Privacy Policy

Preamble

With the following privacy policy, we aim to inform you about the types of your personal data (hereinafter referred to as "data") that we process, the purposes for which we process them, and the extent of this processing. This privacy policy applies to all personal data processing activities we carry out, both within the scope of providing our services and especially on our websites, in mobile applications, and within external online presences, such as our social media profiles (collectively referred to as "online offer").

The terms used are not gender-specific.

As of: May 12, 2024

Table of Contents

  • Preamble
  • Responsible Party
  • Contact Data Protection Officer
  • Overview of Processing
  • Relevant Legal Bases
  • Security Measures
  • Transfer of Personal Data
  • International Data Transfers
  • General Information on Data Storage and Deletion
  • Rights of Data Subjects
  • Business Services
  • Business Processes and Procedures
  • Provision of the Online Offer and Web Hosting
  • Use of Cookies
  • Contact and Inquiry Management
  • Newsletters and Electronic Notifications
  • Web Analysis, Monitoring, and Optimization
  • Social Media Presence
  • Plugins and Embedded Functions and Content
  • Application Procedures
  • Privacy Information for Whistleblowers
  • Whistleblower Systems
  • Changes and Updates
  • Definitions of Terms

Responsible Party

tci - Gesellschaft für technische Informatik mbH
Ludwig-Rinn-Straße 10-14
D-35452 Heuchelheim / Gießen
Germany

Email Address:

info@tci.de

Phone: +49 (0) 6 41/9 62 84-0
Legal Notice:

https://www.tci.de/impressum/

Contact Data Protection Officer

QS-Kornmann -Sandra Kornmann-
Michael Kornmann
Sudetenstrasse 33
35625 Hüttenberg
Germany
Phone: 06403 9295287
Email: mk@qs-kornmann.de

Overview of Processing

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

Types of Processed Data

  • Inventory data.
  • Employee data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Applicant data.
  • Log data.
  • Creditworthiness data.

Categories of Data Subjects

  • Service recipients and clients.
  • Employees.
  • Interested parties.
  • Communication partners.
  • Users.
  • Applicants.
  • Business and contract partners.
  • Third parties.
  • Whistleblowers.

Purposes of Processing

  • Provision of contractual services and fulfillment of contractual obligations.
  • Communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organizational procedures.
  • Organizational and administrative procedures.
  • Application procedures.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Assessment of creditworthiness and reliability.
  • Information technology infrastructure.
  • Whistleblower protection.
  • Finance and payment management.
  • Public relations.
  • Sales promotion.
  • Business processes and economic procedures.

Relevant Legal Bases

Relevant Legal Bases under the GDPR: The following provides an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 (1) sentence 1 lit. a) GDPR) - The data subject has given their consent to the processing of personal data concerning them for one or more specific purposes.
  • Contract performance and pre-contractual inquiries (Art. 6 (1) sentence 1 lit. b) GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the data subject's request prior to entering into a contract.
  • Legal obligation (Art. 6 (1) sentence 1 lit. c) GDPR) - The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) sentence 1 lit. f) GDPR) - The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • Application procedures as a pre-contractual or contractual relationship (Art. 6 (1) sentence 1 lit. b) GDPR) - Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g., health data, such as disability status or ethnic origin) are requested from applicants, so that the controller or the data subject can exercise their rights arising from labor law and social security and social protection law and fulfill their related obligations, their processing is carried out in accordance with Art. 9 (2) lit. b. GDPR, in the case of protecting the vital interests of applicants or other persons in accordance with Art. 9 (2) lit. c. GDPR or for purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care, or the management of health or social care systems and services in accordance with Art. 9 (2) lit. h. GDPR. In the case of voluntary consent to the provision of special categories of data, their processing is based on Art. 9 (2) lit. a. GDPR.

National Data Protection Regulations in Germany: In addition to the GDPR data protection regulations, national data protection regulations apply in Germany. This includes, in particular, the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). The BDSG contains special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, the processing for other purposes, and the transmission as well as automated decision-making in individual cases, including profiling. Furthermore, the data protection laws of the individual federal states may apply.

Note on the applicability of GDPR and Swiss DPA: These data protection notices serve both to provide information under the Swiss DPA and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader territorial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms "processing" of "personal data," "overriding interest," and "particularly sensitive personal data" used in the Swiss DPA, the terms "processing" of "personal data," "legitimate interest," and "special categories of data" used in the GDPR are used. However, the legal significance of the terms is determined according to the Swiss DPA within the scope of its applicability.

Security Measures

We take appropriate technical and organizational measures in accordance with 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 varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.

The measures include, in particular, securing the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, securing of availability, and separation of the data. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to data threats. Additionally, we consider the protection of personal data already in the development or selection of hardware, software, and procedures, according to the principle of data protection, through technology design and privacy-friendly default settings.

IP Address Truncation: If IP addresses are processed by us or by the service providers and technologies used, and the processing of a complete IP address is not required, the IP address is shortened (also known as "IP masking"). In this process, the last two digits or the last part of the IP address after a dot is removed or replaced by placeholders. The purpose of truncating the IP address is to prevent or significantly impede the identification of a person based on their IP address.

