Data Privacy Statement

This data privacy statement provides you with information on the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offering and associated websites, functions and contents, as well as external online presences, e.g. our social media profile (hereinafter collectively referred to as the “online offering”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions set out in Article 4 of the General Data Protection Regulation (GDPR).
  

CONTROLLER

ROTRONIC AG  
Grindelstrasse 6  
CH-8303 Bassersdorf  
Switzerland

Tel.: +41 44 838 11 11  
Fax: +41 44 838 14 83  
e-mail info@rotronic.ch
Internet https://www.rotronic.com 

Managing director with power of representation: Andreas Gähwiler

Legal notice: https://www.rotronic.com/de-ch/about-us/imprint-impressum-mentions-legales-informazione-legale 
 

LEGAL BASES:

  • If we process data from users from the EU/EEC, the legal bases of the GDPR specified below apply.
  • Otherwise, we process the data on the basis of Swiss law. This means that, while the following statements apply, they apply on the basis of Swiss law and not the GDPR standards mentioned.  
     

TYPES OF DATA PROCESSED:

  • Master data (e.g. names, addresses).
  • Contact details (e.g. e-mail, telephone numbers).
  • Content data (e.g. text input, photographs, videos).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Meta/communication data (e.g. device information, IP addresses).  

Visitors and users of the online offering (the data subjects shall hereinafter also be referred to as “users”). 
 

PURPOSE OF PROCESSING

  • Provision of the online offering, its functions and contents.
  • Response to contact inquiries and communication with users.
  • Security measures.
  • Reach measurement/marketing
     

TERMS USED

“Personal data” means any information relating to an identified or identifiable natural person (“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;

“Processing” means any operation or set of operations which is performed in connection with personal data, whether or not by automated means. The term is broadly defined and covers practically every scenario in which data is handled.

“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

The “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.

The “processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the c ontroller. 
 

APPLICABLE LEGAL BASIS

In accordance with Article 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the data privacy statement, the following applies: The legal basis for obtaining consent is Article 6 (1a) and Article 7 GDPR, the legal basis for processing for the performance of our services and the performance of contractual measures, as well as for answering inquiries is Article 6 (1b) GDPR, the legal basis for processing to fulfill our legal obligations is Article 6 (1c) GDPR, and the legal basis for processing to safeguard our legitimate interests is Article 6 (1f) GDPR. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6 (1d) GDPR serves as the legal basis.
 

SAFEGUARDS

Pursuant to Article 32 GDPR and taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

Such measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability and separation in respect of such data. Furthermore, we have established procedures to ensure the exercise of rights of data subjects, data erasure and reactions to scenarios in which data is at risk. In addition, we already consider the protection of personal data during the processes associated with the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default (Article 25 GDPR).
 

COOPERATION WITH CONTRACT DATA PROCESSORS AND THIRD PARTIES

If we disclose data to other persons and companies (contract data processors or third parties) in connection with our processing operations, transmit data to them or otherwise grant them access to the data, this shall only take place on the basis of a statutory authorization (e.g. if the transmission of the data to third parties, such as payment service providers is necessary for the performance of an agreement in accordance with Article 6 (1b) GDPR), if you have granted your consent, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.). 

If we commission third parties with the processing of data on the basis of a “contract data processing agreement”, this shall be done on the basis of Article 28 GDPR.  
 

TRANSMISSION TO THIRD COUNTRIES

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure/the transmission of data to third parties, such processing activities shall only be performed in order to fulfill our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to statutory or contractual authorizations, we shall only process or leave the data in a third country if the special requirements set out in Articles 44 et seq. GDPR are met. This means, for example, that processing is carried out on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU or compliance with officially recognized special contractual obligations (known as “standard contractual clauses”). 
 

RIGHTS OF DATA SUBJECTS

You have the right to request confirmation as to whether the data concerned is being processed, and to request information about this data, as well as further information and a copy of the data in accordance with Article 15 GDPR. In accordance with Article 16 GDPR, you have the right to request that incomplete personal data relating to you be completed, or to have incorrect data relating to you rectified. In accordance with Article 17 GDPR, you have the right to demand that data relating to you be erased immediately or, alternatively, to request the restriction of the processing of the data in accordance with Article 18 GDPR. You have the right to receive the data concerning you that you have provided to us in accordance with Article 20 GDPR, and to request its transmission to other controllers In accordance with Article 77 GDPR, you also have the right to lodge a complaint with the competent supervisory authority. 
 

RIGHT OF REVOCATION

You have the right to revoke consent granted pursuant to Article 7 (3) GDPR with effect for the future. 
 

RIGHT TO OBJECT

You can object to the future processing of the data concerning you in accordance with Article 21 GDPR at any time. The objection can be raised, in particular, with regard to processing for direct marketing purposes.
  

