Privacy Policy
1. Controller, Scope, Data Protection Officer
Controller under the General Data Protection Regulation and applicable national data protection laws of the Member States, as well as other data protection regulations for the processing of your personal data, is:
initOS GmbH
Innungsstraße 7
21244 Buchholz i.d.N.This Privacy Policy applies to this website, including all subpages.
You can reach our Data Protection Officer at datenschutz@initos.com, by mail to our postal address with the addition “Data Protection Officer,” or by phone at +49 4181 13503 80.
2. Privacy at a Glance
General Information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. Detailed information on the subject of data protection can be found in our Privacy Policy below.
Data Collection on this Website
Who is responsible for data collection on this website?
The data processing on this website is carried out by the website operator. You can find the contact details of the operator in the section “Notice to the Responsible Party” in this Privacy Policy.
How do we collect your data?
Your data is collected in part by you providing it to us. This may include, for example, data that you enter into a contact form.
Other data is collected automatically or with your consent when you visit the website through our IT systems. This primarily includes technical data (e.g., internet browser, operating system, or time of page access). The collection of this data occurs automatically as soon as you enter this website.
What do we use your data for?
Some of the data is collected to ensure that the website is provided without errors. Other data can be used to analyze your user behavior.
What rights do you have with regard to your data?
You have the right to receive information about the origin, recipient and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. You also have the right to lodge a complaint with the competent supervisory authority. You can contact us at any time if you have any further questions on the subject of data protection.
Analysis tools and tools from third-party providers
When you visit this website, your surfing behavior may be statistically evaluated. This is mainly done with so-called analysis programs. Detailed information on these analysis programs can be found in the following privacy policy.
3. Hosting
We host the content of our website with the following provider:
Hetzner
The provider is Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen (hereinafter referred to as Hetzner).
For details, please refer to Hetzner’s Privacy Policy: https://www.hetzner.com/de/legal/privacy-policy/.
The use of Hetzner is based on Art. 6(1)(f) GDPR. We have a legitimate interest in providing the most reliable representation of our website. If consent was requested, the processing is carried out exclusively based on Art. 6(1)(a) GDPR and § 25(1) TDDG, to the extent that the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) as defined by TDDG. Consent can be revoked at any time.
4. General notes and mandatory information
Data Protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.
We would like to point out that data transmission over the Internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.
Note on the responsible body
The responsible party for data processing on this website is:
initOS GmbH
Innungsstraße 7
21244 Buchholz i.d.N.
Germany
Phone: +49 (0) 41 81 / 135 03 0
Email: info@initos.com
The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g., names, email addresses, or similar).
Retention Period
Unless a more specific retention period is stated within this Privacy Policy, your personal data will remain with us until the purpose for processing the data no longer applies. If you submit a legitimate request for deletion or withdraw consent for data processing, your data will be deleted, unless we have other legally permissible grounds for retaining your personal data (e.g., tax or commercial law retention periods); in the latter case, deletion will occur once these grounds no longer apply.
General Information on the Legal Grounds for Data Processing on This Website
If you have consented to data processing, we process your personal data based on Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, if special categories of data are processed according to Art. 9(1) GDPR. In the case of explicit consent for the transfer of personal data to third countries, data processing also takes place based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your device (e.g., via device fingerprinting), data processing additionally occurs based on § 25(1) TTDSG. Consent can be revoked at any time.
If your data is necessary for the performance of a contract or for the execution of pre-contractual measures, we process your data based on Art. 6(1)(b) GDPR. Furthermore, we process your data if it is necessary for the fulfillment of a legal obligation, based on Art. 6(1)(c) GDPR. Data processing may also occur based on our legitimate interest according to Art. 6(1)(f) GDPR. The relevant legal grounds for data processing are explained in more detail in the following sections of this Privacy Policy.
Note on data transfer to the USA and other third countries
We use tools from companies based in the USA or other third countries that do not offer adequate data protection standards. When these tools are active, your personal data may be transferred to and processed in these third countries. Please note that in these countries, a level of data protection comparable to that of the EU cannot be guaranteed. For example, US companies are required to provide personal data to security authorities without you, as the data subject, having the ability to take legal action against it. Therefore, it cannot be ruled out that US authorities (e.g., intelligence services) may process, analyze, and permanently store your data located on US servers for surveillance purposes. We have no influence over these processing activities.
