Privacy policy
Privacy policy
Here you can learn how eyepin processes personal data, what information is collected, and what rights you have in relation to your data.
The protection of personal data is of particularly high importance to the management of eyepin GmbH, hereinafter referred to as “eyepin.” The use of the eyepin websites is generally possible without providing any personal data. However, if an individual or a company wishes to use special services provided by our company, the processing of personal data may become necessary. If the processing of personal data is required and there is no legal basis for such processing, we will generally obtain the consent of the data subject.
The processing of personal data—such as the name, address, email address, or telephone number of a data subject—is always carried out in accordance with the General Data Protection Regulation (GDPR) and in compliance with the country-specific data protection regulations applicable to eyepin GmbH. With this privacy policy, eyepin GmbH informs the public about the type, scope, and purpose of the personal data we collect, use, and process. Furthermore, this privacy policy informs data subjects of their rights.
As the data controller, eyepin GmbH has implemented numerous technical and organizational measures to ensure the most complete protection possible of personal data processed through this website. However, internet-based data transmissions can fundamentally have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us via alternative means, for example by telephone.
Personal data received from customers is used solely for administrative purposes and to provide the agreed services. eyepin does not use this data for its own purposes, nor is it passed on to third parties.
This privacy policy is based on the terminology used by the European legislator when enacting the General Data Protection Regulation (GDPR). Our policy is intended to be easily readable and understandable for the public, our customers, and our business partners. To ensure this, we would like to explain the terms used in advance.
This privacy policy uses the following terms:
a) Personal data: Personal data refers to any information relating to an identified or identifiable natural person (“data subject”). A person is considered identifiable if they can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more specific characteristics expressing the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
b) Data subject: A data subject is any identified or identifiable natural person whose personal data is processed by the controller.
c) Processing: Processing is any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
d) Restriction of processing: Restriction of processing means the marking of stored personal data with the aim of limiting its future processing.
e) Profiling: Profiling refers to any form of automated processing of personal data consisting of the use of such data to evaluate certain personal aspects relating to a natural person—particularly to analyze or predict aspects concerning that person’s job performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
f) Pseudonymization: Pseudonymization is the processing of personal data in such a way that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
g) Controller or data controller: The controller is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
h) Processor: A processor is a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.
i) Recipient: A recipient is a natural or legal person, public authority, agency, or other body to whom personal data is disclosed, whether or not they are a third party. However, authorities that may receive personal data in the framework of a particular inquiry under Union or Member State law shall not be regarded as recipients.
j) Third party: A third party is a natural or legal person, public authority, agency, or body other than the data subject, the controller, the processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
k) Consent: Consent is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.
For Germany and internationally (excluding Austria):
eyepin GmbH
Bornholmer Str. 91
10439 Berlin
Germany
Phone: +49 30 1388 288-0
Email: info@eyepin.com
Website: www.eyepin.com
For Austria:
eyepin GmbH
Billrothstraße 52
1190 Vienna
Austria
Phone: +43 1 961 7777-0
Email: office@eyepin.com
Website: www.eyepin.com
The data protection officer of the controller is:
Christian Bader
Email: dataprotection-officer@eyepin.com
Phone Germany/Int.: +49 30 1388 288-405
Phone Austria: +43 1 961 7777-405
Any data subject may contact our data protection officer directly at any time with any questions or suggestions regarding data protection.
The websites of eyepin use cookies. Cookies are text files that are stored on a computer system via an internet browser.
Many websites and servers use cookies. Many cookies contain what is called a cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain different cookies. A specific internet browser can be recognized and identified using the unique cookie ID.
By using cookies, eyepin can provide users of this website with more user-friendly services that would not be possible without the cookie setting.
Using cookies, the information and offers on our website can be optimized with the user in mind. Cookies enable us, as mentioned, to recognize the users of our website. The purpose of this recognition is to make it easier for users to utilize our website. For example, users of a site that uses cookies do not have to enter their access data again each time they visit the site because this is handled by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online store. The online store remembers the items that a customer has placed in the virtual shopping cart via a cookie.
The data subject can, at any time, prevent the setting of cookies by our website by means of a corresponding setting of the internet browser used and can thus permanently deny the setting of cookies. Furthermore, already set cookies can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.
