Data protection - Media!House direct

Data privacy policy

Introduction

With the following privacy policy, 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: July 31, 2021

Table of contents

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Person responsible

Media!House direct

GmbHCarl-Miele-Straße 27-29
33442 Herzebrock-Clarholz
Germany

 

Persons authorized to represent the company: Detlef Bopp, Michael Kuhlmeyer
E-mail-Adresse: anfrage@mediahousedirect.de
Telephone: +49 5245/844080
Imprint: www.mediahousedirect.de/impressum

Contact data protection officer

Stefan Kröger

AUDIT-NRW GmbH
DATA PROTECTION & IT SECURITY
Freigerichtstr. 10
33378 Rheda-Wiedenbrück
Germany

 

Tel.: +49 5242/5701532
E-Mail: sk@audit-nrw.de
Website: www.audit-nrw.de

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • 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 by applicants with regard to a specific position or voluntarily).
  • Content data (e.g. text entries, 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. 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 partners.
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of the processing

  • Evaluation of the visit.
  • 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).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Tracking (e.g. interest/behavioral profiling, use of cookies).
  • Contractual services and 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.
  • Art. 9 para. 1 sentence 1 lit. b GDPR (application procedure as a pre-contractual or contractual relationship) (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 so that the controller or the data subject can exercise their rights under employment 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 access, input, disclosure, safeguarding availability and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats.

 

Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Transfer and disclosure of personal data

As part of our processing of personal data, the data may be transferred 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 group of companies: We may transfer personal data to other companies within our group of companies or grant them access to this data. If this transfer takes place 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”)

 

The following cookie types and functions are distinguished:

    • 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. tracing 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 duration: If we do not provide you with explicit information on the storage duration of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage duration 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). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can obtain further objection notices as part of the information on the service providers and cookies used.

 

Processing of cookie data on the basis of consent: Before we process or have data processed in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has not been given, cookies that are absolutely necessary for the operation of our online offer will be 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).
 
 

Consent with Cookiebot

Our website uses the consent technology of Cookiebot to obtain your consent to the storage of 

certain cookies on your device or for the use of certain technologies and to document this consent
to document this in compliance with data protection regulations. The provider of this technology is Cybot A/S,
Havnegade 39, 1058 Copenhagen, Denmark (hereinafter referred to as “Cookiebot”).
When you enter our website, a connection is established to the servers of
Cookiebot servers in order to obtain your consent and other declarations regarding
cookie usage. Cookiebot then stores a cookie in your
your browser in order to be able to assign the consents given or their revocation to you.
to be able to assign them to you. The data collected in this way will be stored until you ask us to
request deletion, delete the Cookiebot cookie yourself or the purpose for the
data storage no longer applies. Mandatory statutory retention obligations remain unaffected. 

Cookiebot is used in order to fulfill the legally required consent for the use of cookies. 

The legal basis for this is Art. 6 para. 1 lit. c GDPR.

Source: eRecht24

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. in order 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 applicable law to the extent that 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 personally.

 

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.

 

Agency services: We process our customers’ data as part of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services and training services.

    • 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).
    • Data subjects: Interested parties, business and contractual partners.
    • Purposes of processing: Contractual performance and service, contact inquiries and communication, office and organizational procedures, administration and answering inquiries.
    • Legal bases: Fulfilment 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 in the context of providing the hosting service may include all information relating to the users of our online service that is generated in the context of 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, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a 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. 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).
    • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
   

Blogs und Publikationsmedien

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. 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: Contractual services and support, Feedback (e.g. collecting feedback via online form).
    • Legal bases: 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).

 

 

 

Services used and service providers:

  • WordPress.com: Hosting platform for blogs; Service provider: Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA; Website: https://wordpress.com; Privacy Policy: https://automattic.com/de/privacy/

Contact us

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures. Contact enquiries within the scope of contractual or pre-contractual relationships are answered in order to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of 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 partners.
    • Purposes of processing: Contact requests and communication.
    • Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

 

 

 

 

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 email. Please use the contact options provided to you or the contact options provided within our online offering.

 

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 a current 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 messenger providers cannot view the content, they can find out that and when communication partners communicate with us and that technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is also processed.

 

 

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 fulfilment of our communication partners’ needs for 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, for reasons of your security, we reserve the right not to answer enquiries via Messenger. This is the case if, for example, internal contractual information requires special confidentiality or a reply via Messenger does not fulfil 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).
    • Data subjects: Communication partners.
    • Purposes of processing: Contact requests and communication, direct marketing (e.g. by email or post).
    • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

 

 

 

 

 

 

Services used and service providers:

  • Facebook Messenger: Facebook Messenger with end-to-end encryption (the end-to-end encryption of Facebook Messenger requires activation if it is not activated by default); Service provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Opt-Out: https://www.facebook.com/settings?tab=ads.

