Wandhofener Str. 2
58099 Hagen, Germany
CEO: Johann Erich Wilms
Contact data protection officer: firstname.lastname@example.org
Types of data processed
- Inventory data (e.g., personal master data, names or addresses).
- Contact data (e.g. e-mail, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online service (hereinafter referred to collectively as “users”).
Purpose of the processing
- Provision of the online service, its functions and contents.
- Answering contact requests and communicating with users.
- Security measures.
- Reach measurement/marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier (e.g. a cookie) or to one or more specific characteristics which express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, is regarded as identifiable.
“Processing” means any operation or set of operations, which is carried out with or without the aid of automated processes and which involves personal data. The term is broad reaching and covers practically all handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements of that natural person.
“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal bases
The legal basis for obtaining consent is Art. 6 para. 1 item a and Art. 7 GDPR;
The legal basis for the processing for the fulfilment of our services and the implementation of contractual measures as well as the answering of inquiries is Art. 6 para. 1 item b GDPR;
The legal basis for the processing for the fulfilment of our legal obligations is Art. 6 para. 1 item c GDPR;
Art. 6 para. 1 item d GDPR serves as the legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority entrusted to the controller is Art. 6 para. 1 item e GDPR.
The legal basis for the processing to safeguard our legitimate interests is Art. 6 para. 1 item f GDPR.
The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 para. 4 GDPR.
The processing of special categories of data (pursuant to Art. 9 para. 1 GDPR) is governed by the provisions of Art. 9 para. 2 GDPR.
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, extent, circumstances and purposes of the processing, as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
Measures shall include, in particular, the safeguarding of the confidentiality, integrity and availability of data by controlling physical access to the data as well as access to, input, transmission, securing and separation of the data concerning this. Furthermore, we have established procedures to ensure the exercising of data subjects' rights, the erasure of data and the reaction to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.
Cooperation between processors, joint controllers and third parties
Insofar as we disclose data to other persons and companies (contract processors, joint controllers or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the fulfilment of the contract), users have consented, a legal obligation allows for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
Insofar as we disclose, transmit or otherwise grant access to data to other companies of our group of companies, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis corresponding to the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this is done in the context of the use of third party services or disclosure or transfer of data to other persons or companies, this only occurs if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we shall only process or leave the data in a third country if the legal requirements are met. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. in the case of the USA by means of the “Privacy Shield”) or the observance of officially recognised special contractual obligations.
Rights of data subjects
You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
You have the right to demand that we receive the data concerning you that you have provided to us in accordance with the statutory provisions and to demand that it be passed on to other controllers.
Furthermore, you shall have the right to file a complaint with the competent supervisory authority in accordance with the statutory provisions.
Right of revocation
You shall have the right to revoke any consent you have given with future effect.
Right to object
You may object at any time to the future processing of the data concerning you in accordance with the statutory provisions. In particular, objections may be lodged against processing for the purposes of direct marketing.
Cookies and right to object to direct advertising
“Cookies” are small files that are stored on the user's computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after the user's visit to an online service. Temporary cookies, also referred to as “session cookies” or “transient cookies”, are cookies that are cleared after a user leaves an online service and closes their browser. The content of a shopping cart in an online shop or a login status, for example, can be saved in such a cookie. Cookies are referred to as “permanent” or “persistent” and remain saved even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users can also be saved in such a cookie, which are used for range measurement or marketing purposes. “Third Party Cookies” are cookies that are offered by other providers than the controller who operates the online service (otherwise, if they are only their cookies, one speaks of “First Party Cookies”).
If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. Blocking cookies can lead to functional limitations of this online service.
Erasure of data
If the data is not erased because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.
Data protection information in the application process
We shall process the applicant data only for the purpose and within the framework of the application procedure in accordance with the legal requirements. The processing of applicant data shall be carried out to fulfil our (pre)contractual obligations within the scope of the application procedure as defined in Art. 6 para. 1 item b GDPR Art. 6 para. 1 item f GDPR insofar as data processing becomes necessary for us, e.g. within the framework of legal proceedings (in Germany, Section 26 of the BDSG (Federal Data Protection Act) also applies).
The application procedure requires that applicants provide us with the applicant data. If we offer an online form, the necessary applicant data is indicated, otherwise it results from the job descriptions and basically includes the personal details, postal and contact addresses and the documents belonging to the application, such as cover letter, curriculum vitae and certificates. Besides the above, applicants may voluntarily provide us with additional information.
Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily disclosed in the application process, their processing is also carried out in accordance with Art. 9 para. 2 item b GDPR (e.g. health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application procedure, their processing is additionally carried out in accordance with Art. 9 para. 2 item a GDPR (e.g. health data if they are required for the exercise of a profession).
Where made available, applicants may submit their applications via an online form on our website. The data will be transmitted to us in an encrypted form in line with the state of the art.
Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and the applicants themselves must ensure that they are encrypted. We therefore cannot assume any responsibility for the transmission path of the application between the sender and reception on our server and therefore recommend using an online form or postal delivery. Instead of applying via the online form and e-mail, applicants still have the option of sending their application by post.
In the event of a successful application, the data provided by the applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant's data will be erased. Applicants' data will also be erased if an application is withdrawn, which applicants are entitled to do at any time.
