Privacy policy

 

Introduction

With the following data protection declaration, 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 to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as „online offer“).

The terms used are not gender-specific.

Stand: 13. Januar 2021

Table of contents

 

• Introduction
• Person responsible
• Overview of processing operations
• Relevant legal basis
• Security Measures
• Transfer and disclosure of personal data
• Data processing in third countries
• Use of cookies
• Commercial and business services
• Provision of the online offer and web hosting
• Special information on applications (apps)
• Blogs and publication media
• Contact
• Communication via messenger
• Video conferences, online meetings, webinars and screen sharing
• Application process
• Cloud services
• Newsletters and electronic notifications
• Promotional communication via email, post, fax or telephone
• Web analytics, monitoring and optimisation
• Evaluation platforms
• Presence in social networks (social media)
• Plug-ins and embedded functions as well as content
• Planning, organisation and support tools
• Deletion of data
• Amendment and updating of the privacy policy
• Rights of data subjects
• Definitions

Responsible

Martin Gapp, Gapp Recruiting & Research
Von-der-Tann-Str. 25
82319 Starnberg

E-Mail-Adress: datenschutz@gapp-recruiting.de

Telephone: 01 777 200 700

Imprint: gapp-recruiting.de/impressum

Overview of processing

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

Types of data processed

• Event Data (Facebook) („Event Data“ is data that may be transmitted by us to Facebook, e.g. via Facebook Pixel (via apps or other means), and relates to individuals or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc. ; the Event Data is processed for the purpose of forming an overview of the data processed. Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data are deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
• 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 as well as 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. e-mail, 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 on the geographical position of a device or person).
• Contract data (e.g. subject matter of the contract, term, customer category).
• Payment data (e.g. bank details, invoices, payment history).

Special categories of data

• Data revealing racial and ethnic origin.

Categories of data subjects

• Employees (e.g. employees, applicants, former employees).
• Job applicants.
• Business and contractual partners.
• Interested parties.
• Communication partners.
• Customers.
• Users (e.g. website visitors, users of online services). (z.B. Webseitenbesucher, Nutzer von Onlinediensten).

Purposes of the processing

• Provision of our online offer and user-friendliness.
• Conversion measurement (measuring the effectiveness of marketing measures).
• Application procedures (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
• Office and organisational procedures.
• Direct marketing (e.g. by email or post).
• Feedback (e.g. collecting feedback via online form).
• Interest-based and behavioural marketing.
• Contact requests and communication.
• Profiling (creating user profiles).
• Remarketing.
• Reach measurement (e.g. access statistics, recognition of returning visitors).
• Security measures.
• Tracking (e.g. interest/behavioural profiling, use of cookies).
• Provision of contractual services and customer service.
• Administration and response to enquiries.

Relevant legal basis

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 DSGVO, the national data protection regulations in your or our country of residence and domicile may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

 

• Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) – The data subject has given 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 enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject’s request.
• Legal obligation (Art. 6 (1) p. 1 lit. c. DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
• Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) – Processing is necessary to protect 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 (2) lit. b DSGVO) – Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise the rights accruing to him or her under labour law and social security and social protection law and fulfil his or her obligations in this respect, their processing is carried out in accordance with Art. 9 (2) lit. b. DSGVO. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for 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. DSGVO. 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. DSGVO.

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, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.

 

Security measures

We take appropriate technical and organisational measures in accordance with the law, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the level of 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, ensuring 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 availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects‘ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as „IP masking“). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it considerably more difficult to identify a person by their IP address.

SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognise 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 transmitted to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data processing in third countries

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

Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, 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 offer. Stored information may include, for example, language settings on a website, login status, a shopping cart or where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g. when user details are stored using pseudonymous online identifiers, also known as „user IDs“).

The following cookie types and functions are distinguished:

• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his 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, the interests of users used for range measurement or marketing purposes can be stored in such a cookie.
• First-Party-Cookies: First-party cookies are set by ourselves.
• Third-party cookies (also: third-party cookies): Cookies may, on the one hand, 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 personalisation cookies: Statistical, marketing and personalisation cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This procedure is also referred to as „tracking“, i.e. tracking the potential interests of users. Insofar as we use cookies or „tracking“ technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data using 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 help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.

