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DATA PROTECTION

Data Protection

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, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part 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 "online offer").

The terms used are not gender-specific.

Status: August 31, 2021

 

Table of contents

  • • Introduction
  • • Responsible
  • • Overview of processing operations
  • • Relevant legal basis
  • • Security measures
  • • Transfer of personal data
  • • Data processing in third countries
  • • Deletion of data
  • • Use of cookies
  • • Business services
  • • Provision of the online offer and web hosting
  • • Special information on applications (apps)
  • • Registration, login and user account
  • • Contact and inquiry management
  • • Video conferencing, online meetings, webinars and screen sharing
  • • Application procedure
  • • Cloud services
  • • Web analysis, monitoring and optimization
  • • Presence in social networks (social media)
  • • Plugins and embedded functions as well as content
  • • Management, organization and support tools
  • • Modification and updating of the privacy policy
  • • Rights of data subjects
  • • Definitions

 

Responsability

Duncrow GmbH
Christian-Hummel-Weg 46
6710, Nenzing, Austria

E-Mail: office@duncrow.com.

Phone: +43 5522 / 23880.

Imprint: https://duncrow.com/imprint.

 

Overview of the processing operations

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, as well as other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
  • Content data (e.g. entries in online forms).
  • Contact data (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Contract data (e.g. subject matter of contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

  • Employees (e.g., employees, applicants, former employees).
  • Applicants.
  • Business and contractual partners.
  • Interested parties.
  • Communication partners.
  • Customers. Users (e.g., website visitors, users of online services).

Purposes of the processing

  • Provision of our online offer and user-friendliness.
  • Application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Office and organizational procedures.
  • Content Delivery Network (CDN).
  • Direct marketing (e.g. by e-mail or postal mail).
  • Feedback (e.g., collecting feedback via online form).
  • Marketing.
  • Contact requests and communication.
  • Profiles with user-related information (creation of user profiles).
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Provision of contractual services and customer service.
  • Management and response to requests.

Relevant legal bases

The following is an overview of the legal basis 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 country of residence or domicile. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a. GDPR) - The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Performance of a contract and pre-contractual requests (Art. 6 para. 1 p. 1 lit. 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 carried out at the data subject's request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c. GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f. GDPR) - Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or 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. 9(2)(b) GDPR) - Insofar as special categories of personal data within the meaning of Art. 9(1) GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application procedure, so that the controller or the data subject can fulfil the obligations incumbent on him or her under rights under employment law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9(2)(b). GDPR, in case of protection of vital interests of the applicants or other persons according to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. GDPR.
  • National data protection regulations in Austria: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Austria. These include, in particular, the Federal Act on the Protection of Individuals with regard to the Processing of Personal Data (Data Protection Act - DSG). In particular, the Data Protection Act contains special regulations on the right to information, the right to rectification or erasure, the processing of special categories of personal data, processing for other purposes and transmission, and automated decision-making in individual cases.

 

Safety measures

We take appropriate technical and organizational measures 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, in order to ensure a level of protection appropriate to the risk.

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

SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize 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, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. 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 comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to this data. Insofar as this transfer is for administrative purposes, the transfer of the data is based on our legitimate corporate and business interests or takes place insofar as it is necessary for the fulfillment of our contract-related obligations or if the consent of the data subjects or a legal permission exists.

 

Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, entities or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we process or allow the processing of data only in third countries with a recognized level of data protection, contractual obligation by so-called standard protection clauses of the EU Commission, in the presence of 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).

 

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not necessary for the purpose).

If the data are not deleted because they are required for other and 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 assertion, exercise or defense of legal claims or to protect the rights of another natural or legal person.

Within the scope of our data protection notices, we may provide users with further information on the deletion as well as on the retention of data that specifically applies to the respective processing operations.

 

Use of Cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. The primary purpose of a cookie is to store information about a user during or after his visit within an online offer. Stored information may include, for example, language settings on a website, login status, a shopping cart, or where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also known as "user IDs").