COOKIES AND RIGHT TO OBJECT IN DIRECT ADVERTISING

“Cookies” are small files that are stored on the user's computer. Various types of data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit within an online offering. Temporary cookies, or “session cookies”/”transient cookies”, are cookies that are deleted after a user leaves an online offering and closes his/her browser. These cookies are used, for example, to store the content of a shopping cart in an online shop or a login status. Cookies are referred to as “permanent” or “persistent” if they remain stored even after the browser is closed. For example, the login status can be saved when users visit a site again after several days. Cookies can also be used to store user interests for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller that operates the online offering (otherwise, if the cookies are only the controller’s cookies, these are referred to as “first-party cookies”). 

We can use temporary and permanent cookies and provide information on this in our data privacy statement.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser’s system settings. Stored cookies can be deleted in the browser system settings. Deactivating cookies can restrict the functions of this online offering.

A general objection to the use of cookies used for online marketing purposes can be raised for a variety of services, in particular in the case of tracking, via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved [AN1] by deactivating them in the browser settings. Please note that in this case, you may not be able to use all functions of this online offering. 
  

DATA ERASURE

The data processed by us is erased, or its processing restricted, in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this data privacy statement, the data stored by us is erased as soon as it is no longer required for its intended purpose and provided that the erasure does not conflict with any statutory retention obligations. If the data is not erased because it is required for other legally permissible purposes, its processing is restricted. This means that the data is blocked and is not processed for other purposes. This applies, for example, to data that has to be retained for commercial law or tax reasons.

According to the statutory requirements in Germany, the data is retained, in particular, for 10 years in accordance with sections 147 (1) of the German Tax Code (AO), 257 (1) no. 1 and 4, (4) of the German Commercial Code (HGB) (books, records, management reports, accounting documents, trading books, documents relevant for taxation, etc.) and 6 years in accordance with section 257 (1) no. 2 and 3, (4) HGB (commercial letters).

In accordance with legal requirements in Austria, the data is retained, in particular, for 7 years in accordance with section 132 (1) of the Austrian Federal Tax Code (BAO) (accounting documents, receipts/invoices, accounts, evidentiary documents, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with services provided electronically, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used. 
 

BUSINESS-RELATED PROCESSING

In addition, we process

  • contractual data (e.g. subject matter of the contract, term, customer category).
  • payment data (e.g. bank details, payment history)

relating to our customers, prospective customers and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
  

ORDER PROCESSING IN THE ONLINE SHOP AND CUSTOMER ACCOUNT

We process data relating to our customers in the context of the order processes in our online shop to enable them to select and order their chosen products and services, as well as to arrange for their payment and delivery/execution.

The processed data includes master data, communication data, contractual data, payment data, and the data subjects affected by the processing include our customers, interested parties and other business partners. The data is processed for the purpose of providing contractual services in the context of operating an online shop, as well as for billing, delivery and customer services. Within this context, we use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.

Processing is carried out on the basis of Article 6 (1b) (execution of order processes) and c (legally required archiving) GDPR. The information marked as mandatory is required to establish and perform the contract. We only disclose the data to third parties within the context of delivery, payment or within the framework of legal authorizations and obligations vis-à-vis legal advisors and authorities. The data is only processed in third countries if this is necessary for the performance of the contract (e.g. at the customer's request upon delivery or payment).

Users can opt to create a user account that they can use, in particular, to view their orders. During the registration process, users are provided with information on the required mandatory information. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be erased with regard to the user account, unless its retention is necessary for commercial or tax law reasons pursuant to Article 6 (1c) GDPR. Data remains in the customer account until it is erased, with subsequent archiving in the case of a legal obligation. Users are responsible for saving their data before the end of the contract if they have given notice of termination.

When users register, log in again and make use of our online services, we store the IP address and the time of the user action in question. This data is stored on the basis of our legitimate interests, as well as to protect users again misuse and other unauthorized use. We do not disseminate this data to third parties as a matter of principle, unless this is necessary to pursue our claims or there is a statutory obligation pursuant to Article 6 (1c) GDPR.

The data is erased following the expiry of the statutory warranty and comparable obligations, the need for data storage is reviewed every three years; in cases involving statutory archiving obligations, the data is erased after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation).
   

ADMINISTRATION, FINANCIAL ACCOUNTING, OFFICE ORGANIZATION, CONTACT MANAGEMENT

We process data in connection with administrative tasks, as well as the organization of our company, financial accounting and compliance with statutory obligations, e.g. archiving. In this respect, we process the same data that we process in the course of providing our contractual services. The processing bases are Article 6 (1c) GDPR, Article 6 (1f) GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose of, and our interest in, the processing lies in administration, financial accounting, office organization, archiving of data, i.e. tasks which serve to maintain our business activities, to allow us to perform our duties and provide our services. The erasure of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.

