Privacy Policy

Privacy policy

Preamble

With the following privacy policy, we would like to inform you about what types of your 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 the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender specific.

Status: 10 January 2025

Preamble
Person responsible
Contact data protection officer
Overview of processing
Relevant legal bases
Safety measures
Transmission of personal data
International data transfers
Rights of the data subjects
Business services
Business processes and procedures
Payment procedure
Provision of the online offer and web hosting
Use of cookies
Blogs and publication media
Contact and enquiry management
Video conferences, online meetings, webinars and screen sharing
Cloud services
Newsletter and electronic notifications
Advertising communication via e-mail, post, fax or telephone
Web analysis, monitoring and optimisation
Customer reviews and evaluation process
Presence in social networks (social media)
Plug-ins and embedded functions and content
Management, organisation and support tools
Processing of data in the context of employment relationships
Application procedure

Person responsible

Edl Consulting AG
Haldenstrasse 14
8716 Schmerikon
Switzerland

Persons authorised to represent the company: Alexandra Edl, Ralf Edl

E-mail address: contact@edl-consulting.com

Contact data protection officer

If you have any questions about data protection, please contact our data protection advisor:

PlanSec AG
Dieter Huber
Sinserstrasse 67
CH-6330 Cham

mail@plansec.ch
https://www.plansec.ch

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

Inventory data.
Employee data.
Payment data.
Contact details.
Content data.
Contract data.
Usage data.
Meta, communication and process data.
Social data.
Applicant data.
Image and/or video recordings.
Sound recordings.
Protocol data.
Performance and behaviour data.
Working time data.
Creditworthiness data.
Salary data.

Special categories of data

Health data.
Religious or ideological beliefs.
Trade union membership.

Purposes of the processing

Provision of contractual services and fulfilment of contractual obligations.
Communication.
Safety measures.
Direct marketing.
Reach measurement.
Tracking.
Office and organisational procedures.
Conversion measurement.
Target group formation.
Organisational and administrative procedures.
Application procedure.
Feedback.
Marketing.
Profiles with user-related information.
Provision of our online services and user-friendliness.
Assessment of creditworthiness and credit standing.
Establishment and implementation of employment relationships.
Information technology infrastructure.
Financial and payment management.
Public relations.
Sales promotion.
Business processes and business management procedures.

Relevant legal bases

Relevant legal bases according to the GDPR: Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.

Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. 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 para. 1 sentence 1 lit. c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 para. 1 sentence 1 lit. 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 procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants as part of the application procedure (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the controller or the data subject can exercise their rights under labor 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 para. 2 lit. b. GDPR. GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, health or social care or treatment or for the management of health or social care systems and services pursuant to Art. 9 para. 2 lit. h. GDPR. 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 para. 2 lit. a. GDPR.
Processing of special categories of personal data relating to health care, employment and social security (Art. 9 para. 2 lit. h) GDPR) – Processing is necessary for the purposes of preventive or occupational medicine, for the assessment of an employee’s fitness for work, for medical diagnosis, the provision of health or social care or treatment or for the management of health or social care systems and services on the basis of Union or Member State law or on the basis of a contract with a health professional.

Relevant legal bases according to the Swiss Data Protection Act: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (“Swiss FADP” for short). Unlike the GDPR, for example, the Swiss FADP does not generally require that a legal basis for the processing of personal data be specified and that the processing of personal data be carried out in good faith, lawfully and proportionately (Art. 6 para. 1 and 2 of the Swiss FADP). In addition, personal data is only obtained by us for a specific purpose recognisable to the data subject and only processed in a way that is compatible with this purpose (Art. 6 para. 3 of the Swiss FADP).

Note on the applicability of the GDPR and Swiss FADP: This data protection notice serves to provide information in accordance with both the Swiss FADP and the General Data Protection Regulation (GDPR). For this reason, please note that the terms of the GDPR are used due to the broader geographical application and comprehensibility. In particular, instead of the terms “processing” of “personal data”, “overriding interest” and “sensitive personal data” used in the Swiss DPA, the terms “processing” of “personal data”, “legitimate interest” and “special categories of data” used in the GDPR are used. However, the legal meaning of the terms will continue to be determined in accordance with the Swiss DPA within the scope of application of the Swiss DPA.

Security measures

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

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

Securing online connections using TLS/SSL encryption technology (HTTPS): To protect user data transmitted via our online services from unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information transmitted between the website or app and the user’s browser (or between two servers), protecting the data from unauthorised access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. If a website is secured by an SSL/TLS certificate, this is signalled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being transmitted securely and encrypted.

Transmission of personal data

As part of our processing of personal data, it may be transmitted to other bodies, companies, legally independent organisational 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.

International data transfers

Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this only takes place in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de. As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognised the level of data protection for certain companies from the USA as secure as part of the adequacy decision of 10 July 2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.

Disclosure of personal data abroad: In accordance with the Swiss FADP, we only disclose personal data abroad if adequate protection of the data subjects is guaranteed (Art. 16 Swiss FADP). If the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international agreements, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC) or internal company data protection regulations recognised in advance by the FDPIC or a competent data protection authority in another country. According to Art. 16 of the Swiss DPA, exceptions for the disclosure of data abroad may be authorised if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public or data from a register provided for by law. These disclosures are always made in accordance with legal requirements. As part of the so-called “Data Privacy Framework” (DPF), the Swiss have recognised the level of data protection for certain companies from the USA as secure as part of the adequacy decision of 7 June 2024. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework.

