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Private Policy

Data protection

 

Introduction

The following Privacy Policy is intended to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. This Privacy Policy applies to all processing of personal data that we carry out, 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 offering”). 

The terms used are not gender specific. 

Last updated: 30 August 2022 

 Overview of contents  

  • Introduction
  • Controller 
  • Data Protection Officer contact 
  • Overview of processing operations 
  • Relevant legal bases 
  • Security measures 
  • Transmission of personal data 
  • Data processing in third countries 
  • Erasure of data 
  • Use of cookies 
  • Provision of the online offering and web hosting 
  • Contact and enquiry management 
  • Application process 
  • Newsletters and electronic notifications 
  • Promotional communication via email, post, fax or telephone 
  • Online marketing 
  • Presences on social networks (social media) 
  • Plugins and embedded functions and content 
  • Changes and updates to the Privacy Policy 
  • Rights of data subjects 
  • Definitions of terms 

Controller

Thuasne Deutschland GmbH (hereinafter “THUASNE”), Im Steinkamp 12, 30938 Burgwedel, Germany, Tel.: +49 5139 988-0, Fax: +495139 988-177, Email: info@thuasne.de 

 

Data Protection Officer contact 

Carin Schwenger van Tuil, List + Lohr, Garvenstraße 4, 30519 Hannover, Tel.: +49 511 – 49 99 99 -600; email: datenschutz@thuasne.de

Overview of processing operations 

The following overview summarises the types of data processed and the purposes for which they are processed, and identifies the data subjects. 

Types of data processed 

  • Inventory data. 
  • Contact details. 
  • Content data. 
  • Usage data. 
  • Meta/communication data. 
  • Applicant data. 
  • Event data (Facebook). 

Categories of data subjects 

  • Communication partners. 
  • Users. 
  • Applicants. 

Purposes of processing 

  • Provision of contractual services and customer service. 
  • Contact enquiries and communication. 
  • Security measures.
  • Direct marketing. 
  • Reach measurement. 
  • Tracking. 
  • Conversion measurement. 
  • Target group formation. 
  • Management and response to enquiries. 
  • Application process. 
  • Feedback. 
  • Marketing. 
  • Profiles with user-related information.
  • Target group formation. 
  • provision of our online offering and user-friendliness. 
  • Information technology infrastructure. 

Relevant legal bases 

Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or domicile. In addition, if more specific legal bases apply in individual cases, we will inform you of these in the Privacy Policy. 

  • Consent (Article 6 (1) (a) GDPR)  – The data subject has given consent to the processing of personal data concerning him or her for one or more specific purposes. 
  • Contractual performance and pre-contractual enquiries (Article 6 (1) (1) (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. 
  • Legitimate interests (Article 6 (1) (f) GDPR)  – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. 

In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. This includes in particular the German Federal Data Protection Act (BDSG). In particular, the BDSG contains special provisions on the right of access, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates the processing of data for the purposes of the employment relationship (section 26 BDSG), in particular with regard to the establishment, execution or termination of employment relationships as well as the consent of employees. Furthermore, the data protection laws of the individual federal states may apply. 

Security measures 

We take appropriate technical and organisational measures in accordance with statutory 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. 

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access concerning the data, the input, the transmission, the availability and the separation thereof. We have also put in place procedures which ensure that the rights of data subjects are observed, that data is erased and that there are reactions to the endangerment of data. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and procedures in accordance with the principle of data protection, by designing technology and by setting up data protection-friendly default settings. 

SSL encryption (https): we use SSL encryption to protect your data transmitted via our online offering. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser. 

Transmission of personal data 

As part of our processing of personal data, the data may be transmitted to, or disclosed to, other bodies, companies, legally independent organisational units or individuals. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data. 

Data processing in third countries 

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or 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 be done in accordance with statutory requirements. 

Subject to express consent or transmission required by contract or law, we only process or have the data processed in third countries with a recognised level of data protection, contractual obligations based on standard protection clauses of the EU Commission, in the case 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_en).