Securing Online Connections through TLS/SSL Encryption Technology (HTTPS): To protect users' data transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions comply with the highest security standards. When a website is secured with an SSL/TLS certificate, this is indicated by the display of HTTPS in the URL. This serves as an indicator for users that their data is securely and encryptedly transmitted.

Transfer of Personal Data

In the course of our processing of personal data, it may happen that this data is transferred to other entities, companies, legally independent organizational units, or persons or disclosed to them. Recipients of this data may include service providers commissioned with IT tasks or providers of services and content embedded in a website. In such cases, we comply with the legal requirements and conclude appropriate contracts or agreements with the recipients of your data to ensure the protection of your data.

International Data Transfers

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 occurs in the context of the use of services provided by third parties or the disclosure or transfer of data to other persons, entities, or companies, this is done only in accordance with legal requirements. If the data protection level in the third country is recognized by an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers are only carried out if the data protection level is otherwise ensured, particularly through standard contractual clauses (Art. 46 (2) lit. c) GDPR), express consent, or in the case of contractual or legally required transfer (Art. 49 (1) GDPR). We will inform you of the basis of the third country transfer for the individual providers from the third country, with adequacy decisions being the primary basis. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de.

EU-US Trans-Atlantic Data Privacy Framework: In the context of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognized the data protection level as secure for certain companies from the USA within the framework of the adequacy decision of July 10, 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We will inform you within the scope of the data protection notices which service providers we use that are certified under the Data Privacy Framework.

General Information on Data Storage and Deletion

We delete personal data that we process in accordance with legal requirements as soon as the consents underlying the processing are revoked or other legal bases for processing no longer apply. This includes cases where the original purpose for processing no longer applies, or the data is no longer needed. Exceptions to this rule exist if legal obligations or special interests require longer storage or archiving of the data.

In particular, data that must be retained for commercial or tax reasons, or whose storage is necessary for legal prosecution or to protect the rights of other natural or legal persons, must be archived accordingly.

Our data protection notices contain additional information on data retention and deletion specifically for certain processing processes.

If there are multiple indications of retention periods or deletion deadlines for a data point, the longest period is always decisive.

If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships, during which data is stored, the triggering event for the period is the effective date of termination or other termination of the legal relationship.

Data that is no longer required for the originally intended purpose but is retained due to legal requirements or other reasons is processed exclusively for the reasons justifying its retention.

Further Information on Processing Procedures, Processes, and Services:

  • Retention and Deletion of Data: The following general periods apply for retention and archiving under German law:
    • 10 years - Retention period for books and records, financial statements, inventories, management reports, opening balance sheets, and the instructions and other organizational documents necessary to understand them, booking records, and invoices (§ 147 (3) in conjunction with (1) no. 1, 4, and 4a AO, § 14b (1) UStG, § 257 (1) no. 1 and 4, (4) HGB).
    • 6 years - Other business documents: received commercial or business letters, copies of sent commercial or business letters, other documents relevant for taxation, such as time sheets, business accounting sheets, calculation documents, price labels, as well as payroll documents, unless they are already booking records and cash register strips (§ 147 (3) in conjunction with (1) no. 2, 3, 5 AO, § 257 (1) no. 2 and 3, (4) HGB).
    • 3 years - Data necessary to consider potential warranty and compensation claims or similar contractual claims and rights and related inquiries, based on previous business experiences and common industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
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Rights of Data Subjects

Data subject rights under the GDPR: As data subjects, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to Object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to Withdraw Consent: You have the right to withdraw your given 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 access this data and receive further information and a copy of the data in accordance with legal requirements.
  • Right to Rectification: You have the right, in accordance with legal requirements, to request the completion of your data or the correction of incorrect data concerning you.
  • Right to Erasure and Restriction of Processing: You have the right, in accordance with legal requirements, to request the immediate deletion of your data or alternatively, in accordance with legal requirements, to request restriction of the processing of your data.
  • Right to Data Portability: You have the right to receive the data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with legal requirements or to request its transmission to another controller.
  • Right to Lodge a Complaint with a Supervisory Authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Business Services

We process the 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 as well as related measures and in terms of communication with the contractual partners (or pre-contractual), for example, to answer inquiries.

We use this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations, and remedying warranty and other performance-related issues. Furthermore, we use the data to safeguard our rights and for the purposes of the administrative tasks associated with these obligations as well as corporate organization. Additionally, we process the data on the basis of our legitimate interests in proper and business-efficient management and in security measures to protect our contractual partners and our business operations from misuse, threats to their data, secrets, information, and rights (e.g., by involving telecommunications, transport, and other auxiliary services, subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). In accordance with applicable law, we only disclose the data of contractual partners to third parties to the extent necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners are informed about further forms of processing, such as for marketing purposes, within the framework of this privacy policy.

We inform the contractual partners before or during the data collection, e.g., in online forms, through special markings (e.g., colors) or symbols (e.g., asterisks or similar), or personally about which data is required for the aforementioned purposes.

