1. INTRODUCTION
With the following information, we would like to give you as a “data subject” an overview of the processing of your personal data by us and your rights under data protection laws. In principle, it is possible to use our Internet pages without entering personal data. However, if you want to use special services of our enterprise via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we will generally obtain your consent.
The processing of personal data, such as your name, address or e-mail address, is always in line with the German Data Protection Regulation (Datenschutz-Grundverordnung – DS-GVO) and in accordance with the country-specific data protection regulations applicable to the “EWG Essener Wirtschaftsförderungsges. mbH”. By means of this data protection declaration, we would like to inform you about the scope and purpose of the personal data collected, used and processed by us.
As the controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, you are also free to transmit personal data to us by alternative means, for example by telephone or by mail.
2. RESPONSIBLE
The responsible party within the meaning of the DS-GVO is:
EWG Essener Wirtschaftsförderungsges. mbH
Kennedyplatz 5, 45127 Essen, Germany
Phone: 0201 – 820240
Representative of the responsible person: Andre Boschem
3. DATA PROTECTION OFFICER
You can reach the data protection officer as follows:
Björn Leineweber
Phone: 0201 – 890 66 123
E-mail: leineweber@datenschutz-ruhr.de
You can contact our data protection officer directly at any time with all questions and suggestions regarding data protection.
4. DEFINITIONS
The data protection declaration is based on the terms used by the European Directive and Ordinance Maker when issuing the Basic Data Protection Regulation (DS-GVO). Our data protection declaration should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terminology used in advance.
We use the following terms, among others, in this data protection declaration:
Personal data
Personal data is any information relating to an identified or identifiable natural person. 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Data subject
Data subject is any identified or identifiable natural person whose personal data is processed by the controller (our company).
Processing
Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
Profiling
Profiling is any type of automated processing of personal data that consists of using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s job performance, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
Pseudonymization
Pseudonymization is 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 use of additional information, provided that such additional information is kept separate and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
Processor
Processor means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the Controller.
Recipient
Recipient means a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. However, public authorities that may receive personal data in the context of a specific investigation mandate under Union or Member State law are not considered recipients.
Third Party
Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons authorized to process the personal data under the direct responsibility of the controller or the processor.
Consent
Consent is any expression of will in the form of a declaration or other unambiguous affirmative action made voluntarily by the data subject for the specific case in an informed manner and in an unambiguous manner, by which the data subject indicates that he or she consents to the processing of personal data relating to him or her.
5. LEGAL BASIS OF PROCESSING
Art. 6 (1) lit. a DS-GVO (in conjunction with Section 15 (3) TMG) serves as the legal basis for our company for processing operations in which we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for a delivery of goods or the provision of another service or consideration, the processing is based on Article 6 (1) lit. b DS-GVO. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services.
If our company is subject to a legal obligation by which a processing of personal data becomes necessary, such as for the fulfillment of tax obligations, the processing is based on Art. 6 (1) lit. c DS-GVO.
In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result his or her name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 (1) lit. d DS-GVO.
Finally, processing operations could be based on Art. 6(1)(f) DS-GVO. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if you are a customer of our company (recital 47 sentence 2 DS-GVO).
6. TRANSFER OF DATA TO THIRD PARTIES
We do not transfer your personal data to third parties for purposes other than those listed below.
We will only pass on your personal data to third parties if:
1. you have given your express consent to do so in accordance with Art. 6 (1) p. 1 lit. a DS-GVO,
2. the disclosure is permissible under Art. 6 (1) p. 1 lit. f DS-GVO to protect our legitimate interests and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
3. in the event that a legal obligation exists for the disclosure pursuant to Art. 6 (1) sentence 1 lit. c DS-GVO, and
4. this is legally permissible and necessary according to Art. 6 para. 1 p. 1 lit. b DS-GVO for the processing of contractual relationships with you.
In order to protect your data and to allow us to transfer data to third countries (outside the EU/EEA) if necessary, we have concluded commissioned processing agreements based on the standard contractual clauses of the European Commission.
7. TECHNICAL
7.1 SSL/TLS encryption
This site uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us as the operator. You can recognize an encrypted connection by the fact that there is a “https://” instead of a “http://” in the address line of the browser and by the lock symbol in your browser line.
We use this technology to protect your transmitted data.
7.2 Data collection when visiting the website
When you use our website for information purposes only, i.e. if you do not register or otherwise transmit information to us, we only collect data that your browser transmits to our server (in so-called “server log files”). Our website collects a series of general data and information with each call of a page by you or an automated system. This general data and information is stored in the server log files. The following can be recorded
(1) browser types and versions used,
(2) the operating system used by the accessing system,
(3) the website from which an accessing system arrives at our website (so-called referrer),
(4) the sub-websites that are accessed via an accessing system on our website,
(5) the date and time of an access to the Internet site,
(6) an abbreviated Internet protocol address (anonymized IP address),
(7) the Internet service provider of the accessing system.
When using this general data and information, we do not draw any conclusions about your person. Rather, this information is required in order to
(1) deliver the contents of our website correctly,
(2) optimize the content of our website and the advertising for it,
(3) ensure the long-term functionality of our IT systems and the technology of our website, and
(4) to provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack.
