Privacy Policy

Preamble

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Status: February 1st, 2024

Table of contents

  • Preamble
  • Responsible
  • Contact data protection officer
  • Overview of processing operations
  • Relevant legal basis
  • Security measures
  • Transfer of personal data
  • Data processing in third countries
  • Deletion of data
  • Use of cookies
  • Business services
  • Providers and services used in the course of business
  • Provision of the online offer and web hosting
  • Contact and inquiry management
  • Application procedure
  • Web analysis, monitoring and optimization
  • Presence in social networks (social media)
  • Modification and updating of the privacy policy
  • Rights of the data subjects

Responsible

horizoom GmbH
Clayallee 288
14169 Berlin
Phone: 030 – 2799 1907
E-Mail: datenschutz@horizoom.de
Authorized representatives: Jonathan Heinemann, Malte Friedrich-Freksa, Rahel Bonhommet, Thomas Karstens
Impressum: horizoom.de/impressum

Contact Data Protection Officer

Hergen Jenta, External Data Protection Officer
OnPoint-IT GmbH
Am Strehl 153-155
26125 Oldenburg

Telefon: +49 (0) 441 / 38038570
E-Mail: datenschutzbeauftragter@horizoom.de

Processing overview

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

Types of Data Processed

  • Inventory data.
  • Payment data.
  • Contact data.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta data, communication data and process data.
  • Applicant data.

Categories of Persons Concerned

  • Customers.
  • Prospects.
  • Communication partners.
  • Users.
  • Applicants.
  • Business and contractual partners.

Processing Purposes

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Reach measurement.
  • Tracking.
  • Office and organizational procedures.
  • Conversion measurement.
  • Audience building.
  • Managing and responding to inquiries.
  • Application procedures.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and user experience.
  • Information technology infrastructure.

Relevant Legal Bases

The following is an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a) GDPR) – The data subject has given his/her consent to the processing of personal data concerning him/her for a specific purpose or purposes.
  • Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR) – The processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c) GDPR) – The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para 1 p. 1 lit. f) GDPR) – The processing is necessary for the purposes of the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.
  • Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 lit. b) GDPR) – Insofar as special categories of personal data within the meaning of Article 9 (1) of the GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants in the context of the application process so that the controller or the data subject can exercise the rights accruing to him or her under labor law and social security and social protection law and fulfill his or her obligations in this regard, their processing shall be carried out in accordance with Article 9 (2) b. GDPR, in case of protection of vital interests of the applicants or other persons according to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. GDPR.

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

Security Measures

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

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

Shortening of IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as “IP masking”). In this process, the last two digits or the last part of the IP address after a period are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it significantly more difficult to identify a person by their IP address.

TLS encryption (https): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.

Transmission of Personal Data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data transfer within the organization: We may transfer personal data to other entities within our organization or grant them access to this data. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate business and operational interests or is made where it is necessary to fulfill our contract-related obligations or where we have the consent of the data subjects or legal permission.

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, entities or companies, this is only done in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we process or allow the processing of data only in third countries with a recognized level of data protection, contractual obligation by so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission:
https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Data Deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose). If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Our data protection notices may also contain further details on the retention and deletion of data, which take priority for the respective processing operations.

Cookies Usage

Cookies are small text files or other memory tags that store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or functions used of an online offer. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows.

Consent notes:We use cookies in accordance with the law. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service (i.e., our online offering) expressly requested by the user. The strictly necessary cookies usually include cookies with functions related to the display and operability of the online offer , load balancing, security, storage of users’ preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offer requested by the users. The revocable consent will be clearly communicated to the users and will contain the information regarding the respective cookie use.

Notes on the legal basis for data protection: The legal basis under data protection law on which we process users’ personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process the cookies in the course of this privacy policy or as part of our consent and processing procedures.

Storage duration: In terms of storage duration, the following types of cookies are distinguished:

  • emporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile application).
  • Permanent Cookies: Permanent cookies remain stored even after the terminal device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General notes on revocation and objection (Opt-Out): Users can revoke the consents they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 GDPR. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (whereby this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

  • Processing purposes: Reach measurement (e.g. access statistics, recognition of returning visitors); provision of our online offer and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR); Consent (Art. 6 para. 1 p. 1 lit. a) GDPR).