We disclose or transmit data to the tax authorities, consultants, such as tax consultants or auditors, as well as to other fee agencies and payment service providers within this context.

Furthermore, we store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of making contact at a later date. We store this data, which is mainly company-related, permanently.  
  

BUSINESS MANAGEMENT ANALYSES AND MARKET RESEARCH

In order to run a profitable business, to be able to recognize market trends, wishes of contractual partners and users, we analyze the data available to us relating to business transactions, contracts, inquiries, etc. Within this context, we process master data, communication data, contractual data, payment data, usage data, metadata on the basis of Article 6 (1f) GDPR, and the data subjects include contractual partners, interested parties, customers, visitors and users of our online offering.

The analyses are carried out for the purpose of business management evaluations, marketing and market research. Within this context, we can include the profiles of registered users, including information on the services they have used, for example. The analyses help us to increase user-friendliness and to optimize our offering and the profitability of our business. The analyses are used exclusively for our internal purposes and are not disclosed externally, unless they are anonymous analyses including aggregated values.

If these analyses or profiles relate to specific individuals, they will be erased or rendered anonymous when the user issues notice of termination, or otherwise after two years from the time at which the contract was concluded. Otherwise, overall business management analyses and general trend evaluations are prepared anonymously wherever possible.
    

INFORMATION ON DATA PROTECTION DURING THE APPLICATION PROCESS

We only process applicant data for the purpose and in the context of the application process in accordance with the statutory requirements. Applicant data is processed in order to fulfill our (pre-)contractual obligations in the context of the application process within the meaning of Article 6 (1b) GDPR and Article 6 (1f) GDPR if we have to process the data, e.g. within the framework of legal proceedings (in Germany, section 26 of the German Federal Data Protection Act (BDSG) also applies).

The application process requires applicants to provide us with their data. If we offer an online form, the necessary applicant data is marked, is otherwise evident from the job descriptions and generally includes personal details, postal and contact addresses and the documents belonging to the application, such as a cover letter, resume and certificates. In addition, applicants can provide us with additional information voluntarily.

By submitting the application to us, applicants agree to the processing of their data for the purposes of the application process in accordance with the nature and scope set out in this data privacy statement.

Insofar as special categories of personal data within the meaning of Article 9 (1) GDPR are voluntarily communicated within the scope of the application process, they are also processed in accordance with Article 9 (2b) GDPR (e.g. health data, e.g. severely disabled status or ethnic origin). If special categories of personal data within the meaning of Article 9 (1) GDPR are requested from applicants during the application process, they are also processed in accordance with Article 9 (2a) GDPR (e.g. health data, if this is required for the exercise of the occupation in question).

If made available, applicants can send us their applications using an online form on our website. The data is encrypted and transmitted to us using state-of-the-art procedures.  Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and that the applicants themselves are responsible for ensuring that they are encrypted. As a result, we cannot accept any responsibility for the transmission of the application between the sender and receipt on our server, and therefore recommend the use of an online form or dispatch by post. After all, instead of using the online application form and an e-mail, applicants can still send us their application by post.

If the application is successful, the data provided by the applicants may be further processed by us for the purpose of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants' data will be erased. Applicants' data will also be erased if an application is withdrawn, something that applicants are entitled to do at any time.

The data will be erased after a period of six months, subject to justified revocation by the applicant, so that we can answer any follow-up questions relating to the application and fulfill our obligations under the Equal Treatment Act (Gleichbehandlungsgesetz). Invoices for any reimbursement of travel expenses are archived in accordance with the tax law requirements.  
 

REGISTRATION FUNCTION

Users can create a user account. As part of the registration process, users are provided with information on the required mandatory data, which is processed on the basis of Article 6 (1b) GDPR for the purpose of providing the user account. The data processed includes, in particular, the login information (name, password and an e-mail address). The data entered during registration is used for the purpose of using the user account and its purpose.

Users may be notified by e-mail of information relating to their user account, such as technical changes. If users have terminated their user account, their data relating to the user account will be erased, subject to a statutory retention obligation. Users are responsible for saving their data before the end of the contract if they have given notice of termination. We are entitled to irretrievably erase all user data stored during the term of the contract.

When users register, log in and make use of the user account, we store the IP address and the time of the user action in question. This data is stored on the basis of our legitimate interests, as well as to protect users again misuse and other unauthorized use. We do not disseminate this data to third parties as a matter of principle, unless this is necessary to pursue our claims or there is a statutory obligation pursuant to Article 6 (1c) GDPR. The IP addresses are rendered anonymous or erased after 7 days at the latest.
  

COMMENTS AND POSTS

If users leave comments or make other posts, their IP addresses may be used on the basis of our legitimate interests within the meaning of Article 6 (1f) GDPR for 7 days. This is designed to protect us if someone leaves illegal contents in comments and posts (insults, prohibited political propaganda, etc.). In such cases, we can be sued ourselves for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to Article 6 (1f) GDPR to process user information in order to detect spam.