Therefore, the data and information collected is, on the one hand, statistically analyzed by us and, on the other hand, it is evaluated with the aim of increasing the data protection and data security of our enterprise so as to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from any personal data provided by a data subject.
The legal basis for the data processing is Art. 6 para. 1 p. 1 lit. f DS-GVO. Our legitimate interest follows from the purposes for data collection listed above.
8. COOKIES
8.1 General information about cookies
We use cookies on our website. These are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone or similar) when you visit our site.
In the cookie, information is stored that arises in each case in connection with the specific end device used. This does not mean, however, that we thereby gain direct knowledge of your identity.
The use of cookies serves on the one hand to make the use of our offer more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site.
In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your terminal device for a certain fixed period of time. If you visit our site again to use our services, it is automatically recognized that you have already been with us and which entries and settings you have made so that you do not have to enter them again.
On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you. These cookies enable us to automatically recognize that you have already been to our site when you visit it again. These cookies are automatically deleted after a defined period of time.
8.2 Legal basis for the use of cookies
The data processed by cookies, which are required for the proper functioning of the website, are thus necessary to protect our legitimate interests as well as those of third parties in accordance with Article 6 (1) sentence 1 lit. f DS-GVO.
For all other cookies, it applies that you have given your consent to this via our opt-in cookie banner within the meaning of Art. 6 (1) lit. a DS-GVO.
9. CONTENTS OF OUR WEBSITE
9.1 Data processing when opening a customer account and for the execution of a contract
Pursuant to Art. 6 (1) lit. b DS-GVO, personal data is collected and processed if you provide it to us for the execution of a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. Deletion of your customer account is possible at any time and can be done by sending a message to the above address of the person responsible. We store and use the data provided by you for the purpose of processing the contract. After complete processing of the contract or deletion of your customer account, your data will be blocked with regard to tax and commercial law retention periods and deleted after expiry of these periods, unless you have expressly consented to further use of your data or a legally permitted further use of data has been reserved on our part, about which we inform you accordingly below.
9.2 Contacting us / contact form
When contacting us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for contacting you and the associated technical administration. The legal basis for processing the data is our legitimate interest in responding to your request pursuant to Art. 6 (1) lit. f DS-GVO. If your contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b DS-GVO. Your data will be deleted after final processing of your request, this is the case if it can be inferred from the circumstances that the matter concerned has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.
9.3 Application management / job exchange
We collect and process the personal data of applicants. Corresponding data processing may also take place electronically, for example, when applicants submit application documents to us by e-mail or via a web form on our website. On our website, we offer you the opportunity to send us applications for advertised vacancies by e-mail.
Your data will also only be stored in an applicant database beyond the scope of the current application process if you have given us your separate consent to do so.
The processing of your data in connection with your application is carried out for the purpose of processing your application and deciding on the establishment of an employment relationship on the basis of § 26 BDSG. In the event that your application documents are forwarded to third parties, in particular to companies affiliated with us, and your data is stored beyond the current application process, the processing of your data is based on Art. 6 (1) sentence 1 lit. a DSGVO. There is no legal or contractual obligation to provide your data, but the processing of your application is not possible without the provision of the information.
We store the collected data for a period of six months from the date the position is filled.
10. NEWSLETTER DISPATCH
10.1 Newsletter dispatch to existing customers
If you have provided us with your e-mail address when purchasing goods or services, we reserve the right to regularly send you e-mail offers for similar goods or services to those already purchased from our range. In accordance with Section 7 (3) of the German Unfair Competition Act (UWG), we do not need to obtain your separate consent for this. In this respect, the data processing is carried out solely on the basis of our legitimate interest in personalized direct advertising in accordance with Art. 6 Para. 1 lit. f DS-GVO. If you have initially objected to the use of your e-mail address for this purpose, no e-mails will be sent by us. You are entitled to object to the use of your e-mail address for the aforementioned advertising purpose at any time with effect for the future by notifying the responsible person named at the beginning. For this, you will only incur transmission costs according to the prime rates. After receipt of your objection, the use of your e-mail address for advertising purposes will cease immediately.
10.2 Advertising newsletter
On our website, you are given the opportunity to subscribe to our company’s newsletter. Which personal data are transmitted to us when ordering the newsletter, results from the input mask used for this purpose.
We inform our customers and business partners at regular intervals by means of a newsletter about our offers. The newsletter of our company can only be received by you if
(1) you have a valid e-mail address and
(2) you have registered to receive the newsletter.
For legal reasons, a confirmation e-mail will be sent to the e-mail address you entered for the first time for the newsletter dispatch using the double opt-in procedure. This confirmation e-mail serves to verify whether you, as the owner of the e-mail address, have authorized the receipt of the newsletter.
When you register for the newsletter, we also store the IP address of the IT system used by you at the time of registration, as assigned by your Internet service provider (ISP), as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of your e-mail address at a later date and therefore serves our legal protection.
The personal data collected in the context of a registration for the newsletter is used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service or a related registration, as could be the case in the event of changes to the newsletter offer or changes in the technical circumstances. No personal data collected as part of the newsletter service will be passed on to third parties. The subscription to our newsletter can be cancelled by you at any time. The consent to the storage of personal data that you have given us for the newsletter dispatch can be revoked at any time. For the purpose of revoking the consent, you will find a corresponding link in each newsletter. Furthermore, it is also possible to unsubscribe from the newsletter mailing directly on our website at any time or to inform us of this in another way.