Erasure of data 

The data we process is erased in accordance with the statutory provisions as soon as consent to their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data is no longer applicable or it is not necessary for the purpose). Insofar as the data are not erased because they are necessary for other and legally permissible purposes, their processing is limited to those 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 reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. 

As part of our data protection notices, we may provide users with further information on the erasure and retention of data that applies specifically to the respective processing operations. 

Use of cookies 

  • Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to save the login status in a user account, a shopping basket in an e-shop, or the content accessed, or the functions used in an online offering. Cookies may also be used for a variety of purposes, such as the functionality, security and convenience of online offerings and the analysis of visitor flows. 

    Information on consent: we use cookies in accordance with statutory regulations. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of the information, including cookies, is absolutely necessary to provide users with a telemedia service (i.e. our online offering) that they have expressly requested. The revocable consent is clearly communicated to users and contains information about the respective use of cookies. 

    Information on legal bases under data protection law: the legal basis on which we process the personal data of users with the help of cookies depends on whether we ask users for their consent. If the users consent, 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 improving its usability) or, if this is done in the context of fulfilling our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We clarify the purposes for which the cookies are processed by us in the course of this Privacy Policy or as part of our consent and processing operations. 

    Duration of storage: the following types of cookies are differentiated with regard to the duration of storage: 

    • Temporary cookies (also: session cookies): temporary cookies are erased at the latest after a user leaves an online service and closes their end device (e.g. browser or mobile application). 
    • Permanent cookies: permanent cookies remain stored even after the end device has been closed. For example, the login status can be saved or preferred content displayed immediately when the user visits a website again. Users’ data collected with the help of cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. in the context of obtaining consent), users should assume that cookies are permanent and may be stored for up to two years. 

    General information on revocation and objection (opt-out): users may revoke their consent at any time and also object to processing in accordance with the statutory provisions of Art. 21 GDPR. Users can also opt out via their browser settings, for example by deactivating the use of cookies (which may also restrict the functionality of our online services). They can also object to the use of cookies for online marketing purposes via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. 

    More information about processing operations, procedures and services: 

    • Processing of cookie data on the basis of consent: we use a cookie-consent management procedure, in which the consents of users to the use of cookies, or to the processing and providers mentioned in the cookie-consent management procedure, can be obtained, as well as managed and revoked by the users. In this case, the declaration of consent is stored so that it is not necessary to request it again and so that the consent can be proven in accordance with the legal obligation. The data may be stored on the server and/or in a cookie (so-called opt-in cookie or using comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: consent may be stored for up to two years. A pseudonymous user identifier is created and saved with the time of consent, information about the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used. 
    • Borlabs Cookie: cookie consent management; Service provider: hosted locally on our server, no data will be passed on to third parties; Website: https://de.borlabs.io/borlabs-cookie/; Further information: an individual user ID, language as well as types of the consents and the time their granting are stored on the server and in the cookie on the user’s device. 

Provision of the online offering and web hosting 

We process the user data so we can provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device. 

  • Data types processed: usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses). 
  • Data subjects: users (e.g. website visitors, users of online services). 
  • Purposes of processing: provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures. 
  • Legal bases: legitimate interests (Art. 6 (1) (1) (f) GDPR). 

 

More information about processing operations, procedures and services: 

  • Provision of online offering on rented storage space: to provide our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also known as a “web host”); Legal bases: legitimate interests (Art. 6 (1) (1) (f) GDPR). 
  • Collection of access data and log files: access to our online offering is logged in the form of so-called “server log files”. Server log files may include the address and name of the web pages and files accessed, date and time of retrieval, data volumes transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the page visited previously) and, as a rule, IP addresses and the requesting provider. The server log files may be used for security purposes, e.g. to avoid server overload (particularly in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server utilization and stability; Legal bases: legitimate interests (Art. 6 (1) (1) (f) GDPR); Erasure of data: log file information is stored for a maximum of 30 days and then erased or anonymised. Data whose further retention is required for evidentiary purposes is excluded from erasure until the respective incident has been definitively clarified. 

