Déclaration de confidentialité

Introduction

With the following Data Privacy Statement, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes, and in which scope. The Data Privacy Statement applies to all processing of personal data carried out by us, both in the scope of providing 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 services”).

The terms used are not gender-specific.

As at: 11/09/2020

Contents

Controller

duisport industrial solutions group
Alte Ruhrorter Strasse 42–52
47119 Duisburg

Authorized representatives: Managing Directors: Jan-Malte Wöhrle, Christian Staudner

Email address: dis-west@duisport.de

Telephone: +49 203 803-2201

Legal notice: Link to legal notice

Data Protection Officer contact information

Klaus Keukert
S&L IT compliance GmbH
Florinstrasse 18
56218 Mülheim-Kärlich
Germany
Telephone: +49 261 92736-0
Email: datenschutz@duisport.de

Overview of processing operations

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

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application, and the information contained therein, such as cover letter, curriculum vitae, certificates, and other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
  • Content data (e.g. entries in online forms).
  • 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).
  • Location data (information about the geographical position of a device or person).
  • Contract data (e.g. subject matter of contract, term, customer category).

Special categories of data

  • Health data (Art. 9 para. 1 GDPR).

Categories of data subjects

  • Applicants.
  • Interested parties.
  • Communication partners.
  • Customers.
  • Users (e.g. website visitors, users of online services).
  • Sweepstakes and contest participants.

Purposes of processing

  • Provision of our online services and usability.
  • Conversion tracking (Measurement of the effectiveness of marketing activities).
  • Application procedure (establishment and possible subsequent implementation of an employment relationship, as well as its possible later termination).
  • Direct marketing (e.g. by email or postal mail).
  • Organization of sweepstakes and contests.
  • Feedback (e.g. collecting feedback via online form).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Profiling (creation of user profiles).
  • Remarketing.
  • Audience measurement (e.g. access statistics, identification of returning visitors).
  • Security measures.
  • Tracking (e.g. interest-based/behavioral profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Administration of and response to inquiries.

Relevant legal bases

In the following, we share the legal bases of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that, in addition to the regulations of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the Data Privacy Statement.

  • Consent (Art. 6 para. 1 p. 1 lit. a. GDPR) – The data subject has given his or her consent to the processing of personal data relating to him or her for a specific purpose or purposes.
  • Performance of a contract and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject’s request.
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR) – Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the data controller or the data subject can exercise the rights accruing to him or her under labor law and social security and social protection law and fulfill his or her obligations in this regard, their processing is carried out in accordance with Art. 9 para. 2 lit. b. GDPR, in case of protection of vital interests of the applicants or other persons according to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector, or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. GDPR.


National data protection regulations in Germany
: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, and automated decision-making in individual cases, including profiling. Furthermore, it governs how data is processed for employment purposes (Section 26 BDSG), in particular with regard to the establishment, implementation, or termination of employment relationships, as well as the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, implementation costs, the nature, scope, circumstances and purposes of processing, the different probabilities of occurrence, and the extent of the threat to the rights and freedoms of natural persons in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, disclosure of, assurance of the availability of, and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.

SSL encryption (https): To protect your data transmitted via our online services, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.

Transmission and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units, or persons. Recipients of this data may include, for example, payment institutions in the scope of payment transactions, service providers entrusted with IT tasks, or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to this data. If this transfer takes place for administrative purposes, the transfer of the data is based on our legitimate business and commercial interests or takes place if it is necessary for the fulfillment of our contract-related obligations or if the consent of the data subjects or a legal permission has been granted.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the scope of the use of third-party services or the disclosure or transfer of data to other persons, entities, or companies, this will only be done in accordance with legal requirements.

Subject to express consent or contractually or legally required transfer, we process or allow the processing of data only in third countries with a recognized level of data protection, contractual obligation by “standard protection clauses” of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his or her visit within an online service. Stored information may include, for example, language settings on a website, login status, a shopping cart, or the place where a video was viewed. Furthermore, we include in the term “cookies” other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed his or her browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user interests used for audience measurement or marketing purposes can be stored in such a cookie.
  • First-party cookies: First-party cookies are cookies we set ourselves.
  • Third-party cookies: Third-party cookies are mainly used by advertisers (“third parties”) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: On the one hand, cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  • Statistical, marketing and personalization cookies: Furthermore, cookies are usually also used in the scope of audience measurement and when a user’s interests or behavior (e.g. viewing of certain content, use of functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our Data Privacy Statement or as part of a process of obtaining consent.