Recipients of personal data
As part of our business activities, we collaborate with various external parties. In some cases, the transfer of personal data to these external parties is necessary. We only share personal data with external parties if this is required for the performance of a contract, if we are legally obligated to do so (e.g., transferring data to tax authorities), if we have a legitimate interest in the transfer under Art. 6(1)(f) GDPR, or if another legal basis allows the data transfer. When using processors, we share personal data of our customers only based on a valid contract for data processing. In the case of joint processing, an agreement on joint processing is made.
Revocation of your consent to data processing
Many data processing activities are only possible with your explicit consent. You can revoke any consent already given at any time. The lawfulness of the data processing carried out until the revocation remains unaffected by the revocation.
Right to Object to Data Collection in Specific Cases and to Direct Marketing (Art. 21 GDPR)
If the data processing is based on Art. 6(1)(e) or (f) GDPR, you have the right to object at any time, for reasons arising from your particular situation, to the processing of your personal data; this also applies to profiling based on these provisions. The respective legal basis for the processing can be found in this Privacy Policy. If you object, we will no longer process your affected personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims (objection under Art. 21(1) GDPR).
If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such marketing purposes; this also applies to profiling to the extent that it is related to such direct marketing. If you object, your personal data will no longer be used for direct marketing purposes (objection under Art. 21(2) GDPR).
Right to lodge a complaint with the competent supervisory authority
In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. The right to lodge a complaint is without prejudice to other administrative or judicial remedies.
Right to Data Portability
You have the right to have data that we process automatically based on your consent or in fulfillment of a contract provided to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent that it is technically feasible.
Information, Correction and Deletion
You have the right, within the framework of applicable legal provisions, to request free information about your stored personal data, its origin, recipients, and the purpose of data processing, and if applicable, the right to rectification or deletion of this data. For this and any other questions regarding personal data, you can contact us at any time.
Right to Restriction of Processing
You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this. The right to restriction of processing exists in the following cases:
If you dispute the accuracy of the personal data we have stored about you, we generally need time to verify this. During the verification period, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data was unlawful, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you need it for the establishment, exercise, or defense of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
If you have filed an objection under Art. 21(1) GDPR, a balance between your and our interests must be made. As long as it is not determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have requested the restriction of the processing of your personal data, these data – aside from storage – may only be processed with your consent or for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest in the European Union or a Member State.
SSL or TLS encryption
or security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the website operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the change in the browser’s address bar from “http://” to “https://” and by the lock symbol in your browser bar. When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
5. Data Collection on This Website
Cookies
Our websites use so-called “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either temporarily stored for the duration of a session (session cookies) or permanently stored (permanent cookies) on your device. Session cookies are automatically deleted after your visit. Permanent cookies remain on your device until you delete them yourself or they are automatically deleted by your web browser.
Cookies can come from us (first-party cookies) or from third parties (so-called third-party cookies). Third-party cookies allow for the integration of certain services from third-party providers within websites (e.g., cookies for processing payment services).
Cookies have various functions. Many cookies are technically necessary because certain website functions would not work without them (e.g., the shopping cart function or displaying videos). Other cookies can be used to analyze user behavior or for advertising purposes.
Cookies that are necessary for the electronic communication process, to provide certain features you have requested (e.g., for the shopping cart function), or to optimize the website (e.g., cookies for measuring web traffic) are stored based on Art. 6(1)(f) GDPR unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies to ensure the technically error-free and optimized provision of services. If consent for the storage of cookies and similar recognition technologies was requested, the processing will be based solely on this consent (Art. 6(1)(a) GDPR and § 25(1) TTDSG); consent can be withdrawn at any time.
You can configure your browser to notify you when cookies are set and allow cookies only in individual cases, exclude the acceptance of cookies for certain situations or generally, and activate the automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of this website may be limited. The cookies and services used on this website can be found in this privacy policy.
Server Log Files
The provider of the site automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
Browser type and browser version
Operating system used
Referrer URL
Hostname of the accessing computer
Time of the server request
IP address
This data is not merged with other data sources.
The collection of this data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in ensuring the technically error-free presentation and optimization of their website – for this, the server log files must be collected.
Contact Form
If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We will not pass on this data without your consent.
This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your request is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.
We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Mandatory statutory provisions – in particular retention periods – remain unaffected.
Request by e-mail, telephone or fax
If you contact us by e-mail, telephone or fax, we will store and process your inquiry, including all personal data (name, inquiry), for the purpose of processing your request. We will not pass on this data without your consent.