Contact and enquiry management 

When contacting us (e.g. via contact form, email, telephone or social media) and within the framework of existing user and business relationships, the information of the persons making the enquiry is processed insofar as this is necessary to answer the enquiries and any measures requested. 

Responding to contact enquiries and managing contact and enquiry data in the context of contractual or pre-contractual relationships takes place in order to fulfil our contractual obligations or to answer (pre-)contractual enquiries and otherwise on the basis of our legitimate interests in responding to enquiries and maintaining user or business relationships. 

  • Data types processed: contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses). 
  • Data subjects: communication partners.
  • Purposes of processing: contact enquiries and communication; management and response to enquiries; feedback (e.g. collecting feedback via online form); provision of our online offering and user-friendliness; provision of contractual services and customer service. 
  • Legal bases: contract fulfilment and pre-contractual enquiries (Art. 6 (1) (1) (b) GDPR); Legitimate interests (Art. 6 (1) (1) (f) GDPR). 

 

More information about processing operations, procedures and services: 

  • Contact form: if users contact us via our contact form, email or other communication channels, we process the data provided to us in this context to process the matter communicated to us. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfilment and otherwise on the basis of our legitimate interests and the interests of the communication partners in responding to requests and our statutory retention obligations;
  • Legal bases: contract fulfilment and pre-contractual enquiries (Art. 6 (1) (1) (b) GDPR); Legitimate interests (Art. 6 (1) (1) (f) GDPR). 

Application process 

The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information provided there. 

Essentially, the required information includes personal information such as name, address, contact details and proof of the qualifications required for a position. On request, we will also be happy to let you know what information is required. 

If provided, applicants can submit their applications to us 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 email. However, please note that emails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted during transport, but not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission path of the application between the sender and the receipt on our server. 

For the purposes of looking for applicants, submitting applications and selecting applicants, we may use applicant management and recruitment software and platforms and services from third-party providers in compliance with legal requirements. 

Applicants are welcome to contact us to find out 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 (1) GDPR (e.g. health data, such as disability status or ethnic origin) are requested from applicants during the application process in order for the controller or data subject to exercise his or her rights under labour law and social security and social protection law and to comply with his or her obligations in this regard, processing is carried out in accordance with Art. 9 (2) (b) GDPR, in the case of the protection of vital interests of the

Applicants or other persons pursuant to Art. 9 (2) (c) GDPR or for the purposes of preventive health care or occupational medicine, for assessing the employee’s ability to work, for medical diagnostics, for care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Art. 9 (2) (h) GDPR. In the event of communication of the special categories of data based on voluntary consent, the processing is carried out on the basis of Art. 9 (2) (a) GDPR. 

Erasure 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 unsuccessful, the applicant’s data will be erased. Applicants’ data is also erased if an application is withdrawn, which applicants are entitled to do at any time. The data will be erased, subject to a justified revocation 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 to provide evidence under the provisions on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with the provisions of tax law. 

Inclusion in an applicant pool: admission to an applicant pool, if offered, is based on consent. Applicants are advised that their consent to join the talent pool is voluntary, has no influence on the current application process, and that they may revoke their consent at any time with future effect. 

  • Data types processed: inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); applicant data (e.g. personal details, postal and contact addresses, documents pertaining 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). 
  • Data subjects: applicants. 
  • Purposes of processing: application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship). 
  • Legal bases: legitimate interests (Art. 6 (1) (1) (f) GDPR).

Newsletters and electronic notifications 

We only send newsletters, emails and other electronic notifications (hereinafter referred to as “newsletters”) with the consent of the recipient or with legal permission. If the content of the newsletter is specifically described as part of a subscription to the newsletter, it is decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us. 

To subscribe to our newsletters, entering your email address is generally sufficient. However, we may ask you to provide a name for the purpose of personally addressing you in the newsletter or other information if this is necessary for the purposes of the newsletter. 