 

Storage period: If we do not provide you with explicit information on the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.

 

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

Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.

 

• 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 basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

 

BorlabsCookie: Cookie consent management; Service provider: Borlabs; Website: https://de.borlabs.io/borlabs-cookie/; An individual user ID, language as well as types of consent and the time of their submission are stored on the server side and in the cookie on the user’s device.

Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as „contractual partners“) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer enquiries.

 

We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the persons concerned (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Contractual partners will be informed about further forms of processing, e.g. 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 in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

 

We delete the data after the expiry of legal warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for legal archiving reasons (e.g. for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.

 

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

 

Coaching: We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as „clients“) in order to be able to provide our services to them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.

 

Within the scope of our activities, we may also process special categories of data, in particular information on the health of clients, possibly with reference to their sex life or sexual orientation, as well as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership. To this end, we obtain explicit consent from clients where necessary and otherwise process the special categories of data where this serves the health of the clients, the data is public or other legal permissions exist.

 

If it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if the client has given his or her consent, we disclose or transfer the client’s data to third parties or agents, such as authorities, accounting offices and in the area of IT, office or comparable services, in compliance with the requirements of professional law.

Consulting: We process the data of our clients, customers as well as interested parties and other clients or contractual partners (uniformly referred to as „clients“) in order to be able to provide them with our consulting services. The data processed, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship.

 

Insofar as it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if we have the consent of the client, we disclose or transfer the client’s data to third parties or agents, such as public authorities, subcontractors or in the area of IT, office or comparable services, in compliance with the requirements of professional law.

 

Recruiting services: We process the data of job candidates and the personal data of potential employers or their employees as part of our services, which include in particular the search for potential job candidates, contacting them and placing them.

 

We process the information and contact data provided by job candidates for the purposes of establishing, implementing and, if applicable, terminating a contract for job placement. In addition, we may ask interested parties queries about the success of our placement service at a later date, in accordance with legal requirements.

 

We process the data of job candidates as well as employers to fulfil our contractual obligations in order to be able to process the job placement requests submitted to us to the satisfaction of the parties involved.

 

We may log the placement processes in order to be able to prove the existence of the contractual relationship and agreements of the interested parties in accordance with the legal accountability obligations (Art. 5 para. 2 DSGVO). This information is stored for a period of three to four years in case we need to prove the original enquiry (e.g. to be able to prove authorisation to contact job candidates).

 

Management consultancy: We process the data of our customers, clients as well as interested parties and other clients or contractual partners (uniformly referred to as „clients“) in order to be able to provide them with our contractual or pre-contractual services, in particular consultancy services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and business relationship.

 

Insofar as it is necessary for our performance of the contract or required by law, or if we have the consent of the clients, we disclose or transfer the clients‘ data to third parties or agents, such as authorities, courts or in the field of IT, office or comparable services, in compliance with the requirements of professional law.

 

• Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category), 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 as well as other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
• Special categories of personal data: Health data (Art. 9(1) DGSVO), Data concerning sex life or sexual orientation (Art. 9(1) DGSVO), Religious or philosophical beliefs (Art. 9(1) DGSVO), Data revealing racial or ethnic origin.
• Data subjects: Interested parties, business and contractual partners, applicants, customers.
• Purposes of processing: provision of contractual services and customer service, contact requests and communication, office and organisational procedures, administration and response to requests.
• Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Provision of the online offer and web hosting

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

 

The data processed in the course of providing the hosting service may include all information relating to the users of our online service that is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

 

E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

 

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, 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 avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilisation 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 grounds: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Special notes on applications (apps)

We process the data of the users of our application insofar as this is necessary to provide the application and its functionalities to the users, to monitor its security and to further develop it. We may also contact users in compliance with legal requirements, provided that the communication is necessary for the purposes of administration or use of the application. In all other respects, we refer to the data protection information in this data protection declaration with regard to the processing of users‘ data.