Videokonferenzen, Onlinemeetings, Webinare und Bildschirm-Sharing

We use platforms and applications from other providers (hereinafter referred to as “third-party providers”) for the purpose of holding 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 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 optimisation 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 the 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. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
    • Data subjects: Communication partners, users (e.g. website visitors, users of online services).
    • Purposes of Processing: Contractual services and support, contact requests and communication, Office and organisational procedures, Direct marketing (e.g. by e-mail or postal).
    • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

 

 

 

Services used and service providers:

  • Microsoft Teams: Messenger and conference software; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: https://products.office.com; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter.
  • Zoom: Video conferencing, web conferencing and webinars; Service provider: Zoom Video Communications, Inc., 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA; Website: https://zoom.us; Privacy Policy: https://zoom.us/docs/de-de/privacy-and-legal.html; Standard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA).

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 us their application 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 controller or the data subject can exercise the rights arising from labour law and social security and social protection law and fulfil 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 pursuant to Art. 9 para. 2 lit. h. GDPR. 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 cancellation by the applicant, the deletion will take place at the latest after a period of six months so that we can answer any follow-up questions about the application and fulfil 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: Art. 9 para. 1 sentence 1 lit. b GDPR (application procedure as a pre-contractual or contractual relationship) (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 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 labour law and social security and social protection law and fulfil 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 fitness for work, for medical diagnosis, health or social care or treatment or for the management of health or social care systems and services pursuant to Art. 9 para. 2 lit. h. GDPR. 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).
                             

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 websites, 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 optimise their services.

 

 

If we provide forms or other documents and content for other users or publicly accessible websites with the help of cloud services, the providers may store cookies on the 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. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses), Contract data (e.g. contract object, duration, customer category).
    • Affected persons: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
    • Purposes of processing: contact enquiries 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).

 

 

 

Services used and service providers:

    • Apple iCloud: Cloud storage services; Service provider: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; Website: https://www.apple.com/de/; Privacy Policy: https://www.apple.com/legal/privacy/de-ww/.
    • Google Cloud Services: Cloud storage services; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/; Privacy Policy: https://www.google.com/policies/privacy, Security information: https://cloud.google.com/security/privacy; Standard contractual clauses (guaranteeing the level of data protection when processing in third countries): https://cloud.google.com/terms/data-processing-terms; Additional information on data protection: https://cloud.google.com/terms/data-processing-terms.
    • Microsoft cloud services: Cloud storage services; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: https://microsoft.com/de-de; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter.
  • Web.de Freemail online storage: Cloud storage services; Service provider: 1&1 Mail & Media GmbH, Zweigniederlassung Karlsruhe, Brauerstr. 48, 76135 Karlsruhe, Germany; Website: https://web.de/online-speicher/; Privacy Policy: https://web.de/datenschutz/.

Advertising communication via e-mail, post, fax or telephone

We process personal data for the purposes of advertising communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.

 

Recipients have the right to withdraw their consent at any time or to object to advertising communication at any time.

 

After revocation or objection, we may store the data required to prove consent for up to three years on the basis of our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time.

    • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
    • Affected persons: Communication partner.
    • Purposes of processing: Direct marketing (e.g. by email 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).
       

Online marketing

We process personal data for the purposes of advertising communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.

 

Recipients have the right to withdraw their consent at any time or to object to advertising communication at any time.

 

After revocation or objection, we may store the data required to prove consent for up to three years on the basis of our legitimate interests before deleting it. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time.

  • 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), interested parties.
  • 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 (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
  • Possibility of objection (opt-out): We refer you to the data protection notices of the respective providers and the opt-out options specified for the providers (so-called “opt-out”). If no explicit opt-out option has been specified, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas:a) Europe: https://www.youronlinechoices.eu.
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  • b) Canada: https://www.youradchoices.ca/choices.
  • c) USA: https://www.aboutads.info/choices.
  • d) Cross-territory: https://optout.aboutads.info.

Services used and service providers:

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 users’ 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. 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, Tracking (e.g. profiling based on interests and behavior, use of cookies), Remarketing, Web Analytics (e.g. access statistics, recognition of returning visitors).
    • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

 

Services used and service providers:

       

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 the third-party providers. This may affect various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content.

 

If users are referred to 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. text input, photographs, videos), Usage data (e.g. websites visited, interest in content, access times), Meta/communication data (e.g. device information, IP addresses).
    • Data subjects: Communication partners, users (e.g. website visitors, users of online services).
    • Purposes of processing: Contact requests and communication.
    • 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).

 

Services used and service providers:

 

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data no longer applies or it is not required for the purpose).

 

If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person.

 

Further information on the deletion of personal data can also be found in the individual data protection notices of this privacy policy.

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 your cooperation (e.g. consent) or other individual notification.

 

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

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 information about this data and further information and a copy of the data in accordance with the 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.
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Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are listed in alphabetical order.

  • Visit action evaluation: “Visit action evaluation” (conversion tracking) refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful).
  • IP masking: “IP masking” refers to a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymizing processing procedures, particularly in online marketing
  • Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is when users’ potential interests in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behavior (e.g. visiting certain websites and spending time on them, purchasing behavior or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
  • Conversion measurement: Conversion measurement is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: “Profiling” means any form of automated processing of personal data consisting of the use of personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This enables them to better adapt the content of the website to the needs of their visitors, for example. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: The term “remarketing” or “retargeting” is used when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Tracking: The term “tracking” is used when the behavior of users can be tracked across several online offers. As a rule, behavioral and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data, be it collection, analysis, storage, transmission or deletion.
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