Information on legal bases:
The legal basis on which we process your personal data with the aid of cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the aid of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online services and its improvement) or if the use of cookies is necessary to fulfill our contractual obligations.

Duration of storage: Unless we provide you with explicit information regarding the storage duration of permanent cookies (e.g. as part of a “cookie opt-in”), please assume that the storage duration may last up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option to revoke any consent you have given or to object to the processing of your data by means of cookie technologies at any time (collectively referred to as “opt-outs”). You can initially declare your objection using your browser settings, e.g. by disabling cookies (though this may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via a large number of services. Especially in the case of tracking, the following websites offer such a service: https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can obtain further instructions on how to object in the information regarding the service providers and cookies used.

Processing of cookie data on the basis of consent: Before we process or have data processed within the scope of the use of cookies, we ask users for consent that can be revoked at any time. Until consent is expressed, only those cookies are used that are absolutely necessary to run our online services.

Cookie settings / Option to object:

Cookie-preference
  • Types of data 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).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Provision of the online services and web hosting

In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, security services, and technical maintenance services.

The data processed in the scope of provision of hosting services may include any information relating to the users of our online services generated in the scope of usage and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online services to browsers, and all entries made within our online services or from websites.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (“server log files”). The server log files may include the address and name of the websites and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files may be used on the one hand for security purposes, e.g. to prevent server overload (especially in the event of abusive attacks, referred to as “DDoS attacks”) and, on the other hand, to ensure the utilization of the servers and their stability.

  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal bases: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Contact

When contacting us (e.g. by contact form, email, telephone or via social media), the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

Responses to contact requests in the scope of contractual or pre-contractual relationships are made to fulfill our contractual obligations or to respond to (pre-)contractual requests and otherwise on the basis of legitimate interests in responding to the requests.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication.
  • Legal bases: Performance of a contract and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Chatbots and chat functions

We offer online chats and chatbot functions (collectively referred to as “chat services”) as a communication option. A chat is an online conversation conducted with a certain amount of timeliness. A chatbot is software that answers users’ questions or notifies them of messages. When you use our chat features, we may process your personal data.

If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove them in accordance with legal requirements.

We point out to users that the respective platform provider may learn that and when users communicate with our chat services as well as collect technical information about the device used by users and, depending on the settings of their device, also location information (“metadata”) for purposes of optimizing the respective services and for security purposes. Likewise, the metadata of communication via chat services (i.e. information about who communicated with whom, for example) may be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their terms and conditions, to which we refer for further information.

If users agree to a chatbot to activate information with regular messages, they have the option to unsubscribe from the information for the future at any time. The chatbot instructs users how and with which terms they can unsubscribe from the messages. Unsubscribing from chatbot messages deletes the users’ data from the list of message recipients.

We use the aforementioned information to operate our chat services, e.g. to personally address users, to respond to their inquiries, to deliver any requested content, and also to improve our chat services (e.g. to “teach” chatbots answers to frequently asked questions or to identify unanswered inquiries).

Information on legal bases: We use chat services on the basis of consent obtained in advance from users to process their data as part of our chat services (this applies to cases where users are asked for consent, e.g. for a chatbot to send them messages on a regular basis). If we use chat services to answer users’ inquiries about our services or our company, this is done for contractual and pre-contractual communication. Otherwise, we use chat services based on our legitimate interests in optimizing the chat services, their operational efficiency, and increasing the positive user experience.

Revocation, objection, and deletion: You may at any time revoke any consent given or object to the processing of your data within the scope of our chat services.

  • Types of data 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, users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, direct marketing (e.g. by email or postal mail), audience measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest-based/behavioral profiling, use of cookies), remarketing, conversion tracking (measurement of the effectiveness of marketing measures), profiling (creation of user profiles).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Application procedure

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

The basic information required includes personal information such as the name, address, a contact option, and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information as to 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 via email. However, please note that emails are generally not sent encrypted on the Internet. 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 reception on our server.

For purposes of applicant search, submission of applications, and selection of applicants, we may use third-party applicant management, or recruitment software and platforms and services, subject to legal requirements.

Applicants are welcome to contact us regarding the method of submission of the application or to send us the application by mail.