The website of eyepin collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, eyepin does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, eyepin analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller and for his own purposes. The controller may request transfer to one or more processors (e.g., a parcel service), who also uses the personal data exclusively for an internal use which is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of these data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of these data is necessary to secure the controller. These data are not passed on to third parties unless there is a statutory obligation to pass on the data or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time or to have them completely deleted from the data stock of the controller.
The controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees is available to the data subject in this respect as contact persons.
a) Intended Users and Access
The eyepin app is intended exclusively for eyepin’s business customers and their authorised employees and other authorised users. It is not intended for direct use by consumers or event participants.
Use of the app requires an existing eyepin account and the appropriate access authorisation for the eyepin Marketing Platform. The app can only be used if the mobile device has previously been authenticated via the Marketing Platform, assigned to a specific user account (“pairing”), and approved for use.
Each approved device is assigned to a dedicated user of the Marketing Platform. The app can only be used for as long as the device remains approved in the Marketing Platform. If an authorised administrator revokes the approval, the device will no longer be able to access the functions and data provided through the app.
b) Processing of App User Data
When the app is activated and used, the following categories of personal data may be processed in particular:
The data is processed to associate the device with an authorised user, secure access to the app, enforce roles and permissions, provide the agreed app functions, analyse errors, and prevent misuse or unauthorised access.
Where the app user is a party to a contract with eyepin, processing necessary for these purposes is based on Article 6(1)(b) GDPR. Where the app is used by employees or other representatives of a business customer, processing is based on Article 6(1)(f) GDPR. The legitimate interests of eyepin and the relevant business customer consist of the secure and contractually compliant provision and use of the eyepin Marketing Platform and the associated app functions. Where applicable, the relevant national provisions governing the processing of employee data may also apply.
Account and pairing data required for access is generally stored for the duration of the device approval or the existence of the user account. Log and security data is stored for [insert specific retention period], unless a longer retention period is required to investigate a security incident, establish, exercise, or defend legal claims, or comply with statutory obligations.
c) Device Authentication and Pairing
Access to the app is protected by a device-based authentication and pairing procedure. In addition to a valid eyepin user account, a mobile device is required that has previously been authenticated in the Marketing Platform, assigned to the user account, and approved for use.
During the pairing process, the technical identifiers required to associate and approve the device are processed together with the relevant user, the approval status, and the associated timestamps.
Pairing serves to protect user accounts, participant and campaign data, and eyepin’s systems against unauthorised access. Processing is carried out for the performance of contractual obligations pursuant to Article 6(1)(b) GDPR or on the basis of legitimate interests pursuant to Article 6(1)(f) GDPR. The legitimate interest consists of maintaining an appropriate level of security and preventing unauthorised or improper access.
Administrators of the relevant business customer can revoke a device’s approval through the Marketing Platform. Once approval has been revoked, the app can no longer be used on that device.
d) Event Admission and Ticket Validation
The app may be used by business customers for admission and ticket validation at events. For this purpose, the QR code or barcode shown on an admission document, invitation, or ticket is captured using the mobile device’s camera and checked against the participant data provided for the relevant event.
Depending on the design of the event, the following data may be processed in particular:
The camera is used exclusively to capture the QR code or barcode. No camera images, photographs, or video recordings are stored on eyepin’s systems during this process.
The relevant event organiser or business customer generally determines the purposes and essential means of processing participant data. It is the controller responsible for the processing and determines, in particular, the permitted data fields, the legal basis, the authorised users, and the applicable retention period.
When providing the Marketing Platform and app, eyepin generally processes participant data as a processor acting on the business customer’s documented instructions. For this purpose, eyepin and the business customer enter into a data processing agreement in accordance with Article 28 GDPR.
Information about the specific processing of participant data, the applicable legal basis, and the rights of affected participants can be found in the privacy policy or privacy notice of the relevant event organiser. Data subjects should generally exercise their rights regarding this data against the relevant event organiser. Within the scope of the applicable statutory and contractual requirements, eyepin assists the event organiser in responding to such requests.
e) Local Storage of Participant Data
For the purpose of conducting admission checks, the participant lists selected by the business customer are stored locally on the approved mobile device. Local storage makes it possible, in particular, to use the participant lists and record admission status in connection with the event.
As the mobile devices are within the control and responsibility of the relevant business customer, the customer is responsible for implementing appropriate technical and organisational measures to protect the locally stored data. These measures include in particular:
The business customer decides on which mobile devices the app is installed and used and where those devices are taken. The business customer is therefore also responsible for ensuring that personal data stored on mobile devices is not unlawfully transferred to countries outside the European Union or the European Economic Area. This applies in particular where a device is taken to or used in a third country or where locally stored data may be transferred to device, operating system, or cloud backups.