Rights of the data subjects

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

Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Right to withdraw consent: You have the right to withdraw your consent at any time.
Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain information about this data and further information and a copy of the data in accordance with the legal requirements.
Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller.
Complaint to a supervisory authority: In accordance with the legal requirements 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 are habitually resident, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Rights of data subjects under the Swiss DPA:

As a data subject, you have the following rights in accordance with the provisions of the Swiss Data Protection Act:

Right of access: You have the right to request confirmation as to whether personal data concerning you is being processed and to receive the information necessary to enable you to assert your rights under this law and to ensure transparent data processing.
Right to data surrender or transfer: You have the right to request the surrender of your personal data that you have provided to us in a commonly used electronic format.
Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
Right to object, erasure and destruction: You have the right to object to the processing of your data and to request that the personal data concerning you be erased or destroyed.

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 with regard to communication with the contractual partners (or pre-contractual), for example to respond to enquiries.

We use this data to fulfil our contractual obligations. These include, in particular, the obligations to provide the agreed services, any updating obligations and remedies in the event of warranty and other service disruptions. In addition, we use the data to safeguard our rights and for the purpose of the administrative tasks associated with these obligations and the company organisation. We also process the data on the basis of our legitimate interests both in the proper and efficient management of our business and in security measures to protect our contractual partners and our business operations from misuse, jeopardising their data, secrets, information and rights (e.g. to involve telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners will be informed about other forms of processing, such as 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 labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after four 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 ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications and generally after the end of the order.

Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Payment data (e.g. bank details, invoices, payment history); Contact data (e.g. postal and email addresses or telephone numbers); Contract data (e.g. subject matter of the contract, duration, customer category); Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); Applicant data (e.g. personal details, postal addresses, email addresses and telephone numbers). page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other personal or qualification information provided by applicants with regard to a specific position or voluntarily). Employee data (information on employees and other persons in an employment relationship).
Data subjects: Service recipients and clients; interested parties; business and contractual partners; applicants. Employees (e.g. employees, applicants, temporary staff and other employees).
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication; office and organisational procedures; organisational and administrative procedures; business processes and business management procedures. Conversion measurement (measurement of the effectiveness of marketing measures).
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR); Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Recruitment services: We process the data of our clients and candidates (uniformly referred to as “clients”) for the provision of personnel services, including recruitment, personnel development and payroll. The required information is labelled as such when the order is placed 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. If we gain access to information from end customers, employees or other persons, we process this in accordance with legal and contractual requirements.
Procedures required in the context of personnel services include the recruitment of specialists, the development of training and further training measures, the administration of personnel files and payroll accounting as well as the provision of HR advice and support. It also includes conducting application processes and interviews, matching requirements between clients and candidates, selecting suitable candidates for vacancies and monitoring working hours and performance records; Legal bases: Contract fulfilment and pre-contractual enquiries (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).
Coaching: We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide our services to them. The procedures that are carried out as part of and for the purposes of coaching include Contacting and communicating with clients, needs analysis to determine appropriate coaching interventions, planning and conducting coaching sessions, documenting coaching progress, collecting and managing client-specific information and data, scheduling and organising appointments, providing coaching materials and resources, billing and payment management, follow-up and follow-up of coaching sessions, quality assurance and feedback processes.
The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship.
If it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or if the client has given consent, we disclose or transfer the client’s data to third parties or agents, such as authorities, billing offices and in the area of IT, office or comparable services, in compliance with professional regulations; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Consulting: We process the data of our clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide our services to them. The processes that are part of and for the purposes of consulting include Contacting and communicating with clients, conducting needs and requirements analyses, planning and implementing consulting projects, documenting project progress and results, collecting and managing client-specific information and data, scheduling and organising appointments, providing consulting resources and materials, billing and payment management, post-processing and follow-up of consulting projects, quality assurance and feedback processes. The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and client relationship.
If it is necessary for the fulfilment of our contract, for the protection of vital interests or by law, or with the consent of the client, we disclose or transfer the client’s data to third parties or agents, such as authorities, subcontractors or in the field of IT, office or comparable services, in compliance with professional regulations; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Data analysis: We process the data of our customers and clients in order to enable them to analyse, evaluate and advise on data and to provide related services. The required information includes the information required for analysis, evaluation and billing as well as contact information for necessary coordination. Insofar as we receive access to information from end customers, employees or other persons, we process this in accordance with the legal and contractual requirements; legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Online courses and online training: We process the data of participants in our online courses and online training programmes (uniformly referred to as “participants”) in order to be able to provide them with our course and training services. The data processed in this context, the type, scope, purpose and necessity of its processing are determined by the underlying contractual relationship. The data generally includes information on the courses and services utilised and, if part of our range of services, personal specifications and results of the participants. The forms of processing also include the performance assessment and evaluation of our services and those of the course and training instructors. In addition, depending on the features and structure of the respective courses or learning content, further processing operations may be implemented, such as attendance tracking to document participation, progress monitoring to measure and analyse learning progress by collecting examination and test results and analysing interactions in learning platforms, such as forum posts and task submissions; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Recruiting services: We process the data of job candidates and the personal data of potential employers or their employees as part of our services, which include in particular the search for potential job candidates, contacting them and placing them.
We process the information and contact details provided by the job candidates for the purposes of establishing, implementing and, if necessary, terminating a contract for job placement. In addition, we can ask interested parties questions about the success of our placement service at a later date in accordance with legal requirements.
We process the data of job candidates and employers to fulfil our contractual obligations in order to be able to process the job placement requests submitted to us to the satisfaction of the parties involved.
We may record the placement processes in order to be able to prove the existence of the contractual relationship and the consent of the interested parties in accordance with the statutory accountability obligations (Art. 5 para. 2 GDPR). This information is stored for a period of three to four years if we need to prove the original enquiry (e.g. to be able to prove the authorisation to contact the job candidates); legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Management consulting: We process the data of our customers, clients, interested parties and other clients or contractual partners (uniformly referred to as “customers”) in order to be able to provide them with our contractual or pre-contractual services, in particular consulting services. The processed data, the type, scope, purpose and necessity of its processing are determined by the underlying contractual and business relationship.
If it is necessary for the fulfilment of our contract or required by law, or if the customer has given their consent, we disclose or transfer the customer’s data to third parties or agents, such as authorities, courts or in the field of IT, office or comparable services, in compliance with professional regulations; legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Brokerage services: We process the information provided by interested parties as part of the brokerage enquiry for the purposes of establishing, implementing and, if applicable, terminating a contract for the brokerage of offers from providers of the products or services requested by them.
We use the contact details of interested parties to specify their enquiry using the agreed or otherwise permitted communication channel (e.g. telephone or email) and to suggest suitable providers or offers based on the specified enquiry. In addition, we can ask interested parties questions about the success of our brokerage service at a later date, in accordance with legal requirements.
We process the data of both interested parties and providers in order to fulfil our contractual obligations, to link the enquiry submitted to us by interested parties with suitable offers from providers and to forward them to appropriate providers or to suggest providers.
We can log the entries in the online form sent by interested parties in order to be able to prove the existence of the contractual relationship and the consent of the interested parties in accordance with the statutory accountability obligations (Art. 5 para. 2 GDPR). This information is stored for a period of three to four years if we need to prove the original enquiry (e.g. in order to be able to prove the authorisation to contact the interested parties); legal basis: contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Business processes and procedures

