Privacy policy

Introduction

The following privacy policy is intended to inform you about the types of personal data (hereinafter also referred to as ‘data’) we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing 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 offering’).

The terms used are not gender-specific.

As of 31 August 2021

Table of contents

  • Introduction
  • Responsible party
  • Overview of processing
  • Relevant legal bases
  • Security measures
  • Transfer of personal data
  • Data processing in third countries
  • Deletion of data
  • Use of cookies
  • Business services
  • Provision of the online offering and web hosting
  • Special notes on applications (apps)
  • Registration, login and user account
  • Contact and enquiry management
  • Newsletters and electronic notifications
  • Video conferences, online meetings, webinars and screen sharing
  • Application process
  • Cloud services
  • Web analysis, monitoring and optimisation
  • Presence on social networks (social media)
  • Plugins and embedded functions and content
  • Management, organisation and support tools
  • Changes and updates to the privacy policy
  • Rights of data subjects
  • Definitions

Controller

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

Email address: office@duncrow.com.

Phone: +43 5522 / 23880.

Legal notice: https://psa38.games/imprint

Overview of processing

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

Types of data processed

  • Master data (e.g. names, addresses).
  • Applicant data (e.g. personal details, postal and contact addresses, documents relating to the application and the information contained therein, such as cover letters, CVs, references and other information provided by applicants in relation to a specific position or voluntarily provided by applicants about themselves or their qualifications).
  • Content data (e.g. entries in online forms).
  • Contact data (e.g. email, 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 the 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 processing

  • Provision of our online offering and user-friendliness.
  • Application process (justification and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Office and organisational procedures.
  • Content Delivery Network (CDN).
  • Direct marketing (e.g. by email or post).
  • 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.
  • Administration and response to enquiries.

Relevant legal bases

Below you will find an overview of the legal bases of the GDPR on 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. If more specific legal bases are relevant in individual cases, we will inform you of this in the privacy policy.

 

  • Consent (Art. 6 (1) (a) GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
  • Contract performance and pre-contractual enquiries (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6(1)(c) GDPR) - Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6(1)(f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • Application process as a pre-contractual or contractual relationship (Art. 9 para. 2 lit. b GDPR) - Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR (e.g. health data, such as severe disability or ethnic origin) are requested from applicants so that the controller or the data subject can exercise their rights under labour law and social security and social protection law and fulfil their obligations in this regard, their processing is carried out in accordance with Art. 9 (2) (b) GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9(2)(c) GDPR or for the purposes of health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector in accordance with Art. 9 (2) (h) GDPR. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Art. 9 (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 Natural Persons with regard to the Processing of Personal Data (Data Protection Act – DSG). The Data Protection Act contains, in particular, 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 transfer, and automated decision-making in individual cases.

 

Security measures

In accordance with legal requirements, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.

These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access, input, transfer, availability and separation. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted and responses are made to data breaches. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and procedures in accordance with the principle of data protection, through technology design and data protection-friendly default settings.

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

Transmission of personal data

As part of our processing of personal data, data may be transmitted to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect 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. If this transfer takes place for administrative purposes, the transfer of the data is based on our legitimate business and commercial interests or takes place if it is necessary to fulfill our contractual 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 if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through 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).Browsers.

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consent permitted for processing is revoked or other permissions no longer apply (e.g. if the purpose for processing this data no longer applies or it is not required for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons 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.

As part of our data protection information, we can provide users with further information on the deletion and retention of data that applies specifically to the respective processing operations.

Use of cookies

Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after their visit to an online service. The information stored may include, for example, the language settings on a website, the login status, a shopping cart or the location 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")

A distinction is made between the following cookie types and functions:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their 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. The interests of users that are used to measure reach or for marketing purposes can also be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • 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 save logins or other user input or for security reasons).
  • Statistical, marketing and personalization cookies: Cookies are also generally used to measure reach and when a user's interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to display content to users that corresponds to their potential interests. This process is also referred to as “tracking”, i.e. tracking the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or when obtaining consent.

Information on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offering 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 on the storage period of permanent cookies (e.g. as part 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 using your browser settings, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. You can also obtain further information 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 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, managed and revoked by users. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. Consent can be stored on the server 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: Consent may be stored for up to two years. A pseudonymous user identifier is created 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.