Processing of special categories of data: If special categories of personal data within the meaning of Art. 9 para. 1 of the GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application process in order for the controller or the data subject to exercise the rights accruing to him or her under labor law and social security and social protection law and to comply with his or her obligations in this regard, they are processed in accordance with Art. 9 para. 2 lit. b. GDPR, in case of protection of vital interests of the applicants or other persons according to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, for health or social care or treatment, or for the management of health or social care systems and services pursuant to Art. 9 para. 2 lit. h. GDPR. In case of notification of the special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. GDPR.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job vacancy is not successful, the applicants’ data will be deleted. The applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified withdrawal by the applicants, the data will be deleted at the latest after a period of six months so that we can answer any follow-up questions about the application and meet our obligations to present evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process, and that they can revoke their consent at any time for the future.

  • Types of data processed: Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application, and the information contained therein, such as cover letter, curriculum vitae, certificates, and other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
  • Data subjects: Applicants.
  • Purposes of processing: Application procedure (establishment and possible subsequent implementation of an employment relationship, as well as its possible later termination).
  • Legal bases: Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR).

Newsletters and electronic notifications

We send newsletters, emails, and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipients or legal permission. If, in the scope of a subscribing to the newsletter, its contents are outlined in concrete terms, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and about us.

In order to subscribe to our newsletters, it is generally sufficient for you to provide your email address. However, we may request that you provide a name for the purpose of addressing you personally in the newsletter, or provide further information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Subscriptions to our newsletter is always carried out in a “double opt-in procedure”. This means that, after completing your subscription, you will receive an email asking you to confirm your subscription. This confirmation is necessary to ensure that no one can subscribe using another person’s email addresses. The subscriptions to the newsletter are logged in order to be able to furnish evidence of the subscription process according to the legal requirements. This includes the storage of the subscription time, the confirmation time, and the IP address. Changes to your data stored with the shipping service provider are also logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defense against claims. An individual request for deletion 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 in a “block list” for this sole purpose.

The logging of the subscription process takes place on the basis of our legitimate interests for the purposes of proving it proceeded 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.

Information on legal bases: Newsletters are sent on the basis of the recipients’ consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and insofar as this is permitted by law, e.g. in the case of existing customer advertising. If as we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law.

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

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, phone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Special categories of personal data: Health data (Art. 9 para. 1 GDPR).
  • Data subjects: Communication partners.
  • Purposes of processing: Direct marketing (e.g. by email or postal mail).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. 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 will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the above contact options, preferably email, for this purpose.


Services and service providers used:

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

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

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

  • Types of data 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 postal mail).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Sweepstakes and contests

We process the personal data of participants of sweepstakes and contests only in compliance with the relevant data protection provisions, insofar as the processing is contractually necessary for the provision, implementation and, execution of the sweepstakes, the participants have consented to the processing, or the processing serves our legitimate interests (e.g. in the security of the sweepstakes or the protection of our interests against misuse through possible collection of IP addresses when submitting sweepstakes entries).

If contributions from participants are published in the scope of the sweepstakes (e.g. in the scope of a vote or presentation of the sweepstakes entries or the winners or reporting on the sweepstakes), we would like to point out that the names of the participants may also be published in this context. Participants may object to this at any time.

If the sweepstakes takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the usage and data protection provisions of the respective platforms shall also apply. In these cases, we would like to point out that we are responsible for the information provided by the participants within the scope of the sweepstakes and that inquiries with regard to the sweepstakes should be directed to us.

The participants’ data will be deleted as soon as the sweepstakes or contest has ended and the data is no longer required to inform the winners or because queries regarding the sweepstakes are to be expected. In principle, the data of the participants will be deleted no later than 6 months after the end of the sweepstakes. Winners’ data may be retained for longer in order, for example, to answer queries about the prizes or to be able to fulfill the prize services; in this case, the retention period depends on the type of prize and is up to three years for items or services, for example, in order to be able to process warranty claims. Furthermore, the participants’ data may be stored for longer, e.g. in the form of reporting on the sweepstakes in online and offline media.

If data was also collected for other purposes as part of the sweepstakes, its processing and the retention period will be governed by the data protection information on this use (e.g. in the case of registration for the newsletter as part of a sweepstakes).

  • Types of data processed: Inventory data (e.g. names, addresses), content data (e.g. entries in online forms).
  • Data subjects: Sweepstakes and contest participants.
  • Purposes of processing: Organization of sweepstakes and contests.
  • Legal bases: Performance of a contract and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR).

