Data protection

Data privacy statement 

Any collection, processing and use (hereinafter "use") of data is solely for the purpose of providing our services. Our services have been designed to use as little personal information as possible. For that matter, "personal data" is understood as all individual details about a person or factual circumstances of an identifiable natural person (so-called "affected person"). The following statements on data protection describe what types of data are collected when accessing our website, what happens with these data and how you may object to data usage.

1 General information on data processing  

1.1 Person Responsible (Controller)

Responsible within the meaning of the EU General Data Protection Regulation (GDPR) and the new Federal Data Protection Act (BDSG) is:

Undconsorten Managementberatung GmbH & Co. KG   

Address:Kurfürstendamm 194, 10707 Berlin 

Phone: 0049(0)30889294-0

Email: contact@undconsorten.de 

Homepage: undconsorten.de/ 

1.2 Name and address of the Data Protection Officer 

The data protection officer is:

Christina Webersohn of WS Datenschutz GmbH

If you have questions about data protection, you can contact WS Datenschutz GmbH at the following email address: undconsorten@ws-datenschutz.de

WS Datenschutz GmbH

Dircksenstraße 51 

D-10178 Berlin

https://webersohnundscholtz.de

1.3 Protection of your data

We have taken technical and organizational measures to ensure that the requirements of the EU General Data Protection Regulation (GDPR) are met by us, as well as, by external service providers working for us.

If we work with other companies to provide our services, such as email and server providers, this will only be done after an extensive selection process. In this selection process, each individual service provider is carefully selected for its suitability in terms of technical and organizational data protection skills. This selection procedure will be documented in writing and an agreement on the order processing of data (data processing agreement) will only be concluded if the third party complies with the requirements of Art. 28 GDPR.

Your information will be stored on specially protected servers. Access to it is only possible for a few specially authorized persons. Our website is SSL/TLS encrypted, as can be seen by the https:// at the start of our URL. This also involves e-mail communications, which is encoded via SSL certificate.

1.4 Erasure of personal data

We process personal data only if necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

 

2 Use of data on this website and in logfiles

2.1 Scope of processing personal data 

When visiting our website, our web servers temporarily store every access in a log file. The following data is collected and stored until automated erasure:

  • IP-address of the requesting computer
  • Date and time of access
  • Name and URL of the retrieved file
  • Message if the retrieval was successful
  • Detection data of the browser and operating system used
  • Website from which access is made

We or our partners may process additional data occasionally. You will find information about this below.

2.2 Legal basis for processing personal data 

The legal basis for the temporary storage of the data and log files is Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interest is to make our website accessible for you.

2.3 Purpose of data processing

The processing of this data serves: the purpose of enabling the use of the website (connection establishment), system security, the technical administration of the network infrastructure, as well as to optimize the website. The IP address is evaluated only in case of attacks on our network infrastructure or the network infrastructure of our internet provider.

2.4 Duration of storage

As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out. This happens as soon as you close our website. Our hosting service might use data for statistical purposes. Any personal data will be anonymized for this. Our hosting service will delete this data after a period of 6 months.

2.5 Right of objection and erasure

The data processing is necessary in order to present the website and to ensure the website’s operation. Therefore, objecting is impossible.

2.6 Ionos 

Our website uses the services of the hosting provider 1&1. The data processing is carried out by: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur. 

For additional information, please refer to the privacy policy of 1&1: https://www.ionos.de/terms-gtc/terms-privacy/

2.6.1 Duration of storage

The data will be deleted as soon as the purpose of the processing has been fulfilled and no legal or contractual regulations prevent deletion.

2.6.2 Right to objection and erasure

In addition to the right of access, you also have a right to rectification of the personal data stored about you, a right to erasure, a right to blocking and a right to transfer your data. 

Furthermore, you can object to this processing at any time by contacting us or the 1&1 data protection officer. If you wish to exercise any of these rights, you can contact 1&1's data protection officer at the above address or send an e-mail to datenschutz@ionos.de.