  • Processed data types: 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 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 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 and associated measures and in the context of communication with the contractual partners (or pre-contractual), e.g. in order to answer inquiries.

We process this data to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. We only pass on the data of contractual partners to third parties within the framework of the applicable law insofar as this is necessary for the aforementioned purposes or to fulfill legal obligations or with the consent of the persons concerned (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). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, as part of this privacy policy.

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 personally.

We delete the data after the expiry of statutory 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 apply in the relationship between the users and the providers.

Project and development 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 associated activities as well as their payment and provision or execution or performance.

The required information is identified as such in the context of the conclusion of the contract, order or comparable contract 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 receive access to information from end customers, employees or other persons, we process this in accordance with legal and contractual requirements.

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 associated activities as well as their payment and delivery or execution or provision.

The required information is identified as such in the context of the conclusion of the contract, order or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to hold any consultations.

  • Processed data types: Inventory data (e.g. names, addresses), Payment data (e.g. bank details, invoices, payment history), Contact data (e.g. email, telephone numbers), Contract data (e.g. subject matter of contract, duration, customer category).
  • Data subjects: Interested parties, business and contractual partners.
  • Purposes of Processing: Provision of contractual services and customer support, contact requests and communication, Office and organizational procedures, Managing and responding to inquiries.
  • Legal bases: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Provision of the online offer and web hosting

In order to provide our online offering securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offering 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 in the context of providing the hosting service may include all information relating to the users of our online service that is generated in the context of use and communication. This regularly includes the IP address, which is necessary in order to be able to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information relating to the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received (unless an end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and receipt on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every 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, date and time of access, data volumes 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 can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and 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 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.

  • Processed data types: 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: Provision of our online services and user-friendliness, Content Delivery Network (CDN).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Special notes on applications (apps)

We process the data of users of our application insofar as this is necessary to provide users with the application and its functionalities, to monitor its security and to develop it further. We may also contact users in compliance with legal requirements if communication is necessary for the purposes of administering or using the application. Otherwise, we refer to the data protection information in this privacy policy with regard to the processing of user data.

Legal basis: The processing of data required to provide the functionalities of the application serves to fulfill contractual obligations. This also applies if the provision of the functions requires user authorization (e.g. release 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 the purpose of optimizing the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly asked for their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.

  • Processed data types: 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 bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Registration, login and user account

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

As part of the use of our registration and login functions and 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. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.

Users can be informed by e-mail about processes that are 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 a legal permission, obligation or consent of the users.

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

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. email, 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: Provision of contractual services and customer service, security measures, managing and responding to inquiries.
  • Legal bases: Fulfillment of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Contact and inquiry management

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

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

  • Processed data types: 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 bases: Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Newsletter and electronic notifications

We only send newsletters, emails and other electronic notifications (hereinafter “newsletter”) with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name so that we can address you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with other people's e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the mailing service provider are also logged.

Deletion and restriction of processing: We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for erasure is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Contents:

Information about us, our services, promotions and offers.

  • Processed data types: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).

  • Data subjects: Communication partners.

  • Purposes of processing: Direct marketing (e.g. by email or post).

  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably email.

Video conferences, online meetings, webinars and screen sharing

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

Data processed by conference platforms: In the context of participation in a conference, the conference platforms process the participants' personal data listed below. The scope of the processing depends on which data is required in the context of a specific conference (e.g. specification of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of holding the conference, the conference platforms may also process participants' data 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 participants' end devices, their operating system, the browser and its technical and language settings, information on the content of the communication processes, i.e. entries in chats as well as audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference providers. If the participants are registered as users with the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider.

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

Data protection measures for participants: Please note the details of the processing of your data by the conference platforms in their data protection notices and select the optimum security and data protection settings for you in the conference platform settings. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by informing roommates, locking doors and, if technically possible, using the function to make the background unrecognizable). Links to the conference rooms and access data must not be passed on to unauthorized third parties.

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

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), 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 support, contact requests and communication, Office and organizational procedures.
  • Legal bases: Consent (Art. 6 Para. 1 S. 1 lit. a. GDPR), Contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Services used and service providers:

Application procedure

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

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

If provided, applicants can send us their applications 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 are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and receipt on our server.

