Data Policy
Privacy policy
Last updated: April 5, 2024
Outline
• Person in charge
• Overview of processing operations
• Relevant legal bases
• Security Measures
• Rights of data subjects
• Business Services
• Provision of the online offer and web hosting
• Use of cookies
• Blogs and Publication Media
• Contact & Enquiry Management
• Web Analysis, Monitoring and Optimization
• Online Marketing
• Presence in social networks (social media)
• Definitions of termsw
Person in charge
David Avtandil Kharshiladze
ProcessWise
Simbacher Straße 7
80335 Munich
E-mail address: David.kharshiladze@processwise.ai Imprint: https://processwise.ai/impressum
Overview of processing operations
The following table summarises the types of data processed and the purposes for which they are processed, and refers to the data subjects.
Types of data processed
• Inventory data.
• Payment.
• Contact details.
• Content Data.
• Contract.
• Usage.
• Meta, communication and procedural data.
Categories of data subjects
• Interested parties.
• Communication.
• User.
• Business and contractual partners.
Purposes of processing
• Provision of contractual services and fulfilment of contractual obligations.
• Contact requests and communication.
• Security Measures.
• Range measurement.
• Tracking.
• Office and organizational procedures.
• Conversion measurement.
• Manage and respond to requests.
• Feedback.
• Marketing.
• Profiles with user-related information.
• Provision of our online offer and user-friendliness.
• Information technology infrastructure.
Relevant legal bases
Relevant legal bases under the GDPR: 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. Furthermore, if more specific legal bases are relevant in individual cases, we will inform you of these in the privacy policy.
• Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) - The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or for several specific purposes.
• Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 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 request of the data subject.
• Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) - Processing is necessary for compliance with a legal obligation to which the Controller is subject.
• Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) - the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, provided that such interests are not overridden by the interests, fundamental rights and freedoms of the data subject requiring the protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes, in particular, the Act on the Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions 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 the transmission and automated decision-making in individual cases, including profiling. In addition, the data protection laws of the individual federal states may apply.
Security Measures
In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.
The measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, disclosure, availability and segregation of data. Furthermore, we have put in place procedures to ensure the exercise of data subject rights, the deletion of data and reactions to the risk of data being compromised. 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 technical design and through privacy-friendly default settings.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
• Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data based on Art. 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
• Right to withdraw consent: You have the right to withdraw your consent at any time.
• Right of access: You have the right to request confirmation as to whether the data in question is being processed and to request access to this data, as well as further information and a copy of the data in accordance with the legal requirements.
• Right to rectification: In accordance with the law, you have the right to request the completion of the data concerning you or the correction of the inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be erased without undue delay or, alternatively, to demand that the processing of the data be restricted in accordance with the legal requirements.
• Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request that it be transmitted to another controller.
• Complaint to a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you believe that the processing of your personal data infringes the requirements of the GDPR.
Business Services
We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as "contractual partners"), in the context of contractual and comparable legal relationships as well as related measures and with regard to communication with the contractual partners (or pre-contractual), for example to answer enquiries.
We use this data to fulfil our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service failures. In addition, we use the data to safeguard our rights and for the purposes of the administrative tasks associated with these obligations, as well as for the organization of the company. In addition, we process the data on the basis of our legitimate interests in proper and business management as well as in security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the scope of applicable law, we only pass on the data of contractual partners to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of legal obligations. The contractual partners are informed about other forms of processing, such as for marketing purposes, within the framework of this data protection declaration.
We inform the contractual partners which data is required for the aforementioned purposes before or as part of the data collection, e.g. in online forms, by means of special markings (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal reasons of archiving (e.g. for tax purposes, usually ten years). Data that has been disclosed to us by the contractual partner in the context of an order will be deleted in accordance with the specifications and generally after the end of the order.
• Types of data processed: inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); Contact details (e.g. email, phone numbers). Contract data (e.g. subject matter of the contract, duration, customer category).
• Data subjects: interested parties. Business and contractual partners.
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; contact requests and communication; Office and organizational procedures. Manage and respond to requests.
• Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
• Offering software and platform services: We process the data of our users, registered users and any test users (hereinafter referred to collectively as "users") in order to be able to provide them with our contractual services and on the basis of legitimate interests in order to be able to guarantee the security of our offer and to be able to develop it further. The required information is marked as such in the context of the conclusion of the order, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Provision of the online offer and web hosting
We process users' data in order to be able to 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 device.
• Types of data processed: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of our online offer and user-friendliness. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
• Provision of our online offer on our own/dedicated server hardware: For the provision of our online offer, we use server hardware operated by us as well as the associated storage space, computing capacity and software; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Use of cookies
Cookies are small text files or other storage notes that store and read information on end devices. For example, to store the log-in status in a user account, the contents of a shopping cart in an e-shop, the content accessed or functions used in an online offer. Cookies can also be used for a variety of purposes, such as the functionality, security and convenience of online services, as well as the creation of analyses of visitor flows.
Notes on consent: We use cookies in accordance with the legal regulations. Therefore, we obtain prior consent from users, unless it is not required by law. In particular, permission is not necessary if the storage and reading of the information, including cookies, is absolutely necessary in order to provide users with a telemedia service (i.e. our online offering) that they have expressly requested. The revocable consent will be clearly communicated to them and will contain the information on the respective cookie usage.
Notes on legal bases under data protection law: The legal basis on which we process users' personal data with the help of cookies depends on whether we ask them for consent. If users accept, the legal basis for the use of their data is the declared consent. Otherwise, the data used by cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and the improvement of its usability) or, if this is done in the context of the fulfilment of our contractual obligations, if the use of cookies is necessary to meet our contractual obligations. We explain the purposes for which the cookies are used by us in the course of this privacy policy or as part of our consent and processing processes.
Storage period: With regard to the storage period, a distinction is made between the following types of cookies:
• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their device (e.g. browser or mobile application).
• Persistent cookies: Persistent cookies remain stored even after the device is closed. For example, the log-in status can be saved and preferred content can be displayed directly when the user visits a website again. User 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 period of cookies (e.g. as part of obtaining consent), they should assume that they are permanent and that the storage period can be up to two years.
General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also declare an objection to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing processes, procedures and services:
• Processing of cookie data on the basis of consent: We use a consent management solution that obtains user consent to the use of cookies or to the procedures and providers mentioned as part of the consent management solution. This procedure is used to obtain, record, manage and revoke consents, in particular with regard to the use of cookies and similar technologies used to store, read and process information on users' end devices. As part of this procedure, the consent of users is obtained for the use of cookies and the related processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and withdrawing their consents. The declarations of consent are stored in order to avoid a new query and to be able to provide proof of consent in accordance with the legal requirements. The data is stored on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. Unless specific information is available about the providers of consent management services, the following general information applies: The duration of the storage of consent is up to two years. In doing so, a pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) as well as information about the browser, the system and the device used; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
• Compliance: Consent management: procedures for obtaining, logging, managing and withdrawing consents, in particular for the use of cookies and similar technologies to store, read, process and process information on users' terminal equipment and its processing; Service Providers: execution on servers and/or computers under their own responsibility under data protection law; Website: https://complianz.io/; Privacy Policy: https://complianz.io/legal/. Further information: An individual user ID, language, types of consents and the time of their submission are stored on the server side and in the cookie on the user's device.
Blogs and Publication Media
We use blogs or comparable means of online communication and publication (hereinafter referred to as "publication medium"). Readers' data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium within the framework of this data protection notice.
• Types of data processed: inventory data (e.g. names, addresses); contact details (e.g. email, phone numbers); Content data (e.g. submissions in online forms); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; feedback (e.g. collecting feedback via an online form); Provision of our online offer and user-friendliness; Security Measures. Manage and respond to requests.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
• Comments and posts: When users leave comments or other posts, their IP addresses may be stored based on our legitimate interests. This is done for our safety in case someone leaves illegal content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be prosecuted for the comment or contribution and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process the information provided by users for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, in the case of surveys, we reserve the right to store users' IP addresses for the duration of surveys and to use cookies to avoid multiple voting.
The personal information provided in the context of the comments and contributions, any contact and website information as well as the content information will be permanently stored by us until the user objects; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Contact & Enquiry Management
When contacting us (e.g. by post, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information provided by the enquiring persons will be processed insofar as this is necessary to answer the contact requests and any measures requested.