[To be specified: the time or procedure by which locally stored participant lists are deleted from the app, for example manually, following revocation of the device approval, or after a defined period.]
f) Display of Campaign, Reporting, and Platform Information
Authorised users can use the app to access current information from the eyepin Marketing Platform. This includes, in particular, campaign status, sending and delivery information, opens, clicks, registrations, participant numbers, and other campaign or event reports.
The reports may contain personal information relating to individual data subjects. Depending on the relevant campaign, this may include in particular:
the name and contact details of a recipient or participant;
Where the reports displayed contain personal data relating to recipients, prospective customers, event participants, or other contacts of the business customer, eyepin generally processes this data on behalf of the relevant business customer. The business customer determines the purposes and legal bases of the processing, the data entered into the platform, the retention period, and the users who are granted access to personal information relating to individual data subjects.
Information is displayed in the app in accordance with the roles and permissions configured for the relevant user account. The business customer is responsible for limiting access to personal information relating to individual data subjects to persons who require such information for their respective duties.
Where report data is cached or otherwise stored locally on the mobile device, the requirements concerning device security, deletion, and third-country transfers described in section e) apply accordingly.
The app does not use the displayed reports to make decisions based solely on automated processing that produce legal effects concerning data subjects or similarly significantly affect them. [Include only if this accurately reflects the app’s functionality.]
g) Device Permissions
The app requires access to the mobile device’s camera for admission and ticket validation. The camera is only used when the user activates the relevant function and grants the required device permission.
Camera permission can be managed and revoked through the device settings. If permission is not granted or is subsequently revoked, the scanning function cannot be used.
Other device permissions are requested only where they are required for a function activated by the user.
[Add where applicable: notifications, local storage, files, photos, Bluetooth, location, biometric unlocking, or other device functions.]
h) Recipients and Service Providers
Within eyepin, access to personal data is limited to employees who require it to provide, secure, maintain, or support the app.
Carefully selected service providers, particularly providers of hosting, infrastructure, support, or error analysis services, may be used for the technical provision of the app. Where these service providers process personal data on eyepin’s behalf, they are contractually bound in accordance with Article 28 GDPR.
[Add the service providers actually used, including any providers of hosting, analytics, crash reporting, or notification services.]
eyepin transfers personal data to recipients outside the European Union or the European Economic Area only where the applicable legal requirements are met. This does not apply to a third-country transfer that arises solely because the business customer uses or takes a mobile device under its control outside the European Union or the European Economic Area.
i) Data Security
eyepin implements appropriate technical and organisational measures to protect personal data processed through the Marketing Platform and the app against loss, manipulation, and unauthorised access. These measures include, in particular, device-based pairing, the assignment of each device to a dedicated user, the central approval and blocking of devices, and role-based access controls.
The relevant business customer is responsible for the security of the mobile device and the data stored locally on it. App users must keep their access credentials confidential, protect the device against access by unauthorised persons, and immediately report any loss or suspected misuse to the responsible administrator. Where necessary, the administrator must revoke the approval of the affected device without delay.
j) No Use for eyepin’s Own Advertising Purposes
eyepin does not use personal participant, recipient, campaign, or report data processed through the app on behalf of a business customer for its own advertising or marketing purposes. Such data is disclosed only in accordance with the business customer’s documented instructions, for the contractual involvement of processors, or where disclosure is required by law.
On the website of eyepin GmbH, users are given the opportunity to subscribe to the newsletter of our company. The input mask used for this purpose determines what personal data are transmitted to the controller when the newsletter is ordered.
Eyepin GmbH informs its customers and business partners regularly by means of a newsletter about company offers, technical updates, and general marketing information of interest. The newsletter of our company may only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter. A confirmation email will be sent to the email address registered by a data subject for the first time for newsletter delivery, for legal reasons, in the double opt-in procedure. This confirmation email is used to prove whether the owner of the email address as the data subject is authorized to receive the newsletter.
When registering for the newsletter, we also store the IP address of the computer system assigned by the internet service provider (ISP) and used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary to understand the (possible) misuse of the email address of a data subject at a later date and therefore serves the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by email if this is necessary for the operation of the newsletter service or a registration in question, as could be the case in the event of changes to the newsletter offer or technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for sending the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller or to communicate this to the controller in a different way.
