BLEMA Kircheis MAJER M.S. Willett Inc. PAKEA

Privacy

Introduction

This Privacy Policy is intended to inform you about the types of personal data (hereinafter also referred to as “data”) we process, the purposes for which we process it, and the scope of such processing. This 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 the “Online Offer”).

As of: September 2, 2019

Responsible party

Gebrüder Leonhardt GmbH & Co. KG
Blema Kircheis
Erdmann-Kircheis-Straße 13–15
08280 Aue-Bad Schlema
Germany

Authorized Representatives: Uwe Leonhardt
Email Address: datenschutz@blema-kircheis.de
Imprint: https://www.blema.de/impressum

Contact Data Protection Officer

datenschutz@blema-kircheis.de

Overview of Data Processing

The following overview summarizes the types of data processed and the purposes of such processing, and identifies the data subjects.

Types of Data Processed

  • Master data (e.g., names, addresses).
  • Applicant data (e.g., personal details, mailing and contact addresses, documents related to the application and the information contained therein, such as cover letters, resumes, certificates, as well as other information regarding a specific position or voluntarily provided by applicants regarding their personal details or qualifications).
  • Content data (e.g., text entries, photographs, videos).
  • Contact data (e.g., email, phone 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., staff, applicants, former employees).
  • Applicants.
  • Prospective customers.
  • Communication partners.
  • Customers.
  • Users (e.g., website visitors, users of online services).

Purposes of processing

  • Provision of our online services and user-friendliness.
  • Analysis of visitor activity.
  • Application process (justification and any subsequent implementation, as well as possible subsequent termination of the employment relationship).
  • Office and organizational procedures.
  • Direct marketing (e.g., via email or mail).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g., access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g., interest-based/behavioral profiling, use of cookies).
  • Contractual services.
  • Management and response to inquiries.

Applicable Legal Bases

Below, we outline the legal bases under the General Data Protection Regulation (GDPR) on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence or domicile may apply.

  • Consent (Art. 6(1)(a) GDPR) - The data subject has given consent to the processing of personal data concerning him or her for one specific purpose or several specific purposes.
  • Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the data subject’s request.
  • 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.
  • Art. 9(1)(b) GDPR (Application process as a pre-contractual or contractual relationship) (To the extent that, within the scope 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 the rights arising from labor law and the law on social security and social protection and fulfill their respective obligations in this regard, such processing is carried out pursuant to Art. 9(2)(b) GDPR; in the case of the protection of the vital interests of applicants or other persons pursuant to Art. 9(2)(c) GDPR, or for the purposes of preventive healthcare or occupational medicine, for the assessment of an employee’s fitness for work, for medical diagnosis, 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 the provision of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9(2)(a) of the GDPR.) - .

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Germany. These include, in particular, the Act on the Protection against the Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special provisions regarding the right of access, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and the transfer of data, as well as automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), particularly with regard to the establishment, performance, or termination of employment relationships, as well as the consent of employees. In addition, state data protection laws of the individual federal states may apply.

Security Measures

We implement appropriate technical and organizational measures in accordance with legal requirements, 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 risks to the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

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 to, input of, and disclosure of the data, ensuring its availability, and maintaining its separation. Furthermore, we have established procedures that ensure the exercise of data subjects’ rights, the erasure of data, and responses to data breaches. Furthermore, we take the protection of personal data into account from the very beginning of the development or selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default.

SSL Encryption (https): To protect the data you transmit via our online services, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in your browser’s address bar.

Transfer and Disclosure of Personal Data

As part of our processing of personal data, it may occur that the data is transferred to or disclosed to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, payment institutions in connection with payment transactions, service providers entrusted with IT tasks, or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, enter into appropriate contracts or agreements with the recipients of your data to ensure the protection of your data.

Data transfer within the corporate group: We may transfer personal data to other companies within our corporate group or grant them access to this data. If this transfer is made for administrative purposes, the transfer of data is based on our legitimate business and operational interests, or occurs if it is necessary to fulfill our contractual obligations, or if consent from the data subjects or a legal authorization is available.

Use of Cookies

“Cookies” are small files that are stored on users' devices. Cookies can be used to store various types of information. This information may include, for example, language settings on a website, login status, a shopping cart, or the point at which a video was paused.

Cookies are generally also used when a user’s interests or behavior (e.g., viewing certain content, using features, 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 users’ potential interests. We also include other technologies that perform the same functions as cookies under the term “cookies” (e.g., when user information is stored using pseudonymous online identifiers, also known as “user IDs”).