The legal basis for data processing for the purpose of sending the newsletter is Art. 6 (1) lit. a DS-GVO.
10.3 Microsoft Dynamics 365 Marketing
This website uses Microsoft Dynamics 365 Marketing to send newsletters. The provider is Microsoft Deutschland GmbH, Walter-Gropius-Straße 5, 80807 München.
Microsoft Dynamics 365 Marketing is a service with which, among other things, the sending of newsletters can be organized and analyzed. The data you enter for the purpose of receiving the newsletter is stored on Microsoft Deutschland GmbH servers in Europe.
If you do not want Microsoft Dynamics 365 Marketing to analyze your data, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in each newsletter message. Furthermore, you can also unsubscribe from the newsletter directly on the website.
You can revoke the consent you have given at any time. You can also prevent the processing at any time by unsubscribing from the newsletter. You can also prevent the storage of cookies by setting your web browser accordingly. You can also prevent the storage and transmission of personal data by deactivating JavaScript in your web browser or installing a JavaScript blocker (e.g. https://noscript.net or https://www.ghostery.com). We would like to point out that these measures may mean that not all functions of our website are available.
With the help of Microsoft Dynamics 365 Marketing, it is possible for us to analyze our newsletter campaigns. For example, we can see whether a newsletter message was opened and which links, if any, were clicked. In this way, we can determine, among other things, which links were clicked on particularly often.
In addition, we can see whether certain previously defined actions were performed after opening/clicking (conversion rate). For example, we can see whether you have made a purchase after clicking on the newsletter.
Microsoft Dynamics 365 Marketing also allows us to subdivide (“cluster”) newsletter recipients based on various categories. In doing so, newsletter recipients can be subdivided by age, gender or place of residence, for example. In this way, the newsletters can be better adapted to the respective target groups.
The data processing is based on your consent (Art. 6 para. 1 lit. a DS-GVO). You can revoke this consent at any time. The legality of the data processing operations already carried out remains unaffected by the revocation.
The data you provide for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers as well as from the servers of Microsoft Deutschland GmbH after you unsubscribe from the newsletter. Data that has been stored by us for other purposes (e.g. e-mail addresses for the member area) remains unaffected by this.
For more details, please refer to the privacy policy of Microsoft Deutschland GmbH.
Despite the data location chosen by us in Germany, a transmission of data to a Microsoft server in the USA, as well as the corresponding storage there, cannot be completely excluded. By agreeing to the use of this service, you also consent to the processing of your data in the USA in accordance with Art. 49 (1) lit. a DSGVO. Please take note of our notice (below under item 18.) regarding such data transfers.
11. OUR ACTIVITIES IN SOCIAL NETWORKS
We maintain so-called fan pages or accounts or channels on the networks mentioned below in order to provide you with information and offers also within social networks and to offer you further ways to contact us and to inform yourself about our offers. In the following, we inform you about which data we or the respective social network process from you in connection with the call and use of our fan pages/accounts.
Data that we process from you
If you wish to contact us via Messenger or via Direct Message via the respective social network, we generally process your user name via which you contact us and, if applicable, store further data provided by you insofar as this is necessary to process/respond to your request.
The legal basis is Art. 6 para. 1 sentence 1 f) DSGVO (processing is necessary to protect the legitimate interests of the controller).
(Static) usage data we receive from social networks.
We receive automatically provided statistics regarding our accounts via Insights functionalities. The statistics include, among other things, the total number of page views, likes, details on page activities and post interactions, reach, video views/views, and details on the proportion of men/women among our fans/followers.
The statistics only contain aggregated data that cannot be related to individual persons. You are not identifiable to us via this.
What data the social networks process from you
In order to view the content of our fan pages or accounts, you do not have to be a member of the respective social network and, to this extent, no user account for the respective social network is required.
Please note, however, that when you call up the respective social network, the social networks also collect and store data from website visitors without a user account (e.g. technical data in order to be able to display the website to you) and use cookies and similar technologies, over which we have no control. For details, please refer to the privacy policy of the respective social network (see the corresponding links above).
Insofar as you wish to interact with the content on our fan pages/accounts, e.g. comment on, share or like our postings/contributions and/or contact us via messenger functions, prior registration with the respective social network and the provision of personal data is required.
We have no influence on the data processing by the social networks within the scope of their use by you. To our knowledge, your data is stored and processed in particular in connection with the provision of the services of the respective social network, as well as for the analysis of user behavior (using cookies, pixels/web beacons and similar technologies), on the basis of which advertising based on your interests is played both within and outside the respective social network. It cannot be ruled out that your data will be stored by the social networks outside the EU/EEA and passed on to third parties.
Information on, among other things, the exact scope and purposes of the processing of your personal data, the storage period/deletion as well as guidelines on the use of cookies and similar technologies in the context of registration and use of the social networks can be found in the privacy policy/cookie policy of the social networks. There you will also find information on your rights and objection options.
11.1 Instagram
When you visit our Instagram page, Instagram collects, among other things, your IP address and other information that is present on your PC in the form of cookies. This information is used to provide us, as the operator of the Instagram pages, with statistical information about the use of the Instagram page. Instagram provides more detailed information on this under the following link: https://facebook.com/help/pages/insights.