The newsletters of eyepin GmbH contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails that are sent in HTML format to enable log file recording and log file analysis. This allows statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, eyepin GmbH can see if and when an email was opened by a data subject and which links in the email were accessed by data subjects.
Such personal data collected via the tracking pixels in the newsletters are stored and analyzed by the controller in order to optimize the newsletter delivery and to adapt the content of future newsletters even better to the interests of the data subject. These personal data are not disclosed to third parties. Data subjects are entitled at any time to revoke the respective separate declaration of consent issued via the double opt-in procedure. After a revocation, these personal data will be deleted. eyepin automatically regards a withdrawal from the receipt of the newsletter as a revocation.
For selecting appropriate content in the email newsletters offered by eyepin, automated decision-making or profiling is used in some areas. This serves to deliver relevant content.
The website of eyepin GmbH contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (email address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed.
b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European legislator grants the data subject access to the following information:
The data subject shall also have the right to know whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by eyepin GmbH, he or she may, at any time, contact any employee of the controller. An employee of eyepin GmbH shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, eyepin GmbH, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of eyepin GmbH will arrange the necessary measures in individual cases.
e) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by eyepin GmbH, he or she may at any time contact any employee of the controller. The employee of eyepin GmbH will arrange the restriction of the processing.
f) Right to data portability
Each data subject shall have the right granted by the European legislator to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may at any time contact any employee of eyepin GmbH.
g) Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
Eyepin GmbH shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If eyepin GmbH processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to eyepin GmbH to the processing for direct marketing purposes, eyepin GmbH will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by eyepin GmbH for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the data subject may contact any employee of eyepin GmbH. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, eyepin GmbH shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time contact any employee of the controller.
i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time contact any employee of the controller.
The controller shall collect and process the personal data of applicants for the purpose of processing the application procedure. The processing may also be carried out electronically. This is particularly the case if an applicant submits corresponding application documents by email or via a web form on the website to the controller. If the controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Another legitimate interest in this respect could be, for example, a burden of proof in a procedure under the General Equal Treatment Act (AGG).
The controller has integrated components of the company Facebook on this website. Facebook is a social network.
A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a data subject lives outside the USA or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Facebook component (Facebook plug-ins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component. An overview of all the Facebook plug-ins may be accessed under https://developers.facebook.com/docs/plugins/. During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.
If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific sub-site of our website was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.
Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.
The data protection guideline published by Facebook, which is available at https://de-de.facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. In addition, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.
The controller has integrated the component of Google Analytics (with the anonymizer function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which subpages were visited, or how often and for what duration a subpage was viewed. Web analytics are mainly used for the optimization of a website and to carry out a cost-benefit analysis of Internet advertising.
The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
For the web analytics through Google Analytics, the controller uses the application “_gat._anonymizeIp”. By means of this application, the IP address of the Internet connection of the data subject is abridged by Google and anonymized when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google.
During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently make commission settlements possible.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google, and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through JavaScript that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.de/intl/de/policies/privacy/ and under https://www.google.com/analytics/terms/de.html. Google Analytics is further explained under the following Link: https://www.google.com/intl/de_de/analytics/.
The controller has integrated components of the LinkedIn Corporation on this website. LinkedIn is an Internet-based social network that enables users to connect with existing business contacts and to make new business contacts. More than 400 million registered people use LinkedIn in over 200 countries. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.
The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA. For data protection issues outside the USA, LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.
With each visit to one of the individual pages of this website operated by the controller and into which a LinkedIn component (LinkedIn plug-in) is integrated, the web browser on the IT system of the data subject is automatically prompted to download a display of the corresponding LinkedIn component from LinkedIn. More information about the LinkedIn plug-ins can be found at https://developer.linkedin.com/plugins. As part of this technical procedure, LinkedIn is informed about which specific subpage of our website was visited by the data subject.
If the data subject is logged in at LinkedIn at the same time, LinkedIn detects with each visit to our website by the data subject—and for the entire duration of their stay on our website—which specific subpage of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.
LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in at LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn component or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then they may prevent this by logging off from their LinkedIn account before accessing our website.
