Privacy policy

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process and the purposes and extent of processing. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as our “online offering”).

Impersonal, non-gender-specific pronouns and terminology are used.

As of: 07 September 2023

Table of contents

Party responsible

rheingold GmbH und Co. KG
Kaiser-Wilhelm-Ring 46
50672 Cologne

Authorized representatives:

Stephan Grünewald, Hans-Joachim Karopka, Stephan Urlings
E-mail address: rheingold@rheingold-online.de
Phone: +49 (0) 221 912 777-0
Imprint: https://www.rheingold-marktforschung.de/impressum/

Data Protection Officer contact details

eMGe-DaTa Data Protection with System
Michaela Genderka
Blumenstraße 13
47918 Tönisvorst

+49 (0) 2151 94 22 060
m.genderka@emge-data.de

Overview of processing

The following overview summarises the types of data processed and the purposes of their processing, and indicates the data subjects.

Types of data processed

  • Inventory data.
  • Payment details.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta/communication data.
  • Applicant Data.
  • Pictures and/or video recordings.

Categories of persons concerned

  • Customers.
  • Employees.
  • Interested parties.
  • Parties to communication.
  • Users.
  • Applicants.
  • Business and Contractual Partners.
  • Persons depicted.

Purposes of the processing

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organizational procedures.
  • Conversion measurement.
  • Managing and responding to enquiries.
  • Application Procedure.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offer and user-friendliness.
  • Information Technology Infrastructure.

Relevant legal bases

Below, you will find an overview of the legal principles of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our own country of residence or domicile. Should more specific legal foundations be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1.1 a) GDPR) - The data subject has given their consent to the processing of personal data relating to them for a specific purpose or purposes.
  • Contract performance and pre-contractual enquiries (Art. 6 para. 1.1 b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject’s request.
  • Legal obligation (Art. 6 para. 1.1 c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interest (Art. 6 para. 1.1 f) GDPR) - Processing is necessary to protect the legitimate interest of the controller or a third party, unless such interests are overridden by the interests, fundamental rights and freedoms of the data subject, which require the protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 b) GDPR) - To the extent that special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants in the context of the application procedure so that the controller or the data subject can carry out their obligations and exercise specific rights in the field of employment and social security and social protection law, their processing takes place under Art. 9 para. 2 b) GDPR; if in order to protect the vital interests of applicants or other persons, under Art. 9 para. 2 c) GDPR; if for purposes of preventive or occupational medicine, to assess the working capacity of employees, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, under Art. 9 para. 2 h) GDPR. In the case of specified categories of data transferred based on voluntary consent, their processing is based on Art. 9 para. 2 a) GDPR.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special provisions on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes and transmission, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of an employment relationship (section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and employee consent. In addition to this, the data protection laws of the individual Federal States may apply.

Security measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access, input, transfer, assurance of data availability and data segregation. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data and responses to any event compromising the data. We already take the protection of personal data into account during the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

TLS encryption (https): In order to protect your data transmitted via our online offering, we use TLS encryption. You can recognise such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission of personal data

In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude contracts reflecting this or agreements that serve to protect your data held by the recipients of your data.

Data transfer within the organisation: We may transfer or provide access to personal data to other entities within our organisation. Insofar as this disclosure is for administrative purposes, the disclosure of the data is based on our legitimate corporate and business interests or takes place insofar as it is necessary for the fulfilment of our contractual obligations, if the data subjects have given consent or there is legal justification.

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or allow data to be processed in third countries with a recognised level of data protection, a contractual obligation established through the so-called “standard data protection clauses” of the EU Commission, or where there exist certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as the consent permitting processing is revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person.

As part of our privacy notice, we may provide users with additional information on the deletion and retention of data that is specific to the processing operation in question.

Use of cookies

Cookies are small text files, or other small notes, which store and read information on end devices. For example, they may store the login status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions used in an online offering. Cookies can also be used for various purposes, e.g. to ensure the functionality, security and comfort of online offerings and the creation of analyses of visitor flows.

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Cookie settings history

Revoke cookie consents

Notes on consent: We use cookies in accordance with the legal requirements. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not necessary if the storage and recall of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by the user (i.e. our online offering). The revocable consent is clearly communicated to users and contains the information on the respective cookie use.