 

Legal basis: The processing of data required for the provision of the functionalities of the application serves the fulfilment of contractual obligations. This also applies if the provision of the functions requires user authorisation (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for purposes of optimising the application or security purposes), it is carried out on the basis of our legitimate interests. If users are explicitly asked for their consent to the processing of their data, the processing of the data covered by the consent is based on the consent.

 

Commercial use: We process the data of the users of our application, registered users and any test users (hereinafter uniformly referred to as „users“) in order to be able to provide our contractual services to them and on the basis of legitimate interests in order to be able to guarantee the security of our application and to be able to develop it further. The required information is identified as such in the context of the conclusion of the use, order, purchase order or comparable contract and may include the information required for the provision of services and for any billing as well as contact information in order to be able to hold any consultations.

 

Storage of a universal unique identifier (UUID): The application stores a so-called universal unique identifier (UUID) for the purpose of analysing the use and functionality of the application as well as for storing the settings of the users. This identifier is generated when this application is installed (but is not linked to the device, so it is not a device identifier in this sense), remains stored between the start of the application and its updates, and is deleted when users remove the application from their device.

 

Device permissions to access functions and data: The use of our application or its functionalities may require users to have permissions to access certain functions of the devices used or the data stored on or accessible through the devices. By default, these permissions must be granted by the users and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the users‘ device and software. Users can contact us if they need clarification. Please note that denial or revocation of the respective permissions may affect the functionality of our app.

 

No location history and no movement profiles: The location data is only used selectively and is not processed to create a location history or a movement profile of the devices used or their users.

• Types of data processed: inventory data (e.g. names, addresses), meta/communication data (e.g. device information, IP addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, duration, customer category), location data (information on the geographical position of a device or a person).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: provision of contractual services and customer service.
• Legal grounds: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter „publication medium“). Readers‘ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers or for security reasons. For the rest, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

 

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, 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: provision of contractual services and customer service, feedback (e.g. collecting feedback via online form).
• Legal basis: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

 

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

Contacting

When contacting us (e.g. via contact form, email, telephone or via social media), the information provided by the person making the enquiry is processed to the extent necessary to respond to the contact enquiries and any measures requested.

 

The response to contact enquiries in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of the legitimate interests in responding to the enquiries.

 

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Data subjects: Communication partners.
• Purposes of processing: contact requests and communication.
• Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Communication via Messenger

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options.

 

You can also contact us in alternative ways, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer.

 

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure that the message content is encrypted.

 

However, we additionally point out to our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us, as well as technical information on the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.

Notes on legal basis: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us, for example, of their own accord, we use Messenger in relation to our contractual partners as well as in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.

 

Revocation, objection and deletion: You can revoke your consent at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any information provided by the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention obligations.

 

Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer enquiries via Messenger. This is the case if, for example, contractual internals require special confidentiality or an answer via Messenger does not meet formal requirements. In such cases, we will refer you to more adequate communication channels.

 

• Types of data processed: contact data (e.g. e-mail, telephone numbers), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), content data (e.g. entries in online forms).
• Data subjects: Communication partners.
• Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or post).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Video conferencing, online meetings, webinars and screen sharing.

We use platforms and applications of other providers (hereinafter referred to as „Third Party Providers“) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting the third-party providers and their services, we observe the legal requirements.

 

In this context, data of the communication participants are processed and stored on the servers of the third-party providers, insofar as these are part of communication processes with us. This data may include, in particular, registration and contact data, visual and vocal contributions as well as entries in chats and shared screen contents.

 

If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

 

Notes on legal bases: If we ask users for their consent to the use of the third-party providers or certain functions (e.g. consent to a recording of conversations), the legal basis of the processing is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers was agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners. In this context, we would also like to refer you to the information on the use of cookies in this data protection declaration.

 

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, 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: provision of contractual services and customer service, contact requests and communication, office and organisational procedures, direct marketing (e.g. by email or post).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

 

Microsoft Teams: messenger and conferencing software; service providers: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; Website: https://products.office.com; Privacy policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter.

Skype: messenger and conferencing software; service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; website: https://www.skype.com/de/; privacy policy: https://privacy.microsoft.com/de-de/privacystatement, security information: https://www.microsoft.com/de-de/trustcenter.