We delete the data after the expiration of legal warranty and comparable obligations, generally after four years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal reasons of archiving (for tax purposes generally ten years). Data disclosed to us by the contractual partner within the scope of an order will be deleted in accordance with the specifications and generally after the end of the order.

  • Types of Processed Data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); contract data (e.g., subject matter, duration, customer category).
  • Data Subjects: Service recipients and clients; interested parties; business and contractual partners.
  • Purposes of Processing: Providing contractual services and fulfilling contractual obligations; communication; office and organizational procedures; business processes and economic procedures.
  • Retention and Deletion: Deletion as specified in the section "General Information on Data Retention and Deletion".
  • Legal Bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Further Information on Processing Activities, Procedures, and Services:

  • Technical Services: We process the data of our customers and clients (hereinafter referred to collectively as "customers") to enable them to select, purchase, or commission the chosen services or works as well as related activities, including their payment and provision or performance.

    The required information is marked as such within the scope of the order, order, or similar contract conclusion and includes the information required for the provision of services and billing, as well as contact information for any necessary inquiries. If we gain access to information from end customers, employees, or other persons, we process this in accordance with legal and contractual requirements; Legal Basis: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Business Processes and Procedures

Personal data of service recipients and clients – including customers, clients, or in specific cases, clients, patients, or business partners as well as other third parties – is processed within the framework of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates economic operations in areas such as customer management, sales, payments, accounting, and project management.

The data collected is used to fulfill contractual obligations and to streamline operational processes. This includes handling business transactions, managing customer relationships, optimizing sales strategies, and ensuring internal accounting and financial processes. Additionally, the data supports the safeguarding of the controller's rights and promotes administrative tasks and organizational management.

Personal data may be disclosed to third parties if necessary to fulfill the aforementioned purposes or legal obligations. After the expiration of statutory retention periods or when the purpose of the processing ceases to exist, the data will be deleted. This also includes data that must be retained longer due to tax and statutory evidence obligations.

  • Types of Processed Data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); payment data (e.g., bank details, invoices, payment history); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or pictorial messages and posts, as well as information about them, such as authorship details or creation time); contract data (e.g., subject matter, duration, customer category); log data (e.g., log files concerning logins or data retrievals, or access times); usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); credit data (e.g., received credit score, estimated default probability, resulting risk classification, historical payment behavior); metadata, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons). Employment data (information about employees and other persons in an employment relationship).
  • Data Subjects: Service recipients and clients; interested parties; communication partners; business and contractual partners; third parties; users (e.g., website visitors, users of online services). Employees (e.g., employees, applicants, temporary workers, and other staff).
  • Purposes of Processing: Providing contractual services and fulfilling contractual obligations; office and organizational procedures; business processes and economic procedures; communication; marketing; sales promotion; assessment of creditworthiness and credit risk; financial and payment management; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
  • Retention and Deletion: Deletion as specified in the section "General Information on Data Retention and Deletion".
  • Legal Bases: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR); legitimate interests (Art. 6(1)(f) GDPR); legal obligation (Art. 6(1)(c) GDPR).

Further Information on Processing Activities, Procedures, and Services:

  • Contact Management and Contact Maintenance: Procedures required for the organization, maintenance, and security of contact information (e.g., setting up and maintaining a central contact database, regular updates of contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, conducting backups and restorations of contact data, training staff in the effective use of contact management software, regularly reviewing communication history and adjusting contact strategies); Legal Basis: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
  • General Payment Transactions: Procedures required for conducting payment transactions, monitoring bank accounts, and controlling payment flows (e.g., creating and verifying transfers, handling direct debits, checking bank statements, monitoring payment inflows and outflows, managing chargebacks, account reconciliation, cash management); Legal Basis: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
  • Accounting, Accounts Payable, Accounts Receivable: Procedures required for recording, processing, and controlling business transactions in the areas of accounts payable and accounts receivable accounting (e.g., creating and verifying incoming and outgoing invoices, monitoring and managing open items, conducting payment transactions, handling dunning processes, account reconciliation within the framework of receivables and liabilities, accounts payable, and accounts receivable accounting); Legal Basis: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
  • Financial Accounting and Taxes: Procedures required for recording, managing, and controlling finance-related business transactions and for calculating, reporting, and paying taxes (e.g., accounting and booking business transactions, preparing quarterly and annual financial statements, conducting payment transactions, handling dunning processes, account reconciliation, tax advice, preparing and filing tax returns, handling tax matters); Legal Basis: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legal obligation (Art. 6(1)(c) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
  • Purchasing: Procedures required for the procurement of goods, raw materials, or services (e.g., supplier selection and evaluation, price negotiations, order placement and monitoring, checking and controlling deliveries, invoice verification, order management, inventory management, creating and maintaining purchasing policies); Legal Basis: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
  • Sales: Procedures required for planning, executing, and controlling measures for marketing and selling products or services (e.g., customer acquisition, offer creation and tracking, order processing, customer consulting and support, sales promotion, product training, sales controlling and analysis, management of sales channels); Legal Basis: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).
  • Marketing, Advertising, and Sales Promotion: Procedures required for marketing, advertising, and sales promotion (e.g., market analysis and target group identification, development of marketing strategies, planning and execution of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade show participation, customer loyalty programs, sales promotion measures, performance measurement, and optimization of marketing activities, budget management, and cost control); Legal Basis: Legitimate interests (Art. 6(1)(f) GDPR).