On the same legal basis, we reserve the right, in cases involving surveys, to store the IP addresses of users for the duration of these surveys, and to use cookies to prevent users from participating in surveys several times over.

The data provided in the context of comments and posts will be permanently stored by us until the user objects.  
 

COMMENT SUBSCRIPTIONS

Users can subscribe to follow-up comments with their consent in accordance with Article 6 (1a) GDPR. Users will receive a confirmation email to verify that they are the owner of the email address they have entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation e-mail will contain information on the revocation options. For the purpose of furnishing proof of user consent, we store the time of registration together with the IP address of the users and erase this information when users unsubscribe from the subscription.

You can cancel the receipt of our subscription at any time, i.e. revoke your consent. We can store the e-mail addresses that have unsubscribed for up to three years on the basis of our legitimate interests before we erase them in order to be able to prove that consent was previously granted. The processing of this data is limited to the purpose of possible defense against claims. An individual application for erasure can be submitted at any time, provided that the former granting of consent is confirmed at the same time.  
  

AKISMET ANTI-SPAM TESTING

Our online offering uses the “Akismet” service offered by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. The use is based on our legitimate interests within the meaning of Article 6 (1f) GDPR. This service helps to distinguish comments made by real people from spam comments. All comment information is sent to a server in the USA where it is analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be stored even after this period has expired. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information on the browser used and the computer system, and the time the entry was made.

Further information on Akismet's collection and use of the data can be found in Automattic's privacy policy: https://automattic.com/privacy/.

Users are welcome to use pseudonyms or refrain from entering their name or email address. You can prevent the transfer of data completely by not using our comments system. That would be a shame, but unfortunately we are not aware of any other alternatives that work just as effectively.  
 

RETRIEVAL OF PROFILE IMAGES FROM GRAVATAR

We use the Gravatar service provided by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA, within our online offering and especially in our blog.

Gravatar is a service where users can log in and store profile pictures and their e-mail addresses. If users leave posts or comments with their e-mail address on other online presences (especially in blogs), their profile pictures can be displayed next to the posts or comments. For this purpose, the e-mail address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile has been saved for it. This is the only purpose of the transmission of the e-mail address; it will not be used for any other purposes, but will be erased thereafter.

The use of Gravatar is based on our legitimate interests within the meaning of Article 6 (1f) GDPR, as we allow users to personalize their posts and comments using a profile picture with the help of Gravatar.

By displaying the images, Gravatar obtains the IP address of the users, as this is necessary for communication between a browser and an online service. Further information on Gravatar's collection and use of the data can be found in Gravatar's privacy policy: https://automattic.com/privacy/.

If users do not want an image associated with their email address using the Gravatar service to appear in their comments, they should use a non-Gravatar e-mail address for commenting. We would also like to point out that users can also use an anonymous e-mail address, or no e-mail address at all, if they do not wish their own e-mail address to be sent to Gravatar. Users can prevent the transfer of data completely by not using our comments system.  
 

ACCESSING EMOJIS AND SMILIES

Within our WordPress blog, graphical emojis (or smilies), i.e. small graphical files that express feelings, are used. These are obtained from external servers. The providers of the servers collect the IP addresses of the users within this context. This is necessary so that the emoji files can be transmitted to the users' browsers. The emoji service is offered by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Privacy policy of Automattic: https://automattic.com/privacy/. The server domains used are s.w.org and twemoji.maxcdn.com. To our knowledge, these are “content delivery networks”, i.e. servers which serve exclusively to ensure the fast and secure transmission of the files. The personal data of the users is erased after the transmission.

Emojis are used on the basis of our legitimate interests, i.e. interest in ensuring the attractive design of our online offering in accordance with Article 6 (1f) GDPR.  
 

GETTING IN TOUCH

When users get in touch with us (e.g. Using the contact form, e-mail, telephone or social media), their details are processed for the purposes of processing and responding to the contact inquiry pursuant to Article 6 (1b) (in the context of contractual/pre-contractual relationships), Article 6 (1f) (other requests) GDPR. User information can be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization system.

We delete the inquiries if they are no longer necessary. We review this requirement every two years; the statutory archiving obligations also apply.  
 

NEWSLETTER

The following section provides you with information on the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights to object. By subscribing to our newsletter, you agree to receive it and to the procedures described.

Content of the newsletter: We will only send out newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “newsletters”) with the consent of the recipients or if we have statutory authorization to do so. If the contents of a newsletter are specifically described as part of the registration process, they are decisive for the consent granted by the users. In addition, our newsletters contain information about our services and us.