Personal data of service recipients and clients – including customers, clients or, in special cases, clients, patients or business partners as well as other third parties – are processed within the scope of contractual and comparable legal relationships and pre-contractual measures such as the initiation of business relationships. This data processing supports and facilitates business processes in areas such as customer management, sales, payment transactions, accounting and project management.

The data collected is used to fulfil contractual obligations and efficiently design operational processes. This includes the processing of business transactions, the management of customer relationships, the optimisation of sales strategies and the guarantee of internal accounting and financial processes. In addition, the data supports the protection of the rights of the controller and promotes administrative tasks and the organisation of the company.

Personal data may be passed on to third parties if this is necessary to fulfil the stated purposes or legal obligations. The data will be deleted after expiry of statutory retention periods or if the purpose of the processing no longer applies. This also includes data that must be stored for a longer period of time due to tax and legal obligations to provide evidence.

Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); contract data (e.g. subject matter of the contract, term, customer category); log data (e.g. log files relating to logins or retrieval of data or access times); usage data (e.g. page views and visits, access times). contract object, term, customer category); log data (e.g. log files relating to logins or the retrieval of data or access times); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); creditworthiness data (e.g. credit score received, estimated probability of default, risk classification based on this, historical payment behaviour). Meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved).
Data subjects: Service recipients and clients; interested parties; communication partners; business and contractual partners; third parties; users (e.g. website visitors, users of online services). Employees (e.g. employees, applicants, temporary staff and other employees).
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; office and organisational procedures; business processes and business management procedures; communication; marketing; sales promotion; public relations; assessment of creditworthiness and credit standing; financial and payment management. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).

Further information on processing operations, procedures and services:

Contact management and maintenance: Procedures required to organise, maintain and secure contact information (e.g. setting up and maintaining a central contact database, regularly updating contact information, monitoring data integrity, implementing data protection measures, ensuring access controls, performing backups and restoring contact data, training employees in the effective use of contact management software, regularly reviewing communication history and adapting contact strategies); Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
General payment transactions: Procedures required for the execution of payment transactions, the monitoring of bank accounts and the control of payment flows (e.g. creation and verification of transfers, processing of direct debit transactions, checking of account statements, monitoring of incoming and outgoing payments, return debit management, account reconciliation, cash management); legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Bookkeeping, accounts payable, accounts receivable: Procedures required for recording, processing and controlling business transactions in the area of accounts payable and accounts receivable (e.g. Creation and checking of incoming and outgoing invoices, monitoring and management of open items, execution of payment transactions, processing of dunning procedures, account reconciliation in the context of receivables and payables, accounts payable and accounts receivable); Legal basis: Contract fulfilment and pre-contractual enquiries (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).
Financial accounting and taxes: Procedures required for the recording, administration and control of financially relevant business transactions as well as the calculation, reporting and payment of taxes (e.g. Account assignment and posting of business transactions, preparation of quarterly and annual financial statements, execution of payment transactions, processing of dunning procedures, account reconciliation, tax advice, preparation and submission of tax returns, processing of tax matters); Legal basis: Contract fulfilment and pre-contractual enquiries (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).
Marketing, advertising and sales promotion: Procedures required in the context of marketing, advertising and sales promotion (e.g. market analysis and target group determination, development of marketing strategies, planning and implementation of advertising campaigns, design and production of advertising materials, online marketing including SEO and social media campaigns, event marketing and trade fair participation, customer loyalty programmes, sales promotion measures, performance measurement and optimisation of marketing activities, budget management and cost control); legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Public relations: Procedures required in the context of public relations (e.g. development and implementation of communication strategies, planning and implementation of PR campaigns, creation and distribution of press releases, maintenance of media contacts, monitoring and analysis of media response, organisation of press conferences and public events, crisis communication, creation of content for social media and company websites, management of corporate branding); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Payment procedure

As part of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and use other service providers in addition to banks and credit institutions (collectively referred to as “payment service providers”).

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and the data protection information of the payment service providers.

Payment transactions are subject to the terms and conditions and data protection notices of the respective payment service providers, which can be accessed on the respective websites or transaction applications. We also refer to these for further information and the assertion of cancellation, information and other data subject rights.

Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Persons affected: Service recipients and clients; business and contractual partners. Interested parties.
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Business processes and business management procedures.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full. Basis for third country transfers: Switzerland – adequacy decision (Luxembourg).

Provision of the online offer and web hosting

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

Processed data types: Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved). Log data (e.g. log files relating to logins or the retrieval of data or access times).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.). Security measures.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web host”); Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Collection of access data and log files: Access to our online offering is logged in the form of 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 event of abusive attacks, so-called DDoS attacks), and to ensure the utilisation of the servers and their stability; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidentiary purposes is excluded from erasure until the respective incident has been finally clarified.

Use of cookies

The term “cookies” refers to functions that store information on users’ end devices and read it from them. Cookies can also be used for various purposes, for example to ensure the functionality, security and convenience of online offers and to create analyses of visitor flows. We use cookies in accordance with the statutory provisions. If necessary, we obtain the user’s consent in advance. If consent is not required, we rely on our legitimate interests. This applies if the storage and reading of information is essential in order to be able to provide expressly requested content and functions. This includes, for example, saving settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about the scope and which cookies are used.

Information on legal bases under data protection law: Whether we process personal data using cookies depends on consent. If consent has been given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage period: With regard to the storage period, a distinction is made between the following types of cookies:

Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application).
Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the log-in status can be saved and favourite content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), they should assume that they are permanent and that the storage duration can be up to two years.

General information on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also declare an objection to the processing in accordance with the legal requirements, also by means of the privacy settings of their browser.

Processed data types: Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Data subjects: Users (e.g. website visitors, users of online services).
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing operations, procedures and services:

Processing of cookie data on the basis of consent: We use a consent management solution in which user consent is obtained for the use of cookies or for the procedures and providers mentioned in the consent management solution. This procedure is used to obtain, log, manage and revoke consent, in particular with regard to the use of cookies and comparable technologies that are used to store, read and process information on users’ end devices. As part of this procedure, user consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure. Users also have the option of managing and revoking their consent. The declarations of consent are stored in order to avoid repeated requests and to be able to provide proof of consent in accordance with legal requirements. The storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. If no specific information on the providers of consent management services is available, the following general information applies: Consent is stored for up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information on the browser, the system and the end device used; legal basis: consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
BorlabsCookie: Consent management: Process for obtaining, logging, managing and revoking consent, in particular for the use of cookies and similar technologies for storing, reading and processing information on users’ end devices and their processing; Service provider: Execution on servers and/or computers under its own responsibility under data protection law; Website: https://de.borlabs.io/borlabs-cookie/. Further information: An individual user ID, language and types of consent and the time of their submission are stored on the server and in the cookie on the user’s device.

Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data is only processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium in the context of this data protection notice.

Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Contact and enquiry management

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

Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); Usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Affected persons: Communication partner.
Purposes of processing: Communication; organisational and administrative procedures; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing operations, procedures and services:

Contact form: When contacting us via our contact form, by e-mail or other communication channels, we process the personal data transmitted to us to answer and process the respective request. This generally includes details such as name, contact information and any other information that is provided to us and is required for appropriate processing. We use this data exclusively for the stated purpose of establishing contact and communication; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

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: As part 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, participants’ data may also be processed by the conference platforms for security purposes or service optimisation. The processed data includes personal data (first name, surname), 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 communicated transparently to the participants in advance and – if necessary – they will be asked for their consent.

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 using the function to make the background unrecognisable, if technically possible). Links to the conference rooms and access data must not be passed on to unauthorised third parties.

Notes on legal bases: If, in addition to the conference platforms, we also process users’ data and ask users for their consent to use the conference platforms or certain functions (e.g. consent to the recording of conferences), the legal basis for processing is this consent. Furthermore, our processing may be necessary to fulfil our contractual obligations (e.g. in participant lists, in the case of processing the results of discussions, 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. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); image and/or video recordings (e.g. photographs or video recordings of a person); sound recordings. Log data (e.g. log files relating to logins or the retrieval of data or access times).
Data subjects: Communication partners; users (e.g. website visitors, users of online services). Depicted persons.
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; communication. Office and organisational procedures.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Google Hangouts / Meet: Conferencing and communication software; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://hangouts.google.com/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
Microsoft Teams: Audio and video conferencing, chat, file sharing, integration with Office 365 applications, real-time collaboration on documents, calendar functions, task management, screen sharing, optional recording; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.microsoft.com/de-de/microsoft-teams/; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement, Security information: https://www.microsoft.com/de-de/trustcenter. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland).
Zoom: Video conferencing, online meetings, webinars, screen sharing, optional recording of meetings, chat function, integration with calendars and other apps; Service provider: Zoom Video Communications, Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://zoom.us; Privacy Policy: https://explore.zoom.us/de/privacy/; Data processing agreement: https://explore.zoom.us/docs/doc/Zoom_GLOBAL_DPA.pdf. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).

Cloud services

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

In this context, personal data may be processed and stored on the provider’s servers if they are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content. Cloud service providers also process usage data and metadata that they use for security purposes and to optimise their services.

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

Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
Data subjects: Interested parties; communication partners; business and contractual partners. Users (e.g. website visitors, users of online services).
Purposes of processing: Office and organisational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Google Workspace: Cloud-based application software (e.g. text and spreadsheet editing, appointment and contact management), cloud storage and cloud infrastructure services; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://workspace.google.com/; Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://cloud.google.com/terms/data-processing-addendum; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Further information: https://cloud.google.com/privacy.