Information on the legal basis of data protection: The legal basis under data protection law on which we process users’ personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for the processing of their data is their declared consent. Otherwise, the data processed with the aid of cookies will be processed on the basis of our legitimate interest (e.g. in the business management of our online offering and improvement of its usability) or, if this is done in the context of the fulfilment of contractual obligations, if the use of cookies is necessary to do so. We explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing procedures.

Duration of storage: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g. browser or mobile app).
  • Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. For example, a login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also lodge an objection to processing in accordance with the legal requirements under Art. 21 GDPR. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be made via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

  • Types of data processed: Metadata, communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Provision of our online offering and user-friendliness.
  • Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR).

Further guidance on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure under which users’ consent to the use of cookies, or to the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users themselves. The declaration of consent is stored so that it does not have to be repeated and consent can be proven in accordance with the legal obligations. The storage can take place on the server side and/or in a cookie itself (using a so-called opt-in cookie or comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following apply: The duration of storage of consent can be up to two years. In this process, a pseudonymous user identifier is created and stored containing the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) the browser, system and end device used.
  • Real Cookie Banner: Cookie Consent Management; service provider: devowl.io GmbH, Tannet 12, 94539 Grafling, Germany; Legal basis: Legitimate Interests (Art. 6 para. 1.1 f) GDPR); website: https://devowl.io/de/wordpress-real-cookie-banner/; Data protection declaration: https: //devowl.io/de/datenschutzerklaerung/.

Business services

We process data from our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships and related measures and in the context of communication with contractual (or pre-contractual) partners, say, in order to answer enquiries.

We process this data to fulfil our contractual obligations. This includes, in particular, the obligations to provide the agreed services, carry out updates or offer remedies in the event of any disruptions to warranties or other performance. In addition, we process the data to safeguard our rights and for the purposes of the administrative tasks associated with these duties and company organisation. Furthermore, we process the data on the basis of our legitimate interest in proper and business management as well as to provide security measures to protect our contractual partners and our business operations from the misuse and endangerment of data, secrets, information and rights (e.g. to involve telecommunications, transport and other auxiliary services, alongside subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

We inform the contractual partners of the data required for the above-mentioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of legal warranty obligations or similar, i.e., in principle after 4 years, unless the data is stored in a customer account, where, for example, it must be kept for legal archiving reasons. The statutory retention period for documents relevant under tax law, commercial books, inventories, opening balances, annual financial statements, the instructions required to understand these documents and other organisational documents and accounting vouchers is ten years; for commercial and business letters received and reproductions of commercial and business letters sent, six years. The period shall begin at the end of the calendar year in which the last entry was made in the book; in which the inventory, opening balance sheet, annual accounts or management report was drawn up; in which the commercial or business letter was received or dispatched; in which the accounting voucher was created; in which the record was made or other document created.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); contract data (e.g. subject matter of contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); metadata, communication data (e.g. device information, IP addresses).
  • Data subjects: Interested parties; business and contractual partners; customers.
  • Purposes of the processing: Providing contractual services and customer service; contact requests and communication; office and organisational procedures; managing and responding to requests; conversion tracking (measuring the effectiveness of marketing activities); profiles with user-related information (creating user profiles).
  • Legal basis: Contract performance and pre-contractual enquiries (Art. 6 para. 1.1 b) GDPR); legal obligation (Art. 6 para. 1.1 c) GDPR); legitimate interest (Art. 6 para. 1.1 f) GDPR).

Further guidance on processing operations, procedures and services:

  • Economic analyses and market research: For business reasons and in order to be able to recognise market trends, the wishes of contractual partners and users, we analyse the data provided on business processes, contracts, queries etc., where the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offering. The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may take into account the profiles of registered users, if available, together with their details, e.g. services used. The analyses are for us alone and are not disclosed externally, unless they are anonymous analyses with collated, i.e. anonymised values. Furthermore, we take the privacy of users into consideration and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as aggregated data); Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR).
  • Agency Services: We process our clients’ data as part of our contractual services, which may include, for example, conceptual and strategic advice, campaign planning, software and design development/consultancy or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consultancy services and training services; legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1.1 b) GDPR).
  • Consulting: We process the data of our clients, customers, interested parties and other customers or contractual partners (uniformly referred to as “clients”) in order to be able to provide them with our advisory services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship. If it is necessary for the fulfilment of our contract, for the protection of vital interests or required by law, or if we have the consent of the client, we may disclose or transfer the client’s data to third parties or agents such as authorities or subcontractors or to providers of IT, office or comparable services, in compliance with the requirements of professional law; legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1.1 b) GDPR).
  • Online courses and online training: We process the data of participants in our online courses and online training (collectively referred to as “Participants”) in order to provide our course and training services to them. The data processed in this context and the type, scope, purpose and necessity of their processing are determined by the underlying contractual relationship. The data generally includes information on the courses and services used and, if part of our range of services, personal specifications and results for the participants. Among the forms of processing are included performance assessments and evaluations of our services and those of course and training leaders; legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1.1 b) GDPR).
  • Events and functions: We process the data of the participants in events, functions and similar activities offered or hosted by us (hereinafter uniformly referred to as “participants” and “events”) in order to enable them to participate in the events and to take advantage of the services or promotions associated with participation. If we process health-related, religious, political or other special categories of data in this context, this is done within the scope of disclosure (e.g. for thematically oriented events, to the benefit of preventive health care or safety, or with the consent of the data subjects). The required information is identified as such in the context of the order, purchase order or comparable contract-concluding document and includes the information required for the provision of services and invoicing as well as contact information so that any further queries can be made. Where we have access to information from end customers, employees or other persons, we process it in accordance with legal and contractual requirements; legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1.1 b) GDPR).

Provision of the online offering and web hosting

We process user data in order to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or terminal device.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); metadata, communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).).
  • Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR).

Further guidance on processing operations, procedures and services:

  • Provision of online offering via rented storage space: For the provision of our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as “web host”); Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR).
  • ALL-INKL: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: ALL- INKL.COM - New Media Münnich, Owner: Rene Münnich, Hauptstraße 68, 02742 Friedersdorf, Germany; Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR); Website: https: //all-inkl.com/; Data protection declaration: https: //all-inkl.com/datenschutzinformationen/; Order processing agreement: Provided by the service provider.

Contact and enquiry management

When contacting us (e.g. by contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed insofar as this is necessary to answer the contact enquiries and carry out any requested measures.

  • Types of data processed: Contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); metadata, communication data (e.g. device information, IP addresses).
  • Data subjects: Parties to communication.
  • Purposes of the processing: Contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online service and user experience.
  • Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR); contractual performance and pre-contractual enquiries (Art. 6 para. 1.1 b) GDPR).

Further guidance on processing operations, procedures and services:

  • Contact form: If users contact us via our contact form, email or other communication channels, we process the data communicated to us in this context to process the communicated request; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1.1 b) GDPR), legitimate interest (Art. 6 para. 1.1 f) GDPR).

Video conferencing, online meetings, webinars and screen sharing

We use platforms and applications of other providers (hereinafter referred to as "conference platforms") for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as "conference"). When selecting the conference platforms and their services, we observe the legal requirements.

Data processed through conference platforms: In the context of participation in a conference, the conference platforms process the personal data of the participants mentioned below. The scope of the processing depends, firstly, on which data is requested in the context of a specific conference (e.g. access data or real names) and secondly, on which optional information is provided by the participants. In addition to processing for the purpose of running the conference, participants’ data may also be processed by the conference platforms for security purposes or service optimisation. The data processed includes personal data (first name, surname), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address from which internet access is made, information on the participants’ terminal devices, their operating system, the browser and its technical and language settings, information on the content of communication processes, i.e. entries in chats, audio and video data, use of other available functions (e.g. surveys). The contents of the communications are encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, then further data may be processed according to the agreement with the respective conference provider.

Logging and recordings: If text entries, participation results (e.g. from surveys) and video or audio recordings are logged, this will be transparently communicated to the participants in advance and they will be asked for consent, if necessary.

Data protection measures by the participants: Please note the details of the processing of your data by the conference platforms in their data protection notices and select the optimum security and data protection settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a videoconference (e.g. by notifying roommates, locking doors and using the background obscuring function, if technically possible). Links to the conference rooms and access data may not be passed on to unauthorised third parties.

Notes on legal bases: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis of the processing is this consent. Furthermore, our processing may be necessary for the fulfilment of our contractual obligations (e.g. in lists of participants, in the case of processing of interview results, etc.). In addition, user data is processed on the basis of our legitimate interest in efficient and secure communication with our communication partners.