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by ourselves.
  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  • Statistical, marketing and personalization cookies: Furthermore, cookies are generally also used in the context of range measurement and when a user's interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This process is also referred to as "tracking", i.e., tracking the potential interests of users. Insofar as we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: If we do not provide you with explicit information about the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can obtain further instructions on how to object in the context of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in the context of which the consent of users to the use of cookies, or the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of 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 information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

 

Business services

We process data of 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 as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the data subjects (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of legal warranty and comparable obligations, i.e., generally after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons (e.g., for tax purposes generally 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

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 shall apply in the relationship between the users and the providers.

Project and development services: We process the data of our customers as well as clients (hereinafter uniformly referred to as "Customers") in order to enable them to select, acquire or commission the selected services or works as well as related activities as well as their payment and provision or execution or performance.

The required information is identified as such in the context of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we obtain access to information of end customers, employees or other persons, we process this information in accordance with the statutory and contractual provisions.

Further information on commercial services: We process the data of our customers and clients (hereinafter uniformly referred to as "Customers") in order to enable them to select, purchase or commission the selected services or works and related activities as well as their payment and delivery or execution or performance.

The required data are identified as such in the context of the order, purchase order or comparable contract conclusion and include the data required for the provision of services and billing as well as contact information in order to be able to hold any consultations.

  • Types of data processed: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category).
  • Data subjects: Prospective customers, business and contractual partners.
  • Purposes of processing: provision of contractual services and customer service, contact requests and communication, office and organizational procedures, administration and response to requests.
  • Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 p. 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

 

Provision of the online offer and web hosting

In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storing of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files may be used on the one hand for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability.

Content Delivery Network: We use a "content delivery network" (CDN). A CDN is a service that helps deliver the content of an online offering, especially large media files such as graphics or program scripts, more quickly and securely using regionally distributed servers connected via the Internet.

  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
    Purposes of processing: provision of our online offer and user-friendliness, content delivery network (CDN).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

 

Special notes on applications (apps)

We process the data of the users of our application insofar as this is necessary to provide the application and its functionalities to the users, to monitor its security and to further develop it. We may also contact users in compliance with legal requirements, provided that the communication is necessary for purposes of administration or use of the application. In all other respects, we refer to the data protection information in this privacy policy with regard to the processing of users' data.

Legal basis: the processing of data required for the provision of the functionalities of the application serves the fulfillment of contractual obligations. This also applies if the provision of the functionalities requires authorization of the users (e.g. releases of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for purposes of optimizing the application or security purposes), it is based on our legitimate interests. If users are explicitly asked for their consent to the processing of their data, the processing of the data covered by the consent is based on the consent.

  • Types of data processed: inventory data (e.g. names, addresses), meta/communication data (e.g. device information, IP addresses).
  • Purposes of processing: provision of contractual services and customer service.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Registration, login and user account

Users can create a user account. In the course of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The processed data includes in particular the login information (username, password and an e-mail address).

In the context of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the prosecution of our claims or there is a legal obligation to do so.

Users may be informed by e-mail about events relevant to their user account, such as technical changes.

Deletion of data after termination: If users have terminated their user account, their data with regard to the user account will be deleted, subject to any legal permission, obligation or consent of the users.

It is the responsibility of users to back up their data upon termination prior to the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: providing contractual services and customer service, security measures, managing and responding to requests.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Deletion of data after termination: If users have terminated their user account, their data with regard to the user account will be deleted, subject to any legal permission, obligation or consent of the users.

It is the responsibility of users to back up their data upon termination prior to the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: providing contractual services and customer service, security measures, managing and responding to requests.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

 

Contact and inquiry management

When contacting us (e.g. via 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 to the extent necessary to respond to the contact requests and any requested measures.

The response to the contact inquiries as well as the management of contact and inquiry data in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries and maintaining user or business relationships.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
  • Data subjects: Communication partners.
  • Purposes of processing: contact requests and communication.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. 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 comply with the legal requirements.