Newsletter and electronic notifications

We send newsletters, emails and other electronic notifications (hereinafter “newsletter”) exclusively with the consent of the recipient or on the basis of a legal basis. If the content of the newsletter is mentioned when registering for the newsletter, this content is decisive for the user’s consent. To subscribe to our newsletter, it is normally sufficient to provide your email address. However, in order to be able to offer you a personalised service, we may ask you to provide your name so that we can address you personally in the newsletter or to provide further information if this is necessary for the purpose of the newsletter.

Deletion and restriction of processing: We may store the unsubscribed email 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 potential defence 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 verifying that it is 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 dispatch system.

Contents:
Information about us, our services, promotions and offers.

Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
Affected persons: Communication partner.
Purposes of processing: Direct marketing (e.g. by email or post).
Reach measurement (e.g. access statistics, recognition of returning visitors).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Option to object (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 cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options given above, preferably e-mail.

Further information on processing operations, procedures and services:

Measurement of opening and click rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server or its server, if we use a dispatch service provider, when the newsletter is opened. As part of this retrieval, technical information, such as details of the browser and your system, as well as your IP address and the time of retrieval are initially collected. This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether and when the newsletters are opened and which links are clicked on. The information is assigned to the individual newsletter recipients and stored in their profiles until it is deleted. The analyses are used to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users. The measurement of opening and click rates as well as the storage of the measurement results in the user profiles and their further processing are carried out on the basis of user consent. Unfortunately, it is not possible to revoke the performance measurement separately; in this case, the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted; legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Brevo: E-mail dispatch and automation services; Service provider: Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.brevo.com/; Privacy Policy: https://www.brevo.com/legal/privacypolicy/; Data processing agreement: Provided by the service provider. Basis for third country transfers: Switzerland – adequacy decision (Germany).

Advertising communication via e-mail, post, fax or telephone

We process personal data for the purposes of advertising communication, which may take place via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.

Recipients have the right to withdraw their consent at any time or to object to advertising communication at any time.

After revocation or objection, we store the data required to prove the previous authorisation for contacting or sending up to three years after the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing the revocation or objection of the user, we also store the data required to avoid renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name).

Processed data types: inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers). Content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation).
Affected persons: Communication partner.
Purposes of processing: direct marketing (e.g. by email or post); marketing. Sales promotion.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Xing: Social network for contact tracing; Service provider: XING AG, Dammtorstraße 30, 20354 Hamburg, Germany; Website: www.xing.de. Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.
LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitors’ data used to create the “page insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and the actions they take. Details are also collected about the devices used, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from the user profiles, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.
We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of the data subjects (i.e. users can, for example, send requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Web analysis, monitoring and optimisation

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

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

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

In addition, the IP addresses of users are stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. 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 purpose of the respective process.

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, economical and recipient-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.

Processed data types: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles). Provision of our online services and user-friendliness.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
Security measures: IP masking (pseudonymisation of the IP address).
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Google Analytics: We use Google Analytics to measure and analyse the use of our online offering on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or e-mail addresses. It is used to assign analysis information to an end device in order to recognise which content users have called up within one or more usage processes, which search terms they have used, which they have called up again or which they have interacted with our online offering. The time of use and its duration are also stored, as well as the sources of the users who refer to our online offering and technical aspects of their end devices and browsers.
Pseudonymised user profiles are created with information from the use of various devices, whereby cookies may be used. Google Analytics does not log or store individual IP addresses for EU users. However, Analytics provides rough geographic location data by deriving the following metadata from IP addresses: City (and the city’s inferred latitude and longitude), Continent, Country, Region, Subcontinent (and ID-based counterparts). For EU traffic, the IP address data is used exclusively for this derivation of geolocalisation data before it is immediately deleted. It is not logged, is not accessible and is not used for other purposes. When Google Analytics collects measurement data, all IP queries are performed on EU-based servers before the traffic is forwarded to Analytics servers for processing; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Security measures: IP masking (pseudonymisation of the IP address); Privacy Policy: https://policies.google.com/privacy; Data processing agreement: https://business.safety.google/adsprocessorterms/; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – adequacy decision (Ireland); Opt-Out: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of adverts: https://myadcenter.google.com/personalizationoff. Further information: https://business.safety.google/adsservices/ (types of processing and processed data).

Customer reviews and evaluation process

We participate in review and rating procedures in order to evaluate, optimise and advertise our services. If users rate us or otherwise provide feedback via the participating review platforms or procedures, the general terms and conditions or terms of use and the providers’ data protection notices also apply. As a rule, the evaluation also requires registration with the respective providers.

In order to ensure that the reviewers have actually used our services, we transmit the necessary data relating to the customer and the service used (including name, email address and order number or item number) to the relevant review platform with the customer’s consent. This data is used solely to verify the authenticity of the user.

Processed data types: Contract data (e.g. subject matter of the contract, duration, customer category); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Persons affected: Service recipients and clients. Users (e.g. website visitors, users of online services).
Purposes of processing: Feedback (e.g. collecting feedback via online form). Marketing.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Glassdoor: Job portal and reviews; Service provider: Glassdoor LLC, 300 Mission Street, 16th Floor, San Francisco, CA 94105, USA; Website: www.glassdoor.de. Privacy Policy: https://hrtechprivacy.com/de/brands/glassdoor#privacypolicy.
Google Customer Reviews: Service for obtaining and/or presenting customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.com/; Privacy Policy: https://policies.google.com/privacy; Third country transfer basis: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland); Further information: As part of the collection of customer reviews, an identification number and time for the business transaction to be evaluated, in the case of review requests sent directly to customers, the customer’s e-mail address and their country of residence as well as the review details themselves are processed; Further information on the types of processing and the data processed: https://business.safety.google/adsservices/. Data processing conditions for Google advertising products: Information on the services Data processing terms between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
kununu: Rating platform; Service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.kununu.com/de; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung. Basis for third country transfers: Switzerland – adequacy decision (Germany).