 

3 Use of cookies

3.1 Description and scope of data processing 

Our website uses cookies. This means that when using the website, cookies are stored on your computer. Cookies are small text files which are assigned to the browser you are using and which are stored on your hard drive. Through this information flows to us or the party who set the cookie. Cookies cannot run programs on or transmit viruses to your computer. They are used by us to improve your user experience, analyze your user behavior, optimize marketing measures and increase the efficiency of the services.The following data may be transmitted:

  • Frequency of website visits
  • Length of stay
  • Which functions of the website are used by you
  • Your cookie-settings
  • Language settings
  • Used search terms

Upon entering our website, a consent banner informs you about the use of cookies on this website and asks for your consent to the use of cookies. Also, you are pointed to the data privacy statement of this website:

3.2 Legal basis for data processing

The legal basis for the processing of data by cookies, which do not only serve the functionality of our website, is Art. 6 para. 1 s. 1 lit. a) GDPR.

The legal basis for the processing of data for cookies, which serve only the functionality of this website, is Art. 6 para. 1 s. 1 lit. f) GDPR.

3.3 Purpose of data processing

Our legitimate interests are to provide you with a working website connection and to ensure a comfortable use of this website. Also, we need to process your personal data to solve occurring safety and security issues, as well as to ensure system stability.

The data processing takes place to make a statistical evaluation of our website possible.

3. 4 Duration of storage 

This website uses the following types of cookies. The extend and function of each are being explained below:

  • Transient cookies (see a)
  • Persistent cookies (see b)

a) Transient cookies are automatically deleted when you close the browser. This is especially true for session cookies which store your session ID, with which various requests from your browser can be assigned to your session. This will allow your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close the browser.

b) Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie.

3.5 Right to objection and erasure 

You have the possibility to revoke your consent to the data processing by means of cookies, which do not only serve the functionality of the website. In addition, we do not set cookies until you have agreed to set cookies when you visit the site. In this way, you can prevent data processing via cookies on our website. You can also delete the cookies in your browser's security settings at any time. Please note that you may not be able to use all the features of this website. The setting of cookies can also be prevented at any time by appropriate settings in your internet browser.

 

4 Contact

4.1 Description and scope of data processing

Via our website it is possible to contact us via contact form. This will require different data to answer the request, which will be automatically saved for processing.  The following data are required to process your request:

  • Email address 
  • First name 
  • Last name
  • Message

Furthermore, you can enter the following data optionally:

  • Job title
  • Company name 
  • Contact source 
  • Telephone number

You can also contact us by e-mail at contact@undconsorten.de or by telephone on +49 (0) 30 88 92 94 -0. Your data will not be passed on to third parties, unless you have given your consent. 

4.2 Legal basis for data processing

The legal basis depends on Art. 6 para. 1 s. 1 lit. b) GDPR. For voluntary information, your consent pursuant to Art. 6 para. 1 sentence 1 lit. a) GDPR is the legal basis used.

4.3 Purpose of data processing

The processing of personal data from the input form is used solely handling the contact request.

4.4 Duration of storage

The data will be deleted as soon as we answer your request. There might occur rare cases when legal or contractual retention periods interfere with the erasure of your personal data. In this case your data will be deleted after these periods.

4.5 Right to objection and erasure

The user has the right to withdraw their consent to the processing of personal data at any time. If the user contacts us, they can object to storage of their personal data at any time. In such cases, the conversation cannot be continued. All personal data that has been stored in the course of the contact will be deleted.

 

5 Data processing for applications with Personio

5.1 Description and scope of data processing

Our careers page is operated by the personnel administration and applicant management software Personio. The data processing is carried out by: Personio SE & Co. KG, Seidlstraße 3 4, 80335 Munich, Germany. 

The data transmitted as part of your application is transferred using TLS encryption and stored in a database. We are solely responsible for this data as the controller carrying out this online application process. Personio is merely the operator of the software and this recruiting page and, in this context, a processor in accordance with Art. 28 GDPR. An order processing contract has been concluded with Personio. In addition, Personio GmbH processes further data, some of which may also be personal data, in order to provide its services, in particular for the operation of this recruiting site. The following data is processed by Personio:

  • Access logs (server logs) 
  • Error logs (error logs) 
  • cookies 

In addition, we process the following data when you complete the application form 

  • First and last name 
  • e-mail address 
  • telephone number 
  • Date of availability 
  • Information on salary expectations 
  • Gender affiliation 
  • Curriculum vitae 
  • Personal cover letter 
  • Other personal documents

Further information on data protection at Personio can be found here: www.personio.de/datenschutzerklaerung. If you have any questions about data protection at Personio, you can contact Personio at any time at the following e-mail address: datenschutz@personio.de.

5.2 Legal basis for data processing

Data processing will be based on Art. 88 GDPR and § 26 BDSG (2018). The legal basis for the use of Personio is our legitimate interest in providing an online application process in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR.