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); metadata, communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners; users (e.g. website visitors, users of online services); persons depicted.
  • Purposes of the processing: Provision of contractual services and customer service; contact requests and communication; office and organisational procedures.
  • Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR).

Further guidance on processing operations, procedures and services:

Application procedure

The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information provided there.

In principle, the required disclosure includes personal information such as the applicant’s name, address, a means of contact and evidence of the qualifications required for a job. Upon request, we will be happy to provide additional information about which details are required.

Where available, applicants may submit their applications to us using an online form. The data is encrypted for transmission to us according to the state of the art. Applicants can also send us their applications by email. Please note, however, that emails on the internet are generally not sent in encrypted form. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and its receipt on our server.

For the purposes of applicant searches, submission of applications and selection of applicants, we may use applicant management or recruitment software and platforms and services from third party providers in compliance with the legal requirements.

Applicants are welcome to contact us regarding the method of submission of the application or to send us the application by post.

Processing of special categories of data: To the extent that special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can carry out their obligations and exercise specific rights in the field of employment and social security and social protection law, their processing takes place under Art. 9 para. 2 b) GDPR; if in order to protect the vital interests of applicants or other persons, under Art. 9 para. 2 c) GDPR; if for purposes of preventive or occupational medicine, to assess the working capacity of employees, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, under Art. 9 para. 2 h) GDPR. In the case of specified categories of data transferred based on voluntary consent, their processing is based on Art. 9 para. 2 a) GDPR.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a vacancy is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Deletion takes place subject to a justified revocation by the applicant at the latest after the expiry of a period of six months allowing us to answer any follow-up questions about the application and meet our obligations to provide evidence under the regulations on the equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary and has no influence on the current application process, and that they can revoke their consent at any time with future effect.

  • Types of data processed: Inventory data (e.g. names, addresses);contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as the cover letter, curriculum vitae, certificates, other information provided with regard to a specific position or voluntarily surrendered by applicants with regard to their person or qualifications).
  • Data subjects: Applicants.
  • Purposes of the processing: Application procedure (establishment, possible subsequent implementation and possible subsequent termination of the employment relationship).
  • Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 b) GDPR).

Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the storage and management of content (e.g. document storage and management; exchange of documents, content and information with specific recipients; publication of content and information).

In this context, personal data may be processed and stored on the servers of the providers insofar as these are part of communication processes with us or are otherwise processed by us as set out in the context of this data protection declaration. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents. The providers of the cloud services also process usage data and metadata, which are used by them for security purposes and for service optimisation.

If we use the cloud services to provide forms or similar documents and content to other users or publicly accessible websites, the providers may store cookies on users’ devices for the purposes of web analytics or to remember users’ settings (e.g. for media control).

  • Types of data processed: Inventory data (e.g. names, addresses);Contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); metadata, communication data (e.g. device information, IP addresses); image and/or film recordings (e.g. photographs or video of a person).
  • Data subjects: Customers; employees (e.g. employees, applicants, former employees); interested parties; communication partners; persons depicted.
  • Purposes of the processing: Office and organisational procedures; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).).
  • Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR).

Further guidance on processing operations, procedures and services:

  • Google Photos: Online service for storing images and videos; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https: //www.google.com/photos/about/; Data protection declaration: https: //policies.google.com/privacy.

Newsletter and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter “newsletters”) only with the consent of the recipients or with legal permission. Insofar as the contents of the newsletter are specifically described in the course of registration, they are decisive for the consent of the user. Furthermore, our newsletters contain information about our services and ourselves.

To subscribe to our newsletters, it is generally sufficient for you to enter your email address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further details, provided that these are relevant for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in procedure. This means you will receive an email after registration asking you to confirm your registration. This confirmation is necessary so that no one can register using other people’s email addresses. Subscriptions to the newsletter are logged in order to be able to provide proofs of the subscription process in accordance with legal requirements. This includes the storage of the login and confirmation time as well as the IP address. Also logged are changes to your data stored with the distribution service provider.

Erasure and restriction of processing: We may store unsubscribed email addresses for up to three years before deleting them, based on our legitimate interest in proving that consent was previously given. The processing of this data is limited to the purpose of a possible defence against legal claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. If an obligation arises to lastingly observe an objection, we reserve the right to store the email address in a block list (so-called “block list”) for this purpose alone.