Slack: Messenger and conferencing software; service provider: Slack Technologies, Inc, 500 Howard Street, San Francisco, CA 94105, USA; website: https://slack.com/intl/de-de/; privacy policy: https://slack.com/intl/de-de/legal.

TeamViewer: Conference software; Service provider: TeamViewer GmbH, Jahnstr. 30, 73037 Göppingen, Germany; website: https://www.teamviewer.com/de; privacy policy: https://www.teamviewer.com/de/datenschutzerklaerung/.

Zoom: video conferencing, web conferencing and webinars; service provider: Zoom Video Communications, Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA; website: https://zoom.us; privacy policy: https://zoom.us/docs/de-de/privacy-and-legal.html; standard contractual clauses (ensuring level of data protection for processing in third countries): https://zoom.us/docs/de-de/privacy-and-legal.html (referred to as Global DPA).

Application procedure

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

 

In principle, the required information includes personal information such as name, address, contact details and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information on which details are required.

 

If provided, applicants can submit their applications to us using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails sent via the Internet are generally not encrypted. As a rule, e-mails are encrypted in transit, 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 the 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 post.

 

Processing of special categories of data: Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants in the context of the application procedure in order to enable the controller or the data subject to exercise the rights accruing to him or her under labour law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2) lit. b. DSGVO, in the case of the protection of vital interests of the applicants or other persons pursuant to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnostics, for 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. DSGVO. In the case of a communication of the special categories of data based on voluntary consent, their processing is based on Art. 9 (2) lit. a. DSGVO.

 

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicants‘ data will be deleted. Applicants‘ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion will take place, subject to a justified withdrawal by the applicants, at the latest after the expiry of a period of six months to enable us to answer any follow-up questions about the application and to comply with our obligations to provide evidence under the Equal Treatment of Applicants Regulations. 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 be included 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.

 

Duration of data retention in the applicant pool in months: 36

 

Concretisation regarding the applicant pool

 

Reason for data storage:

 

We store data on our candidates in order to consider you for current and future vacancies. The data is stored in our database and is used as the basis for decision-making in finding and selecting the right candidate(s). Access is given to Gapp Recruiting & Research consultants when searching for suitable candidates for recruiting mandates.

 

Type of data processing:

 

We use the data stored in our database to decide which candidates to present to our clients. We also process the data in order to communicate it to our clients. Furthermore, we use contact data of our candidates to keep you informed about relevant vacancies and news of our company. Candidates have the right to access the data stored by Gapp Recruiting & Research. Searches of the database may be supported by electronic suggestions based on basic indicators.

 

Intention of transfer:

 

We transfer data of our candidates to our clients in order to place candidates there. Data of our candidates will only be transferred to third parties if they have been explicitly informed about the vacancy, the client and the transfer beforehand. Accordingly, our candidates also give permission to be informed about potentially suitable vacancies and employers.

 

Location of storage:

 

Your data will be stored on the servers of Starhunter GmbH at Erika-Mann-Str 23, D-80636 Munich, or its subcontractors.

 

Duration of storage:

 

We store and process data and documents of our candidates for 36 months. At the end of each 36-month period, our candidates receive an e-mail with a link to our current data protection policy. If the candidates agree to the storage and processing of their data and documents again, the data and documents will remain stored for a further 36 months. If the candidates do not agree, the data and documents will be anonymised.

 

What is the source of the data?

 

Data is collected from a variety of sources. These include, but are not limited to, data sent to us by candidates, such as application forms, CVs, imports from XING & LinkedIn, as well as notes from face-to-face interviews & phone calls we have with candidates and information from third parties such as our clients or referees.

 

Automated decision making:

The pre-selection is supported by automated decision-making. For example, candidates with experience in relevant industries or functional areas can be pre-sorted. In the event of a match, our candidates are explicitly informed by email or telephone before your data is passed on to third parties.