To the extent that we use cookies or “tracking” technologies, we will inform you separately in our Privacy Policy.

Information on Legal Bases: The legal basis on which we process your personal data using cookies depends on whether we ask for your consent. If this applies and you consent to the use of cookies, the legal basis for processing your data is your expressed consent. Otherwise, the data processed using cookies is 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.

Withdrawal and Objection (Opt-Out): Regardless of whether processing is based on consent or legal authorization, you have the option at any time to withdraw any consent you have given or to object to the processing of your data via cookie technologies (collectively referred to as “opt-out”).

You can initially express your objection through your browser settings, e.g., by disabling the use of cookies (although this may also limit the functionality of our online offering).

Objection to the use of cookies for online marketing purposes can be expressed through a variety of services, particularly in the case of tracking, via the U.S. site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ or generally at http://optout.aboutads.info.

Processing of cookie data based on consent: Before we process or have data processed in connection with the use of cookies, we ask users for their consent, which may be revoked at any time. Until consent is given, only cookies necessary for the operation of our online service will be used. Their use is based on our interest and the interest of users in the expected functionality of our online service.

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

Contacting Us

When you contact us (e.g., via the contact form, email, phone, or social media), we process the information provided by the person making the inquiry to the extent necessary to respond to the inquiry and to take any requested actions.

Responding to contact inquiries within the scope of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre-)contractual inquiries, and otherwise based on the legitimate interests in responding to the inquiries.

  • Types of data processed: Master data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., text entries, photographs, videos).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact inquiries and communication.
  • Legal basis: Performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Communication via Messenger

We use messenger services for communication purposes and therefore ask that you review the following information regarding the functionality of the messengers, encryption, the use of communication metadata, and your options for objecting.

You can also contact us through alternative channels, such as by phone or email. Please use the contact options provided to you or those listed on our website.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we would like to point out that the communication content (i.e., the content of the message and attached images) is encrypted end-to-end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use an up-to-date version of the messenger with encryption enabled to ensure that the message content is encrypted.

However, we also inform our communication partners that while the messenger providers do not view the content, they can determine whether and when communication partners are communicating with us, as well as process technical information about the communication partners’ devices and, depending on their device settings, location information (so-called metadata).

Notes on Legal Bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Furthermore, if we do not ask for consent and you, for example, contact us on your own initiative, we use messengers in our relationship with our contractual partners and in the context of contract initiation as a contractual measure, and in the case of other interested parties and communication partners, based on our legitimate interests in fast and efficient communication and in meeting our communication partners’ needs regarding communication via messengers. Furthermore, we would like to point out that we do not initially transmit the contact data provided to us to the messaging services without your consent.

Withdrawal, Objection, and Deletion: You may withdraw any consent you have given at any time and object to communication with us via messaging services at any time. In the case of communication via messaging services, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any inquiries from the communication partner, provided that no reference back to a previous conversation is expected and no legal retention obligations preclude the deletion.

Reservation Regarding Redirection to Other Communication Channels: Finally, we would like to point out that, for your security, we reserve the right not to respond to inquiries via Messenger. This is the case, for example, if internal contractual matters require special confidentiality or if a response via Messenger does not meet formal requirements. In such cases, we will direct you to more appropriate communication channels.

Skype: Skype’s end-to-end encryption requires that it be enabled (unless it is enabled by default).

  • Types of data processed: Contact data (e.g., email, phone numbers), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), content data (e.g., text entries, photographs, videos).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication, direct marketing (e.g., via email or mail).
  • Legal bases: Consent (Art. 6(1)(a) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers used:

Online Conferences, Meetings, and Webinars

We use platforms and applications from other providers (hereinafter referred to as “third-party providers”) for the purpose of conducting video and audio conferences, webinars, and other types of video and audio meetings. When selecting third-party providers and their services, we comply with legal requirements.

In this context, data from communication participants is processed and stored on the third-party providers’ servers to the extent that such data is part of communication processes with us. This data may include, in particular, registration and contact information, visual and audio contributions, as well as chat entries and shared screen content.

If users are referred to third-party providers, or their software or platforms, in the context of communication, business, or other relationships with us, the third-party providers may process usage data and metadata, which they process for security, service optimization, or marketing purposes. We therefore ask that you review 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 the processing is consent. Furthermore, their use may be part of our (pre)contractual services, provided that the use of third-party providers has been agreed upon in this context. Otherwise, user data is processed based on our legitimate interests (i.e., interest in efficient In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Master data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., text entries, photographs, videos), 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: Contractual services, contact requests and communication, office and organizational procedures.
  • Legal bases: Consent (Art. 6(1)(a) GDPR), performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers used:

Provision of the Online Service and Web Hosting

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

The data processed in connection with the provision of hosting services may include all information relating to users of our online services that is generated during use and communication. This regularly includes the IP address, which is necessary to deliver the content of online services to browsers, and all entries made within our online service or on websites.