Data Processed by Conference Platforms: In the course of participating in a conference, the conference platforms process the personal data of the participants mentioned below. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific conference (e.g., provision of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants' data may also be processed by the conference platforms for security purposes or service optimization. The processed data includes personal data (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the Internet access, information on the end devices of the participants, their operating system, the browser and its technical and linguistic settings, information on the content of the communications, i.e. entries in chats and audio and video data, as well as the use of other available functions (e.g. surveys). Content of communications is 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 participants in advance and they will be asked for consent - if necessary.

Data protection measures of the participants: Please note the details of the processing of your data by the conference platforms in their data protection notices and select the security and data protection settings that are optimal 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 as well as access data, may not be passed on to unauthorized third parties.

Notes on legal basis: If, in addition to the conference pl

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of contractual services and customer service, contact requests and communication, office and organizational procedures.
  • Legal bases: consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

  • Discord: instant messaging, chat, voice conferencing and video conferencing; service provider: Discord, Inc, 444 De Haro St, Suite 200, San Francisco, California 94107, USA; website: https://discordapp.com/; privacy policy: https://discordapp.com/privacy.
  • TeamViewer: Conference software; Service provider: TeamViewer GmbH, Jahnstr. 30, 73037 Göppingen, Germany; Website: https://www.teamviewer.com/de; Privacy policy: https://www.teamviewer.com/en/privacy-notice/.

 

Application procedure

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

In principle, the required information includes personal information such as name, address, contact details and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information as to what information is required.

If provided, applicants can submit their applications to us using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails sent via the Internet are generally not encrypted. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the transmission path of the application between the sender and the reception on our server.

For purposes of applicant search, submission of applications, and selection of applicants, we may use third-party applicant management, or recruitment software and platforms and services, subject to legal requirements.

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

Processing of special categories of data: insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application process in order for the controller or the data subject to exercise the rights accruing to him or her under labor law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2) letter b. GDPR, in case of protection of vital interests of the applicants or other persons according to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, for care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. GDPR. In the case of notification of the special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. 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 job offer is not successful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is awithdrawn, which applicants are entitled to do at any time. Subject to a justified withdrawal by the applicants, the deletion will take place at the latest after the expiry of a period of six months so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be 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 inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

  • Types of data processed: applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
  • Data subjects: Applicants.
  • Purposes of processing: application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 9(2)(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 following purposes: document storage and management, calendar management, e-mail dispatch, spreadsheets and presentations, exchange of documents, content and information with specific recipients or publication of web pages, forms or other content and information, as well as chats and participation in audio and video conferences.

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

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

Notes on legal bases: If we ask for consent to use the cloud services, the legal basis of the processing is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed within this framework. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient and secure management and collaboration processes)

  • Types of data processed: inventory data (e.g., names, addresses), contact data (e.g., e-mail, phone numbers), content data (e.g., entries in online forms), usage data (e.g., web pages visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Data subjects: Customers, employees (e.g., employees, applicants, former employees), prospective customers, communication partners.
  • Purposes of processing: office and organizational procedures.
  • Legal bases: consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

  • Google Cloud Services: cloud storage, cloud infrastructure services and cloud-based application software; Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https:

Eingesetzte Dienste und Diensteanbieter:

 

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 behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can see, for example, at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimization.

In addition to web analysis, we may also use test procedures, for example, to test and optimize different versions of our online offering or its components.

For these purposes, so-called user profiles may be created and stored in a file (so-called "cookie") or similar procedures may be used with the same purpose. This information may include, for example, content viewed, web pages visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. This means that we, as well as 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 purposes of the respective procedures.

Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this Privacy Policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of 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: Consent (Art. 6 para. 1 p. 1 lit. a. GDPR), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

 

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 may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (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 privacy statements and information provided by the operators of the respective networks.