Provision of Online Services and Web Hosting

We process the data of users to provide them with our online services. To this end, we process the user's IP address, which is necessary to transmit the contents and functions of our online services to the user's browser or device.

  • Types of Processed Data: Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); metadata, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons); log data (e.g., log files concerning logins or data retrievals, or access times).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Providing our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures.
  • Retention and Deletion: Deletion as specified in the section "General Information on Data Retention and Deletion".
  • Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further Information on Processing Activities, Procedures, and Services:

  • Provision of Online Services on Rented Storage Space: To provide our online services, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also referred to as "web host"); Legal Basis: Legitimate interests (Art. 6(1)(f) GDPR).
  • Collection of Access Data and Log Files: Access to our online services is logged in the form of so-called "server log files". Server log files can include the address and name of the retrieved web pages and files, date and time of retrieval, transmitted data volumes, messages about successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), and generally IP addresses and the requesting provider. Server log files can be used for security purposes, e.g., to avoid overloading the servers (especially in case of misuse attacks, so-called DDoS attacks), and to ensure server utilization and stability;
  • Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR).
  • Deletion of Data: Logfile information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidence purposes is excluded from deletion until the final clarification of the respective incident.

Use of Cookies

Cookies are small text files or other memory markers that store and read information on end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the accessed contents or used functions of an online service. Cookies can also be used for different purposes, such as ensuring the functionality, security, and comfort of online services, as well as creating analyses of visitor flows.

Notes on Consent: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users, unless it is not required by law. Consent is not necessary, in particular, if the storage and reading of the information, including cookies, are absolutely necessary to provide the users with a service they have expressly requested (i.e., our online service). The revocable consent is clearly communicated to them and includes the information on the respective use of cookies.

Notes on Data Protection Legal Bases: The legal basis on which we process the users' personal data using cookies depends on whether we ask users for their consent. If the users agree, the legal basis for the processing of their data is the declared consent. Otherwise, the data processed by means of cookies is based on our legitimate interests (e.g., in a business-efficient operation of our online service and its improvement) or, if necessary to fulfill our contractual obligations, when the use of cookies is required to meet our contractual obligations. We inform about the purposes for which cookies are used by us in this privacy policy or in the context of our consent and processing processes.

Storage Duration: The following types of cookies are distinguished concerning the storage duration:

  • Temporary Cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g., browser or mobile application).
  • Permanent Cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved, and preferred content can be displayed directly when the user visits a website again. Similarly, the user data collected with cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), they should assume that these are permanent and that the storage duration can be up to two years.

General Information on Withdrawal and Objection (Opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing according to legal requirements, also via the privacy settings of their browser.

  • Types of Processed Data: Metadata, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR). Consent (Art. 6(1)(a) GDPR).

Further Information on Processing Activities, Procedures, and Services:

  • Processing of Cookie Data Based on Consent: We use a consent management solution to obtain the users' consent for the use of cookies or the procedures and providers mentioned within the consent management solution. This procedure serves to obtain, log, manage, and revoke consents, particularly concerning the use of cookies and similar technologies to store, read, and process information on the users' end devices. As part of this procedure, the users' consents for the use of cookies and the associated data processing, including the specific processing and providers mentioned in the consent management procedure, are obtained. Users also have the opportunity to manage and revoke their consents. The consent declarations are stored to avoid having to query them again and to be able to prove the consent in accordance with legal requirements. The storage is server-side and/or in a cookie (so-called opt-in cookie) or by using comparable technologies to assign the consent to a specific user or their device. If no specific information is available on the providers of consent management services, the following general information applies: The duration of the storage of the consent is up to two years. A pseudonymous user identifier is created, stored along with the time of consent, details of the scope of consent (e.g., concerning categories of cookies and/or service providers), as well as information about the browser, system, and end device used; Legal Basis: Consent (Art. 6(1)(a) GDPR).
  • Usercentrics: Consent management: Procedure for obtaining, logging, managing, and revoking consents, particularly for the use of cookies and similar technologies to store, read, and process information on users' end devices and their processing; Service Provider: Usercentrics GmbH, Sendlinger Straße 7, 80331 Munich, Germany; Website: https://usercentrics.com/en/. Privacy Policy: https://usercentrics.com/privacy-policy/.

Contact and Inquiry Management

When contacting us (e.g., by post, contact form, email, phone, or via social media) and within existing user and business relationships, the details of the inquiring persons are processed as necessary to respond to contact inquiries and any requested actions.