Subject to a justified revocation by the applicant, erasure will take place after a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the German Equal Treatment Act (Gleichbehandlungsgesetz). Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the user's details are used to process the contact enquiry and to process it in accordance with Art. 6 para. 1 item b (within the framework of contractual/pre-contractual relationships), Art. 6 para. 1 item f (other inquiries) GDPR. The user data can be stored in a customer relationship management system (“CRM system”) or comparable inquiry organisation.
We will erase the requests if they are no longer necessary. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
With the following references we shall inform you about the contents of our newsletter as well as the subscription, delivery and statistical evaluation procedures and your rights to object. By subscribing to our newsletter, you agree to the receipt and procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter referred to as “newsletters”) only with the consent of the recipient or a legal permission. Insofar as the contents of the newsletter are specifically described within the framework of subscription, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and who we are.
Double opt-in and logging: Subscription to our newsletter takes place in what is known as a double opt-in procedure. This means that you will receive an e-mail after subscription asking you to confirm your subscription. This confirmation is necessary so that no one can subscribe with other e-mail addresses. The subscriptions to the newsletter are logged in order to be able to document the subscription process in accordance with the legal requirements. This includes storing the login and confirmation times as well as the IP address. Likewise the changes of your data stored with the e-mail service provider are logged.
Subscription data: To subscribe to the newsletter, it is sufficient to enter your e-mail address. As an option, we ask you to enter a name in the newsletter in order to address you personally.
The sending of the newsletter and the performance measurement associated with it are based on the consent of the recipients pursuant to Art. 6 para. 1 item a, Art. 7 GDPR in conjunction with Section 7 para. 2 no. 3 German Unfair Competition Act ("UWG") or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6 para. 1 item f. GDPR in conjunction with Section 7 para. 3 UWG.
The subscription procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 para. 1 item f GDPR. We are committed to using a user-friendly and secure newsletter system that serves our business interests, meets users' expectations, and allows us to provide evidence of consent.
Cancellation/revocation - You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed email addresses for up to three years based on our legitimate interests before erasing them to provide evidence of prior consent. The processing of this data is limited to the purpose of a possible defence against claims that may arise. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time.
Hosting and e-mail delivery
The hosting services used by us are used to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail delivery, security services and technical maintenance services which we use for the purpose of operating this online service.
Hereby we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in the efficient and secure provision of this online service in accordance with Art. 6 para. 1 item f GDPR in conjunction with Art. 28 GDPR (conclusion of a contract for the processing of orders).
Collection of access data and log files
We, or our hosting provider, collect data on each access to the server on which this service is located (referred to as server log files) on the basis of our legitimate interests within the meaning of Art. 6 para. 1 item f GDPR. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud actions) for the duration of maximally 7 days and erased afterwards. Data, the further storage of which is necessary for evidence purposes, shall be exempted from erasure until the respective incident has been finally clarified.
Google is certified under the Privacy Shield Agreement, providing a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online service by users, to compile reports on the activities within this online service and to provide us with other services associated with the use of this online service and the internet. In the process, pseudonymous user profiles of the users can be created from the processed data.
We only use Google Analytics with IP anonymisation enabled. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
The personal data of the users will be erased or anonymised after 14 months.
Online presences on social media
We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services.
We would like to advise you that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users' rights. With respect to US providers that are certified under the Privacy Shield, we would like to point out that by doing so they commit themselves to complying with EU data protection standards.
Furthermore, user data is usually processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements inside and outside the platforms which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer, on which the user's usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of users' personal data is carried out on the basis of our legitimate interests in the effective information of users and communication with users in accordance with Art. 6 para. 1 item f GDPR. If the users are requested by the respective providers of the platforms to give their consent to the aforementioned data processing, the legal basis for the processing is Art. 6 para. 1 item a, Art. 7 GDPR.
For a detailed representation of the respective processing and possibilities of objection (Opt-out), we will refer to the following linked information offered by the providers.
Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.
Integration of third-party services and content
Within our online service, we use content or service offers from third parties on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 para. 1 item f GDPR) content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always assumes that the third-party providers of this content use the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the reproduction of these contents. We strive to use only those contents, whose respective providers use the IP address only for the delivery of the contents. Third parties may also use pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.
Use of Facebook Social Plugins
We use Social Plugins (“Plugins”) of the social network facebook.com which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 para. 1 item f GDPR).
This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online service within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement, providing a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user calls up a function of this online service that contains such a plugin, their device establishes a direct connection with Facebook's servers. The content of the plugin is transmitted directly from Facebook to the user's device and integrated into the online service by the user. In the process, user profiles of the users can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and shall therefore inform users to the best of our knowledge.
By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online service. If the user is logged in to Facebook, Facebook can assign the visit to their Facebook account. When users interact with the plugins, e.g. by clicking the Like button or commenting, the corresponding information is transferred directly from their device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to know and store their IP address. According to Facebook, only an anonymous IP address is stored in Germany.
If a user is a Facebook member and does not want Facebook to collect information about them via this online service and link it to their Facebook stored member data, they must log out of Facebook and clear their cookies before using our online service. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.