creating user profiles), Security measures, Managing and responding to inquiries.
- Legal Basis : Legitimate Interests (Article 6 (1) (f) GDPR), Consent (Article 6 (1) (a) GDPR), Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
Services and service providers being used:
- Facebook plugins and contents : Facebook Social Plugins and contents – This can include content such as images, videos or text and buttons with which users can share content from this online service within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here : https://developers.facebook.com/docs/plugins/; Service provider : https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland, Mutterunternehmen : Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA ; Website : https://www.facebook.com ; Privacy Policy : https://www.facebook.com/about/privacy ; Privacy Shield (Safeguarding the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ; Opt-Out : Settings for advertisements : https://www.facebook.com/settings?tab=ads.
- Google Fonts : We integrate the fonts (“Google Fonts”) of the provider Google, whereby the data of the users are used solely for purposes of the representation of the fonts in the browser of the users. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and consideration of possible licensing restrictions for their integration. Service provider : Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, , parent company : Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ; Website : https://fonts.google.com/; Privacy Policy : https://policies.google.com/privacy ; Privacy Shield (Safeguarding the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Instagram plugins and contents : Instagram plugins and contents – This can include content such as images, videos or text and buttons with which users can share content from this online service within Instagram . Service provider : https://www.instagram.com, Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA ; Website : https://www.instagram.com ; Privacy Policy : http://instagram.com/about/legal/privacy.
- LinkedIn plugins and contents : LinkedIn plugins and contents – This can include content such as images, videos or text and buttons with which users can share content from this online service within LinkedIn. Service provider : LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ; Website : https://www.instagram.com ; Privacy Policy : https://www.linkedin.com/legal/privacy-policy ; Privacy Shield (Safeguarding the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active ; Opt-Out : https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
- YouTube videos : Video contents ; Service provider : Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, , parent company : Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ; Website : https://www.youtube.com ; Privacy Policy : https://policies.google.com/privacy ; Privacy Shield (Safeguarding the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ; Opt-Out : Opt-Out-Plugin : http://tools.google.com/dlpage/gaoptout?hl=en, Settings for the Display of Advertisements : https://adssettings.google.com/authenticated.
Erasure of data
The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose).
If the data is not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
Further information on the erasure of personal data can also be found in the individual data protection notices of this privacy policy.
Changes and Updates to the Privacy Policy
We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us.
Rights of Data Subjects
As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 18 and 21 of the GDPR:
- Right to Object : You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR , including profiling based on those provisions.
Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right of withdrawal for consents : You have the right to revoke consents at any time.
- Right of access : You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
- Right to rectification : You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
- Right to Erasure and Right to Restriction of Processing : In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
- Right to data portability : You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller.
- Complaint to the supervisory authority : You also have the right, under the conditions laid down by law, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
Terminology and Definitions
This section provides an overview of the terms used in this privacy policy. Many of the terms are drawn from the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended above all for the purpose of comprehension. The terms are sorted alphabetically.
- Controller : “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Conversion Tracking : “Conversion Tracking” refers to a procedure by which the effectiveness of marketing measures can be determined. As a rule, a cookie is stored on the devices of the users within the websites on which the marketing measures are carried out and then called up again on the target website (e.g. this enables us to track whether the ads we placed on other websites were successful).
- Conversion tracking : Conversion tracking is a method used to evaluate the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website (e.g. we can thus trace whether the advertisements placed by us on other websites were successful).
- IP Masking : IP masking is a method by which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address alone can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymizing processing methods, particularly in online marketing.
- Interest-based and behavioral marketing : Interest-related and/or behaviour-related marketing is the term used when potential user interest in advertisements and other content is predicted if possible. This is done on the basis of information on the previous behaviour of users (e.g. visiting and staying on certain websites, purchasing behaviour or interaction with other users), which is stored in a so-called profile. For these purposes cookies are usually used.
- Personal Data : “personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Processing : The term “processing” covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.
- Profiling : “Profiling” means any automated processing of personal data consisting in the use of such personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information regarding age, gender, location and movement data, interaction with websites and their contents, shopping behaviour, social interactions with other people) (e.g. interests in certain contents or products, click behaviour on a website or the location). Cookies and web beacons are often used for profiling purposes.
- Remarketing : Remarketing” or “retargeting” is the term used, for example, to indicate for advertising purposes which products a user is interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
- Targeting : Tracking” is the term used when the behaviour of users can be traced across several websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users presumably corresponding to their interests.
- Web Analytics : Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to optimize the content of the website to better meet the needs of their visitors. For purposes of web analytics, pseudonymous cookies and web beacons are frequently used in order to recognize returning visitors and thus obtain more precise analyses of the use of an online service.