5.3 Purpose of data processing

We process your data exclusively for the purpose of carrying out the application process. The purpose of data processing by Personio is to provide an online application process and to optimize the application process.

5.4 Duration and storage

In case of successful application and employment, the personal data is stored in accordance with the legal requirements. In case of unsuccessful application, the data will be deleted in accordance with the rules of the local erasure concept. In doing so the provisions of the AGG (German Employment Law), especially the existing evidence pursuant to § 22 AGG, are taken into account.

This does not apply if we are obliged to any legal erasure periods or if you have given consent to store your data for further communication with us (e.g. we have another suitable job in the future). If you have given consent the legal basis for further storage of your data is Art. 6 para. 1 s. 1 lit. c) or lit. a) GDPR.

5.5 Right to objection and erasure

You can contact us at any time and object to further processing of your data. All personal data processed by us in the course of the application process will be deleted in this case, unless deletion is prevented by mandatory statutory provisions.

 

6 Provision of further information via the website

6.1 Description and scope of data processing

On our website you can request us to forward further information by email to you. This requires you to enter personal data in an online form. The following data is at least collected for this:

  • Email address
  • First name       
  • Last name 

Furthermore, you can enter the following data optionally:

  • Job title
  • Company name 
  • Contact source 
  • Telephone number

The information provided by the data subject in the online form will be used exclusively for supplying you with the requested information and will not be disclosed to third parties. 

6.2 Legal basis for data processing

If the data subject enters mandatory personal data in the registration form, the legal basis of the data processing is based on Art. 6 para. 1 s. 1 lit. b) GDPR. However, if the user also enters personal data in the optional input field, the data processing is based on Art. 6 para. 1 s. 1 lit. a) GDPR.

6.3 Purpose of data processing

We process your data exclusively for the purpose of sending you the requested further information.

6.4 Duration of storage

The data are deleted as soon as the purpose of storage is no longer required and no statutory or regulatory retention periods of erasure contradict.

6.5 Right to objection and erasure

You have the option of managing your data yourself at any time. You can do this by using the corresponding link in our emails or by contacting us directly.

 

7 Newsletter

7.1 Description and scope of data processing

On our website visitors can subscribe to our newsletter. When subscribing to the newsletter, you will be asked to provide personal data for processing. This is the data that is requested in the newsletter registration form. The following data is at least collected for this:

  • Email address
  • First name
  • Last name 

This data is necessary to send the newsletter to its recipients.

Furthermore, you can enter the following data optionally:

  • Job title
  • Company name 
  • Contact source 
  • Telephone number

The newsletter will be sent via email only after the sign-up process is completed. In order to meet the requirements of the GDPR, we use DOI (Double Opt.-In). If you sign up for our newsletter, we will send a confirmation email to the address you provided us with. This email contains a confirmation link that you must click to complete the sign-up process. Following this procedure, the IP address, date and time of login are stored. This is done to prevent abuses. We won’t transfer the data to third parties.

7.2 Legal basis for data processing

This processing is legally based on Art. 6 para. 1 s.1 lit. a) GDPR, thus your consent. Existing customers may also receive our newsletter without having given their explicit consent. This is carried out only within the strict boundaries of § 7 para. 3 UWG (German Act against unfair Competition) and in accordance to Art. 95 GDPR. This equals the legal basis of Art. 6 para. 1 s.1 lit. f) GDPR. Our legitimate interests are to provide information about our products through promotional e-mails to our existing customers and thereby keep in contact with these customers.

7.3 Purpose of data processing 

The newsletter has the functions of informing the affected parties about offers and news at a regular basis. 

7.4 Duration of storage

We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

7.5 Right to objection and erasure

You can withdraw your consent at any time and manage your data yourself. You can unsubscribe from the newsletter or change your preferences at any time by using the corresponding link in our emails or by contacting us directly.

 

8 Events

8.1 Description and scope of data processing

We organise events and webinars. This requires you to enter personal data in a registration form. The following data is at least collected for this:

  • Email address
  • First name
  • Last name 
  • Telephone number (for on-site events)

Furthermore, you can enter the following data optionally:

  • Job title
  • Company name 
  • Contact source 
  • Telephone number

The information provided by you in the registration form will be used exclusively for supplying you with information regarding and organising the event and will not be disclosed to third parties. 