Email Sending and Hosting: The web hosting services we use also include the sending, receiving, and storage of emails. For these purposes, the addresses of the recipients and senders, as well as further information regarding email transmission (e.g., the providers involved) and the contents of the respective emails, are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that emails are generally not sent in encrypted form over the internet. As a rule, emails are encrypted during transmission but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We therefore cannot assume any responsibility for the transmission of emails between the sender and their receipt on our server.

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

The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (particularly in the case of malicious attacks, so-called DDoS attacks), and, on the other hand, to ensure server capacity and stability.

  • Types of data processed: Content data (e.g., text entries, photographs, videos), 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: Legitimate interests (Art. 6(1)(f) GDPR).

Application Process

The application process requires applicants to provide us with the information necessary for their evaluation and selection. The specific information required is outlined in the job description or, in the case of online forms, in the instructions provided there.

Generally, the required information includes personal details such as name, address, contact information, and proof of the qualifications necessary for the position. Upon request, we are also happy to provide further details regarding the required information.

If available, applicants may submit their applications to us via an online form. The data is transmitted to us in encrypted form using state-of-the-art technology. Applicants may also submit their applications to us via email. However, please note that emails are generally not sent in encrypted form over the internet. While emails are typically encrypted during transmission, they are not encrypted on the servers from which they are sent or received. We therefore cannot assume any responsibility for the transmission of the application between the sender and its receipt on our server.

For the purposes of candidate search, submission of applications, and selection of candidates, we may use applicant tracking or recruitment software, as well as platforms and services from third-party providers, in compliance with legal requirements.

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

Processing of special categories of data: To the extent that 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), so that the controller or the data subject can exercise the rights arising from labor law and the law on social security and social protection and fulfill their respective obligations in this regard, such processing is carried out in accordance with Article 9(2)(b) GDPR; in the case of the protection of the vital interests of applicants or other persons pursuant to Art. 9(2)(c) GDPR, or for the purposes of preventive healthcare or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnosis, for 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 event that special categories of data are provided on the basis of voluntary consent, their processing is based on Article 9(2)(a) of the GDPR.

Deletion of Data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job opening 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. Deletion takes place, subject to a valid revocation by the applicant, no later than after the expiration of a period of six months, so that we can answer any follow-up questions regarding the application and fulfill our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any travel expense reimbursements are archived in accordance with tax law requirements.

Inclusion in a Candidate Pool: Inclusion in a candidate pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the ongoing application process, and that they may revoke their consent at any time with future effect.

Duration of data retention in the candidate pool in months: 6 months

  • Types of data processed: Applicant data (e.g., personal details, mailing and contact addresses, documents submitted with the application and the information contained therein, such as cover letters, resumes, certificates, as well as other information regarding a specific position or voluntarily provided by applicants regarding their personal details or qualifications).
  • Data subjects: Applicants.
  • Purposes of processing: Application process (establishment and any subsequent implementation, as well as possible subsequent termination of the employment relationship).
  • Legal basis: Art. 9(1)(b) GDPR (recruitment process as a pre-contractual or contractual relationship) (To the extent that 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 the rights arising from labor law and the law on social security and social protection and fulfill their respective obligations in this regard, such processing is carried out pursuant to Art. 9(2)(b) GDPR; in the case of the protection of the vital interests of applicants or other persons pursuant to Art. 9(2)(c) GDPR, or for the purposes of preventive healthcare or occupational medicine, for the assessment of the employee’s fitness for 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 pursuant to Art. 9(2)(h) GDPR. In the case of the provision of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9(2)(a) of the GDPR.

Cloud Services

We use software services accessible via the Internet and run on their providers’ servers (so-called “cloud services,” also known as “Software as a Service”) for the following purposes: document storage and management, calendar management, email sending, spreadsheets and presentations, sharing documents, content, and information with specific recipients, or publishing websites, forms, or other content and information, as well as chats and participation in audio and video conferences.

In this context, personal data may be processed and stored on the providers’ servers to the extent that such data is part of communication processes with us or is otherwise processed by us as set forth in this Privacy Policy. This data may include, in particular, users’ master data and contact information, as well as data regarding transactions, contracts, other processes, and their contents. The cloud service providers also process usage data and metadata, which they use for security purposes and to optimize their services.