Presence in social networks (social media)

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

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

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behaviour and the resulting interests of users. The latter may in turn be used, for example, to place adverts within and outside the networks that presumably correspond to the interests of the users. Cookies are therefore generally stored on users’ computers, in which the user behaviour and interests of the users are stored. In addition, data can also be stored in the user profiles independently of the devices used by the users (especially if they are members of the respective platforms and are logged in there).

For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.

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

Processed data types: Contact data (e.g. postal and email addresses or telephone numbers); Content data (e.g. text or image messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Usage data (e.g. page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Communication; feedback (e.g. collecting feedback via online form). Public relations.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

LinkedIn: Social network – We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitors’ data used to create the “page insights” (statistics) of our LinkedIn profiles. This data includes information about the types of content users view or interact with and the actions they take. Details are also collected about the devices used, such as IP addresses, operating system, browser type, language settings and cookie data, as well as information from the user profiles, such as job function, country, industry, hierarchy level, company size and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy.
We have concluded a special agreement with LinkedIn Ireland (“Page Insights Joint Controller Addendum”, https://legal.linkedin.com/pages-joint-controller-addendum), which regulates in particular which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfil the rights of the data subjects (i.e. users can, for example, send requests for information or deletion directly to LinkedIn). The rights of users (in particular the right to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. Joint responsibility is limited to the collection and transfer of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Option to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Xing: Social network; Service provider: New Work SE, Am Strandkai 1, 20457 Hamburg, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.xing.com/; Privacy Policy: https://privacy.xing.com/de/datenschutzerklaerung. Basis for third country transfers: Switzerland – adequacy decision (Germany).

Plug-ins and embedded functions and content

We incorporate 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 be, for example, graphics, videos or city maps (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavour to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, but may also 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 permission. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Processed data types: Usage data (e.g. page views and dwell time, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Data subjects: Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of our online services and user-friendliness; reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behavioural profiling, use of cookies); target group formation. Marketing.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”. Storage of cookies for up to 2 years (Unless otherwise stated, cookies and similar storage methods may be stored on users’ devices for a period of two years).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Adequacy Decision (Ireland). Possibility of objection (opt-out): Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de; Settings for the display of adverts: https://myadcenter.google.com/personalizationoff.

Management, organisation and support tools

We use services, platforms and software from other providers (hereinafter referred to as “third-party providers”) for the purposes of organising, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.

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

If users are referred to the 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 for security purposes, service optimisation or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

Processed data types: Content data (e.g. text or image messages and posts and the information relating to them, such as information on authorship or time of creation); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, persons involved); contact data (e.g. postal and email addresses or telephone numbers). Inventory data (e.g. full name, residential address, contact information, customer number, etc.).
Affected persons: Communication partners. Users (e.g. website visitors, users of online services).
Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Asana: Project management – organisation and management of teams, groups, workflows, projects and processes; Service provider: Asana, Inc, 1550 Bryant Street, Suite 200, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://asana.com; Privacy Policy: https://asana.com/de/terms#privacy-policy; Data processing agreement: https://asana.com/de/terms#data-processing. Basis for third country transfers: EU/EEA – Data Privacy Framework (DPF), Switzerland – Data Privacy Framework (DPF).
calendly: Online appointment scheduling and appointment management; Service provider: Calendly LLC, 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://calendly.com/de; Privacy Policy: https://calendly.com/privacy; Data processing agreement: https://calendly.com/dpa. Basis for third country transfers: EU/EEA – Standard Contractual Clauses (https://calendly.com/dpa), Switzerland – Standard Contractual Clauses (https://calendly.com/dpa).
Miro: Online whiteboard and collaboration platform; Service provider: Realtimeboard Inc. dba Miro, 201 Spear Street Suite 1100, San Francisco, California 94105, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://miro.com/; Privacy Policy: https://miro.com/legal/privacy-policy/; Data processing agreement: https://miro.com/legal/vendor-data-processing-addendum/. Basis for third country transfers: EU/EEA – Standard Contractual Clauses (https://miro.com/legal/vendor-data-processing-addendum/), Switzerland – Standard Contractual Clauses (https://miro.com/legal/vendor-data-processing-addendum/).

Processing of data in the context of employment relationships

In the context of employment relationships, personal data is processed with the aim of effectively organising the establishment, implementation and termination of such relationships. This data processing supports various operational and administrative functions that are necessary for the management of employee relations.

Data processing covers various aspects ranging from contract initiation to contract cancellation. This includes the organisation and administration of daily working hours, the administration of access rights and authorisations as well as the handling of personnel development measures and employee appraisals. The processing is also used for payroll accounting and the administration of wage and salary payments, which are critical aspects of contract fulfilment.

Data processing also takes into account the legitimate interests of the responsible employer, such as ensuring safety in the workplace or collecting performance data to evaluate and optimise operational processes. Data processing also includes the disclosure of employee data as part of external communication and publication processes, where this is necessary for operational or legal purposes.

This data is always processed in compliance with the applicable legal framework, whereby the aim is always to create and maintain a fair and efficient working environment. This also includes taking into account the data protection of the employees concerned, the anonymisation or deletion of data after the purpose of processing has been fulfilled or in accordance with statutory retention periods.