Logging of the registration process is based on our justified interest in documenting the proper procedures used. If we commission a service provider to send emails, this is done on the basis of our legitimate interest in an efficient and secure sending system.

Content:

Information about us, our services, promotions and offers.

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); metadata, communication data (e.g. device information, IP addresses); usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Parties to communication.
  • Purposes of the processing: Direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 para. 1.1 a) GDPR); legitimate interest (Art. 6 para. 1.1 f) GDPR).
  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. A link for cancelling the newsletter can be found at the end of each newsletter; alternatively, you can use one of the contact options given above, preferably email, for this purpose.

Further guidance on processing operations, procedures and services:

  • Measurement of opening and click rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from its server. In the course of this retrieval, technical information, such as information on the browser and your system, as well as your IP address and the time of the retrieval, are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of open rates and click rates as well as the storage of the measurement results in the users’ profiles and their further processing are based on the users’ consent. A separate revocation of performance measurement is unfortunately not possible; in this case, the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted; legal basis: Consent (Art. 6 para. 1.1 a) GDPR).
  • MailPoet: Email marketing service; Service provider: Aut O'Mattic A8C Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR); Website: https://www.mailpoet.com/; Data protection declaration: https://automattic.com/privacy/.

Web analysis, monitoring and optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at which time our online offering or its functions or content are used most often, and invite reuse as appropriate. Likewise, we can understand which areas need optimisation.

In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarised for a usage process, may be created for these purposes and information may be stored in a browser or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymisation by truncating the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation; instead, pseudonyms are used. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); metadata, communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR).

Further guidance on processing operations, procedures and services:

  • Matomo (without cookies): Matomo is a privacy-friendly web analytics software that is used without cookies and in which the recognition of returning users takes place with the help of a so-called "digital fingerprint", which is stored anonymously and changed every 24 hours; With the "digital fingerprint", user movements within our online offering are recorded with the help of pseudonymized IP addresses in combination with user-side browser settings in such a way that conclusions about the identity of individual users are not possible. The user data collected as part of the use of Matomo is only processed by us and is not shared with third parties; Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR); Website: https://matomo.org/.
  • Matomo Tag Manager is a service for managing tags that are triggered by a specific event that inserts a third-party script or sends data to a third-party service. No cookies in the technical sense are set on the user's client device, but technical and personal data such as the IP address are transmitted from the client to the service provider's server to enable the use of the service.

Online marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, “content”) based on users’ potential interests and measuring its effectiveness.

For these purposes, so-called “user profiles” can be created and stored in a file (a so-called “cookie”), or similar procedures used, by means of which the information on the user relevant to the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners, technical information such as the browser or computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.

The IP addresses of the users are also stored. However, we use IP masking procedures (i.e., pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored as part of the online marketing process; rather, pseudonyms are used. This means that neither we, nor the providers of the online marketing procedures, know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can generally be read later on other websites that use the same online marketing procedure, analysed for the purpose of displaying content, supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, plain data may be assigned to the profiles. This is the case if users are, for example, members of a social network whose online marketing procedures we use and the network links the users’ profiles to the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g. by giving their consent as part of the registration process.

In principle, we only receive access to collated information about the success of our advertisements. However, in the context of so-called “conversion tracking”, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to a contract being concluded with us. Conversion tracking is used solely to analyse the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); metadata, communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behaviour-related profiling, use of cookies); marketing; profiling with user-related information (creation of user profiles); provision of our online offering and user-friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the opt-out functions given for the providers. If no explicit opt-out function has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore recommend the following additional opt-outs, which are offered summarily for the respective areas: a) Europe: https: //www.youronlinechoices.eu. b) Canada: https: //www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) International: https://optout.aboutads.info.

Further guidance on processing operations, procedures and services:

  • Google Ad Manager: We use the "Google Marketing Platform" (and services such as "Google Ad Manager") to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on presumed user interests. This allows us to display ads for and within our online offering in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products he or she has been interested in on other online offers, this is referred to as "remarketing"; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR); Website: https://marketingplatform.google.com; Data protection declaration: https: //policies.google.com/privacy; Further information: Types of processing as well as data processed: https://privacy.google.com/businesses/adsservices; Google Advertising Products Data Processing Terms: Information on services Data processing terms and conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms; if Google acts as processor, data processing terms and conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with users active there, or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This can result in risks to users because, for example, it could make it more difficult to enforce users’ rights.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and derived interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that are assumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, within which the usage behaviour and interests of the users are stored. Furthermore, these usage profiles may also include data independent of the devices used by users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt out), we refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights too, we point out that these can be made most effectively towards the providers. Only the providers have access to the users’ data and can directly take appropriate measures and provide information. If you still need help, you can contact us.