Surveys and polls

The surveys and polls we conduct (hereinafter referred to as “surveys”) are evaluated anonymously. Personal data is only processed insofar as necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address in order to display the survey in the user’s browser or to enable a resumption of the survey with the aid of a temporary cookie (session cookie)) or users have consented to this.

Information on legal bases: If we request that participants consent to the processing of their data, this forms the legal basis for the processing; otherwise, the processing of participants’ data is based on our legitimate interests in conducting an objective survey.

  • Types of data 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, users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, direct marketing (e.g. via email or postal mail), tracking (e.g. interest-based/behavioral profiling, use of cookies), feedback (e.g. collecting feedback via online form).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Web analytics, monitoring, and optimization

Web analytics (also referred to as “audience measurement”) is used to evaluate the flow of visitors to our online services and may include behavior, interests, or demographic information about visitors, such as age or gender, in the form of pseudonymous data. With the help of audience measurement, we can recognize, for example, at what time our online services or their functions or content are most frequently used or elicit reuse. Moreover, it can help us understand which areas require optimization.

In addition to web analytics, we may also use test procedures, for example, to test and optimize different versions of our online services or their components.

For these purposes, “user profiles” may be created and stored in a file (a “cookie”) or similar procedures may be used with the same purpose. This information may include, for example, content viewed, websites visited and elements used there, and technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect users. In general, we do not store any real user identification (such as email addresses or names) in the scope of web analytics, A/B testing, and optimization, only pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Information on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for the processing of this data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical, and user-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this Data Privacy Statement.

  • Types of data 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: Audience measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest-based/behavioral profiling, use of cookies), conversion tracking (measurement of the effectiveness of marketing measures), profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymization of IP addresses).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).


Services and service providers used:

Online marketing

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

For these purposes, “user profiles” are created and stored in a file (a “cookie”) or similar procedures are used, by means of which the information about the user relevant to the presentation of the aforementioned content is stored. 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, and information on usage times. If users have consented to the collection of their location data, this may also be processed.

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, we do not store any real user identification (such as email addresses or names) in the scope of online marketing procedures, only pseudonyms. This means that we and the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

In exceptional cases, real user identification may be assigned to the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedure we use and the network links the profiles of the users with the aforementioned data. For this reason, please note that users may make additional arrangements with the providers, e.g. by giving consent in the scope of registration.

In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of “conversion tracking”, we can check which of our online marketing processes have led to a “conversion”, i.e. to the conclusion of a contract with us, for example. Conversion tracking is used solely to analyze the success of our marketing measures.

Unless otherwise stated, please assume that cookies used will be stored for a period of two years.

Information on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for the processing of this data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical, and user-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this Data Privacy Statement.

  • Types of data 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), interested parties.
  • Purposes of processing: Tracking (e.g. interest-based/behavioral profiling, use of cookies), remarketing, conversion tracking (measurement of the effectiveness of marketing measures), interest-based and behavioral marketing, profiling (creation of user profiles), audience measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures: IP masking (pseudonymization of IP addresses).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).
  • Option to object (opt-out): We refer to the data protection information of the respective providers and the options to object (“opt-out”) specified for the providers. If no explicit opt-out option has been specified, it is possible to disable cookies in the settings of your browser. However, this may restrict functions of our online services. We therefore recommend the following additional opt-out options, which are offered collectively for different target regions:
    a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-regional: https://optout.aboutads.info.


Services and service providers used:

Rating platforms

We participate in rating procedures in order to evaluate, optimize, and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the general terms and conditions of business or use and the data protection information of the providers also apply. As a rule, the rating also requires registration with the respective providers.

In order to ensure that the persons rating have actually used our services, we send, with the consent of the customers, the data required for this purpose with regard to the customer and the service used to the respective rating platform (including name, email address, and order or item number). This data is used solely to verify the authenticity of the user.

  • Types of data processed: Contractual data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers, users (e.g. website visitors, users of online services).
  • Purposes of processing: Feedback (e.g. collecting feedback via online form).
  • Legal bases: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).


Services and service providers used:

Presence in social networks (social media)

We maintain an online presence within social networks and process user data in this scope 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 the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce the rights of users.

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

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

In the case of requests for information and the assertion of the rights of data subjects, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, feel free to contact us.

  • Types of data processed: Inventory data (e.g. names, addresses), 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, tracking (e.g. interest-based/behavioral profiling, use of cookies), remarketing.
  • Legal bases: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).