Processed data types: Employee data (information on employees and other persons in an employment relationship); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. text or image messages and contributions as well as information relating to them, such as information on authorship or time of creation); social data (data subject to social confidentiality, e.g. from social security organisations). content data (e.g. textual or pictorial messages and contributions and the information relating to them, such as details of authorship or time of creation); social data (data subject to social confidentiality and processed, for example, by social insurance providers, social welfare providers or pension authorities); log data (e.g. log files relating to logins or the retrieval of data or access times); performance and behaviour data (e.g. aspects of performance and behaviour). performance and behavioural aspects such as performance evaluations, feedback from superiors, training participation, compliance with company guidelines, self-assessments and behavioural assessments); working time data (e.g. start of working hours, end of working hours, actual working hours, target working hours, break times, overtime, holidays, special leave days, sick days, absences, home office days, business trips); salary data (e.g. basic salary, bonus payments, bonuses, premiums). basic salary, bonus payments, premiums, tax class information, supplements for night work/overtime, tax deductions, social security contributions, net amount paid out); image and/or video recordings (e.g. photographs or video recordings of a person); usage data (e.g. page views and length of stay, click paths, intensity and frequency of use, device types and operating systems used, interactions with content and functions). Meta, communication and process data (e.g. IP addresses, time data, identification numbers, persons involved).
Special categories of personal data: Health data; Religious or philosophical beliefs. Trade union membership.
Persons affected: Employees (e.g. salaried employees, applicants, temporary staff and other employees).
Purposes of processing: Establishment and implementation of employment relationships (processing of employee data in the context of the establishment and implementation of employment relationships); business processes and business management procedures; provision of contractual services and fulfilment of contractual obligations; public relations; security measures. Office and organisational procedures.
Legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR); Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR); Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR). Processing of special categories of personal data relating to health, work and social security (Art. 9 para. 2 lit. h) GDPR).

Further information on processing operations, procedures and services:

Working time recording: Procedures for recording employees’ working hours include both manual and automated methods, such as the use of time clocks, time recording software or mobile apps. This involves activities such as entering clock-in and clock-out times, break times, overtime and absences. Checking and validating the recorded working times includes comparing them with shift schedules, checking absences and authorising overtime by supervisors. Reports and analyses are created on the basis of the recorded working hours in order to provide time sheets, overtime reports and absence statistics for management and the HR department; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Authorisation management: Procedures required to define, manage and control access rights and user roles within a system or organisation (e.g. Creation of authorisation profiles, role and access-based control, review and approval of access requests, regular review of access rights, tracking and auditing of user activities, creation of security policies and procedures); Legal basis: Performance of a contract and pre-contractual requests (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).
Special categories of personal data: Special categories of personal data are processed in the context of the employment relationship or to fulfil legal obligations. The special categories of personal data processed include data relating to the health, trade union membership or religious affiliation of employees. This data may, for example, be passed on to health insurance companies or processed to assess employees’ ability to work or for occupational health management or for information to the tax office; legal basis: fulfilment of contract and pre-contractual enquiries (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).
Sources of the processed data: Personal data obtained as part of the employee’s application and/or employment relationship is processed. In addition, if required by law, personal data is collected from other sources. These may be tax authorities for tax-relevant information, the respective health insurance company for information on incapacity for work, third parties such as employment agencies or publicly accessible sources such as professional social networks in the context of application procedures; legal bases: Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Purposes of data processing: Employees’ personal data is primarily processed to establish, implement and terminate the employment relationship. In addition, the processing of this data is necessary to fulfil legal obligations in the area of tax and social security law. In addition to these primary purposes, employee data is also used to fulfil regulatory and supervisory requirements, to optimise electronic data processing processes and to compile internal or cross-company data, possibly including statistical data. Furthermore, employee data may be processed for the assertion of legal claims and for defence in legal disputes; legal bases: Contract fulfilment and pre-contractual enquiries (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).
Transmission of employee data: Employee data is only processed internally by those departments that require it to fulfil operational, contractual and legal obligations.
Data is only passed on to external recipients if this is required by law or if the employees concerned have given their consent. Possible scenarios for this could be requests for information from authorities or in the case of capital formation benefits. Furthermore, the controller may forward personal data to other recipients if this is necessary to fulfil its contractual and legal obligations as an employer. These recipients may include: a) Banks b) Health insurance funds, pension insurance providers, pension providers and other social insurance providers c) Authorities, courts (e.g. tax authorities, labour courts, other supervisory authorities as part of the fulfilment of reporting and information obligations) d) Tax and legal advisors e) Third-party debtors in the event of wage and salary garnishment f) Other bodies to which legally binding declarations must be made.
In addition, data may be passed on to third parties if this is necessary for communication with business partners, suppliers or other service providers. Examples of this are details in the sender area of emails or letterhead and the creation of profiles on external platforms; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Transfer of employee data to third countries: The transfer of employee data to third countries, i.e. countries outside the European Union (EU) and the European Economic Area (EEA), only takes place if this is necessary for the fulfilment of the employment relationship, is required by law or if employees have given their consent. Employees will be informed separately about the details, if required by law; legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Business trips and travel expense accounting: Procedures required for the planning, execution and accounting of business trips (e.g. booking of trips, organisation of accommodation and means of transport, administration of travel expense advances, submission and verification of travel expense reports, control and accounting of costs incurred, compliance with travel guidelines, handling of travel expense management); Legal basis: Contract fulfilment and pre-contractual enquiries (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).
Payroll accounting and payroll accounting: Procedures required for the calculation, payment and documentation of wages, salaries and other remuneration of employees (e.g. Recording of working hours, calculation of deductions and supplements, payment of taxes and social security contributions, preparation of wage and salary statements, management of payroll accounts, reporting to the tax office and social security institutions); Legal basis: Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR).
Deletion of employee data: Employee data in Switzerland is deleted when it is no longer required for the purpose for which it was collected, unless it must be retained or archived due to legal obligations or due to the interests of the employer. The following retention and archiving obligations are observed:
10 years – Retention period for books and records, annual financial statements, inventories, annual reports, opening balance sheets, accounting vouchers and invoices as well as all necessary work instructions and other organisational documents (Art. 958f of the Swiss Code of Obligations (CO)).
10 years – Data required for the consideration of potential claims for damages or similar contractual claims and rights, as well as for the processing of related enquiries based on past business experience and common industry practices, are stored for the statutory limitation period of ten years, unless a shorter period of five years is applicable, which is relevant in certain cases (Art. 127, 130 CO). Claims expire after five years for rent, lease and capital interest payments and other periodic services, for the supply of food, for catering and hospitality debts as well as from craft services, retail sale of goods, medical care, professional work of lawyers, legal agents, attorneys and notaries and from the employment relationship of employees (Art. 128 CO).
Personnel file management: Procedures required for the organisation, updating and management of employee data and documents (e.g. recording of personnel master data, storage of employment contracts, references and certificates, updating of data in the event of changes, compilation of documents for employee appraisals, archiving of personnel files, compliance with data protection regulations); Legal basis: Contract fulfilment and pre-contractual enquiries (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), Processing of special categories of personal data relating to health, work and social security (Art. 9 para. 2 lit. h) GDPR).
Personnel development, performance evaluation and employee appraisals: Procedures that are necessary in the area of employee promotion and development as well as in the evaluation of their performance and in the context of employee appraisals (e.g. needs analysis for further training, planning and implementation of training measures, preparation of performance evaluations, implementation of target agreement and feedback discussions, career planning and talent management, succession planning); Legal basis: Contract fulfilment and pre-contractual enquiries (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), Processing of special categories of personal data relating to health, employment and social security (Art. 9 para. 2 lit. h) GDPR).
Obligation to provide data: The controller shall inform employees that the provision of their data is required. This is generally the case if the data is required for the establishment and performance of the employment relationship or if its collection is required by law. It may also be necessary to provide data if employees assert claims or if employees are entitled to claims. The implementation of these measures or fulfilment of services is dependent on the provision of this data (for example, the provision of data for the purpose of receiving wages); legal bases: Contract fulfilment and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), Legal obligation (Art. 6 Para. 1 S. 1 lit. c) GDPR), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
Publication and disclosure of employee data: Employee data is only published or disclosed to third parties if this is necessary for the fulfilment of work tasks in accordance with the employment contract. This applies, for example, if employees are named as contact persons in correspondence, on the website or in public registers following consultation or an agreed job description, or if the area of responsibility includes representative functions. This may also be the case if a presentation or communication with the public takes place as part of the fulfilment of tasks, such as photographs taken as part of public relations work. Otherwise, employees’ data will only be published with their consent or on the basis of the employer’s legitimate interests, for example in the case of stage or group photos taken as part of a public event; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Application procedure