This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your request is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.
The data you send to us via contact requests will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
6. Newsletter
Newsletter Data
If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.
The data you provide us with for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose no longer applies. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. Data stored by us for other purposes remains unaffected by this. When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the computer system 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 in order to be able to trace the (possible) misuse of a data subject’s e-mail address at a later date and therefore serves as legal protection for the controller.
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist if this is necessary to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.
Sending Newsletters to Existing Customers
If you order goods or services from us and provide your email address in the process, we may subsequently use this email address to send you newsletters, provided we have informed you about this in advance. In such cases, the newsletter will only contain direct advertising for our own similar goods or services. You can unsubscribe from receiving this newsletter at any time. A corresponding unsubscribe link is included in every newsletter. The legal basis for sending the newsletter in this case is Art. 6(1)(f) GDPR in conjunction with § 7(3) UWG (German Act Against Unfair Competition).
After unsubscribing from the newsletter distribution list, your email address may be stored in a blacklist to prevent future mailings. The data in the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with legal requirements for sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Storage in the blacklist is not time-limited. You may object to the storage if your interests outweigh our legitimate interest.
Use of Rapidmail
Description and Purpose:
We use rapidmail for sending newsletters. The provider is rapidmail GmbH, Wentzingerstraße 21, 79106 Freiburg, Germany. rapidmail is used to organize and analyze the sending of newsletters. The data you enter for the purpose of subscribing to the newsletter is stored on rapidmail’s servers in Germany. If you do not wish to be analyzed by rapidmail, you must unsubscribe from the newsletter. We provide a corresponding unsubscribe link in every newsletter message.
For analysis purposes, the emails sent with rapidmail contain a so-called tracking pixel, which connects to the servers of rapidmail when the email is opened. This makes it possible to determine whether a newsletter message has been opened. Furthermore, we can use rapidmail to determine whether and which links within the newsletter message are clicked. Optionally, links in the email can be set up as tracking links to count your clicks.
Legal Basis:
The legal basis for this data processing is Art. 6(1)(a) GDPR.
Recipient:
The recipient of the data is rapidmail GmbH.
Transfer to Third Countries:
There is no transfer of data to third countries.
Duration of Storage:
The data you provide to us for the purpose of receiving the newsletter will be stored until you unsubscribe from the newsletter and will be deleted from both our servers and the servers of rapidmail after unsubscription. Data stored by us for other purposes (e.g. email addresses for a member area) remain unaffected.
Right of Withdrawal:
You have the right to withdraw your consent to data processing at any time with future effect. The legality of data processing carried out prior to the withdrawal remains unaffected.
Further Privacy Information:
For more details, please refer to rapidmail’s data security information: https://www.rapidmail.de/datensicherheit.
You can find more information about rapidmail’s analytics features here: https://www.rapidmail.de/wissen-und-hilfe
7. Handling of Applicant Data
Contact Person for Questions or Information Requests
If you have any questions or suggestions regarding data protection or the processing of your personal data, our Data Protection Officer is happy to assist you at datenschutz@initos.com.
Personal Data and Purpose Limitation
The subject of data protection is personal data (Art. 4 No. 2 GDPR). This includes individual details about personal or factual circumstances, such as name, address, email address, or telephone number, which you provide to us in the course of the application process, as well as any data we may receive from third parties:
Personal data (e.g., applicant name, address, date of birth)
Contact details (e.g., phone number, email address)
Resume data (e.g., professional career, secondary employment, qualifications, hobbies)
Results from selection procedures (e.g., tests, interviews)
Process data (e.g., status, appointment dates)
Your personal data is stored and used electronically solely for the purpose of processing your application.
Legal Basis
The processing of your personal data is lawful pursuant to Art. 6(1)(a) GDPR, as you have given your consent to the processing of your personal data for one or more specific purposes prior to submitting your application.
Consent to Processing and Use
You consent to employees from the HR department and the respective specialist department having access to your personal data during the application process. Your data will only be used by a limited group of authorized users. Your personal data will not be disclosed to third parties by us or by persons commissioned by us, unless we are legally obliged to do so (e.g. to government authorities).
Storage and Deletion of Data
The general statutory retention and deletion periods apply. We store your personal data as follows:
for the duration of the application process;
if your application is unsuccessful, from the date the rejection letter is sent, for the period in which we may need the data to resolve inquiries or disputes;
with your explicit consent to retain the data beyond the statutory retention period, until the consent is withdrawn.