LinkedIn provides the option to unsubscribe from email messages, SMS messages, and targeted ads, as well as to manage ad settings at https://www.linkedin.com/psettings/guest-controls. LinkedIn also partners with providers such as Quantcast, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame, which may set cookies. These cookies can be rejected at https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy of LinkedIn is available at https://www.linkedin.com/legal/privacy-policy. The LinkedIn cookie policy is available at https://www.linkedin.com/legal/cookie-policy.
The controller has integrated components from Xing on this website. Xing is an Internet-based social network that enables users to connect with existing business contacts and to establish new business connections. Individual users can create a personal profile on Xing. Companies, for example, can create company profiles or publish job offers on Xing.
The operating company of Xing is XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.
Each time one of the individual pages of this website, operated by the controller and on which a Xing component (Xing plug-in) has been integrated, is accessed, the web browser on the IT system of the data subject is automatically prompted to download a display of the corresponding Xing component from Xing. More information about the Xing plug-ins can be accessed at https://dev.xing.com/plugins. As part of this technical process, Xing is informed about which specific subpage of our website was visited by the data subject.
If the data subject is logged in at Xing at the same time, Xing detects with each visit to our website by the data subject—and for the entire duration of their stay on our Internet site—which specific subpage was visited by the data subject. This information is collected through the Xing component and associated with the respective Xing account of the data subject. If the data subject clicks on one of the Xing buttons integrated on our website, for example the “Share” button, Xing matches this information with the personal Xing user account of the data subject and stores the personal data.
Xing receives information via the Xing component that the data subject has visited our website, provided that the data subject is logged in at Xing at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Xing component or not. If such a transmission of information to Xing is not desirable for the data subject, then they may prevent this by logging off from their Xing account before accessing our website.
The data protection policy published by Xing, which is available at https://www.xing.com/privacy, provides information about the collection, processing, and use of personal data by Xing. Furthermore, Xing has published data protection notices for the XING Share button at https://www.xing.com/app/share.
The controller has integrated components of YouTube on this website. YouTube is an Internet video portal that allows video publishers to upload 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 kinds of videos, so you can access both full movies and TV shows, as well as music videos, trailers, or user-created videos 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 Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
Each time one of the individual pages of this website, operated by the controller and on which a YouTube component (YouTube video) has been integrated, is accessed, the web browser on the IT system of the data subject is automatically prompted to download a display of the corresponding YouTube component from YouTube. More information about YouTube may be retrieved under https://www.youtube.com/yt/about/de/. As part of this technical process, YouTube and Google are informed about which specific subpage of our website was visited by the data subject.
If the data subject is logged in on YouTube at the same time, YouTube recognizes with each visit to a subpage that contains a YouTube video, which specific subpage of our website was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.
YouTube and Google receive information via the YouTube component that the data subject has visited our website, provided that the data subject is logged in on YouTube at the time of the call-up to our website. This occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of information to YouTube and Google is not desirable for the data subject, they may prevent this by logging off from their YouTube account before accessing our website.
The data protection policies published by YouTube, available at https://www.google.de/intl/de/policies/privacy/, provide information about the collection, processing, and use of personal data by YouTube and Google.
Art. 6(1)(a) GDPR serves as the legal basis for our company for processing operations for 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 the data subject is a party, as is the case, for example, in processing operations necessary for the supply of goods or the provision of any other service or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to such processing operations that are necessary for carrying out pre-contractual measures, for example, in the case of inquiries concerning our products or services.
If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1)(c) GDPR.
In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or other third party. Then the processing would be based on Art. 6(1)(d) GDPR.
Ultimately, processing operations could be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations that are not covered by any of the aforementioned legal grounds if the processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47, Sentence 2 GDPR).
If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business in favor of the well-being of all our employees and shareholders.
The criterion used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data are routinely deleted, provided they are no longer necessary for the fulfillment of the contract or the initiation of a contract.
We clarify that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with them. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded.
Before personal data are provided by the data subject, the data subject must contact one of our employees. Our employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.
Source reference: This privacy policy is based in part on the privacy policy generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as a data protection officer, in cooperation with RC GmbH, which recycles used computers, and the law firm WILDE BEUGER SOLMECKE | Rechtsanwälte.
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According to Art. 2(1) GDPR, the Regulation applies to the wholly or partly automated processing of personal data and to the non-automated processing of personal data which are contained or are intended to be contained in a filing system.
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation). The German version corresponds to the version in the Official Journal of the European Union of 04.05.2016, DE L 119/1 and the correction of 22.11.2016, OJ L 314/72.
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