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

Notes on Legal Bases: If we request consent for 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: Master data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., text entries, photographs, videos), usage data (e.g., websites visited, interest in content, access times), Meta/communication data (e.g., device information, IP addresses), contract data (e.g., subject matter of the contract, term, customer category).
  • Data subjects: Customers, employees (e.g., staff, applicants, former employees), prospective customers, communication partners.
  • Purposes of processing: Office and organizational procedures.
  • Legal basis: Consent (Art. 6(1)(a) GDPR), performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR), legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers used:

Online Marketing

We process personal data for online marketing purposes, which include, in particular, the display of advertising and other content (collectively referred to as “Content”) based on users' potential interests, as well as the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (a so-called “cookie”) or similar methods are used to store user information relevant to the display of the aforementioned content. This information may include, for example, content viewed, websites visited, online networks used, as well as communication partners and technical details such as the browser used, the computer system used, and information regarding usage times. If users have consented to the collection of their location data, this may also be processed.

Users’ IP addresses are also stored. However, we use IP masking methods (i.e., pseudonymization by truncating the IP address) to protect users. Generally, no clear user data (such as email addresses or names) is stored as part of online marketing procedures; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is generally stored in cookies or via similar methods. These cookies can generally also be read later on other websites that use the same online marketing process, analyzed for the purpose of displaying content, supplemented with additional data, and stored on the server of the online marketing service provider.

In exceptional cases, clear data may be associated with the profiles. This is the case, for example, when users are members of a social network whose online marketing methods we use and the network links the users’ profiles to the aforementioned information. Please note that users may enter into additional agreements with the providers, e.g., by giving consent during registration.

We generally only have access to aggregated information regarding the success of our advertisements. However, within the scope of so-called conversion tracking, we can determine which of our online marketing methods led to a so-called conversion, i.e., for example, the conclusion of a contract with us. Conversion tracking is used solely to analyze the success of our marketing measures.

Information 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 on the basis of our legitimate interests (i.e., interest in efficient, cost-effective, and user-friendly services). In this context, we would also like to draw your attention to the information regarding 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), prospective customers.
  • Purposes of processing: Tracking (e.g., interest-based/behavioral profiling, use of cookies), remarketing, visit campaign analysis, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measuring the effectiveness of marketing measures), reach measurement (e.g., access statistics, identification of returning visitors).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6(1)(a) GDPR), Legitimate interests (Art. 6(1)(f) GDPR).
  • Right to object (opt-out): We refer you to the privacy policies of the respective providers and the opt-out options provided by them. If no explicit opt-out option has been provided, you have the option of disabling cookies in your browser settings. However, this may limit certain functions of our online service. We therefore also recommend the following opt-out options, which are offered in summary form for the respective regions: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: http://optout.aboutads.info.

Services and service providers used:

Social Media Presence

We maintain an online presence on social media platforms to communicate with users active on those platforms or to provide information about us.

Please note that this may involve the processing of user data outside the European Union. This may pose risks to users, as it could, for example, make it more difficult to enforce their rights. With regard to U.S. providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we note that they thereby commit to complying with EU data protection standards.

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

For a detailed description of the respective forms of processing and the options for objection (opt-out), we refer you to the privacy policies and information provided by the operators of the respective networks.

We also note that requests for information and the exercise of data subject rights are most effectively addressed directly with the providers. Only the providers have access to users’ data and can take appropriate measures and provide information directly. If you still require assistance, please contact us.

  • Types of data processed: Master data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., text entries, photographs, videos), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, tracking (e.g., interest-based/behavioral profiling, use of cookies), remarketing, reach measurement (e.g., access statistics, recognition of returning visitors).
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).

Services and service providers used:

Plugins, Embedded Features, and Content

We incorporate features and content elements into our online platform that are sourced from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may include, for example, graphics, videos, social media buttons, and posts (hereinafter collectively referred to as “content”).