8.2 Legal basis for data processing

If the data subject enters mandatory personal data in the registration form, the legal basis of the data processing is based on Art. 6 para. 1 s. 1 lit. b) GDPR. However, if the user also enters personal data in the optional input field, the data processing is based on Art. 6 para. 1 s. 1 lit. a) GDPR.

8.3 Purpose of data processing

We process your data exclusively for the purpose of organising the event.

8.4 Duration of storage

The data are deleted as soon as the purpose of storage is no longer required and no statutory or regulatory retention periods of erasure contradict.

8.5 Right to objection and erasure

You have the option of managing your data yourself at any time. You can do this by using the corresponding link in our emails or by contacting us directly.

 

9 Social media links

We have integrated social media platforms through into our services, which may result in the social media provider receiving data from you. If you click on the social media link, the website of the respective social media provider is loaded. By loading the website of the respective social media provider via our services, the respective reference data is transmitted to the respective social media provider. Provided that you do not click on the links of the social media providers, no data transfer takes place.

Further information on data processing by the social media providers can be found here:

LinkedIn: https://www.linkedin.com/legal/privacy-policy

Instagram:  https://help.instagram.com/155833707900388 https://www.instagram.com/about/legal/privacy

XING: https://www.xing.com/pages/undconsortenmanagementberatunggmbh-co-kg

 

10 Tracking and analytics

For the continuous improvement of our website we use the following tracking and analytics tools. Below you can find information on which personal data is processed in each case and how you can reach the respective service providers:

10.1 Microsoft Clarity 

10.1.1 Description and scope of data processing

Data processing for the European Economic Area and for Switzerland is carried out by Microsoft Ireland Operations Limited, One Microsoft Pace, South Country Business Park, Leopardstown, Dublin 18, Ireland a subsidiary of: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. 

The information collected includes: 

  • IP address, 
  • time of access, 
  • duration of access 
  • Interaction on the website (clicks, scrolls, mouse movements) 
  • location 
  • Browser information 
  • Screen resolution 
  • language settings 

If you consent to this data processing, cookies are used to collect and analyze this data. Cookies are small text files that are stored locally in the cache of the visitor's Internet browser. Cookies make it possible to recognize the Internet browser. The information collected by a cookie may be transferred to a Microsoft Corporation server in the USA and stored there. We have concluded an order processing contract with Microsoft, which obliges Microsoft to protect the data of our customers. Further information on data protection at Microsoft can be found here: privacy.microsoft.com/de-de/privacystatement 

10.1.2 Legal basis of data processing

The legal basis for processing data is your given consent, Art. 6 para. 1 s. 1 lit. a) GDPR.

10.1.3 Purpose of data processing

The processing of your personal data enables us to analyze your use of our website. By evaluating the data obtained, we are able to compile information about the use of the individual components of our website. This helps us to constantly improve our website and its user-friendliness. 

10.1.4 Duration of storage

The data will be deleted 52 weeks after your last visit to our website.

10.1.5 Right to objection and erasure

You have the option to withdraw your consent to data processing at any time. To do this, you can change your settings in our Consent Manager.

10.2 Google Analytics 4.0

10.2.1 Description and scope of data processing

Our website uses Google Analytics. This is a service for analyzing access to websites of Google Inc. ("Google") and allows us to improve our website.  Data processing for the European Economic Area and for Switzerland is carried out by:Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Cookies enable us to analyze your use of our website. The information collected may include 

  • IP address 

    • time of access 
    • duration of access
    • From which website you came to our website
    • Interaction on the website
    • Demographic characteristics, if the website visitor is logged into their Google Account
    • Device categories, browser type, operating system, screen resolution

     

and are transmitted to a Google server in the USA and stored there. The analysis of your activities on our website is transmitted to us in the form of reports. Google may pass on the information collected to third parties if this is required by law or if third parties process this data on behalf of Google. IP anonymization is carried out by Google by default and cannot be deactivated, so IP addresses are only processed further in abbreviated form in order to exclude any possible direct personal reference to you. You can find more information on the terms of use and data protection of Google Analytics at https://policies.google.com, https://support.google.com/analytics/answer/6004245?&ref_topic=2919631#zippy=%2Ccookies-und-kennzeichnungen-von-google-analytics, and https://support.google.com/analytics/answer/9019185?#zippy=%2Cthemen-in-diesem-artikel

10.2.2 Legal basis of data processing

The legal basis is your given consent, Art. 6 para 1 s. 1 lit. a) GDPR. 