Double opt-in and logging: Registration for our newsletter uses what is known as a double opt-in procedure. This means that after registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register using e-mail addresses that are not their own. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the login and confirmation time, as well as the IP address. Changes to your data stored with the shipping service provider are also logged.

Registration details: To subscribe to the newsletter, it is sufficient for you to enter your e-mail address. In addition, we ask you to provide a name so that the newsletter can address you personally.

The dispatch of the newsletter and the performance measurement associated with it are based on the recipient's consent pursuant to Article 6 (1a), Article 7 GDPR in conjunction with section 7 (2) no. 3 of the Unfair Competition Act (UWG) or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Article 6 (1f) GDPR in conjunction with section 7 (3) UWG.

The registration procedure is logged on the basis of our legitimate interests pursuant to Article 6 (1f) GDPR. We are interested in the use of a user-friendly and secure newsletter system that both serves our business interests and meets user expectations, and also allows us to provide proof of consent.

Termination/revocation - You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to unsubscribe from the newsletter at the end of each newsletter. We can store the e-mail addresses that have unsubscribed for up to three years on the basis of our legitimate interests before we erase them in order to be able to prove that consent was previously granted. The processing of this data is limited to the purpose of possible defense against claims. An individual application for erasure can be submitted at any time, provided that the former granting of consent is confirmed at the same time.  
 

NEWSLETTER - DISPATCH SERVICE PROVIDER

The newsletter will be sent out by the dispatch service provider ClickDimensions, 5901 Peachtree Dunwoody Road, NE, Suite B500, Atlanta, GA 30328, USA. You can find the data protection provisions of the dispatch service provider here. The dispatch service provider is used on the basis of our legitimate interests in accordance with Article 6 (1f) GDPR and a contract data processing agreement pursuant to Article 28 (3) sentence 1 GDPR.

The dispatch service provider can use the recipient data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data relating to our newsletter recipients to approach them itself or to pass the data on to third parties.  
 

NEWSLETTER - PERFORMANCE MEASUREMENT

The newsletters contain what is known as a “web-beacon”, i.e. a pixel-sized file which is downloaded from our server when the newsletter is opened or, if we use a dispatch service provider, from the latter’s server. As part of this download process, technical information, such as information about the browser and your system, as well as your IP address and time of download, is initially collected.

This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their download locations (which can be determined using the IP address) or access times. The statistical analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our aim, nor that of any dispatch service provider we may use, to observe individual users. Rather, the evaluations help us to recognize the reading habits of our users and to adapt our contents to suit them or to send different content according to the interests of our users.

Unfortunately, the separate revocation of the performance measurement is not possible. In such cases, the entire newsletter subscription has to be canceled.  
 

HOSTING AND E-MAIL DISPATCH

The hosting services we use serve to allow us to make the following services available: Infrastructure and platform services, computing capacity, storage space and database services, e-mail delivery, security services and technical maintenance services that we use for the purpose of operating this online offering.

Within this context, we or our hosting provider process(es) master data, contact details, content data, contractual data, usage data, metadata and communication data relating to customers, interested parties and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering according to Article 6 (1f) GDPR in conjunction with Article 28 GDPR (conclusion of contract data processing agreement).  
 

COLLECTION OF ACCESS DATA AND LOG FILES

We/our hosting provider collect(s) data on each access to the server on which this service is located (known as “server log files”) on the basis of our legitimate interests within the meaning of Article 6 (1f) GDPR. The access data includes the name of the website accessed, file, date and time of access, data volume transmitted, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for a maximum of 7 days for security reasons (e.g. to investigate misuse or fraud) and is then erased. Data whose further storage is required for evidentiary purposes is excluded from erasure until the incident in question has been clarified with definitive effect.  

GOOGLE TAG MANAGER

Google Tag Manager is a solution that we can use to manage “website tags” using an interface (allowing us to incorporate Google Analytics and other Google marketing services into our online offering, for example). The tag manager itself (which implements the tags) does not process any personal data relating to users. Regarding the processing of users' personal data, reference is made to the following information on the Google services. Use policy: https://www.google.com/intl/de/tagmanager/use-policy.html.  
 

GOOGLE ANALYTICS

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online offering within the meaning of Article 6 (1f) GDPR), we use Google Analytics, a web analysis service offered by Google LLC ("Google"). Google uses cookies. As a rule, the information generated by the cookie about the use of the online offering will be transmitted to and stored by Google on servers in the United States.

Google is certified under the Privacy Shield Agreement, meaning that it undertakes to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering and to provide us with further services associated with the use of this online offering and the use of the Internet. Pseudonymous user profiles can be created using the data processed.

We only use Google Analytics with IP anonymity enabled. This means that Google will truncate the user IP addresses within member states of the European Union or other signatory states to the European Economic Area (EEA) treaty. The full IP address is only sent to and truncated by Google servers in the USA in exceptional cases.