  • Types of Processed Data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or pictorial messages and posts, as well as information about them, such as authorship details or creation time); usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); metadata, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
  • Data Subjects: Communication partners.
  • Purposes of Processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via an online form). Providing our online services and user-friendliness.
  • Retention and Deletion: Deletion as specified in the section "General Information on Data Retention and Deletion".
  • Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR). Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Further Information on Processing Activities, Procedures, and Services:

  • Contact Form: When contacting us via our contact form, by email, or other communication methods, we process the personal data provided to us to respond to and handle the respective request. This generally includes information such as name, contact information, and any other information shared with us and necessary for appropriate handling. We use this data solely for the specified purpose of contacting and communication; Legal Basis: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Newsletter and Electronic Notifications

We send newsletters, emails, and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or based on a legal authorization. If the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. For the registration to our newsletter, providing your email address is usually sufficient. However, to offer you a personalized service, we may request your name for personal address in the newsletter or other information, if necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests to prove that consent was previously given. The processing of this data is limited to the purpose of a potential defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a blocklist (so-called "blocklist").

The logging of the registration process is based on our legitimate interests for the purpose of proving its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure sending system.

Contents:

Information about us, our services, promotions, and offers.

  • Types of Processed Data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); metadata, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons); usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
  • Data Subjects: Communication partners.
  • Purposes of Processing: Direct marketing (e.g., by email or postal).
  • Retention and Deletion: 3 years - Contractual claims (AT) (Data required to consider potential warranty and compensation claims or similar contractual claims and rights, as well as handling related inquiries, based on past business experiences and usual industry practices, will be stored for the duration of the regular statutory limitation period of three years (§§ 1478, 1480 ABGB)). 10 years - Contractual claims (CH) (Data required to consider potential compensation claims or similar contractual claims and rights, as well as handling related inquiries, based on past business experiences and usual industry practices, will be stored for the statutory limitation period of ten years, unless a shorter period of 5 years is applicable, which is relevant in certain cases (Art. 127, 130 OR)).
  • Legal Bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).
  • Opt-out Option: You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. A link to unsubscribe from the newsletter is usually found at the end of each newsletter, or you can use one of the contact options above, preferably email.

Further Information on Processing Activities, Procedures, and Services:

  • Measurement of Open and Click Rates: The newsletters contain a so-called "web beacon", i.e., a pixel-sized file that is retrieved from our server or, if we use a shipping service provider, from their server when the newsletter is opened. This retrieval first collects technical information such as details about the browser and your system, as well as your IP address and the time of retrieval. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked. The information is assigned to individual newsletter recipients and stored in their profiles until deleted. The evaluations are used to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of open and click rates and the storage of the measurement results in the profiles of the users and their further processing is based on the consent of the users. Separate revocation of the success measurement is unfortunately not possible; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the profile information stored will be deleted; Legal Basis: Consent (Art. 6(1)(a) GDPR).
  • HubSpot: Email dispatch and automation services; Service Provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.hubspot.de; Privacy Policy: https://legal.hubspot.com/privacy-policy; Data Processing Agreement: https://legal.hubspot.com/dpa. Third Country Transfer Basis: Data Privacy Framework (DPF).

Web Analysis, Monitoring, and Optimization

Web analysis (also referred to as "reach measurement") serves to evaluate the visitor flows of our online service and can include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online service or its functions or contents are most frequently used or invite reuse. It is also possible to track which areas need optimization.

In addition to web analysis, we may also use test procedures to test and optimize different versions of our online service or its components.

Unless otherwise specified below, profiles, i.e., data summarized into a usage process, can be created and information stored and read in a browser or end device for these purposes. The collected information includes, in particular, visited websites and used elements, as well as technical information such as the browser used, the computer system used, and usage times. If users have agreed to the collection of their location data, this can also be processed.

Furthermore, the IP addresses of users are stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect the users. Generally, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing, and optimization, but pseudonyms. This means that neither we nor the providers of the used software know the actual identity of the users, but only the data stored in their profiles for the respective procedures.

Notes on Legal Bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is the consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this context, we also refer to the information on the use of cookies in this privacy policy.

  • Types of Processed Data: Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); metadata, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Reach measurement (e.g., access statistics, identification of returning visitors); profiles with user-related information (creating user profiles); tracking (e.g., interest/behavior-related profiling, use of cookies).
  • Retention and Deletion: Deletion as specified in the section "General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods can be stored on users' devices for up to two years).
  • Security Measures: IP masking (pseudonymization of the IP address).
  • Legal Bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further Information on Processing Activities, Procedures, and Services:

Presences in Social Networks (Social Media)

We maintain online presences within social networks and process user data in this context to communicate with the users active there or to offer information about us.

We point out that user data may be processed outside the area of the European Union. This can result in risks for the users because, for example, the enforcement of the users' rights could be made more difficult.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created based on the usage behavior and resulting interests of the users. These profiles may, in turn, be used to place advertisements within and outside the networks that presumably correspond to the users' interests. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Moreover, data can also be stored in the user profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).

For a detailed presentation of the respective processing forms and the objection options (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.

Also, in the case of requests for information and the assertion of data subject rights, we point out that these can be most effectively asserted with the providers. Only they have access to the users' data and can take direct action and provide information. If you still need help, you can contact us.

 

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  • Types of Processed Data: Contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts, and related information such as authorship details or time of creation). Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems, interactions with content and functions).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Communication; feedback (e.g., collecting feedback via an online form). Public relations.
  • Retention and Deletion: Deletion according to the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR).