10.2.3 Purpose of data processing

By processing the data, we can analyze how our website is used, so we can improve it for our users.

10.2.4 Duration of storage

The data will be deleted 2 (event data) or 14 (user data) months after your last visit to our website.

10.2.5 Right to objection and erasure

You can withdraw your consent to data processing at any time with effect for the future. Please use our consent banner for this purpose. You can also prevent the installation of cookies from Google Analytics yourself by making the appropriate settings in your browser software. Google Analytics can also be deactivated and controlled using browser extensions, e.g. https://tools.google.com/dlpage/gaoptout

10.3 Google Tag Manager

10.3.1 Description and scope of data processing

Google Tag Manager is a solution that allows us to manage so-called website tags via an interface (and thus, for example, integrate Google marketing services into our online offer). The Tag Manager serves as a "manager" of the implemented tags. This allows us to centrally manage integrated Google products or other analysis tools on our website. The tags embedded on the website are referred to as sections of code that make it possible to track your activities on our website. By using our website, users download the Google Tag Manager, which automatically results in the user's IP address being forwarded to Google With regard to the processing of personal data, please refer to the information on Google services. Data processing for the European Economic Area and Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

You can access the usage guidelines of the Google Tag Manager here: https://www.google.com/intl/de/tagmanager/use-policy.html 

10.3.2 Legal basis for data processing

The legal basis for the processing of personal data is your consent pursuant to Art. 6 para. 1 s. 1 lit. a) GDPR.

10.3.3 Purpose of data processing

Google Tag Manger simplifies the management and organization of the analysis tools used for the website. In order to integrate an analysis tool, JavaScript codes must be integrated into the website. By using Google Tag Manger, it is possible for us to manage these embedded codes from one place. 

10.3.4 Duration of storage

Since data storage is not carried out directly by Google Tag Manager, but the data is forwarded to the tracking tools, it is necessary to check with the individual embedded tracking tools how long the data is stored.

10.3.5 Right to objection and erasure

You have the option at any time to revoke a given consent to data processing with effect for the future. For this, you would have to contact the respective data protection officers of the tools. Further information regarding the management of your data can be found in the data protection statements of the tools used. 

 

11 Tools for advertisement and marketing

Tools are also included on our website to ensure that our website is displayed to you during an internet search, as a relevant search result or as an advertisement. Below, the programs used in connection with our website have been broken down for you:

11.1 Google Ads

11.1.1 Description and scope of data processing

We have integrated the services of Google Ads (formerly Google AdWords) on our website. Google Ads is an internet advertising service. We use Google Ads to gain relevance in the results of Google's search engine. Data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

If the user accesses our website through a Google ad, Google will set a so-called conversion cookie on the user's system. For the explanation of the cookies, please refer to the pass to the cookies. The conversion cookie is used to create and analyze web-use statistics.

The conversion cookie stores the IP address when visiting the website. This data is stored in the USA. It is possible that Google will share this information with third parties.  

For further privacy notices of Google refer to: https://policies.google.com/privacy?hl=en&gl=de

11.1.2 Legal basis of data processing

The legal basis is your consent pursuant to Art. 6 para. 1 s. 1 lit. a) GDPR. 

11.1.3 Purpose of data processing

In particular, we use Google Ads to gain relevance in the results of Google's search engine.These advertisements are carried out to reach a greater audience. 

11.1.4 Duration of storage

30 days after setting the conversion cookie the cookie loses its validity. This means that the user can no longer be identified. Within these 30 days both- us and Google can track which subpages have been accessed.

11.1.5 Right to objection and erasure

You have the option to withdraw your consent to data processing at any time. To do so, please contact our data protection officer. 

The setting of cookies can be prevented at any time by making the appropriate settings in your Internet browser. Cookies that have already been set can also be deleted in the Internet browser settings. Please note that preventing the setting of cookies may mean that not all functions are available without restriction. 

You can use this link www.google.com/settings/ads/plugin to permanently prevent data processing in your browser. As a result, it is possible that functions of our website will no longer be fully available. 

It is also possible in the browser settings to object only to cookies for conversation tracking and thus to user-related advertising by Google. To do this, please click on the following link: www.google.de/settings/ads. We would like to point out that a new setting is required if you delete the cookies in your browser. 

You can also click on the following link to deactivate those user-related ads that are part of the "About Ads" self-regulation campaign. We would like to point out that a new setting will be required if you delete the cookies in your browser.