The IP address transmitted by the user’s browser will not be merged with other Google data. Users can configure their browser software in such a way as to prevent cookies from being saved; users can also stop the information generated by the cookie relating to their use of the online offering from being transmitted to Google, and stop Google from processing this data by downloading and installing the browser plugin that is available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

For more information about how Google uses your information, setting and opt-out options, please read Google's Privacy Policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

Users' personal data will be erased or rendered anonymous after 14 months.  
  

CREATION OF TARGET GROUPS USING GOOGLE ANALYTICS

We use Google Analytics to display the advertisements placed by Google and its partners within advertising services only to those users who have actually shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products that are identified on the basis of the websites visited) that we transmit to Google (known as “remarketing” or "Google Analytics Audiences”). With the help of remarketing audiences, we also want to ensure that our advertisements match potential user interests.  
 

GOOGLE ADWORDS AND CONVERSION MEASUREMENT

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online offering within the meaning of Article 6 (1f) GDPR), we use the services offered by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

Google is certified under the Privacy Shield Agreement, meaning that it undertakes to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the Google “AdWords” online marketing process to place ads in the Google Advertising Network (e.g. in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our online offering in a more targeted manner in order to present users only with those ads that potentially match their interests. For example, if a user is shown ads for products in which he/she has shown an interest in other online offerings, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google Advertising Network is active are accessed, Google directly executes a code from Google and “(re)marketing tags” (invisible graphics or code, also known as “web beacons”) are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (comparable technologies can also be used instead of cookies). This file records which websites the user visits, which content he/she is interested in and which offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, the time of the visit and further information on the use of the online offering.

We also receive an individual “conversion cookie”. The information collected with the help of the cookie is used by Google to generate conversion statistics for us. However, we only receive information on the total number of anonymous users who clicked on our ad and were redirected to a page with a conversion tracking tag. We do not, however, receive any information that can be used to identify users personally.

The user data is processed pseudonymously within the Google Advertising Network. This means that Google does not store and process, for example, the names or e-mail addresses of users, but processes the relevant data on a cookie-related basis within pseudonymous user profiles. Consequently, from Google's point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymization. The information collected about the users is transmitted to Google and stored on Google's servers in the USA.

For more information about how Google uses your information, setting and opt-out options, please read Google's Privacy Policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
  

GOOGLE DOUBLECLICK

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online offering within the meaning of Article 6 (1f) GDPR), we use the services offered by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

Google is certified under the Privacy Shield Agreement, meaning that it undertakes to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the online marketing procedure Google “Doubleclick” to place ads in the Google Advertising Network (e.g. in search results, in videos, on websites, etc.). Double Click is characterized by the fact that ads are displayed in real time based on users' presumed 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 those ads that potentially match their interests. For example, if a user is shown ads for products in which he/she has shown an interest in other online offerings, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google Advertising Network is active are accessed, Google directly executes a code from Google and “(re)marketing tags” (invisible graphics or code, also known as “web beacons”) are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (comparable technologies can also be used instead of cookies). This file records which websites the user visits, which content he/she is interested in and which offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, the time of the visit and further information on the use of the online offering.

The IP address of the users is also recorded, although it is truncated within member states of the European Union or in other signatory states to the EEA Treaty. The full IP address is only sent to and truncated by Google servers in the USA in exceptional cases. The above information may also be linked by Google to such information from other sources. If the user then visits other websites, ads tailored to his/her presumed interests can be displayed to him/her on the basis of his/her user profile.

The user data is processed pseudonymously within the Google Advertising Network. This means that Google does not store and process, for example, the names or e-mail addresses of users, but processes the relevant data on a cookie-related basis within pseudonymous user profiles. Consequently, from Google's point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymization. The information collected by Google Marketing Services about the users is transmitted to Google and stored on Google's servers in the USA.

For more information about how Google uses your information, setting and opt-out options, please read Google's Privacy Policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
    

JETPACK (WORDPRESS STATS)

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online offering within the meaning of Article 6 (1f) GDPR), we use the Jetpack plug-in (in this case, the "Wordpress Stats” sub-function), which integrates a tool for the statistical analysis of visitor access and is provided by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack uses "cookies", which are text files that are stored on your computer and allow your use of the website to be analyzed.

The information generated by the cookie about your use of this online offering is stored on a server in the USA. The data processed can be used to create user profiles, although these are only used for analysis purposes and not for advertising purposes. Further information can be found in Automattic's data privacy statements: https://automattic.com/privacy/ and information on Jetpack cookies at: https://jetpack.com/support/cookies/.
   

FACEBOOK PIXEL, CUSTOM AUDIENCES AND FACEBOOK CONVERSION

Within our online offering, on the basis of our legitimate interests in the analysis, optimization and profitable operation of our online offering and for these purposes, we use the “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook").