Further Information on Processing Activities, Procedures, and Services:

  • Facebook Pages: Profiles within the social network Facebook - We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page (so-called "Fanpage"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, known as "Page Insights", to page operators so they can gain insights into how people interact with their pages and related content. We have entered into a specific agreement with Facebook ("Information about Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates, in particular, which security measures Facebook must observe and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, address information or deletion requests directly to Facebook). The rights of users (especially to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information about Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection of and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, especially regarding the transmission of the data to the parent company Meta Platforms, Inc. in the USA; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy. Third Country Transfer Basis: Data Privacy Framework (DPF).
  • LinkedIn: Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of data of visitors that is collected for the purpose of creating "Page Insights" (statistics) of our LinkedIn profiles.
    This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data) and profile information from users, such as job function, country, industry, hierarchy level, company size, and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy
    We have entered into a specific agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum (the 'Addendum')", https://legal.linkedin.com/pages-joint-controller-addendum), which regulates, in particular, which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill data subject rights (i.e., users can, for example, address information or deletion requests directly to LinkedIn). The rights of users (especially to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection of and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, especially regarding the transmission of the data to the parent company LinkedIn Corporation in the USA; Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Third Country Transfer Basis: Data Privacy Framework (DPF). Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • YouTube: Social network and video platform; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR); Privacy Policy: https://policies.google.com/privacy; Third Country Transfer Basis: Data Privacy Framework (DPF). Opt-Out: https://myadcenter.google.com/personalizationoff.
  • Xing: Social network; Service Provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal Bases: Legitimate interests (Art. 6(1)(f) GDPR); Website: https://www.xing.com/. Privacy Policy: https://privacy.xing.com/en/privacy-policy.

Plugins and Embedded Functions and Content

We integrate function and content elements into our online service that are sourced from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include graphics, videos, or maps (collectively referred to as "content").

The integration always requires that the third-party providers of this content process the IP address of the users, as without the IP address, they could not send the content to their browser. The IP address is thus necessary for the display of these contents or functions. We strive to use only content whose respective providers use the IP address solely to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. 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 include technical information about the browser and operating system, referring websites, visit times, and other information about the use of our online service, as well as being linked to such information from other sources.

Notes on Legal Bases: If we ask users for their consent to the use of the third-party providers, the legal basis for the data processing is consent. Otherwise, the user data is processed based on our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this context, we also refer you to the information on the use of cookies in this privacy policy.

  • Types of Processed Data: Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems, interactions with content and functions); metadata, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons); inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers). Content data (e.g., textual or visual messages and posts, and related information such as authorship details or time of creation).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Providing our online services and user-friendliness. Performance of contractual services and fulfillment of contractual obligations.
  • Retention and Deletion: Deletion according to the information provided in the section "General Information on Data Retention and Deletion". Storage of cookies for up to 2 years (unless otherwise specified, cookies and similar storage methods can be stored on users' devices for up to two years).
  • Legal Bases: Consent (Art. 6(1)(a) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Further Information on Processing Activities, Procedures, and Services:

Application Process

The application process requires applicants to provide us with the data necessary for their assessment and selection. The required information is derived from the job description or, in the case of online forms, from the information provided therein.

Generally, the required information includes personal details such as name, address, contact details, and proof of the qualifications necessary for the job. Upon request, we are happy to provide additional information on the required details.

Where available, applicants can submit their applications via our online form, which is encrypted according to the latest technology. Alternatively, it is also possible to send applications to us by email. However, we would like to point out that emails sent over the internet are generally not encrypted. Although emails are usually encrypted during transport, this does not apply to the servers from which they are sent and received. Therefore, we cannot take responsibility for the security of the application during its transmission between the sender and our server.

To search for applicants, receive applications, and select applicants, we may use applicant management or recruitment software and platforms and services from third-party providers, observing the legal requirements.

Applicants are welcome to contact us regarding the method of submitting their application or to send the application by post.

Processing of Special Categories of Data: If special categories of personal data (Art. 9(1) GDPR, e.g., health data such as disability status or ethnic origin) are requested from applicants in the application process or provided by them, their processing is carried out so that the controller or the data subject can exercise their rights under labor law and social security and social protection law and fulfill their obligations in this regard, in the case of protection of vital interests of the applicants or other persons, or for purposes of preventive or occupational medicine, for the assessment of the employee's working capacity, for medical diagnosis, for the provision or treatment in the health or social sector, or for the management of systems and services in the health or social sector.

Deletion of Data: The data provided by the 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 not successful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Deletion will occur, subject to a justified withdrawal by the applicants, at the latest after a period of six months so that we can answer any follow-up questions about the application and comply with our obligations under the provisions on equal treatment of applicants. Invoices for any travel expense reimbursement will be archived following 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 be included in the talent pool is voluntary, does not affect the ongoing application process, and they can withdraw their consent at any time for the future.

  • Types of Processed Data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts, and related information such as authorship details or time of creation). Applicant data (e.g., personal details, postal and contact addresses, application documents, and the information contained therein such as cover letter, CV, certificates, and other information provided voluntarily by applicants about their person or qualifications).
  • Data Subjects: Applicants.
  • Purposes of Processing: Application process (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Retention and Deletion: Deletion according to the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Bases: Application process as a pre-contractual or contractual relationship (Art. 6(1)(b) GDPR).