11.2 LinkedIn Insight Tag

11.2.1 Description and scope of data processing

We place advertising on LinkedIn. We use LinkedIn analytics and conversion tracking technology to test the effectiveness of this advertising on LinkedIn.

The data processing is carried out by:

LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

LinkedIn places a cookie on your computer, from which information about the delivery of advertising can be obtained. The cookie’s text files contain information about your visits to our website and to the pages you have viewed in order to provide specific product recommendations for subsequent visits to our website or third-party websites. The cookie contains a randomly assigned alias. If you revisit our website or LinkedIn within a certain period, LinkedIn will be able to recognize you through this alias. However, this information cannot be linked to your person. Neither we nor LinkedIn will link this information to any personal information and will not share your personal information with third parties.

11.2.2 Legal basis of data processing

The data processing is based on Art. 6 para. 1 s. 1 lit. a) GDPR.

11.2.3 Purpose of data processing

It is in our legitimate interest to inform you about relevant our offers in a targeted and user-friendly form. This also represents the purpose of the data processing.

11.2.4 Duration of storage

The data will be deleted as soon as it is no longer needed for our recording purposes.

11.2.5 Right to objection and erasure

You may object to the described data processing by LinkedIn and use of data opening this link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out and following the instructions.

If you choose this option, a new cookie (opt-out cookie) will be set in your browser informing LinkedIn that no data regarding your browser behaviour may be stored. Please note that the setting must be made for all browsers you use. If all your cookies are deleted in a browser, this will also affect the LinkedIn opt-out cookie.

 

12 HubSpot

12.1 Description and scope of data processing

We use "HubSpot", a platform for marketing, sales, customer management and customer service. The data processing is carried out by: HubSpot, Inc, 25 First Street Cambridge, MA 02141, USA. 

HubSpot collects the data entered in the contact form as well as the day and time the email was opened and stores it in our software. Your data is stored on servers in the USA. We use the service for analysis purposes and to evaluate the use of our website. 

HubSpot does not use the data and does not pass it on to third parties. We trust in the reliability and IT and data security of HubSpot. Further information on data protection at HubSpot can be found at https://legal.hubspot.com/de/terms-of-service

12.2 Legal basis for data processing

The data processing of your data entered in the contact form by HubSpot is carried out in accordance with Art. 6 Para. 1 S. 1 lit. b) GDPR. The data processing of the day and time of e-mail opening is based on our legitimate interest in customer-friendly communication and acquisition in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR. 

The legal basis for data processing for analysis purposes is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a) GDPR. 

12.3 Purpose of data processing

We use HubSpot as our sub- processor to ensure an efficient management of our mailing list and to send newsletters to stay in touch with you.

We use HubSpot to effectively analyze user behavior on our website.

12.4 Duration of storage

According to HubSpot, HubSpot only stores your personal data for as long as we use your personal data. HubSpot deletes your data when we delete you from our address file or delete our account with HubSpot after a period of 30 days.

12.5 Right to objection and erasure

You have the option to withdraw your consent to data processing at any time. You have the option to object to data processing at any time. To do so, please contact our data protection officer. 

You can also prevent the day and time of e-mail opening from being saved by yourself by not downloading the image files in the e-mail. 

 

13 Service providers from third countries

In order to be able to provide our services, we use the support of service providers from third party countries (non-EU countries). In order to ensure the protection of your personal data in this case, we conclude processing contracts with each - carefully selected - service provider. All of our processors provide sufficient guarantees to implement appropriate technical and organizational measures. Our third country data processors are either located in a country with an adequate level of data protection (Art. 45 GDPR) or provide appropriate safeguards (Art 46 GDPR). 

Adequate level of protection: The provider comes from a country whose level of data protection has been recognized by the EU Commission. For more information, see: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en 

EU standard contract clauses: Our provider has submitted to the EU standard contractual clauses to ensure secure data transfer. For more information, see: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en

Binding Corporate Rules: Article 47 of the GDPR provides the possibility of ensuring data protection when transferring data to a third country via Binding Corporate Rules. These are examined and approved by the data security authorities within the framework of the consistency mechanism pursuant to Art. 63 GDPR. 

Consent: In addition, a data transfer to a third country without an adequate level of protection will only take place if you have given us your consent in accordance with Art. 49 sec. 1 lit. a) GDPR for this purpose.