The application process requires applicants to provide us with the data necessary for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the 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. On request, we will be happy to provide additional information on what details are required.

If available, applicants are welcome to submit their applications via our online form, which is encrypted using state-of-the-art technology. Alternatively, it is also possible to send us applications by e-mail. However, we would like to point out that e-mails sent via the Internet are generally not encrypted. Although e-mails are generally encrypted in transit, this does not take place on the servers from which they are sent and received. Therefore, we cannot assume any responsibility for the security of the application on its transmission path between the sender and our server.

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

Applicants are welcome to contact us about how to submit their application or send it to us by post.

Processing of special categories of data: Insofar as special categories of personal data (Art. 9 para. 1 GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants or communicated by them as part of the application procedure, their processing is carried out so that the controller or the data subject can exercise the rights arising from labour law and social security and social protection law and fulfil his or her obligations in this regard. In the case of the protection of the vital interests of applicants or other persons or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s fitness for work, for medical diagnosis, for the provision of health or social care or treatment or for the management of health or social care systems and services.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is unsuccessful, the applicant’s 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 justified cancellation by the applicant, the deletion will take place at the latest after a period of six months so that we can answer any follow-up questions about the application and fulfil our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax regulations.

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.

Processed data types: Inventory data (e.g. full name, residential address, contact information, customer number, etc.); contact data (e.g. postal and email addresses or telephone numbers); content data (e.g. textual or visual messages and contributions as well as the information relating to them, such as information on authorship or time of creation). Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other information relating to a specific position or voluntarily provided by applicants regarding their person or qualifications).
Persons concerned: Applicants.
Purposes of processing: Application procedure (justification and possible subsequent implementation and possible subsequent termination of the employment relationship).
Storage and deletion: Deletion in accordance with the information in the section “General information on data storage and deletion”.
Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures and services:

Personio: Recruitment platform and applicant management services (job advertisements, applicant search and application process); Service provider: Personio SE & Co KG, Seidlstraße 3, 80335 Munich, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.personio.de/; Privacy Policy: https://www.personio.de/datenschutzerklaerung/. Basis for third country transfers: Switzerland – adequacy decision (Germany).

Privacy Policy

Privacy policy

Preamble

Table of contents

Person responsible

Contact data protection officer

Overview of processing

Types of data processed

Special categories of data

Categories of affected persons

Purposes of the processing

Relevant legal bases

Security measures

Transmission of personal data

International data transfers

Rights of the data subjects

Business services

Business processes and procedures

Payment procedure

Provision of the online offer and web hosting

Use of cookies

Blogs and publication media

Contact and enquiry management

Video conferences, online meetings, webinars and screen sharing

Cloud services

Newsletter and electronic notifications

Advertising communication via e-mail, post, fax or telephone

Web analysis, monitoring and optimisation

Customer reviews and evaluation process

Presence in social networks (social media)

Plug-ins and embedded functions and content

Management, organisation and support tools

Processing of data in the context of employment relationships

Application procedure

Phone

Email

Social Media