• Types of data processed: contact details (e.g. e-mail, telephone numbers); Content data (e.g. submissions in online forms); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
• Data subjects: Communication partners.
• Purposes of processing: contact requests and communication; managing and responding to requests; Feedback (e.g. collecting feedback via online form). Provision of our online offer and user-friendliness.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Further information on processing processes, procedures and services:
• Contact form: If users contact us via our contact form, e-mail or other means of communication, we process the data provided to us in this context in order to process the requested request; Legal basis: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Web Analysis, Monitoring and Optimization
Web analysis (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, identify at what time our online offer or its functions or content are used most often, or invite them to reuse them. It is also possible for us to understand which areas need optimization.
In addition to web analysis, we may also use test procedures to test and optimize different versions of our online offering or its components, for example.
Unless otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created for these purposes and information can be stored in a browser or in a terminal device and then read out. The information collected includes, in particular, websites visited and elements used there, as well as 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 from us or from the providers of the services we use, the processing of location data is also possible.
In addition, the IP addresses of the users are stored. However, we use IP masking (i.e. pseudonymization by shortening the IP address) to protect users. In general, in the context of web analysis, A/B testing and optimization, no clear user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as 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 purpose of the respective procedures.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data will be 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 draw your attention to the information on the use of cookies in this privacy policy.
• Types of data processed: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles). Provision of our online offer and user-friendliness.
• Security measures: IP masking (pseudonymization of the IP address).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further information on processing processes, procedures and services:
• Google Analytics: We use Google Analytics to measure and analyze the use of our online services on the basis of a pseudonymous user identification number. This identification number does not contain any unique information, such as names or email addresses. It is used to assign analysis information to a device in order to identify which content users have accessed within one or different usage processes, which search terms they have used, which they have called up again or have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offer and technical aspects of their devices and browsers.
Pseudonymous profiles of users are created with information from the use of different devices, whereby cookies can be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides coarse geographic location data by deriving the following metadata from IP addresses: city (and the city's derived latitude and longitude), continent, country, region, subcontinent (and ID-based counterparts). In the case of EU traffic, the IP address data is used exclusively for this derivation of geolocation data before it is immediately deleted. They are not logged, are not accessible and are not used for other purposes. When Google Analytics collects metrics, all IP queries are performed on EU-based servers before traffic is routed to Analytics servers for processing; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymization of the IP address); Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third-country transfers: Data Privacy Framework (DPF); Possibility of objection (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and data processed).
Online Marketing
We process personal data for the purpose 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 (the so-called "cookie") or similar processes are used, by means of which the information about the user relevant for the presentation of the aforementioned content is stored. This 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 on usage times and functions used. If users have consented to the collection of their location data, this data can also be processed.
In addition, the IP addresses of the users are stored. However, we use available IP masking methods (i.e. pseudonymization by shortening the IP address) for user protection. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing procedures, do not know the actual user identity, but only the information stored in their profiles.
The statements in the profiles are usually stored in cookies or by means of similar processes. These cookies can generally also be read on other websites that use the same online marketing method and analysed for the purpose of displaying content, supplemented with further data and stored on the server of the online marketing process provider.
Exceptionally, it is possible to assign clear data to the profiles, especially if the users are, for example, members of a social network whose online marketing procedures we use and the network connects the user profiles with the aforementioned information. Please note that users can make additional arrangements with the providers, for example by giving their consent as part of the registration process.
As a matter of principle, we only have access to aggregated information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us, for example. Conversion measurement is used solely to analyze the success of our marketing efforts.
Unless otherwise specified, we ask you to assume that cookies used will be stored for a period of two years.
Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is permission. Otherwise, users' data will be 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 draw your attention to the information on the use of cookies in this privacy policy.
• Types of data processed: Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
• 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/behavioural profiling, use of cookies); Marketing; Profiles with user-related information (creating user profiles). Conversion measurement (measuring the effectiveness of marketing efforts).
• Security measures: IP masking (pseudonymization of the IP address).
• Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
• Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options specified for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of disabling cookies in your browser settings. However, this may limit the functions of our online offering. We therefore also recommend the following opt-out options, which are offered in summary for the respective territories:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
(d) Cross-territorial: https://optout.aboutads.info.
Further information on processing processes, procedures and services:
• Google Ads and conversion measurement: online marketing for the purpose of placing content and advertisements within the service provider's advertising network (e.g. in search results, videos, websites, etc.) so that they are displayed to users who have a presumed interest in the ads. In addition, we measure the conversion of the ads, i.e. whether the users took them as an opportunity to interact with the ads and use the advertised offers (so-called conversion). However, we only receive anonymous information and not personal information about individual users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Types of processing and data processed: https://business.safety.google/adsservices/. Data processing conditions between controllers and standard contractual clauses for third-country transfers of data: https://business.safety.google/adscontrollerterms.
Presence in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the area of the European Union. This can result in risks for users, for example because it could make it more difficult to enforce user rights.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behavior and the resulting interests. The latter, in turn, may be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. Therefore, cookies are usually stored on users' computers, in which the user's usage behavior and interests are stored. In addition, data may also be stored in the usage profiles, regardless of the devices used by the users (especially if they are members of the respective platforms and logged in there).
For a detailed description of the respective forms of processing and the options for objection (opt-out), we 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 subject rights, we would also like to point out that these can be most effectively asserted with the providers. Only the latter have access to the user data and can directly take appropriate measures and provide information. If you still need help, you can contact us.
• Types of data processed: contact details (e.g. e-mail, telephone numbers); Content data (e.g. submissions in online forms); Usage data (e.g. websites visited, interest in content, access times). Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
• 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 basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further information on processing processes, procedures and services:
• Facebook pages: profiles within the social network Facebook; Service Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: Together with Meta Platforms Ireland Limited, we are responsible for the collection (but not the further processing) of data of visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content that users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in Facebook's Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, known as "Page Insights", for Page operators to gain insights into how people interact with their Pages and with the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. Users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. For more information, see "About Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data). Joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular with regard to the transfer of the data to the parent company Meta Platforms, Inc. in the USA.
• LinkedIn: Social network; Service Providers: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF); Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. Further information: We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not further processing) of visitor data for the purposes of compiling the "page insights" (statistics) of our LinkedIn profiles.
This data includes information about the types of content that users view or interact with, or the actions they take, as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data) and details from users' profiles, such as job function, country, industry, hierarchy level, company size, and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy
We have entered into a special agreement with LinkedIn Ireland ("Page Insights Joint Controller Addendum (the 'Addendum')", https://legal.linkedin.com/pages-joint-controller-addendum) which regulates, in particular, which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to LinkedIn). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection of the data by and the transfer to Ireland Unlimited Company, a company based in the EU. Further processing of the data is the sole responsibility of Ireland Unlimited Company, in particular with regard to the transmission of the data to the parent company LinkedIn Corporation in the USA.
• YouTube: social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF). Possibility of objection (opt-out): https://myadcenter.google.com/personalizationoff.
Definitions
This section provides an overview of the terminology used in this Privacy Policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to serve the purpose of understanding.
• Conversion measurement: Conversion measurement (also known as "visit action evaluation") is a method used to determine the effectiveness of marketing efforts. For this purpose, a cookie is usually stored on the user's devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, it allows us to understand whether the ads we serve on other websites have been successful.
• Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable natural person is defined as one who identifies directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific which are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data consisting in the use of such personal data to identify certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behaviour and interests, such as interacting with websites and their content, etc.) analyze, evaluate, or predict (e.g., interest in certain content or products, click behavior on a web page, or location). Cookies and web beacons are often used for profiling purposes.
• Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offer and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of the reach analysis, operators of online services can recognize, for example, at what time users visit their websites and what content they are interested in. This allows them to better adapt the content of the websites to the needs of their visitors, for example. For the purpose of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
• Tracking: "Tracking" is when the behavior of users can be tracked across several online offers. As a rule, behavioural and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to show users advertisements that are likely to match 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 which is performed on personal data, whether or not by automated means. The term is broad and encompasses practically any handling of data, be it collection, evaluation, storage, transmission or deletion.