  • Types of data processed: Contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); metadata, communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Contact requests and communication; feedback (e.g. collecting feedback via online forms); marketing.
  • Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR).

Further guidance on processing operations, procedures and services:

Plugins, embedded functions and content

Into our online offering, we integrate functional and content elements that are drawn from the servers of their respective providers (hereinafter referred to as “third-party providers”). This may include, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is thus required for the display of this content or function. We endeavour only to use content whose providers solely use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to analyse information such as visitor traffic on the pages of this website. This pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering; it may also be linked to such information from other sources.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); metadata, communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of the processing: Provision of our online offering and user-friendliness.
  • Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR).

Further guidance on processing operations, procedures and services:

  • Google Fonts (obtained from the Google server): The obtaining of typefaces (and symbols) for the purpose of ensuring a technically secure, maintenance-free and efficient use of fonts and symbols with a view to up-to-dateness and loading times, uniform presentation and consideration of possible restrictions under licensing law. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted; these are necessary for the provision of the typefaces as dependent on the devices used and the technical environment; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR); Website: https://fonts.google.com/; Data protection declaration: https: //policies.google.com/privacy.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interest (Art. 6 para. 1.1 f) GDPR); Website: https: //www.youtube.com; Data protection declaration: https: //policies.google.com/privacy; Opt-out: Opt-out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de; Ad Display Settings: https://adssettings.google.com/authenticated.
  • Weglot: This website includes features of the translation service Weglot. The provider is Weglot SAS, 138, rue Pierre Joigneaux in Bois-Colombes 92270 France. Weglot is loaded when the website is called up. With Weglot, the language can be changed to a language other than German via the country-language icon, in the header of the website. This allows a direct connection between the user browser and the Weglot server when visiting this website. Weglot thus receives the information that you have visited this website with your IP address. The storage and analysis of the data is based on Art. 6 para. 1 lit. f DSGVO. A corresponding consent is requested via the cookie and privacy settings of the website. The processing then takes place exclusively on the basis of Art. 6 para. 1 lit. a DSGVO. Consent can be revoked at any time via the data protection settings on each sub-page. For more information, please refer to Weglot's data protection declaration at https://weglot.com/privacy/.

Amendment and update of the data protection declaration

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.

Rights of the data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Article 6 para. 1 e) or f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to such processing for such purposes; this also applies to profiling, insofar as it is connected with such direct advertising.
  • Right to revocation of consent: You have the right to revoke any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether such data is being processed and to access to this data, as well as to obtain further information about them and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the legal requirements, you have the right to request that the data concerning you be completed or that the incorrect data concerning you be corrected.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data relating to you be deleted immediately or, alternatively, to demand restriction of the processing of the data.
  • The right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, commonly used and machine-readable format in accordance with the legal requirements, or to request that it be transferred to another controller.
  • Right to complain to a supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection authority, in particular the supervisory authority in the Member State where you usually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you violates the GDPR.

Supervisory authority responsible for us:

Die Landesbeauftragte für den Datenschutz
North Rhine-Westphalia
Kavalleriestraße 2-4
40213 Düsseldorf

Tel.: 0211 384240
poststelle@ldi.nrw.de

Definition of terms

This section provides you with an overview of the terms used in this data protection declaration. Many of the terms are taken from the law and defined above all in Art. 4 GDPR. These legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • Conversion tracking: Conversion tracking is a procedure that can be used to determine the effectiveness of marketing measures. This is usually done by storing a cookie on the users’ devices within the websites where the marketing takes place and then retrieving it again on the target website. For example, we can use it see whether the ads we have placed on other websites have been successful.
  • Personal data: "Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a “cookie”) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects (e.g. interest in certain content or products, click behaviour on a website or location) relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and may include visitors’ behaviour or interests in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Tracking: “Tracking” is when the behaviour of users can be traced across several online offerings. As a rule, information on behaviour and interests with regard to the online offerings made use of is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Controller: The “Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and encompasses practically every handling of data, be it collection, evaluation, storage, transmission or deletion.