Facebook is certified under the Privacy Shield Agreement, meaning that it undertakes to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

With the help of the Facebook pixel, Facebook is able to identify the visitors of our online offering as a target group for the display of ads ("Facebook ads"). Consequently, we use the Facebook pixel so that we only display the Facebook ads to those Facebook users who have actually shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products that are identified on the basis of the websites visited) that we transmit to Facebook (known as “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads match potential user interests and are not considered an annoyance. The Facebook pixel also helps us understand the effectiveness of Facebook ads for statistical and market research purposes by showing whether users have been redirected to our website after clicking on a Facebook ad (known as “conversion”).

Facebook processes the data in accordance with Facebook's Data Policy. Accordingly, general information on the display of Facebook ads is set out in Facebook's Data Policy: https://www.facebook.com/policy. For specific information and details about the Facebook Pixel and how it works, visit the Facebook Help section: https://www.facebook.com/business/help/651294705016616.

You can object to the collection of your data by the Facebook pixel and its use to display Facebook ads. To set what types of ads you see within Facebook, you can visit the page set up by Facebook and follow the instructions on usage-based advertising preferences: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

You can also opt out of the use of cookies for reach measurement and promotional purposes via the opt-out page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and also the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
  

ETRACKER

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online offering within the meaning of Article 6 (1f) GDPR), we use the analysis service “etracker” offered by etracker GmbH, Erste Brunnenstrasse 1 20459 Hamburg.

The data collected is analyzed on an exclusively pseudonymous basis, is only stored on servers in Germany, and is not merged with other data or passed on to third parties.

When user data is stored, the IP addresses, device and domain data of the users, in particular, are also only stored in truncated form or are encrypted so that it is not possible to draw conclusions as to the identity of the individual user. The IP address is truncated at the earliest possible point in time and this process is automated by default. Pseudonymous user profiles are created based on the data processed by etracker using cookies. Identifiers for recognizing an app user, performing session and cross-device tracking and providing behavioral data for remarketing are, however, securely pseudonymized/encrypted. Furthermore, etracker contractually guarantees the protection of users' processed data thanks to the conclusion of a contract data processing agreement in accordance with Article 28 (3) sentence 1 GDPR.

You can object to the collection and saving of data at any time with effect for the future. To prevent your visitor data from being collected and stored in the future, you can obtain an opt-out cookie from etracker using the following link. This will ensure that no visitor data from your browser will be collected and stored by etracker in the future: http://www.etracker.de/privacy?et=VWs5YV.

The opt-out sets an opt-out cookie called "cntcookie" from etracker. Please do not delete this cookie as long as you wish to maintain your objection.

Further information can be found in etracker's data protection provisions: https://www.etracker.com/datenschutz.

BING ADS

Within our online offering and on the basis of our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online offering within the meaning of Article 6 (1f) GDPR), we use the “Bing Ads” conversion and tracking tool offered by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Microsoft stores cookies on the user’s devices in order to enable an analysis of the use of our online offering by users if the latter have accessed our online offering via a Microsoft Bing ad (known as "conversion measurement"). This allows Microsoft and us to recognize that someone has clicked on an ad, has been redirected to our online offering and has reached a previously defined target page (known as the "conversion page"). We only see the total number of users who clicked on a Bing ad and were then redirected to the conversion page. No IP addresses are stored. No personal information relating to the identity of the users is communicated.

Microsoft is certified under the Privacy Shield Agreement, meaning that it undertakes to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).

If users do not wish to participate in the Bing Ads tracking process, they can also deactivate the storage of a cookie that is required for this purpose in their browser settings or using Microsoft's opt-out page: http://choice.microsoft.com/de-DE/opt-out.

Users can find further information on data protection and the cookies used for Microsoft Bing Ads in Microsoft's data privacy statement: https://privacy.microsoft.com/de-de/privacystatement.
 

ONLINE PRESENCES IN SOCIAL MEDIA

We maintain online presences within social networks and platforms in order to communicate with active customers, interested parties and users who are active there, and to inform them about our services.

We would like to point out that user data may be processed outside the European Union within this context. This can pose risks for users because, for example, it may prove more difficult for users to enforce their rights. With regard to US providers certified under the Privacy Shield, we would like to point out that this commitment results in them undertaking to comply with EU data protection standards.

Furthermore, user data is usually processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the platforms that are presumed to match the interests of the users. For these purposes, cookies are usually stored on the user's computer and save information on the user's usage behavior and interests. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the platforms in question and are logged in to them).

Users' personal data is processed on the basis of our legitimate interests in effective user information and communication with users pursuant to Article 6 (1f) GDPR. If the users are asked by the respective providers to consent to data processing (i.e. to give their consent by ticking a checkbox or clicking a “confirm” button, for example), the legal basis for the processing is Article 6 (1a), Article 7 GDPR.