We delete your data in accordance with the relevant legal provisions once the respective recruitment process is completed. After that, your personal data can no longer be accessed or used by our company.
Data transfer to third countries
Data is not transferred to third countries.
Right to information, right of access and rectification, right of revocation
You have the right to request information under Article 15 of the GDPR and to update or request the deletion of the personal data you have provided at any time by notifying the recipient. You can decide for yourself which information you provide to us. Fields marked with an * are mandatory fields that we need for the application process. Fields not marked with an * are optional and can be filled in voluntarily. You are responsible for all content in your online application, such as photos, and must ensure compliance with legal requirements, such as trademark, copyright, personal rights, or other third-party rights. You have the right to data portability and the right to file a complaint with a data protection supervisory authority. You are always entitled to withdraw your consent to the use of personal data.
Obligation to Provide Data
If you do not provide us with the mandatory information described in the previous section, it is unfortunately not possible for you to apply to us electronically via our careers page.
Talent Pool
If you cannot be offered a suitable position at the time of your application, the data you provide/transmit throughout the application process may be collected, processed and used in the talent pool even after completion. This is done to establish contact for professional purposes and for possible consideration for a subsequent job offer. You agree to this use separately.
Security
Data protection and data security are our top priority. We therefore use various technical and organizational security measures to protect your data from accidental or intentional manipulation, loss, destruction or access by unauthorized third parties.
When personal data is collected and processed in the aforementioned context, this information is transmitted in encrypted form to ensure that your data is always sufficiently secure. We continuously adapt the measures to technical developments in order to be able to guarantee the greatest possible security in the future.
8. Plugins und Tools
Social Media Links
Our website contains links to social networks such as Facebook, Instagram, LinkedIn, Github and Xing. When you access the parts of our website that contain such links, no personal data is transmitted to the operators of these social networks. Only when you click on the link and thereby visit the social network in question does the operator of the network visited receive personal data relating to you. For more information about the data processing that takes place when you visit a social network and the controller within the meaning of Art. 4 No. 7 GDPR, please refer to the website of the respective social network.
Consent
Any further processing of your personal data will only take place if you have given us your consent and we are therefore authorized to process your personal data in accordance with Art. 6 para. 1 a) GDPR. In some areas of our website, you have the option of granting such express consent. In each case, we will inform you of the purpose for which the data will be processed in the event of your consent and how long we will store this personal data.
YouTube with enhanced data protection
This website integrates videos from the YouTube platform. The provider of the pages is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
When you visit one of our pages that includes a YouTube video, a connection to the YouTube servers is established. In the process, the YouTube server is informed about which of our pages you have visited. If you are logged into your YouTube account, you allow YouTube to directly associate your browsing behavior with your personal profile. You can prevent this by logging out of your YouTube account.
We use YouTube in extended data protection mode. According to YouTube, videos played in this mode are not used to personalize browsing on YouTube. Ads shown in extended data protection mode are also not personalized. In this mode, no cookies are set. However, so-called Local Storage elements are saved in the user’s browser, which function similarly to cookies, can contain personal data, and may be used for recognition purposes. For more details on the extended data protection mode, see: https://support.google.com/youtube/answer/171780.
Activating a YouTube video may trigger additional data processing operations over which we have no control.
The use of YouTube is in the interest of presenting our online content in an appealing way. This constitutes a legitimate interest pursuant to Art. 6 (1)(f) GDPR. If consent has been requested, the processing is carried out exclusively based on Art. 6 (1)(a) GDPR and § 25 (1) TDDDG, provided the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) in accordance with the TDDDG.
Further information about data protection at YouTube can be found in their privacy policy:
https://policies.google.com/privacy?hl=en.
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States that aims to ensure compliance with European data protection standards in the context of data processing in the U.S. Any company certified under the DPF is committed to complying with these data protection standards. More information is available from the provider at the following link:
https://www.dataprivacyframework.gov/participant/5780.
Google Fonts
This site uses so-called Google Fonts, provided by Google, for the uniform display of fonts. When you access a page, your browser loads the required fonts into its browser cache in order to display text and fonts correctly.
For this purpose, the browser you use must connect to Google’s servers. As a result, Google becomes aware that your IP address has been used to access this website. The use of Google Fonts is based on Art. 6 (1)(f) GDPR. The website operator has a legitimate interest in the uniform presentation of the typeface on its website. If consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG.