 

Candidates‘ rights:

 

• You have the right to withdraw your given consents at any time and with immediate effect.
• You have the right to information about the personal data stored about you.
• You have the right to data portability. This means that we will transfer your data within 72 hours in a machine-readable format.
• You have the right to have your personal data corrected.
• You have the right to have your personal data deleted.
• You have the right to restrict the processing of your personal data.
• You have the right to object to the processing of your personal data.
• You have the right to lodge a complaint with the relevant supervisory authority.
• Types of data processed: applicant data (e.g. personal details, postal and contact addresses, the documents relating to the application and the information contained therein, such as cover letter, CV, certificates and other information relating to a specific job or voluntarily provided by applicants about their person or qualifications).
• Data subjects: Applicants.
• Purposes of the processing: Application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
• Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b DSGVO).

Services used and service providers:

 

LinkedIn Recruiter: Recruiting platform and services; Service provider: https://www.linkedin.com, LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy.

Xing: Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.com; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

Cloud services

We use software services accessible via the internet and running on their providers‘ servers (so-called „cloud services“, also referred to as „software as a service“) for the following purposes: document storage and management, calendar management, emailing, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

 

In this context, personal data may be processed and stored on the servers of the providers to the extent that these are part of communication processes with us or are otherwise processed by us as set out in the context of this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The cloud service providers also process usage data and metadata used by them for security purposes and service optimisation.

 

If we use the cloud services to provide forms or other documents and content to other users or publicly accessible websites, the providers may store cookies on the users‘ devices for the purpose of web analysis or to remember the users‘ settings (e.g. in the case of media control).

 

Notes on legal bases: Where we ask for consent to use cloud services, the legal basis for processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure administrative and collaboration processes).

 

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, 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), contract data (e.g. subject matter of contract, term, customer category).
• Data subjects: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
• Purposes of processing: Office and organisational procedures.
• Legal grounds: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

 

Apple iCloud: Cloud storage services; Service providers: Apple Inc, Infinite Loop, Cupertino, CA 95014, USA; website: https://www.apple.com/de/; privacy policy: https://www.apple.com/legal/privacy/de-ww/.

Microsoft Cloud Services: Cloud storage services; Service provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA; website: https://microsoft.com/de-de; privacy policy: https://privacy.microsoft.com/de-de/privacystatement, security information: https://www.microsoft.com/de-de/trustcenter.

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter „newsletters“) only with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Apart from that, our newsletters contain information about our services and us.

 

In order to subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of a personal address in the newsletter, or further details, if these are necessary for the purposes of the newsletter.

 

Double opt-in procedure: The registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.

 

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove consent previously given. The processing of this data will be limited to the purpose of a possible defence 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 e-mail address in a block list (so-called „block list“) for this purpose alone.

 

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

 

Notes on legal basis: The newsletter is 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 to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it has been carried out in accordance with the law.

 

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

 

Measurement of opening and click-through rates: The newsletters contain a so-called „web beacon“, i.e. a pixel-sized file that is retrieved from our server or, if we use a dispatch service provider, from their server when the newsletter is opened. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.

 

This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. We use the evaluations to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

 

The measurement of opening rates and click rates as well as the storage of the measurement results in the users‘ profiles and their further processing are based on the users‘ consent.

 

Unfortunately, a separate revocation of the performance measurement is not possible; in this case, the entire newsletter subscription must be cancelled or revoked. In this case, the stored profile information will be deleted.

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
• Data subjects: Communication partners, users (e.g. website visitors, users of online services).
• Purposes of processing: direct marketing (e.g. by email or post), reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-based profiling, use of cookies), remarketing, conversion measurement (measurement of the effectiveness of marketing measures).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
• 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 use one of the contact options given above, preferably e-mail, for this purpose.

Services used and service providers:

 

• Google Analytics: measuring the success of email campaigns and building user profiles with a storage period of up to two years; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Opt-out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.

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

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

 

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

 

After 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 is limited to the purpose of a possible defence against claims. An individual deletion request 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. e-mail, telephone numbers).
• Data subjects: Communication partners.
• Purposes of processing: direct marketing (e.g. by e-mail or post).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Web analysis, monitoring and optimisation

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, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.

 

In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offer or its components.