Further guidance on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or the processing and providers named in the cookie consent management procedure, can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used; legal basis: consent (Art. 6 para. 1 p. 1 lit. a) GDPR).
  • Cookiebot: Cookie-Consent-Management; Provider: Cybot A/S, Havnegade 39, 1058 Kopenhagen, Denmark; Website: https://www.cookiebot.com/de; Privacy Policy: https://www.cookiebot.com/de/privacy-policy/; Further Information: Stored data (on the server of the service provider): The user’s IP number in anonymized form (the last three digits are set to 0), the date and time of consent, browser details, the URL from which the consent was sent, An anonymous, random and encrypted key value; the user’s consent status.
  • Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. In Analytics, higher level geographic location data is provided by collecting the following metadata based on IP search: “city” (and the derived latitude and longitude of the city), “continent”, “country”, “region”, “subcontinent” (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. Users’ IP addresses are not logged and are truncated by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Consent (Art. 6 par. 1 p. 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Order Processing Agreement: https://business.safety.google/adsprocessorterms/; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries):  https://business.safety.google/adsprocessorterms; Possibility of Objection (Opt-Out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de,  Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further Information: https://privacy.google.com/businesses/adsservices (Types of processing and the data processed).
  • Google Analytics in consent mode: In consent mode, personal data of users is processed by Google for measurement and advertising purposes, depending on the consent of the users. Consent is obtained from users as part of our online services. If the consent of the users is missing altogether, the data will only be processed on an aggregated (i.e. not assigned and summarized to individual users) level. If the consent only includes statistical measurement, no personal data of users will be processed for ad placement or measurement of advertising success (so-called “conversion”); Legal Basis: Consent (Art. 6 par. 1 p. 1 lit. a) GDPR); Website: https://support.google.com/analytics/answer/9976101?hl=de.

Business Services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data in order to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of 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 disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

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

We delete the data after the expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant under tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period shall commence at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or dispatched or the accounting document was created, furthermore the recording was made or the other documents were created.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

  • Types of data processed: Inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contact data (e.g., e-mail, telephone numbers); contract data (e.g., subject matter of contract, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta, communication and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Persons concerned: interested parties; business and contractual partners; customers.
  • Processing Purposes: Providing contractual services and customer service; contact requests and communications; office and organizational procedures; managing and responding to requests; conversion measurement (measuring the effectiveness of marketing efforts); profiling user-related information (creating user profiles).
  • Legal Bases: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 p. 1 lit. c) GDPR); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).

Further guidance on processing operations, procedures and services::

  • Economic analyses and market research: For business reasons and in order to be able to recognize market trends, wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of persons concerned may include contractual partners, interested parties, customers, visitors and users of our online offer.The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users together with their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take into account the privacy of the users and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
  • Agency services: We process our clients’ data as part of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consulting services, and training services; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR).
  • Consulting: We process the data of our clients, customers as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to be able to provide our consulting services to them. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship. we disclose or transfer client data to third parties or agents, such as authorities, subcontractors or in the area of IT, office or comparable services, in compliance with the requirements of professional law; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR).

Providers and Services Used in the Course of Business

As part of our business operations, we use additional services, platforms, interfaces or plug-ins from third-party providers (in short, “services”) in compliance with legal requirements. Their use is based on our interests in the proper, lawful and economic management of our business operations and our internal organization.

Types of data processed: inventory data (e.g., names, addresses); payment data (e.g., bank details, invoices, payment history); contact data (e.g., e-mail, telephone numbers); content data (e.g., entries in online forms); contract data (e.g., subject matter of contract, term, customer category); usage data (e.g., websites visited, interest in content, access times); meta, communication and procedural data (e.g., IP addresses, time data, identification numbers, consent status).
Data subjects: Customers; prospective customers; users (e.g., website visitors, users of online services); business and contractual partners; communication partners.
Purposes of processing: provision of contractual services and customer service; office and organizational procedures; contact requests and communication; marketing.
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).

Further guidance on processing operations, procedures and services::

  • Zammad: Management of contact requests, service tickets and communication; Service provider: Zammad GmbH, Marienstraße 18, 10117 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR); Website: https://zammad.com/de/; Privacy policy: https://zammad.com/de/unternehmen/datenschutz.
  • 1&1 IONOS: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy; Order processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/.
  • Keyingress: provision of survey software and panel software; service provider: Ingress GmbH, Weidestraße 122a, 22083 Hamburg, Germany; Website: https://www.ingress.de; Privacy policy: https://www.ingress.de/Kontakt/Datenschutz/.

Provision of the Online Offer and Web Hosting

We process the 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 terminal device.

Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
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.).); provision of contractual services and customer service.
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).

Further guidance 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 referred to as “web hoster”); Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).
1&1 IONOS: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy; Order processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/.

Contact and Request Management

When contacting us (e.g. by mail, contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).
Data subjects: Communication partners.
Purposes of processing: contact inquiries and communication; managing and responding to inquiries; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.
Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR); contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) GDPR).