Double opt-in procedure: subscription to our newsletter generally takes place via what is referred to as a double opt-in procedure. This means that you will receive an email after registration asking you to confirm your registration. This confirmation is necessary so that no one can log in with third-party email addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the shipping service provider are also logged. 

Erasure and restriction of processing: we may store the discarded email addresses for up to three years based on our legitimate interests before we erase them in order to be able to prove previously given consent. 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 previous existence of consent is confirmed. In the event of obligations to comply with contradictions on a permanent basis, we reserve the right to store the email address for this purpose only in a block list. 

The logging of the registration process is based on our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure delivery system. 

Contents: information about us, our services, promotions and offers. 

  • Data types processed: inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); meta/communication data (e.g. device information, IP addresses); usage data (e.g. websites visited, interest in content, access times). 
  • Data subjects: communication partners. 
  • Purposes of processing: direct marketing (e.g. by email or post). 
  • Legal bases: consent (Art. 6 (1) (1) (a) GDPR). 
  • Option to object (opt-out): you can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You can either find a link to cancel the newsletter at the end of each newsletter or use one of the contact options listed above, preferably by email. 

 

More information about processing operations, procedures and services: 

  • Measurement of opening and click rates: the newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved by our server when the newsletter is opened or, if we use a shipping service provider, by its server. As part of this retrieval, technical information is first collected, such as information about the browser and your system, as well as your IP address and the time of retrieval. This information is used to technically improve our newsletter on the basis of technical data or target groups and their reading behaviour based on their retrieval location (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened, and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are erased. The evaluations help us identify our users’ reading habits and to adapt our content to them or to send different content according to our users’ interests. The measurement of the opening rates and click rates as well as the storage of the measurement results in the users’ profiles and their further processing are carried out on the basis of the users’ consent. Unfortunately, a separate revocation of the performance measurement is not possible. In this case, the entire newsletter subscription must be cancelled or objected to. In this case, the saved profile information is erased; Legal bases: consent (Art. 6 (1) (1) (a) GDPR). 

Promotional communication via email, post, fax or telephone 

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

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

After revocation or objection, we will store the data required to prove the previous authorisation to establish contact or to consignation for up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of users, we also store the data necessary to avoid re-establishing contact (e.g. email address, telephone number, name, depending on the communication channel). 

  • Data types processed: inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers). 
  • Data subjects: communication partners. 
  • Purposes of processing: direct marketing (e.g. by email or post). 
  • Legal bases: consent (Art. (6) (1) (1) (a) GDPR); Legitimate interests (Art. 6 (1) (1) (f) GDPR). 

Online marketing 

We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of their effectiveness. 

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”), or similar methods are used to store the information about the user relevant to the presentation of the aforementioned content. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used, as well as information about usage times and functions used. If users have consented to the collection of their location data, this data may also be processed. 

The IP addresses of the users are also stored. However, we use available IP masking methods (i.e. pseudonymisation by shortening the IP address) to protect users. Generally speaking, the online marketing process does not store plain user data (such as email addresses or names), but rather pseudonyms. This means that we and the providers of the online marketing methods do not know the users’ actual identity, but only the information stored in their profiles. 

The information in the profiles is usually stored in cookies or by similar means. These cookies may later generally also be used on other websites using the same online marketing method, read and analysed for the purpose of displaying content, supplemented with additional data and stored on the server of the online marketing method provider. 

In exceptional cases, clear data may be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing methods we use, and the network links the users’ profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, e.g. by consent within the scope of registration. 

As a matter of principle, we only receive access to aggregated information about the success of our advertisements. However, in the context of so-called conversion measurements, we may check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. Conversion measurement is used solely to analyse the success of our marketing measures. 

Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years. 