By means of the transmitted statistical information, it is not possible for us to draw conclusions about individual users. We only use this information to respond to the interests of our users and to continuously improve our online presence and ensure its quality.
We collect your data via our fan page only to realize a possible provision for communication and interaction with us. This collection usually includes your name, message content, comment content, and the profile information you provide “publicly”.
The processing of your personal data for our above-mentioned purposes is based on our legitimate business and communicative interest in offering an information and communication channel pursuant to Art. 6 (1) f) DSGVO. Should you, as a user, have given your consent to the data processing vis-à-vis the respective provider of the social network, the legal basis of the processing extends to Art. 6 (1) a), Art. 7 DSGVO.
Due to the fact that the actual data processing is carried out by the provider of the social network, our access to your data is limited. Only the provider of the social network is authorized to fully access your data. Due to this, only the provider can directly take and implement appropriate measures to fulfill your user rights (information request, deletion request, objection, etc.). The assertion of corresponding rights is therefore most effective directly against the respective provider.
We are jointly responsible with Instagram for the personal content of the fan page. Data subject rights can be asserted with Facebook Ireland as well as with us.
The primary responsibility for the processing of Insights data lies with Instagram in accordance with the GDPR and Instagram fulfills all obligations under the GDPR with regard to the processing of Insights data, Facebook Ireland provides the essence of the Page Insights supplement to the data subjects.
We do not make any decisions regarding the processing of Insights data and all other information resulting from Art. 13 GDPR, including legal basis, identity of the controller and storage period of cookies on user devices.
Further information can be found directly at Instagram (Supplemental Agreement with Facebook): https://www.facebook.com/legal/terms/page_controller_addendum.
11.2 LinkedIn
LinkedIn is a social network of LinkedIn Inc. based in Sunnyvale, California, USA, which enables the creation of private as well as professional profiles of natural persons and company profiles. Users can maintain their existing contacts and make new ones within the social network. Businesses and other organizations can create profiles that upload photos and other company information to present themselves as employers and hire employees. Other LinkedIn users have access to this information and can write their own articles and share this content with others. The network’s focus is on professional exchanges on specialized topics with people who share the same professional interests.
When using or visiting the network, LinkedIn automatically collects data from users or visitors during the use or visit, such as username, job title and IP address. This is done with the help of various tracking technologies. LinkedIn provides benefits with information, offers and recommendations, among other things, based on the data collected in this way.
We collect your data via our company profile only to realize a possible provision for communication and interaction with us. This collection usually includes your name, message content, comment content, and the profile information you provide “publicly”.
The processing of your personal data for our above-mentioned purposes is based on our legitimate business and communicative interest in offering an information and communication channel pursuant to Art. 6 para. 1 f DSGVO. Should you as a user have given your consent to the data processing to the respective provider of the social network, the legal basis of the processing extends to Art. 6 para. 1 a, Art. 7 DSGVO.
Due to the fact that the actual data processing is carried out by the provider of the social network, our access to your data is limited. Only the provider of the social network is authorized to fully access your data. Due to this, only the provider can directly take and implement appropriate measures to fulfill your user rights (information request, deletion request, objection, etc.). The assertion of corresponding rights is therefore most effective directly against the respective provider.
We are jointly responsible with LinkedIn for the personal content of our company profile. Data subject rights can be asserted with LinkedIn Inc. as well as with us.
We do not make any decisions regarding the data collected on LinkedIn’s site using tracking technologies.
For more information on LinkedIn, please visit: https://about.linkedin.com.
For more information on LinkedIn’s privacy policy, please visit: https://www.linkedin.com/legal/privacy-policy.
Further information on storage duration/deletion as well as guidelines on the use of cookies and similar technologies in the context of registration and use at LinkedIn can be found at: https://de.linkedin.com/legal/cookie-policy?trk=homepage-basic_footer-cookie-policy.
11.3 Twitter
Twitter is a social network of Twitter Inc. based in San Francisco, California, USA, which enables the creation of private profiles of natural persons (Personal Account) as well as professional profiles (Professional Account) of natural persons and companies. Via Twitter, users can, among other things, compose short messages (so-called “tweets”), interact with the content of other users, e.g., compose so-called “retweets”, submit likes to posts, share posts and reply when other users mention or tag you in content.
When using or visiting the network and thus also when visiting our Twitter account, Twitter automatically collects data from the users or visitors, for example user name and IP address, during the use or visit. This is done with the help of tracking technologies, in particular using cookies. Twitter provides users with information, offers and recommendations, among other things, based on the data collected in this way. This information is used to provide us, as the operator of our Twitter site, with statistical information about the use of the Twitter site. You can find more information on this in Twitter’s privacy policy: https://twitter.com/privacy#twitter-privacy-1.
By means of the transmitted statistical information, it is not possible for us to draw conclusions about individual users. We only use this information to respond to the interests of our users and to continuously improve our online presence and ensure its quality.
We collect your data via our fan page only to realize a possible provision for communication and interaction with us. This collection usually includes your name, message content, comment content as well as the profile information provided by you “publicly”.
The processing of your personal data for our above-mentioned purposes is based on our legitimate business and communicative interest in offering an information and communication channel pursuant to Art. 6 para. 1 f DSGVO. Should you as a user have given your consent to the data processing to the respective provider of the social network, the legal basis of the processing extends to Art. 6 para. 1 a, Art. 7 DSGVO.