Data Protection Information for Whistleblowers

In this section, you will find information on how we handle data from whistleblowers, as well as from affected and involved parties in the context of our whistleblower process. Our goal is to provide a simple and secure way to report possible misconduct by us, our employees, or service providers, especially for actions that violate laws or ethical guidelines. We also ensure appropriate handling and processing of the reports.

Types of Processed Data:

In the context of receiving and processing reports and in the subsequent whistleblower process, we may collect various data. This includes, in particular, the data provided by a whistleblower, such as:

  • Name, contact details, and location of the whistleblower,
  • Names and data of possible witnesses or individuals affected by the report,
  • Names and data of the individuals against whom the report is directed,
  • Data on the alleged misconduct,
  • Other relevant details, if provided by the whistleblower.

For the purposes of fact-finding and further procedure, we also process the following personal data:

  • Unique identification of the report,
  • Contact details of the whistleblower, if provided,
  • Personal data of individuals mentioned in the report, if provided,
  • Personal data of individuals indirectly affected by the fact-finding process, if applicable,
  • Personal data of individuals from other involved companies (e.g., in the context of legal advice), if relevant,
  • Other data related to the matter.

Special Categories of Personal Data:

It may happen that we collect special categories of personal data as part of our activities, particularly if they are provided by a whistleblower. These include:

  • Health-related data of a person,
  • Data on the racial or ethnic origin of individuals,
  • Information on religious or philosophical beliefs of a person,
  • Details of a person's sexual orientation.

These data are only processed if they are relevant to the handling of the respective report and have been explicitly provided by the whistleblower.

Use of Our Online Forms: Please note that it is possible to submit reports anonymously. To ensure the security of your data when using our online forms, we recommend accessing them in the so-called 'incognito mode' of your browser. Here is how you can open an incognito window: a) On a Windows PC: Open your browser and press Ctrl+Shift+N; b) On a Mac: Open your browser and press Command+Shift+N; c) On mobile devices: Switch to private mode via the tab menu.

When accessing our website in normal mode, your browser automatically sends certain information to our server, such as browser type and version, date and time of access. This also includes the IP address of your device. This data is temporarily stored in a log file and automatically deleted after a maximum of 30 days.

The processing of the IP address serves technical and administrative purposes for the connection establishment of our website. It ensures the security, stability, and functionality of the whistleblower form and is an essential part of our measures to ensure confidential reporting.

The processing of the logged data is based on Article 6(1)(f) GDPR. Our legitimate interest lies in the need for security and the necessity to ensure the technical prerequisites for smooth and trouble-free reporting.

Providing Names: You have the option to submit reports anonymously. Unless prohibited by national laws, we recommend providing your name and contact details. This enables us to pursue the report more effectively and, if necessary, to contact you directly.

If you provide your name and contact details, your identity will be kept strictly confidential. Exceptions to this confidentiality exist only if we are legally obliged to disclose your identity. This may be necessary to protect or defend our rights or the rights of our employees, customers, suppliers, or business partners. Another exception exists if it is found that the allegations were made with malicious intent.

Provision of Data to Third Parties: Data related to the submitted reports will only be shared with third parties under certain circumstances. This occurs either a) if you have given us your explicit consent to do so, or b) if there is a legal obligation to share the data. Potential third parties include public authorities, government, regulatory, or tax authorities, if the disclosure is necessary to fulfill a legal or regulatory obligation. Additionally, we may appoint lawyers and other professional advisors to examine suspected misconduct and take necessary actions after an investigation, such as initiating disciplinary or legal proceedings. We may also carefully select and monitor service providers who receive data for these purposes (e.g., operators of a web-based reporting system). These service providers are contractually obligated to comply with applicable data protection regulations as part of data processing agreements.

Data Retention and Deletion: Personal data will only be processed as long as it is necessary to fulfill the processing purposes described above. If these data are no longer needed for the stated purposes, they will be deleted. In certain situations, the data may be retained longer to meet legal requirements, as long as this is necessary and proportionate. In such cases, the data will be deleted as soon as they are no longer necessary for these purposes.

Technical and Organizational Measures: We have implemented the necessary contractual, technical, and organizational measures to ensure the security of all data processed by us. This data is processed exclusively for the specified purposes. The incoming reports are processed by authorized personnel who have access to the respective reports and conduct the subsequent fact-finding process. Our employees are specifically trained for the proper conduct of fact-finding processes, educated, and obligated to maintain strict confidentiality.

  • Types of Processed Data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); employee data (information about employees and other persons in an employment relationship); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts, and related information such as authorship details or time of creation). Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems, interactions with content and functions).
  • Data Subjects: Employees (e.g., employees, applicants, temporary workers, and other staff); third parties. Whistleblowers.
  • Purposes of Processing: Whistleblower protection.
  • Retention and Deletion: Deletion according to the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Bases: Consent (Art. 6(1)(a) GDPR); legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Whistleblower Systems

In the context of our whistleblower process, we use external providers. We act within the legal requirements and ensure that the technical and organizational requirements for security measures we adhere to are also met by the external providers.