If your browser does not support Google Fonts, a standard font from your computer will be used.
Further information on Google Fonts can be found at:
https://developers.google.com/fonts/faq
and in Google’s privacy policy:
https://policies.google.com/privacy?hl=en.
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States that aims to ensure compliance with European data protection standards during data processing in the U.S. Any company certified under the DPF commits to complying with these data protection standards. More information is available from the provider at the following link:
https://www.dataprivacyframework.gov/participant/5780.
Google Maps
This site uses the Google Maps map service. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. This service allows us to embed map content on our website.
To use the features of Google Maps, it is necessary to store your IP address. This information is typically transferred to a Google server in the USA and stored there. The provider of this site has no influence over this data transmission. When Google Maps is activated, Google may use Google Fonts for the uniform display of fonts. When accessing Google Maps, your browser loads the necessary web fonts into its browser cache to correctly display text and fonts.
The use of Google Maps is in the interest of providing an attractive presentation of our online offerings and in making it easier to find the locations specified on our website. This constitutes a legitimate interest as defined in Art. 6 (1)(f) GDPR. If consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TDDDG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG.
Data transfer to the USA is based on the EU Commission’s standard contractual clauses. Details can be found here:
https://privacy.google.com/businesses/gdprcontrollerterms/
and
https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.
More information on how Google handles user data can be found in Google’s privacy policy:
https://policies.google.com/privacy?hl=en.
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States designed to ensure compliance with European data protection standards for data processing in the U.S. Any company certified under the DPF commits to adhering to these data protection standards. Further information is available from the provider at the following link:
https://www.dataprivacyframework.gov/participant/5780.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
reCAPTCHA is used to determine whether data entered on this website (e.g. in a contact form) is made by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of website visitors based on various characteristics. This analysis begins automatically as soon as the visitor enters the website. A cookie is set for this purpose, which stores the data for 60 days. The analysis includes evaluation of various information (e.g. IP address, how long the visitor stays on the website, or mouse movements made by the user). The data collected during the analysis is transmitted to Google.
The reCAPTCHA analyses run entirely in the background. Website visitors are not notified that an analysis is taking place.
The storage and analysis of the data is based on Art. 6 (1)(f) GDPR. The website operator has a legitimate interest in protecting its online offerings from abusive automated spying and from SPAM. If consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TDDDG, to the extent that the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.
Further information about Google reCAPTCHA can be found in the Google Privacy Policy and Google Terms of Use at the following links:
https://policies.google.com/privacy?hl=en and
https://policies.google.com/terms?hl=en.
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States intended to ensure compliance with European data protection standards for data processing in the U.S. Every company certified under the DPF commits to complying with these data protection standards. More information is available from the provider at the following link:
https://www.dataprivacyframework.gov/participant/5780.
Google Analytics
We use Google Analytics on this website, a web analytics service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Inc. uses third-party cookies. The information generated by these cookies is used by Google Inc. to evaluate your use of the website, to compile reports on website activity for us, and to provide other services related to website and internet usage. The IP address transmitted by your browser as part of Google Analytics is not merged with other Google data.
This website also uses Google Analytics for cross-device analysis of visitor flows via a User ID. With the User ID, interaction data from different devices and sessions can be clearly assigned to a single user. You can deactivate the cross-device analysis of your usage in your customer account under “My Data,” “Personal Data.” User data is stored for two months. Event data is stored for 14 months.
We use Google Analytics to analyze and improve our website. Through the statistics obtained, we aim to enhance our offering and make it more interesting for you as a user. The legal basis for the use of Google Analytics is set out in section 3.6.
We have concluded a data processing agreement with Google Inc. as our processor, which obliges Google to protect your data. The information generated by the third-party cookie about your use of this website (including your IP address) is generally transmitted to a Google Inc. server in the USA and stored there. On our website, we have extended Google Analytics with the code “gat._anonymizeIp();” to ensure IP anonymization (so-called “IP masking”). This means that your IP address is shortened by Google Analytics within member states of the European Union before being transmitted to a Google Inc. server in the USA. As a result, a direct personal identification via the IP address is no longer possible. Only in exceptional cases is the full IP address transmitted to a Google Inc. server in the USA and shortened there. For the exceptional cases in which personal data is transferred to the USA, Google Inc. has submitted to the EU-U.S. Data Privacy Framework:
https://www.dataprivacyframework.gov/EU-US-Framework.