Due to the fact that the actual data processing is carried out by the provider of the social network, our access to your data is limited. Only the provider of the social network is authorized to fully access your data. Due to this, only the provider can directly take and implement appropriate measures to fulfill your user rights (information request, deletion request, objection, etc.). The assertion of corresponding rights is therefore most effective directly against the respective provider.
We are jointly responsible with Twitter for the personal content of the fan page. Data subject rights can be asserted with Twitter Inc. as well as with us.
The primary responsibility under the GDPR for the processing of insights data lies with Twitter and Twitter fulfills all obligations under the GDPR with regard to the processing of insights data. Twitter Inc. provides the substance of the Page Insights Supplement to data subjects.
We do not make any decisions regarding the processing of Insights data and storage duration of cookies on user devices.
For more information on, among other things, the exact scope and purposes of the processing of your personal data, storage duration/deletion, and guidelines on the use of cookies and similar technologies in the context of registration and use, please refer to Twitter’s Privacy Policy/Cookie Policy:
Privacy Policy: https://twitter.com/privacy#twitter-privacy-1
Cookie policy: https://help.twitter.com/rules-and-policies/twitter-cookies
11.4 XING
XING is a social network of New Work SE based in Hamburg, Germany, which enables the creation of private as well as professional profiles of natural persons and company profiles. Users can maintain their existing contacts and make new ones within the social network. Businesses and other organizations can create profiles that upload photos and other company information to present themselves as employers and recruit employees. Other XING users have access to this information and can write their own articles and share this content with others. The focus of the network is on professional exchange on specialist topics with people who share the same professional interests.
When using or visiting the network, XING or third parties engaged by XING automatically collect data from users or visitors during the use or visit, for example user name, job title and IP address. This is done with the help of various tracking technologies. XING provides benefits with information, offers and recommendations based on the data collected in this way, among other things.
We collect your data via our company profile only to realize a possible provision for communication and interaction with us. This collection usually includes your name, message content, comment content, and the profile information you provide “publicly”.
The processing of your personal data for our above-mentioned purposes is based on our legitimate business and communicative interest in offering an information and communication channel pursuant to Art. 6 para. 1 f DSGVO. If you, as a user, have given your consent to the data processing to the respective provider of the social network, the legal basis of the processing extends to Art. 6 (1) a, Art. 7 DSGVO.
Due to the fact that the actual data processing is carried out by the provider of the social network, our access to your data is limited. Only the provider of the social network is authorized to fully access your data. Due to this, only the provider can directly take and implement appropriate measures to fulfill your user rights (information request, deletion request, objection, etc.). The assertion of corresponding rights is therefore most effective directly against the respective provider.
Together with XING, we are responsible for the personal content of our company profile. Data subject rights can be asserted with New Work SE as well as with us.
We do not make any decisions regarding the data collected on the XING site using tracking technologies.
Further information on XING can be found at: https://corporate.xing.com/de/unternehmen/
Further information on data protection at XING can be found at: https://privacy.xing.com/de/datenschutzerklaerung.
12. WEB ANALYSIS
12.1 Matomo
We have integrated the Matomo component of the provider InnoCraft Ltd, 150 Willis St, 6011 Wellington, New Zealand, on this website. Matomo is a software tool for web analysis, i.e. for collecting, collating and evaluating data on the behavior of visitors to websites. Among other things, data is collected about the website from which a data subject has accessed a website (so-called referrer), which subpages of the website have been accessed or how often and for how long a subpage has been viewed. This is used to optimize the website and for cost-benefit analysis of Internet advertising.
The software is operated on the server of the controller, and the log files, which are sensitive under data protection law, are stored exclusively on this server.
Matomo sets a cookie on your IT system. The setting of the cookie enables us to analyze the use of our website. Each time one of the individual pages of this website is called up, the Internet browser on your IT system is automatically prompted by the Matomo component to transmit data to our server for the purpose of online analysis. As part of this technical procedure, we obtain knowledge of personal data, such as the IP address of the person concerned, which we use, among other things, to trace the origin of visitors and clicks.
By means of the cookie, personal information, for example the access time, the place from which an access originated and the frequency of visits to our website are stored. Each time you visit our website, this personal data, including the IP address of the Internet connection you are using, is transmitted to our server. This personal data is stored by us. We do not pass on this personal data to third parties.
You can prevent the setting of cookies by our website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting of the Internet browser used would also prevent Matomo from setting a cookie on your IT system. In addition, a cookie already set by Matomo can be deleted at any time via an Internet browser or other software programs.
Furthermore, you have the option to object to and prevent the collection of data generated by Matomo related to a use of this website. To do this, you must set an opt-out cookie. If your IT system is deleted, formatted or reinstalled at a later time, the data subject must set an opt-out cookie again. However, with the setting of the opt-out cookie, there is the possibility that our Internet pages are no longer fully usable for you.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 (1) lit. a DS-GVO.
Further information and the applicable data protection provisions of Matomo can be found at https://matomo.org/privacy/.
You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.