  • Data types processed: content data (e.g. input into online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); event data (Facebook) (“event data” is data that can be transmitted from us to Facebook, for example via Facebook pixel (via apps or other means) and relates to people or their actions; data includes, for example, information about visits to websites, interactions with content, functions, app installations, purchases of products, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not include the actual content (such as comments written), login information and contact information (i.e. no names, email addresses and telephone numbers). Event data is erased by Facebook after a maximum of two years, the target groups formed from them with the erasure of our Facebook account). 
  • Data subjects: users (e.g. website visitors, users of online services). 
  • Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behaviour-based profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; profiles with user-related information (creation of user profiles); target group formation (identifying target groups relevant for marketing purposes or other output of content); provision of our online offering and user-friendliness. 
  • Safety measures: IP masking (pseudonymisation of the IP address). 
  • Legal bases: consent (Art. 6 (1) (1) (a) GDPR). 
  • Option to object (opt-out): we refer to the data protection notices of the respective providers and the options for objecting to the providers (so-called “opt-out”). If no explicit opt-out option has been specified, you may disable cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore also recommend the following opt-out options, which are offered in summary for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Across all areas: https://optout.aboutads.info. 

 

More information about processing operations, procedures and services: 

  • Facebook pixel and target group formation (Custom Audiences): with the help of the Facebook pixel (or similar functions, for transmitting event data or contact information via interfaces in apps), Facebook is able to determine the visitors to our online offering as the target group for the display of ads (so-called “Facebook Ads”). Accordingly, we use the Facebook pixel to display the Facebook Ads we place on Facebook only to users on Facebook and within the services of partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who have certain characteristics (e.g. interest in certain topics or products that become apparent from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of users and are not annoying. Using the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: Consent (Art. 6 (1) (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Further information: event data of users, i.e. information on behaviour and interests, is processed for the purposes of targeted advertising and target group formation on the basis of the agreement on joint responsibility (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum). The joint responsibility is limited to the collection and transfer of data to Meta Platforms Ireland Limited, an EU-based company. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses between Meta Platforms Ireland Limited and Meta Platforms, Inc.). 

Presences on social networks (social media) 

We maintain online presences within social networks and process user data in order to communicate with users active there or to provide information about us. 

We would like to point out that user data may be processed outside of the European Union. This may give rise to risks for users, for example because it might make it more difficult to enforce users’ rights. 

Furthermore, users’ data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on user behaviour and the resulting interests of users. The usage profiles may in turn be used, for example, to place advertisements within and outside the networks that are presumably in the users’ interest. For these purposes, cookies are generally stored on the users’ computers, which store the user’s usage behaviour and interests. Data may also be stored in the usage profiles regardless of the devices used by the users (particularly 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 options for objecting (opt-out), please refer to the privacy policies and information provided by the operators of the respective networks. 

In the case of requests for information and the assertion of data subjects’ rights, we would like to point out that these can be asserted most effectively with the providers. Only providers have access to user data and can take appropriate measures and provide information directly. If you still need help, please do not hesitate to contact us. 

  • Data types processed: contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses). 
  • Data subjects: users (e.g. website visitors, users of online services). 
  • Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing. 
  • Legal bases: legitimate interests (Art. 6 (1) (1) (f) GDPR). 

 

More information about processing operations, procedures and services: 

  • Instagram: social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: legitimate interests (Art. 6 (1) (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy. 
  • Facebook pages: profiles within the social network Facebook – Together with Meta Platforms Ireland Limited, we are responsible for collecting (but not for further processing) the data of visitors to our Facebook page (so-called “fan page”). This information includes information about the types of content that users view or interact with, or the actions they take (see “Things that 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 “App, browser and device information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use your information?” Facebook also collects and uses information to provide analytics services, so-called “Page Insights”, to site operators to gain insight into how people interact with their sites and the content associated with them. We have entered into a special agreement with Facebook (“Information about Page Insights Data”, https://www.facebook.com/legal/terms/page_controller_addendum) which, in particular, regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users may, for example, send information or erasure requests directly to Facebook). The rights of users (in particular the right to information, erasure, 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 Data” (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: legitimate interests (Art. 6 (1) (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guaranteed level of data protection when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Agreement on joint responsibility: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint responsibility is limited to the collection and transfer of data to Meta Platforms Ireland Limited, an EU-based company. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses between Meta Platforms Ireland Limited and Meta Platforms, Inc.). 
  • LinkedIn: social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal bases: legitimate interests (Art. 6 (1) (1) (f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (guaranteed level of data protection when processing in third countries): https://legal.linkedin.com/dpa; Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. 
  • Twitter: social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, Parent company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal bases: legitimate interests (Art. 6 (1) (1) (f) GDPR); Privacy Policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization). 
  • Xing: social network; Service provider: XING AG, Dammtorstrasse 29-32, 20354 Hamburg, Germany; Legal bases: legitimate interests (Art. 6 (1) (1) (f) GDPR); Website: https://www.xing.com; Privacy Policy: https://privacy.xing.com/en/privacy-policy. 