Further information on Google Inc. can be found at:
Terms of Use: https://marketingplatform.google.com/about/analytics/terms/en/
Privacy Policy: https://policies.google.com/privacy?hl=en&gl=en
Contact details of Google’s representative in the EU:
Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.
You can prevent the installation of cookies by setting your browser software accordingly; however, please note that in this case you may not be able to fully use all features of our website. You can also prevent the collection of the data generated by the cookie related to your use of the website (including your IP address) and its processing by Google Analytics by downloading and installing the browser plugin available at the following link:
https://tools.google.com/dlpage/gaoptout?hl=en
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States intended to ensure compliance with European data protection standards for data processing in the U.S. Every company certified under the DPF commits to complying with these data protection standards. More information is available from the provider at the following link:
https://www.dataprivacyframework.gov/participant/5780.
Google Tag Manager
We use Google Tag Manager on this website, a tag management system provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Inc. uses third-party cookies. The information generated by these cookies is used by Google Inc. to evaluate your use of the website, to compile reports on website activity for us, and to provide other services related to website and internet usage. The cookies are stored for 60 days. Google Tag Manager collects data on the website and forwards it to the connected analytics tool Google Analytics. That tool stores and analyzes the data. User data is stored for two months, and event data is stored for 14 months.
The legal basis for using Google Tag Manager is Art. 6 (1) lit. a GDPR.
We have concluded a data processing agreement with Google Inc. as our processor, which obliges Google Inc. to protect your data.
The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States that aims to ensure compliance with European data protection standards for data processing in the USA. Each company certified under the DPF commits to complying with these data protection standards. More information is available from the provider at the following link:
https://www.dataprivacyframework.gov/participant/5780.
Borlabs Cookie Banner
This website uses Borlabs Cookie, which sets a technically necessary cookie (borlabs-cookie) to store your cookie consents. Borlabs Cookie does not process any personal data.
The borlabs-cookie stores the consents you gave when entering the website. If you wish to revoke these consents, you must delete the cookie in your browser. When you re-enter or reload the website, you will be asked for your cookie consent again.
The legal bases for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest lies in the management of the cookies and similar technologies used and the related consents.
9. Data Processing via Our Facebook Fan Page
We maintain an online presence on the social network Facebook, operated by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), to communicate with customers, prospects, and users active there and to inform them about our services (hereinafter referred to as “Facebook Fan Page”).
Regarding the data processing that occurs when visiting our Facebook Fan Page, Facebook and we are jointly responsible within the meaning of Art. 26 (1) GDPR. Our respective obligations resulting from this joint responsibility are set out in an agreement between Facebook and us, known as the “Page Insights Controller Addendum.” This agreement can be viewed here:
https://www.facebook.com/legal/terms/page_controller_addendum
The key points of the agreement are summarized here:
https://www.facebook.com/legal/terms/information_about_page_insights_data
When using our Facebook Fan Page, we statistically evaluate how users interact with the page. For this purpose, we receive comprehensive statistics from Facebook regarding visits and usage of our Facebook Fan Page, known as “Facebook Insights.” These statistics do not contain any personal data but are aggregated data with no reference to individual persons. As the operator of the fan page, we do not have access to personal data and cannot view or retrieve such data from Facebook. It is not possible for us to identify individuals. We also do not create profiles of individual users.
These statistics help us tailor our Facebook Fan Page to user needs and continuously optimize it. This may also serve marketing and advertising purposes by analyzing user interests—for example, displaying advertisements on or off our Facebook Fan Page that likely align with users’ interests. To enable such statistical evaluations, Facebook typically stores cookies on users’ devices, which record user behavior and interests. When you visit our Facebook Fan Page, a cookie is placed to recognize you while you are logged into your Facebook account and to make browsing the page easier. According to Facebook, cookies and the data collected through them are deleted or anonymized within 90 days. No additional cookies are used. To our knowledge, Facebook does not generate or use other data, such as entries in the local storage, for non-members of Facebook.
Apart from that, we only process data that you may provide to us via our Facebook Fan Page—for example, to respond to your questions or comments, or to reply to your posts or messages via Facebook.
The processing of your personal data in connection with visiting our Facebook Fan Page is based on our legitimate interest in providing effective user information and communication pursuant to Art. 6 (1) f) GDPR.