13. ADVERTISING
13.1 Google Ads (formerly AdWords)
Our website uses the functions of Google Ads, hereby we advertise for this website in Google search results, as well as on third-party websites. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). For this purpose, Google sets a cookie in the browser of your terminal device, which automatically enables interest-based advertising by means of a pseudonymous cookie ID and on the basis of the pages you visit.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 Para. 1 lit. a DS-GVO.
Further data processing only takes place if you have consented to Google linking your internet and app browsing history to your Google account and using information from your Google account to personalize ads you view on the web. In this case, if you are logged in to Google while visiting our website, Google uses your data together with Google Analytics data to create and define target group lists for cross-device remarketing. For this purpose, Google temporarily links your personal data with Google Analytics data to form target groups.
You can permanently disable the setting of cookies for ad targeting by downloading and installing the browser plug-in available at the following link: https://www.google.com/settings/ads/onweb/.
Alternatively, you can obtain information about the setting of cookies and make settings for this from the Digital Advertising Alliance at the Internet address www.aboutads.info. Finally, you can set your browser so that you are informed about the setting of cookies and decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general. If you do not accept cookies, the functionality of our website may be limited.
Further information and the data protection provisions regarding advertising and Google can be viewed here: https://www.google.com/policies/technologies/ads/
Your pseudonymized data may be transferred by Google to a server in the USA and stored there. By agreeing to the use of this service, you also consent to the processing of your data in the USA in accordance with Art. 49 (1) lit. a DSGVO. Please take note of our notice (below under item 18.) regarding such data transfers.
14. PLUGINS AND OTHER SERVICES
14.1 Google Maps
On our website, we use Google Maps (API) from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Maps is a web service for displaying interactive (land) maps to visually display geographical information. By using this service, our location can be displayed to you, for example, and a possible journey can be made easier.
Already when calling up those sub-pages in which the map of Google Maps is integrated, information about your use of our website (such as your IP address) is transmitted to Google servers in the USA and stored there. This occurs regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. If you do not want the assignment with your profile at Google, you must log out of your Google user account. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them. You have the right to object to the creation of these user profiles, and you must contact Google to exercise this right.
If you do not agree to the future transmission of your data to Google in the context of the use of Google Maps, you also have the option of completely disabling the Google Maps web service by turning off the JavaScript application in your browser. Google Maps and thus also the map display on this website can then not be used.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 (1) lit. a DS-GVO.
You can view Google’s terms of use at https://www.google.de/intl/de/policies/terms/regional.html, the additional terms of use for Google Maps can be found at https://www.google.com/intl/de_US/help/terms_maps.html.
Detailed information on data protection in connection with the use of Google Maps can be found on the Google website (“Google Privacy Policy”): https://www.google.de/intl/de/policies/privacy/
Your pseudonymized data may be transferred by Google to a server in the USA and stored there. By agreeing to the use of this service, you also consent to the processing of your data in the USA in accordance with Art. 49 (1) lit. a DSGVO. Please take note of our notice (below under item 18.) regarding such data transfers.
14.2 Vimeo (Videos)
Plugins of the video portal Vimeo of Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA are integrated on our website. When you call up a page of our website that contains such a plugin, your browser establishes a direct connection to the servers of Vimeo. The content of the plugin is transmitted by Vimeo directly to your browser and integrated into the page. Through this integration, Vimeo receives the information that your browser has accessed the corresponding page of our website, even if you do not have a Vimeo account or are not currently logged in to Vimeo. This information (including your IP address) is transmitted by your browser directly to a Vimeo server in the USA and stored there.
If you are logged in to Vimeo, Vimeo can directly assign your visit to our website to your Vimeo account. If you interact with the plugins (such as pressing the start button of a video), this information is also transmitted directly to a Vimeo server and stored there.
The described data processing operations are carried out in accordance with Art. 6 (1) lit. f DS-GVO on the basis of Vimeo’s legitimate interest in market research and the needs-based design of the service.
If you do not want Vimeo to assign the data collected via our website directly to your Vimeo account, you must log out of Vimeo before visiting our website.
For the purpose and scope of the data collection and the further processing and use of the data by Vimeo, as well as your rights in this regard and setting options for protecting your privacy, please refer to the privacy policy of Vimeo: https://vimeo.com/privacy.
For videos from Vimeo that are embedded on our site, the tracking tool Google Analytics is automatically integrated. This is Vimeo’s own tracking, to which we have no access and which cannot be influenced by our site. Google Analytics uses so-called “cookies” for tracking, which are text files that are stored on your computer and allow an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 Para. 1 lit. a DS-GVO.
Your data may be transferred by Vimeo to a server in the USA and stored there. By agreeing to the use of this service, you also consent to the processing of your data in the USA in accordance with Art. 49 (1) lit. a DSGVO. Please take note of our notice (below under item 18.) regarding such data transfers.
14.3 YouTube (videos)
We have integrated YouTube components on this website. YouTube is an Internet video portal that allows video publishers to post video clips free of charge and other users to view, rate and comment on them, also free of charge. YouTube allows the publication of all types of videos, which is why complete film and TV shows, but also music videos, trailers or videos made by users themselves can be accessed via the Internet portal.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. YouTube, LLC is a subsidiary of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Each time you call up one of the individual pages of this website that is operated by us and on which a YouTube component (YouTube video) has been integrated, the Internet browser on your IT system is automatically prompted by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. Further information on YouTube can be found at https://www.youtube.com/yt/about/de/. Within the scope of this technical procedure, YouTube and Google receive knowledge of which specific sub-page of our website is visited by you.