 

For these purposes, so-called user profiles may be created and stored in a file (so-called „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 the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, 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 basis: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, users‘ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you 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 data (e.g. device information, IP addresses).
• Data subjects: Users (e.g. website visitors, users of online services).
• Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-based profiling, use of cookies), conversion measurement (measurement of the effectiveness of marketing measures), profiling (creation of user profiles).
• Security measures: IP masking (pseudonymisation of the IP address).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

 

Google Analytics: Reach measurement and web analysis; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy.

Evaluation platforms

We participate in rating procedures in order to evaluate, optimise 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 transmit, with the consent of the customers, the data required for this with regard to the customer and the service used to the respective rating platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.

 

Rating widget: We integrate so-called „rating widgets“ into our online offer. A widget is a functional and content element integrated into our online offer that displays variable information. It can be displayed, for example, in the form of a seal or comparable element, sometimes also called a „badge“. In this case, the corresponding content of the widget is displayed within our online offer, but it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website called up within our online offer to the server of the widget provider and the widget provider receives certain technical data (access data, including IP address) which are necessary so that the content of the widget can be delivered to the user’s browser.

 

Furthermore, the widget provider receives information that users have visited our online offer. This information may be stored in a cookie and used by the widget provider to identify which online services participating in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes.

 

• Types of data processed: contract 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), reach measurement (e.g. access statistics, recognition of returning visitors), conversion measurement (measuring the effectiveness of marketing measures), interest-based and behavioural marketing, profiling (creating user profiles).
• Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

 

• ProvenExpert: Reviews and Widget; Service provider: Expert Systems AG, Quedlinburger Strasse 1, 10589 Berlin, Germany; Website: https://www.provenexpert.com/de-de/; Privacy policy: https://www.provenexpert.com/de-de/datenschutzbestimmungen/.

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 users active there or to offer information about us.

 

We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the 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 behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users‘ computers, in which the usage behaviour and the 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 data protection declarations and information provided by the operators of the respective networks.

 

In the case of information requests and the assertion of data subject rights, we also 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, then you can contact us.

 

Facebook: We are jointly responsible with Facebook Ireland Ltd. 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 users view or interact with, or the actions they take (see under „Things you and others do and provide“ in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under „Device Information“ in the Facebook Data Policy Statement: https://www.facebook.com/policy). As explained in the Facebook Privacy Policy under „How do we use this information?“, Facebook also collects and uses information to provide analytics services called „Page Insights“ to Page operators to provide them with insights into how people interact with their Pages and the content associated with them. We have entered into a special agreement with Facebook („Page Insights Information“, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfil the data subject rights (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. Further information can be found in the „Information on Page Insights“ (https://www.facebook.com/legal/terms/information_about_page_insights_data).

 

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, 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/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

 

Facebook: Social network; Service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy; Opt-out: Ad settings: https://www.facebook.com/settings?tab=ads.

LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Twitter: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland; parent company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; privacy policy: https://twitter.com/de/privacy, (settings) https://twitter.com/personalization.

YouTube: Social network and video platform; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; privacy policy: https://policies.google.com/privacy; opt-out: https://adssettings.google.com/authenticated.

Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

Plugins and embedded functions and content

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

 

The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they could not send the content to their browser. The IP address is thus required for the presentation of these contents or functions. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as „web beacons“) for statistical or marketing purposes. The „pixel tags“ can be used to analyse 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 online offering, as well as being linked to such information from other sources.

 

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

Facebook plugins and content: We are jointly responsible with Facebook Ireland Ltd. for collecting or receiving in transmission (but not further processing) „Event Data“ that Facebook collects or receives in transmission through the Facebook social plugins (and content embedding features) that run on our Online Service for the purposes of: a) displaying content and advertising information that is relevant to users‘ perceived interests; b) delivering commercial and transactional messages (e.g., targeting users via Facebook Messenger); c) improving ad delivery and personalising features and content (e.g., improving recognition of which content or ads are relevant to which users). (c) improving ad delivery and personalising features and content (e.g., improving the ability to identify which content or advertising information is likely to be of interest to users). We have entered into a specific agreement with Facebook („Controller Addendum“, https://www.facebook.com/legal/controller_addendum), which in particular regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfil the data subject rights (i.e. users can, for example, direct information or deletion requests to Facebook). Note: When Facebook provides us with metrics, analytics and reports (which are aggregated, i.e. do not receive details of individual users and are anonymous to us), this processing is not carried out under shared responsibility but on the basis of a commissioned processing agreement („Data Processing Terms „, https://www.facebook.com/legal/terms/dataprocessing) the „Data Security Terms and Conditions“ (https://www.facebook.com/legal/terms/data_security_terms) and, with regard to processing in the USA, on the basis of standard contractual clauses („Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). 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.