  • Types of Processed Data: Inventory data (e.g., full name, residential address, contact information, customer number, etc.); employee data (information about employees and other persons in an employment relationship); contact data (e.g., postal and email addresses or phone numbers); content data (e.g., textual or visual messages and posts, and related information such as authorship details or time of creation). Usage data (e.g., page views and duration, click paths, usage intensity and frequency, device types and operating systems, interactions with content and functions).
  • Data Subjects: Employees (e.g., employees, applicants, temporary workers, and other staff); third parties. Whistleblowers.
  • Purposes of Processing: Whistleblower protection.
  • Retention and Deletion: Deletion according to the information provided in the section "General Information on Data Retention and Deletion".
  • Legal Bases: Consent (Art. 6(1)(a) GDPR); legal obligation (Art. 6(1)(c) GDPR). Legitimate interests (Art. 6(1)(f) GDPR).

Changes and Updates

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as the changes in the data processing we carry out make this necessary. We will inform you as soon as changes require your cooperation (e.g., consent) or other individual notifications.

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 we ask you to check the information before contacting us.

Definitions

In this section, you will find an overview of the terms used in this privacy policy. As far as the terms are legally defined, their legal definitions apply. The following explanations are primarily intended to aid understanding.

  • Employees: Employees are defined as individuals in an employment relationship, be it as employees, workers, or in similar positions. An employment relationship is a legal relationship between an employer and an employee, established by an employment contract or agreement. It includes the employer's obligation to pay the employee remuneration while the employee performs their work. The employment relationship encompasses various phases, including the establishment, where the employment contract is concluded, the implementation , where the employee performs their work duties, and the termination, when the employment relationship ends, either by termination, mutual agreement, or otherwise. Employee data includes all information relating to these individuals in the context of their employment. This includes aspects such as personal identification data, identification numbers, salary and bank details, working hours, leave entitlements, health data, and performance evaluations.
  • Inventory Data: Inventory data includes essential information required for the identification and management of contractual partners, user accounts, profiles, and similar associations. This data may include personal and demographic information such as names, contact information (addresses, phone numbers, email addresses), birth dates, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between individuals and services, institutions, or systems by enabling clear identification and communication.
  • Content Data: Content data includes information generated during the creation, editing, and publication of all types of content. This category of data can include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited to the actual content but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates.
  • Contact Data: Contact data is essential information that enables communication with individuals or organizations. This includes phone numbers, postal addresses, and email addresses, as well as communication means such as social media handles and instant messaging identifiers.
  • Meta, Communication, and Procedural Data: Meta, communication, and procedural data are categories containing information about how data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. This can include file size, creation date, document author, and modification history. Communication data captures the exchange of information between users over various channels, such as email traffic, call logs, messages on social networks, and chat histories, including the involved persons, timestamps, and transmission paths. Procedural data describes the processes and workflows within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs used for tracking and verifying operations.
  • Usage Data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data encompasses a wide range of information showing how users utilize applications, which features they prefer, how long they stay on certain pages, and the paths they navigate through an application. Usage data can also include usage frequency, activity timestamps, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Additionally, usage data plays a crucial role in identifying trends, preferences, and potential problem areas within digital offerings.
  • Personal Data: "Personal data" refers to any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Profiles with User-Related Information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that involves using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information regarding demographics, behavior, and interests, such as interaction with websites and their content, etc.). For profiling purposes, cookies and web beacons are often used.
  • Log Data: Log data is information about events or activities recorded in a system or network. This data typically includes details such as timestamps, IP addresses, user actions, error messages, and other information about the use or operation of a system. Log data is often used for system problem analysis, security monitoring, or performance reporting.
  • Reach Measurement: Reach measurement (also known as web analytics) serves to evaluate visitor flows of an online service and may include behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online services can, for example, recognize when users visit their websites and what content they are interested in. This allows them to better adapt the content of the websites to the needs of their visitors. For reach measurement purposes, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online service.
  • Tracking: "Tracking" refers to the ability to track user behavior across multiple online services. Behavior and interest information regarding the used online services is typically stored in cookies or on the servers of the providers of tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Controller: A "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 or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it is collecting, evaluating, storing, transmitting, or deleting.
  • Contract Data: Contract data are specific information related to formalizing an agreement between two or more parties. They document the conditions under which services or products are provided, exchanged, or sold. This data category is essential for managing and fulfilling contractual obligations and includes both the identification of the contracting parties and the specific terms and conditions of the agreement. Contract data can include start and end dates of the contract, the nature of the agreed services or products, pricing agreements, payment terms, termination rights, renewal options, and special terms or clauses. They serve as a legal basis for the relationship between the parties and are crucial for clarifying rights and obligations, enforcing claims, and resolving disputes.
  • Payment Data: Payment data includes all information necessary for processing payment transactions between buyers and sellers. This data is crucial for electronic commerce, online banking, and any other form of financial transaction. It includes details such as credit card numbers, bank account details, payment amounts, transaction data, verification numbers, and billing information. Payment data can also include information about payment status, chargebacks, authorizations, and fees.
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