For a detailed description of the individual processing operations and the opportunities to object (opt-out), we refer to the information provided by the providers linked below.

Also in the case of requests for information and the assertion of user rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. If you nevertheless require assistance, please feel free to contact us.

- Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) - data privacy statement: https://www.facebook.com/about/privacy/, opt-out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.

- Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – data privacy statement:  https://policies.google.com/privacy, opt-out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – data privacy statement/opt-out: http://instagram.com/about/legal/privacy/.

- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) - data privacy statement: https://twitter.com/de/privacy, opt-out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

- Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – data privacy statement/opt-out: https://about.pinterest.com/de/privacy-policy.

- LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) - data privacy statement https://www.linkedin.com/legal/privacy-policy, opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.

- Xing (XING AG, Dammtorstrasse 29-32, 20354 Hamburg, Germany) - data privacy statement/opt-out: https://privacy.xing.com/de/datenschutzerklaerung.
 

INTEGRATION OF THIRD-PARTY SERVICES AND CONTENT

Within our online offering and on the basis of our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online offering within the meaning of Article 6 (1f) GDPR), we use content or service offerings of third parties to incorporate their content and services, such as videos or fonts (hereinafter collectively referred to as "content").

This always requires the third-party providers of this content to see users’ IP address, as without the IP address, they cannot send the content to the user’s browser. As a result, the IP address is required to display this content. We strive only to use content whose providers only use the IP address to display the content in question. Third-party providers can also use what are known as pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. “Pixel tags" can be used to evaluate 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 include technical information about the browser and operating system, referring websites, the time of the visit and other information about the use of our online offering. This information may also be linked to such information from other sources.
 

YOUTUBE

We integrate the videos of the "YouTube" platform of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.
 

GOOGLE FONTS

We integrate the fonts (“Google Fonts”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.
 

GOOGLE RECAPTCHA

We integrate the function for the recognition of bots, e.g. for entries in online forms ("ReCaptcha") of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.
 

GOOGLE MAPS

We integrate the maps of the “Google Maps” service of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The data processed may include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (as a rule in the settings of their mobile devices). The data may be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.
 

XING

Functions and contents of the Xing service, offered by XING AG, Dammtorstrasse 29-32, 20354 Hamburg, Germany, may be integrated into our online offering. This may include, for example, content such as images, videos or text and buttons that users can use to share content from this online offering within Xing. If the users are members of the Xing platform, Xing can assign the access to the abovementioned contents and functions to the users’ profiles on Xing. Xing data privacy statement: https://privacy.xing.com/de/datenschutzerklaerung.
 

LINKEDIN

Functions and contents of the LinkedIn service, offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, may be integrated into our online offering. This may include, for example, content such as images, videos or text and buttons that users can use to share content from this online offering within LinkedIn. If the users are members of the LinkedIn platform, LinkedIn can assign the access to the abovementioned contents and functions to the users’ profiles on LinkedIn. LinkedIn data privacy statement: https://www.linkedin.com/legal/privacy-policy.. LinkedIn is certified under the Privacy Shield Agreement, meaning that it undertakes to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active). Privacy Policy: https://www.linkedin.com/legal/privacy-policy, opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
 

HOTJAR

We use Hotjar to better understand the needs of our users and to optimize the offering on this website. With the help of Hotjar technology, we gain a better understanding of our users' experiences (e.g. how much time users spend on which pages, which links they click on, what they like and what they don't like, etc.) and this helps us to tailor our offering to reflect our users' feedback. Hotjar uses cookies and other technologies to collect information about the behavior of our users and their end devices (in particular the IP address of the device (collected and stored in anonymous form only), screen size, device type (unique device identifiers), information about the browser used, location (country only), preferred language for displaying our website). Hotjar stores this information in a pseudonymized user profile. The information is used neither by Hotjar nor by us to identify individual users and is not combined with other data about individual users. You can find further information in Hotjar’s data privacy statement here.

You can object to Hotjar storing a user profile and information about your visit to our website, and to the storage of Hotjar tracking cookies on other websites by clicking on this Opt-Out-Link.
 

USE OF THE SALESVIEWER® TECHNOLOGY

The SalesViewer® technology of SalesViewer® GmbH is used on this website to collect and save data for marketing, market research and optimization purposes.  User profiles may be created using this data under a pseudonym. This involves using what is known as a tracking script, which serves to collect company-related data. The data collected using this technology is not used to personally identify visitors to this website without the express permission of the data subject, and is not matched with any personal information pertaining to the person with the pseudonym.

The collection and storage of data can be revoked at any time with effect for the future by clicking on this link here to prevent future data collection by SalesViewer® within this website. An opt-out cookie for this website is stored on your device for this purpose. If you delete your cookies in this browser, you must click on this link again.

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