For the purposes of searching for applicants, submitting applications, and selecting applicants, we may, in compliance with legal requirements, use applicant management or recruitment software, platforms, and services from third-party providers.

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

Processing of special categories of data: If, as part of the application process, special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g., health data, such as severe disability status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise their rights under labor law and social security and social protection law and fulfill their obligations in this regard, such data will be processed in accordance with Art. 9 (2) (b) GDPR; in the case of protecting the vital interests of applicants or other persons, in accordance with Art. 9 (2) (c) GDPR. GDPR or for the purposes of preventive healthcare or occupational medicine, for assessing an employee's ability to work, for medical diagnostics, for the provision of care or treatment in the health or social sector, or for the administration of systems and services in the health or social sector pursuant to Art. 9 (2) (h) GDPR. In the case of voluntary consent, the special categories of data are disclosed, their processing is based on Art. 9 (2) (a) GDPR.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship if their application is successful. Otherwise, if the application for a job offer is unsuccessful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a legitimate revocation by the applicant, the data will be deleted after a period of six months at the latest, so that we can answer any follow-up questions regarding the application and fulfill our documentation obligations 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 ongoing application process, and that they can revoke their consent at any time for the future.

  • Types of data processed: Applicant data (e.g., personal information, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letters, CVs, references, and other personal or qualification information provided by applicants with regard to a specific position or voluntarily provided by them).
  • Data subjects: Applicants.
  • Purposes of processing: Application process (establishment and possible subsequent implementation, as well as possible subsequent termination of the employment relationship).
  • Legal basis: Application process 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, email delivery, spreadsheets and presentations, the exchange of documents, content, and information with specific recipients, or the publication of websites, forms, or other content and information, as well as chats and participation in audio and video conferences.

Within this framework, personal data may be processed and stored on the providers' servers if it is part of communication with us or is otherwise processed by us as set out in this privacy policy. This data may include, in particular, user master data and contact details, data on transactions, contracts, other processes, and their contents. The providers of cloud services also process usage data and metadata, which they use for security purposes and to optimize services.

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

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

  • Types of data processed: Inventory data (e.g., names, addresses), contact data (e.g., email, telephone numbers), content data (e.g., entries in online forms), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Data subjects: Customers, employees (e.g., employees, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: Office and organizational procedures.
  • Legal bases: Consent (Art. 6 (1) (a) GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

Web Analysis, Monitoring, and Optimization

Web analysis (also known as "reach measurement") is used to evaluate visitor traffic 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, for example, identify at what time our online offering or its functions or content are most frequently used or encourage reuse. Likewise, we can understand which areas require optimization.

In addition to web analysis, we may also use testing procedures to, for example, 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 for the same purpose. This information may include, for example, content viewed, websites 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.

Users' IP addresses are also stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention 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 recurring visitors), profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR), Legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

Presences on social networks (social media)

We maintain online presences within social networks and, in this context, process user data 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 could result in risks for users, for example, because it could make it more difficult to enforce users' rights.

Furthermore, user data is generally processed within social networks for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of users. These user profiles can, in turn, be used, for example, to place advertisements within and outside the networks that presumably correspond to the users' interests. For these purposes, cookies are generally stored on users' computers, in which the user behavior and interests are stored. Furthermore, data may also be stored in user profiles regardless of the devices used by users (especially if users are members of the respective platforms and are logged in).

For a detailed description of the respective processing methods and the opt-out options, please refer to the privacy policies 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 would like to point out that these can be most effectively asserted with the providers. Only the providers have access to user data and can directly take appropriate measures and provide information. If you still need help, please contact us.

Facebook: We are jointly responsible with Facebook Ireland Ltd. for the collection (but not the further processing) of data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "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 preferences, cookie data; see "Device Information" in the Facebook Data Policy: 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 help them understand how people interact with their Pages and the content associated with them. We have concluded a special agreement with Facebook ("Information on Page Insights", https://www.facebook.com/legal/terms/page_controller_addendum), which specifically regulates the security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e., users can, for example, submit requests for information or deletion directly to Facebook). Users' rights (in particular, the right 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., email, 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 inquiries and communication, feedback (e.g., collecting feedback via online forms), marketing.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

Plugins and Embedded Functions and Content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos, or city maps (hereinafter collectively referred to as "content").