 

14 Your rights

You have the following rights with respect to the personal data concerning you: 

14.1 Right to withdraw a given consent (Art. 7 GDPR)

If you have given your consent to the processing of your data, you can withdraw it at any time. This will affect the admissibility of processing your personal data by us for the time after you have withdrawn your consent. To withdraw your consent, contact us personally or in written form.

14.2 Right of access (Art. 15 GDPR)

You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and the following information:

  • the purpose of processing;
  • the categories of personal data concerned;
  • the recipients or the categories of recipient to whom your personal data have been or will be disclosed, in particular recipients in countries outside of the EU or international organisations; 
  • where possible, the envisaged period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;
  • all available information on the source of your personal data; 
  • the existence of automated decision-making, including profiling, referred to Art. 22 para. 1 and 4 GDPR and, in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

In the case of such a request, you must provide enough information about your identity to proof that the request concerns your own personal data.

14.3 Right to rectification and erasure (Art. 16, 17 GDPR)

You have the right to obtain from us without undue delay the rectification and completion of inaccurate personal data concerning yourself.

You may also request the erasure of your personal data if any of the following applies to you:

  • the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed;
  • you withdraw consent on which the processing is based according to Art. 6 para. 1 s.1 lit. a) or Art. 9 para. 2 lit. a) GDPR, and where there is no other legal ground of processing;
  • you object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or the you object to the processing pursuant to Art. 21 para. 2 GDPR;
  • the personal data have been unlawfully processed;
  • the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject;
  • the personal data have been collected in relation to the offer of information society services referred to in Art. 8 para. 1.

Where we made the personal data public and are obliged to erase the personal data pursuant to Art. 17 para. 1 GDPR, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

These rights shall not apply to the extent that processing is necessary:

  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  • for reasons of public interest in the area of public health in accordance of Art. 9 para. 2 lit. h) and i) as well as Art. 9 para. 3 GDPR;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, in so far as the right referred to above is likely to render impossible or seriously impair the achievement of the objectives of that processing, or
  • for the establishment, exercise or defence of legal claims.

14.4 Right to restriction of processing (Art. 18 GDPR)

You shall have the right to obtain from us restriction of processing where one of the following applies:

  • the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  • we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;
  • you have objected to processing pursuant to Art. 21 para. 1 GDPR pending the verification whether our legitimate grounds override yours.

Where processing has been restricted under the aforementioned conditions, such personal data shall, except for storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

If the limitation of the processing is restricted, you will be informed by us before the restriction is lifted.

14.5 Right to information (Art. 19 GDPR)

If you have asserted us your right to rectification, erasure or restriction of data processing, we will inform all recipients of your personal data to correct, delete or restrict the processing of data, unless this proves impossible or involves disproportionate effort.

You also have the right to know which recipients have received your personal data.

14.6 Right to data portability (Art. 20 GDPR)

You have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to transmit those data to another controller, where

  • the processing is based on consent pursuant of Art. 6 para. 1 s.1 lit. a) GDPR or of Art. 9 para. 2 lit. a) GDPR or is based on a contract pursuant of Art. 6 para. 1 s. 1 lit. b) DS-GVO; and
  • the processing is carried out by automated means.

In exercising your right to data portability, you have the right to obtain that personal data transmitted directly from us to another controller, as far as technically feasible. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority that has been delegated to us.

14.7 Right to object (Art. 21 GDPR)

Where we based the processing of your personal data on a legitimate interest (Art. 6 para. 1 s. 1 lit. f) GDPR), you may object to the processing. The same applies if the data processing is based on Art. 6 para. 1 s. 1 lit. e).

In this case, we ask you to explain the reasons why we should not process your personal data. Based on this we will terminate or adapt the data processing or show you our legitimate reasons why we continue the data processing.

14.8 Right to lodge a complaint with supervisory authority (Art. 77 GDPR)

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against the infringes of the GDPR.

The supervisory authority to which the complaint has been submitted shall inform you of the status and results of the complaint, including the possibility of a judicial remedy according to Article 78 GDPR.

 

15 How you perceive these rights

To exercise these rights, please contact our data protection officer:

Christina Webersohn from Webersohn & Scholtz GmbH 

undconsorten@ws-datenschutz.com 

or by mail:

WS Datenschutz GmbH

Dircksenstraße 51 

D-10178 Berlin

 

16 Subject to change

We reserve the right to change this privacy policy in compliance with legal requirements.

August 2024