Please note that Facebook may also independently process the aforementioned data for its own purposes, without our involvement or influence. This includes, for example, the display of content on third-party Facebook pages tailored to your general Facebook settings and the personalization of such content. Facebook may also transfer the aforementioned data to third countries such as the USA, e.g., to servers operated by Facebook, Inc., which may pose additional risks. Details on the protective measures taken by Facebook can be found here:
https://www.facebook.com/legal/terms/information_about_page_insights_data and
https://www.facebook.com/about/privacy/
If Facebook transfers data to the USA for our purposes in specific cases, both Facebook and we ensure that such transfers are based on appropriate safeguards in accordance with Art. 44 et seq. GDPR—for example, by agreeing to the EU Commission’s Standard Contractual Clauses, which may include safeguards such as data encryption under Art. 46 (2) c) GDPR.
The agreement with Facebook stipulates that Facebook assumes primary responsibility for processing Insights data and fulfills all obligations under the GDPR regarding this processing. Facebook is therefore primarily responsible for complying with the information obligations under Art. 13 and 14 GDPR, as well as for safeguarding your rights as a data subject. In particular, for requests for information or to assert other data subject rights, we recommend contacting Facebook directly, as only Facebook has access to user data and can take appropriate actions and provide information.
Users of our Facebook Fan Page can exercise their rights under Art. 12 et seq. GDPR—particularly the rights to deletion (Art. 17), restriction of processing (Art. 18), objection (Art. 21), and access (Art. 15)—with Facebook, as described here:
https://www.facebook.com/legal/terms/information_about_page_insights_data.
If you still require assistance, you are welcome to contact us.
For more information about how Facebook processes and uses data when you visit our Facebook Fan Page, please refer to:
https://www.facebook.com/about/privacy/
and specifically for Facebook Insights:
https://www.facebook.com/legal/terms/information_about_page_insights_data
There you will also find settings to protect your privacy and options to object.
Presences on other social networks
We maintain an online presence on other social networks to communicate with active users there or to provide information about us. We would like to point out that user data may be processed outside the European Union. This can present risks for users, as enforcing their rights could be more difficult. Regarding US providers that are certified under the EU-US Data Privacy Framework or provide comparable guarantees of a secure level of data protection, we note that they commit to complying with EU privacy standards.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, user behavior and the resulting interests can be used to create usage profiles. These profiles can, in turn, be used to display advertisements within and outside the networks that presumably align with users’ interests. For these purposes, cookies are typically stored on users’ devices, which store their usage behavior and interests. Additionally, usage profiles may store data independent of the devices used by the users (especially when users are members of the respective platforms and logged in).
For a detailed description of the respective processing forms and opt-out options, we refer to the privacy policies and information provided by the operators of the respective networks.
Even in the case of requests for information and the assertion of data subject rights, we would like to point out that these are most effectively asserted with the providers. Only the providers have access to user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email addresses, phone numbers), content data (e.g., text entries, photographs, videos), usage data (e.g., visited websites, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
- Affected persons: Users (e.g., website visitors, users of online services).
- Purposes of processing: Contact inquiries and communication, tracking (e.g., interest- and behavior-based profiling, use of cookies), remarketing, reach measurement (e.g., access statistics, recognition of returning visitors).
- Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
Used services and service providers:
- Instagram: Social network; Service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA; Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/.
- Xing: Social network; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Website: https://www.xing.de; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.
- LinkedIn: Social network; Service provider: LinkedIn 1000 W Maude Ave, Sunnyvale, CA 94085, United States, Website: https://www.linkedin.com (operator of the LinkedIn website: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland), Privacy policy: https://de.linkedin.com/legal/privacy-policy?, Cookie policy: https://de.linkedin.com/legal/cookie-policy?.
- Github: Online service for version control of software development projects; Service provider: GitHub Inc. San Francisco, California, United States, Website: https://github.com/, Privacy policy: https://docs.github.com/de/site-policy/privacy-policies/github-general-privacy-statement
10. Update of these Privacy Notices
From time to time, it may be necessary to update these privacy notices, for example, due to new legal or regulatory requirements or new offerings on our website. We will inform you accordingly at this location. In general, we recommend that you regularly check these privacy notices to see if any changes have been made. You can recognize any changes, among other things, by the updated version indicated at the bottom of this document.
Source: https://www.e-recht24.de
Version: 10/2024