If the data subject is logged into YouTube at the same time, YouTube recognizes which specific sub-page of our website you are visiting when you call up a sub-page that contains a YouTube video. This information is collected by YouTube and Google and assigned to your YouTube account.
YouTube and Google always receive information via the YouTube component that you have visited our website if you are logged into YouTube at the same time as calling up our website; this takes place regardless of whether you click on a YouTube video or not. If you do not want this information to be transmitted to YouTube and Google, you can prevent the transmission by logging out of your YouTube account before accessing our website.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 (1) lit. a DS-GVO.
The privacy policy published by YouTube, which is available at https://www.google.de/intl/de/policies/privacy/, provides information about the collection, processing and use of personal data by YouTube and Google.
Your pseudonymized data may be transferred by Google and Youtube to a server in the USA and stored there. By agreeing to the use of this service, you also consent to the processing of your data in the USA in accordance with Art. 49 (1) lit. a DSGVO. Please take note of our notice (below under item 18.) regarding such data transfers.
14.3 Blis-Online
We operate a management platform for commercial locations via the tool or website “blis-online” or “GeoDok”. The service is operated by GeoDok GmbH, Jülicher Str. 9, 33613 Bielefeld. There is an order processing relationship with GeoDok GmbH within the meaning of the DSGVO. Data that is collected via this service and transmitted to us or made available for inspection is used by us to process your request, i.e. to contact you, to possibly put you in touch with the landlord, as well as in the context of a possible (pre-)contractual data collection and processing. The data processing is therefore initially carried out on the basis of legitimate interest within the meaning of Art. 6 (1) f) DSGVO, whereby we assume that the interest on our part carried out with the platform outweighs your interest in avoiding data processing due to the contact initiated by you, and in the case of (pre-)contractual measures within the meaning of At. 6 (1) b) DSGVO. Data taken from any real estate platforms follow from the use of an API provided by the real estate platform; the provider of the real estate platform is therefore responsible for the provision of data via the API in terms of data protection law. The use by us is based on an existing contract with the respective real estate platform (Art. 6 para. 1 b) DSGVO) or on the basis of legitimate interest (Art. 6 para. 1 f) DSGVO).
15. YOUR RIGHTS AS A DATA SUBJECT
15.1 Right to confirmation
You have the right to request confirmation from us as to whether personal data concerning you is being processed.
15.2 Right to information Art. 15 DS-GVO
You have the right to obtain from us, at any time and free of charge, information about the personal data stored about you, as well as a copy of this data in accordance with the legal provisions.
15.3 Right to rectification Art. 16 DS-GVO
You have the right to demand that incorrect personal data concerning you be corrected. Furthermore, you have the right to request the completion of incomplete personal data, taking into account the purposes of the processing.
15.4 Deletion Art. 17 DS-GVO
You have the right to demand that we delete the personal data concerning you without undue delay, provided that one of the reasons provided for by law applies and to the extent that the processing or storage is not necessary.
15.5 Restriction of processing Art. 18 DS-GVO
You have the right to demand that we restrict processing if one of the legal requirements applies.
15.6 Data portability Art. 20 DS-GVO
You have the right to receive the personal data concerning you, which has been provided to us by you, in a structured, common and machine-readable format. You also have the right to transfer this data to another controller without hindrance from us to whom the personal data has been provided, provided that the processing is based on consent pursuant to Art. 6(1)(a) DS-GVO or Art. 9(2)(a) DS-GVO or on a contract pursuant to Art. 6(1)(b) DS-GVO and the processing is carried out with the aid of automated procedures, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
Furthermore, when exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to have the personal data transferred directly from one controller to another controller, to the extent that this is technically feasible and provided that this does not adversely affect the rights and freedoms of other individuals.
15.7 Objection Art. 21 DS-GVO
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6(1)(e) (data processing in the public interest) or (f) (data processing on the basis of a balance of interests) DS-GVO.
This also applies to profiling based on these provisions within the meaning of Art. 4 No. 4 DS-GVO.
If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
In individual cases, we process personal data to conduct direct marketing. You may object to the processing of personal data for the purpose of such advertising at any time. This also applies to profiling, insofar as it is related to such direct advertising. If you object to us processing for direct marketing purposes, we will no longer process the personal data for these purposes.
In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you which is carried out by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the DS-GVO, unless such processing is necessary for the performance of a task carried out in the public interest.
You are free to exercise your right to object by means of automated procedures using technical specifications in connection with the use of information society services, notwithstanding Directive 2002/58/EC.
15.8 Revocation of consent under data protection law
You have the right to revoke consent to the processing of personal data at any time with effect for the future.
15.9 Complaint to a supervisory authority
You have the right to complain about our processing of personal data to a supervisory authority responsible for data protection.
16. ROUTINE STORAGE, DELETION AND BLOCKING OF PERSONAL DATA
We process and store your personal data only for the period of time required to achieve the purpose of storage or if this has been provided for by the legal provisions to which our company is subject.
If the storage purpose ceases to apply or if a prescribed storage period expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.