 

Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), event data (Facebook) („event data“ is data that can be transmitted, e.g. via Facebook Pixel (via apps or in other ways) by us to Facebook and relates to individuals or their actions; the data includes e.g.. Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as written comments), no login information and no contact information (i.e. no names, email addresses and telephone numbers). Event data are deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), inventory data (e.g. names, addresses).

• Data subjects: Users (e.g. website visitors, users of online services), communication partners.
• Purposes of processing: Provision of our online offer and user-friendliness, provision of contractual services and customer service, contact requests and communication, direct marketing (e.g. by e-mail or post), tracking (e.g. interest/behaviour-based profiling, use of cookies), interest-based and behaviour-based marketing, profiling (creation of user profiles), security measures, administration and response to requests.
• Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO).

Services used and service providers:

 

• Facebook plugins and content: Facebook social plugins and content – This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/; Service provider: Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; opt-out: settings for advertisements: https://www.facebook.com/settings?tab=ads.
• LinkedIn plugins and content: LinkedIn plugins and content- This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offering within LinkedIn. Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
• YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.youtube.com; privacy policy: https://policies.google.com/privacy; opt-out: opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, ad display settings: https://adssettings.google.com/authenticated.
• Xing plugins and buttons: Xing plugins and buttons – This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Xing. Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.com; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

Planning, organisation and support tools

We use services, platforms and software of other providers (hereinafter referred to as „third-party providers“) for the purposes of organisation, administration, planning as well as provision of our services. When selecting the third-party providers and their services, we observe the legal requirements.

 

In this context, personal data may be processed and stored on the servers of the third-party providers. This may involve various data which we process in accordance with this data protection declaration. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.

 

If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

 

Notes on legal basis: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Furthermore, their use may be a component of our (pre-)contractual services, provided that the use of the third-party providers was agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

 

• Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, 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).
• Legal grounds: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose for processing this data has ceased to apply or it is not required for the purpose).

 

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. I.e. the data is 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 defence 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 notices of this data protection declaration.

 

Amendment and updating of the data protection declaration

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as changes in the data processing carried out by us 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.

 

Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.

 

Rights of data subjects

As a data subject, you have various rights under the GDPR, in particular as set out in Articles 15 to 21 of the GDPR:

 

• Right to object: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you 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 revoke any consent given at any time.
• Right to information: 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 the legal requirements.
• Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
• Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with the law.
• Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another person responsible.
• Complaint to the supervisory authority: You also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, in accordance with the law, if you consider that the processing of personal data concerning you infringes the GDPR.

Definitions of terms

This section provides you with an overview of the terms used in this privacy statement. Many of the terms are taken from the law and defined primarily in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. 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 to uniquely identify a person. Therefore, IP masking is a means of pseudonymising processing procedures, especially in online marketing.
• Interest-based and behavioural marketing: Interest-based and/or behavioural marketing is when potential interests of users in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting certain websites and staying on them, buying behaviour or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
• Conversion measurement: Conversion measurement (also referred to as „visit action evaluation“) is a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
• Personal data: „Personal data“ means any information relating to an identified or identifiable natural person (hereinafter „data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. 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“ is any form of automated processing of personal data that consists of using that personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information relating to age, gender, location data and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
• Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include visitors‘ behaviour or interests in certain information, such as website content. With the help of reach analysis, 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 reach analysis purposes, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
• Remarketing: „Remarketing“ or „retargeting“ is when, for example, for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
• Location data: Location data is generated when a mobile device (or another device with the technical requirements of location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. 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 dependent on a location.
• Tracking: We speak of „tracking“ when the behaviour of users can be traced 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 display advertisements to users that are likely to correspond to their interests.
• Controller: „Controller“ is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
• Processing: „Processing“ means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission or erasure.