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

Facebook: We are jointly responsible with Facebook Ireland Ltd. for the collection (but not further processing) of data from visitors to our Facebook page (known as a "Fan Page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things You and Others Do and Provide" in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under "Device Information" in the Facebook Data Policy Statement: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, called "Page Insights," to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have entered into a special agreement with Facebook ("Page Insights Information," https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, direct information or deletion requests to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data).

  • Types of data processed: contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: contact requests and communication, feedback (e.g. collecting feedback via online form), marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

 

Plugins and embedded functions and content

We incorporate into our online offering functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, 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, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or functionality. We strive to use only such content whose respective providers use the IP address only for the delivery of 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 analyze information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may 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 offer as well as be linked to such information from other sources.

Notes on legal basis: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g., function libraries that we use for the purpose of displaying or making our online offering user-friendly). In doing so, the respective providers collect the IP address of the user and may process this for the purpose of transmitting the software to the user's browser and for security purposes, as well as for the evaluation and optimization of their offer.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: provision of our online offer and user-friendliness, provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR), consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR).

Services used and service providers:

  • Font Awesome: Display of fonts and symbols; Service provider:  Fonticons, Inc. ,6 Porter Road Apartment 3R, Cambridge, MA 02140, USA; Website: https://fontawesome.com/; Privacy Policy: https://fontawesome.com/privacy.
  • Google Fonts: We integrate the fonts ("Google Fonts") of the provider Google, whereby the user's data is used solely for the purpose of displaying the fonts in the user's browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display, as well as taking into account possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://fonts.google.com/; privacy policy: https://policies.google.com/privacy.
  • OpenStreetMap: We incorporate the maps of the service "OpenStreetMap", which are offered on the basis of the Open Data Commons Open Database License (ODbL) by the OpenStreetMap Foundation (OSMF). User data is used by OpenStreetMap solely for the purposes of displaying the map functions and for caching the selected settings. This data may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually executed within the settings of their mobile devices). Service Provider: OpenStreetMap Foundation (OSMF); website: https://www.openstreetmap.de; privacy policy: https://wiki.openstreetmap.org/wiki/Privacy_Policy.
  • reCAPTCHA: We integrate the "reCAPTCHA" function to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called "bots"). Processed data may include IP addresses, information about operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on web pages, previously visited web pages, interactions with ReCaptcha on other web pages, possibly cookies, and results of manual recognition processes (e.g. answering questions asked or selecting objects in images). Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.google.com/recaptcha/; privacy policy: https://www.google.com/recaptcha/; opt-out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de,  Ad Display Settings: https://adssettings.google.com/authenticated.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.youtube.com; privacy policy: 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.

 

Management, organization and auxiliary tools

We use services, platforms and software of other providers (hereinafter referred to as "Third-Party Providers") for the purpose of organizing, managing, planning as well as providing our services. When selecting third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of the third-party providers. This may involve various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.

If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

Notes on legal basis: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication.
  • Legal basis: consent (Art. 6 para. 1 p. 1 lit. a. GDPR), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR).

Services used and service providers:

 

Change and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the 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.

If we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information 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 concerning you which is carried out on the basis of Art. 6(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 the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to revoke any consent given at any time.
  • Right to information: you have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: you have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data.
  • Right to data portability: you have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format, or to request that it be transferred to another controller, in accordance with the law.
  • Complaint to 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 supervisory authority, in particular a 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 infringes the GDPR.

 

Definition of terms

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

 

  • Content Delivery Network (CDN): A "Content Delivery Network" (CDN) is a service with the help of which the content of an online offer, in particular large media files such as graphics or program scripts can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.
  • IP masking: IP masking is a method of deleting the last octet, i.e., the last two numbers of an IP address, so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing methods, especially in online marketing
  • 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. 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 such personal data to analyze, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g., interests in certain content or products, click behavior on a website or location). 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 can include visitors' behavior 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 enables 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 recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Controller: "Controller" is 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 includes virtually any handling of data, be it collection, analysis, storage, transmission or deletion.
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