17. DURATION OF STORAGE OF PERSONAL DATA
The criterion for the duration of storage of personal data is the respective statutory retention period. After expiration of the period, the corresponding data is routinely deleted, provided that it is no longer required for the fulfillment or initiation of the contract.
18. DATA PROCESSING IN THIRD COUNTRIES
Some of the services we use (see corresponding notes at the providers / services) may also process data in the USA. The USA is considered by the ECJ to be a country with an insufficient level of data protection according to EU standards. In particular, there is a risk that your data may be processed by US authorities for control and monitoring purposes – possibly without the possibility of legal recourse. In this regard, we inform you that all necessary and required measures have been taken to sufficiently document data protection and to ensure the highest possible level of security for these transfers to the USA. For this purpose, not only were the necessary AV contracts concluded and the applicability of the EU standard contractual clauses agreed upon. Separate guarantees for data security were also agreed with the providers. We documented all measures and subjected them to a risk assessment and a data privacy impact assessment.
19. GENERAL INFORMATION FOR DATA PROCESSING OUTSIDE OUR WEBSITE
Contact / Visitors
You can get in touch with us. The data processed for this purpose (e.g. e-mail data, your name) are necessary to enable communication and to process your request. Further data you provide us with facilitate a personal approach or a better or faster processing.
These processing operations are based on Art. 6 (1) lit. b DSGVO, insofar as this is necessary for the initiation or execution of a contract. Otherwise, the processing is based on our legitimate interest pursuant to Art. 6 (1) lit. f DSGVO. Our legitimate interest is to respond to your request.
Suppliers, service providers & business partners
We use contact and communication data and other relevant personal data from our suppliers, service providers and business partners, insofar as they or their employees are natural persons. We process this data to carry out the business relationship, communication as well as contact maintenance. The provision of data is regularly required for the initiation, execution and billing of contracts, otherwise a contract cannot be concluded.
The processing is based on Art. 6 para. 1 lit. b DSGVO, insofar as this is necessary for the initiation or execution of a contract. As far as it does not concern the initiation or performance of a contract, the processing operations are based on our legitimate interest according to Art. 6 (1) lit. f DSGVO. Our legitimate interest is the processing of business cooperation and contact maintenance.
The storage period is based on the general statute of limitations or the tax retention obligations.
Applications
You can apply to us by sending us your documents. We process the personal data provided in this context exclusively for the purpose of processing your application. The processing is necessary to initiate an employment relationship, furthermore, to enable the related communication and to process your request.
In individual cases, we process – to the extent necessary for the initiation of the employment relationship – personal data that we have permissibly received from third parties (e.g. recruiters) or obtained from publicly accessible sources (e.g. social networks or Internet search engines).
These processing operations are based on Art. 6 para. 1 lit. b DSGVO in conjunction with. § Section 26 (1) BDSG.
We regularly store this data for a period of up to 6 months after completion of the application process. Any storage beyond this period will only take place if you have expressly consented to this in accordance with Art. 6 Para. 1 lit. a DSGVO.
There is no legal or contractual obligation to provide your data, but the processing of your application is not possible without the provision of the information.
Recipients of the above data
As part of our above activities, we work with service providers, partners, government agencies and other third parties who may receive personal data, including, but not limited to:
– Service providers for hosting services
– IT and telecommunications service providers
– Logistics and delivery service providers
– Service providers for file storage and disposal
– Authorities and institutions
We only transfer your data to these recipients if this is necessary to fulfill a contract with you, if we are subject to a legal obligation to do so, or if we have a legitimate interest in transferring your data. The legitimate interest may consist primarily in the maintenance of the company organization or in the assertion, exercise or defense of legal claims. If you have any further questions, please contact our data protection officer.
As a matter of principle, we do not pass on any personal data to recipients who have their registered office outside the EEA in so-called third countries. Should such transfers take place in individual cases, we ensure a secure level of protection in accordance with Chapter 5 of the GDPR by, among other things, concluding the contract supplements currently recommended by the authorities and by agreeing on special protection mechanisms for your data; such data processing and its effects are documented and regularly subjected to a risk assessment.
Storage period
If we store your personal data, this will only be for a limited period of time and no longer than necessary. In principle, we delete your data when it is no longer necessary for the processing purpose for which it was collected or there are other legal reasons that require deletion.
Insofar as we are subject to legal retention obligations that require longer retention, we store the data for this period, in particular to comply with retention periods under commercial and tax law, which are between 2 and 10 years.
Other legal reasons for retention may be that we must retain data for evidentiary purposes for the duration of the applicable statute of limitations. These periods generally range from 2 to 30 years.
If you have any further questions, please contact our data protection officer.
Obligation to provide
Insofar as the personal data is required for the establishment and implementation of the contractual relationship and the associated contractual or legal obligations, this data must be provided by you so that we can meet our performance obligations or legal obligations. Without the provision of the data, we may no longer be able to provide the service, not properly or not completely.
20. UPDATE AND AMENDMENT OF THE DATA PROTECTION DECLARATION
This privacy policy is currently valid and has the status: May 2023.
Due to the further development of our Internet pages and offers or due to changed legal or official requirements, it may become necessary to change this data protection declaration. You can access and print out the current data protection declaration at any time on the website at “https://www.ewg.de/ewg_1/datenschutz_2/ewg_datenschutz.de.html”.