This integration always requires that the third-party providers of this content process the user’s IP address, as they would not be able to send the content to the user’s browser without it. The IP address is therefore necessary for the display of this content or these functions. We strive to use only such content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Through these “pixel tags,” information such as visitor traffic on the pages of this website can be analyzed. The pseudonymous information may also be stored in cookies on the user’s device and may include, among other things, technical information about the browser and operating system, referring websites, time of visit, and other details regarding the use of our online offering, as well as being 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 on the basis of our legitimate interests (i.e., interest in efficient, cost-effective, and user-friendly services). In this context, we would also like to draw your attention to the information regarding 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), master data (e.g., names, addresses), contact data (e.g., email, phone numbers), content data (e.g., text entries, photographs, videos).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness, contractual services, security measures, administration, and responding to inquiries.
  • Legal basis: Legitimate interests (Art. 6(1)(f) GDPR), consent (Art. 6(1)(a) GDPR), performance of a contract and pre-contractual inquiries (Art. 6(1)(b) GDPR).

Services and service providers used:

Changes and Updates to the Privacy Policy

We ask that you review the content of our Privacy Policy on a regular basis. We will update the Privacy Policy as soon as changes to our data processing practices make it necessary to do so. We will notify you as soon as the changes require action on your part (e.g., consent) or any other individual notification.

Rights of Data Subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 through 18 and 21 of the GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you that is carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed, as well as access to such data, further information, and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request that data concerning you be completed or that incorrect data concerning you be rectified.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without delay, or alternatively, in accordance with legal requirements, to request a restriction on the processing of the data.
  • Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request that it be transmitted to another controller.
  • Complaint to a supervisory authority: You also have the right, in accordance with legal requirements, to lodge a complaint with a supervisory authority—in particular in the Member State of your habitual residence, your workplace, or the place of the alleged infringement—if you believe that the processing of your personal data violates the GDPR.

Supervisory authority responsible for us:

Sächsischer Datenschutzbeauftragter
Devrientstraße 5
01067 Dresden
Germany
Phone: 03 51/85471-101
Fax: 03 51/85471-109
Email: saechsdsb@slt.sachsen.de
Website: http://www.datenschutz.sachsen.de

Definitions

This section provides an overview of the terms used in this Privacy Policy. Many of these terms are derived from the law and are defined primarily in Article 4 of the GDPR. The legal definitions are binding. The explanations below, however, are intended primarily to aid understanding. The terms are listed in alphabetical order.

  • Conversion Tracking: "Besuchsaktionsauswertung" (englisch "Conversion Tracking") bezeichnet ein Verfahren, mit dem die Wirksamkeit von Marketingmaßnahmen festgestellt werden kann. Dazu wird im Regelfall ein Cookie auf den Geräten der Nutzer innerhalb der Webseiten, auf denen die Marketingmaßnahmen erfolgen, gespeichert und dann erneut auf der Zielwebseite abgerufen. Beispielsweise können wir so nachvollziehen, ob die von uns auf anderen Webseiten geschalteten Anzeigen erfolgreich waren).
  • IP-Masking: “IP masking” refers to a method in which the last octet—i.e., the last two digits 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 marketingInterest-Based and Behavioral Marketing: Interest-based and/or behavioral marketing refers to the practice of predicting users’ potential interests in ads and other content as accurately as possible. This is done based on information about their prior behavior (e.g., visiting and spending time on specific websites, purchasing behavior, or interaction with other users), which is stored in a so-called profile. Cookies are generally used for these purposes.
  • Conversion tracking: Conversion tracking is a method used to determine the effectiveness of marketing measures. To do this, a cookie is typically stored on users’ devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
  • Personal Data: “Personal data” refers to any information relating to an identified or identifiable natural person (hereinafter “data subject”); a natural person is considered identifiable if they 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.
  • Profiling: “Profiling” refers to any form of automated processing of personal data consisting of the use of such personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this includes information regarding age, gender, location data and movement data, interaction with websites and their content, purchasing behavior, and social interactions with other people) or to predict them (e.g., interests in specific content or products, click behavior on a website, or location). Cookies and web beacons are frequently used for profiling purposes.
  • Audience measurement: Audience measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and may include the behavior or interests of visitors regarding specific information, such as website content. With the help of reach analysis, website owners can, for example, determine at what times visitors access their website and what content interests them. This allows them, for example, to better tailor the website’s content to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are frequently used to identify returning visitors and thus obtain more accurate analyses of the use of an online service.
  • Remarketing: The terms “remarketing” or “retargeting” are used when, for example, a website records which products a user has shown interest in for advertising purposes, in order to remind the user of these products on other websites, such as through advertisements.
  • Tracking: “Tracking” refers to the ability to track user behavior across multiple online services. Typically, behavioral and interest-based information regarding the online services used is stored in cookies or on the servers of the providers of tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Controller: The “controller” is the natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, whether it involves collection, evaluation, storage, transmission, or deletion.
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