Plugins and embedded functions and content 

We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This may include, for example, graphics, videos or city maps (hereinafter referred to as “content”). 

The integration always requires the third-party providers of this content to process the user’s IP address, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required for the display of this content or functions. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information, such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offering, and be linked to such information from other sources. 

  • Data types processed: usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms). 
  • Data subjects: users (e.g. website visitors, users of online services). 
  • Purposes of processing: provision of our online offering and user-friendliness. 
  • Legal bases: legitimate interests (Art. 6 (1) (1) (f) GDPR). 

 

More information about processing operations, procedures and services: 

Changes and updates to the Privacy Policy 

We ask that you check the content of our Privacy Policy regularly. We will amend the Privacy Policy as soon as changes to the data processing we carry out 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 for companies and organisations in this Privacy Policy, please note that the addresses may change over time and please check the details before contacting us. 

Rights of data subjects 

As a data subject, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR: 

  • Right to object: you have the right, on grounds relating to your particular situation, to object 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 these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, including profiling to the extent that it is related to such direct marketing. 
  • Right to withdraw consent: you have the right to withdraw any consent you have given at any time. 
  • Right of access: you have the right to obtain confirmation as to whether the data in question is being processed and to obtain access to such data as well as further information and a copy of the data in accordance with the statutory provisions. 
  • Right to rectification: in accordance with the statutory provisions, you have the right to request the completion of the 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 without delay 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 that you have provided to us in a structured, commonly used and machine-readable format in accordance with statutory requirements or to request its transfer to another controller. 
  • Complaint with a supervisory authority: in accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you believe that the processing of personal data concerning you infringes the GDPR. 

Definitions of terms 

This section provides an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and are primarily defined in Art. 4 GDPR. The statutory definitions are binding. The following explanations, on the other hand, are primarily intended for the purpose of comprehension. The terms are sorted alphabetically. 

  • Conversion measurement: conversion measurement (also referred to as “visit action evaluation”) is a method of determining the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users’ devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. This allows us, for example, 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 “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 characteristics 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” refers to any type of automated processing of personal data consisting of the use of personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, different information about demographics, behaviour and interests, such as interaction with websites and their content, etc.) may be used to analyse, evaluate or predict them (e.g. interests in certain content or products, click behaviour 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 visitor flows to an online offering and may include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can identify, for example, when visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to their visitors’ needs. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used in order to identify returning visitors and thus obtain more accurate analyses of the use of an online offering. 
  • Tracking: “tracking” is when the behaviour of users can be tracked across several online offerings. As a rule, behavioural and interest information regarding the online services used is stored in cookies or on the servers of the providers of tracking technologies (so-called profiling). This information may subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests. 
  • Controller: “controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. 
  • Processing: “processing” means any operation or set of operations, whether or not by automated means, relating to personal data. The term is wide-ranging and covers practically any handling of data, be it collection, evaluation, storage, transmission or erasure. 
  • Target group formation: target group formation (or “Custom Audiences”) is used when target groups are determined for advertising purposes, such as displaying advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it may be concluded that the user is interested in advertisements for similar products or the online shop in which the user viewed the products. The term “Lookalike Audiences” (or similar target groups) is used when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purposes of creating Custom Audiences and Lookalike Audiences. 

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