Services and service providers used:

Plugins and embedded functions and content

We integrate functional and content elements into our online services that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, social media buttons, or posts (hereinafter uniformly referred to as “content”).

Integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. Therefore an IP address is required to display this content or these functions. We strive to use only such content whose respective providers use the IP address only for the delivery of 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 analyze 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, time of visit, and other information about the use of our website, as well as be linked to such information from other sources.

Information on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for the processing of this data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical, and user-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this Data Privacy Statement.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or person), 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 services and usability, provision of contractual services and customer service, security measures, administration of and response to inquiries.
  • Legal bases: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR), consent (Art. 6 para. 1 p. 1 lit. a. GDPR), performance of a contract and pre-contractual request (Art. 6 para. 1 p. 1 lit. b. GDPR).


Services and service providers used:

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consents granted for its processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

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

Further information on the deletion of personal data can also be found in the individual data protection information of this Data Privacy Statement.

Amendment and updating of the Data Privacy Statement

We request that you inform yourself regularly about the content of our Data Privacy Statement. We adapt the Data Privacy Statement as soon as changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Insofar as we provide addresses and contact information of companies and organizations in this Data Privacy Statement, we ask you to note that the addresses may change over time and to check the information before contacting us.

Rights of data subjects

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

  • Right to object: You have the right to object at any time to the processing of your personal data on the basis of Art. 6 para. 1 lit. e or f GDPR for reasons that arise from your special situation; this also applies with regard to profiling based on these provisions. Where your personal data is processed for direct advertising purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling, insofar as it is associated with such direct advertising.
  • Right of revocation of consent: You have the right to revoke any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with legal requirements.
  • Right to correction: In accordance with legal requirements, you have the right to demand that the data relating to you be supplemented or that any inaccurate data relating to you be corrected.
  • Right to deletion and restriction of processing: In accordance with legal requirements, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with legal requirements, to demand that the processing of the data be restricted.
  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request that it be transferred to another controller.
  • Right to complain to a supervisory authority: You also have the right, as provided by law, to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Definition of terms

This section provides you with an overview of the terms used in this Data Privacy Statement. Many of the terms are taken from the law and defined especially in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • IP masking: “IP masking” refers to a method in which the last octet, i.e. the last two numbers of an IP address, is deleted so that the IP address can no longer be used for the unique identification of a person. IP masking is therefore a means of pseudonymizing processing methods, especially in online marketing.
  • Interest-based and behavioral marketing: Interest-based and/or behavioral marketing refers to the practice of predetermining the potential interests of users in ads and other content as exactly as possible. This is done with the aid of information about their previous behavior (e.g. visiting and staying on certain websites, purchasing behavior, or interaction with other users), which is stored in a “profile”. Cookies are generally used for these purposes.
  • Conversion tracking: Conversion tracking is a method used to determine 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 take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
  • Personal data: “Personal data” refers to any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Profiling: “Profiling” refers to any type of automated processing of personal data that consists of using that personal data to analyze and evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this may include information concerning age, gender, location and movement data, interaction with websites and their content, shopping behavior, or social interactions with other people) for the purpose of predicting the future behavior of that person (e.g. interests in certain content or products, clicking behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
  • Audience measurement: Audience measurement (also referred to as “web analytics”) is employed to evaluate the flow of visitors to an online service and can include visitors’ behavior or interest in certain information, such as website content. With the help of audience measurement, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of audience measurement, pseudonymous cookies and web beacons are often used to recognize returning visitors, thereby obtaining more precise analyses of the use of an online service.
  • Remarketing: “Remarketing” or “retargeting” refers, for example, to the practice carried out for advertising purposes of noting which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. using advertisements.
  • Location data: Location data is created when a mobile device (or another device with the technical requirements of location determination) connects to a radio cell, a WLAN, or similar technical intermediaries and location determination functions. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other information that is dependent on a specific location.
  • Tracking: “Tracking” refers to the tracking the behavior of users across several online services. As a rule, behavioral and interest-related information regarding the online services used is stored in cookies or on servers of the providers of the tracking technologies (referred to as “profiling”). This information can subsequently be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: “Controller” refers to the natural or legal person, public authority, agency, or other body that alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: “Processing” refers to any operation or set of operations performed with personal data, with or without the aid of automated procedures. The term is broadly defined and includes virtually any kind of data handling, be it collection, evaluation, storage, transmission, or deletion.