Integration always requires that the third-party providers of this content process the users' IP address, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content or functions. We endeavor to only use content whose respective providers use the IP address solely to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. These "pixel tags" enable information, such as visitor traffic on the pages of this website, to be evaluated. 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, the time of visit, and other information about the use of our online offering, as well as be linked to such information from other sources.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for data processing is consent. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention 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 to display or enhance the user-friendliness of our online offering). The respective providers collect the users' IP address and may process it for the purposes of transmitting the software to the user's browser, for security purposes, and for evaluating and optimizing their offerings.

  • 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., email, 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 offering and user-friendliness, provision of contractual services, and customer service.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR), consent (Art. 6 (1) (a) GDPR), contract fulfillment, and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Services and service providers used:

  • 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. User 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 the technically secure, maintenance-free, and efficient use of fonts, their consistent display, and 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 integrate the maps of the "OpenStreetMap" service, which are offered by the OpenStreetMap Foundation (OSMF) on the basis of the Open Data Commons Open Database License (ODbL). User data is used by OpenStreetMap exclusively for the purpose of displaying the map functions and for caching the selected settings. This data may include, in particular, users' IP addresses and location data, which, however, are not collected without their consent (usually done through their mobile device settings). 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 detect whether entries (e.g., in online forms) are made by humans and not by automatically operating machines (so-called "bots"). The data processed may include IP addresses, information about operating systems, devices, or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies, and the results of manual recognition processes (e.g., answering questions 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://policies.google.com/privacy; Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: 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 option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.

Management, Organization, and Support Tools

We use services, platforms, and software from third-party providers (hereinafter referred to as "third-party providers") for the organization, administration, planning, and provision of our services. We comply with legal requirements when selecting third-party providers and their services.

In this context, personal data may be processed and stored on the servers of third-party providers. This may affect various data that we process in accordance with this Privacy Policy. This data may include, in particular, user master data and contact details, data on transactions, contracts, other processes, and their content.

If users are referred to third-party providers or their software or platforms as part 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 privacy policies of the respective third-party providers.

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for processing data is consent. Furthermore, their use may be part of our (pre-)contractual services, provided the use of third-party providers was agreed upon within this framework. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient, economical, and user-friendly services). In this context, we would also like to draw your attention 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., email, 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 inquiries and communication.
  • Legal bases: Consent (Art. 6 (1) (a) GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

  • WeTransfer: Transfer of files over the internet; Service provider: WeTransfer BV, Oostelijke Handelskade 751, Amsterdam, 1019 BW, Netherlands; Website: https://wetransfer.com; Privacy Policy: https://wetransfer.com/legal/privacy.

Changes and updates to this privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt this privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that these addresses may change over time and ask you to check the information before contacting us.

Rights of data subjects

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

  • Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Article 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
  • Right of withdrawal of consent: You have the right to withdraw consent given at any time.
  • Right of information: You have the right to request confirmation as to whether the data in question is being processed and to access this data, as well as further information and a copy of the data in accordance with the statutory requirements.
  • Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
  • Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to request that data concerning you be erased immediately or, alternatively, to request that processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right, in accordance with the statutory provisions, to receive the data concerning you that you have provided to us in a structured, common, and machine-readable format or to request that it be transmitted to another controller.
  • Complaint to a supervisory authority: In accordance with the statutory provisions 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 in which you habitually 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.

Definitions of Terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are intended primarily to facilitate understanding. The terms are sorted alphabetically.

 

  • Content Delivery Network (CDN): A "Content Delivery Network" (CDN) is a service that enables the faster and more secure delivery of online content, especially large media files such as graphics or program scripts, using regionally distributed servers connected via the Internet.
  • IP Masking: "IP masking" is a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, particularly 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., a cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Profiles with user-related information: The processing of "profiles with user-related information," or "profiles" for short, encompasses any type of automated processing of personal data that consists in using this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information regarding 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 visitor flows 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, for example, determine when visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes to recognize returning visitors and thus obtain more precise analyses of the use of an online service.
  • Controller: The "controller" is the natural or legal person, public authority, agency, or other body that alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: "Processing" is any operation or series of operations performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually every handling of data, be it collection, analysis, storage, transmission, or deletion.