Further guidance on processing operations, procedures and services:

Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context for the purpose of processing the communicated request; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) GDPR), Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR).

Application Procedure

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

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

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

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

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

Processing of special categories of data: Insofar as special categories of personal data within the meaning of Article 9 (1) of the GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants in the context of the application process so that the controller or the data subject can exercise the rights accruing to him or her under employment law and social security and social protection law and fulfill his or her obligations in this regard, their processing is carried out in accordance with Article 9 (2) b. GDPR, in case of protection of vital interests of the applicants or other persons according to Art. 9 para. 2 lit. c. GDPR or for the purposes of preventive health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnostics, for care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. GDPR. In the case of notification of the special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. GDPR.

Deletion of data: The data provided by applicants may be further processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a justified withdrawal by the applicants, the deletion will take place at the latest after the expiry of a period of six months so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses will be archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

Duration of data retention in the applicant pool in months: 12 months

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); 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, as well as other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
  • Data subjects: Applicants.
  • Purposes of processing: application procedure (establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship).
  • Legal basis: Application procedure as a pre-contractual or contractual relationship (Art. 6 para. 1 lit. b) GDPR); Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).Further guidance on processing operations, procedures and services:LinkedIn Recruiter: job search and application-related services within the LinkedIn platform; service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) p. 1 lit. f) GDPR); Website: https://www.linkedin.com; T&Cs: https://legal.linkedin.com/dpa; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa.
    Stepstone: services related to employee acquisition/recruitment (search for employees, communication, application procedures, contract negotiations); service provider: StepStone Deutschland GmbH, Völklinger Straße 1, 40219 Düsseldorf, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR); Website: https://www.stepstone.de; Privacy policy: https://www.stepstone.de/Ueber-StepStone/Rechtliche-Hinweise/datenschutzerklaerung/.

Webanalyse, Monitoring und Optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimization.

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

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, may be created for these purposes and information may be stored in a browser, or in a terminal device, and read from it. The information collected includes, in particular, websites visited and 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 agreed to the collection of their location data from us or from the providers of the services we use, location data may also be processed.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

  • Types of data processed: Usage data (e.g., web pages visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, consent status).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiling with user-related information (creation of user profiles); tracking (e.g. interest/behavior-based profiling, use of cookies); conversion measurement (measurement of the effectiveness of marketing measures); target group formation; marketing; provision of our online offer and user friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) GDPR).

Further guidance on processing operations, procedures and services::

  • 1&1 IONOS WebAnalytics: Reach measurement and web analysis; Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) GDPR); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy; Order processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/; Further information: The data is collected either by a pixel or by a log file, without the use of cookies; the IP address of visitors is transmitted when a page request is sent, anonymized directly after transmission and processed further without reference to a person; the data is processed on the basis of an order processing contract.
  • Google Analytics 4: We use Google Analytics to measure and analyze the use of our online offer on the basis of a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognize which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offering. Likewise, the time of use and its duration are stored, as well as the sources of the users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, and cookies may be used. In Analytics, higher level geographic location data is provided by collecting the following metadata based on IP search: “city” (and the derived latitude and longitude of the city), “continent”, “country”, “region”, “subcontinent” (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. Users’ IP addresses are not logged and are truncated by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: consent (Art. 6 (1) p. 1 lit. a) GDPR); Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms/; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms; Opt-out: Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated; Further information: https://privacy.google.com/businesses/adsservices (Types of processing as well as data processed).
  • Google Analytics in consent mode: In consent mode, personal data of users is processed by Google for measurement and advertising purposes, depending on the consent of the users. Consent is obtained from users as part of our online services. If the consent of the users is missing altogether, the data will only be processed on an aggregated (i.e. not assigned and summarized to individual users) level. If the consent only includes statistical measurement, no personal data of users is processed for ad placement or measurement of advertising success (so-called “conversion”); legal basis: consent (Art. 6 (1) p. 1 lit. a) GDPR); website: https://support.google.com/analytics/answer/9976101?hl=de.
  • Google Tag Manager: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (please refer to further details in this privacy policy). With the Tag Manager itself (which implements the tags), therefore, no profiles of users are created or cookies are stored, for example. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Consent (Art. 6 (1) p. 1 lit. a) GDPR); Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy; Order processing contract: https://business.safety.google/adsprocessorterms; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://business.safety.google/adsprocessorterms.

Presences in Social Networks (Social Media)

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

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

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

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements and information provided by the operators of the respective networks.

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

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

Further guidance on processing operations, procedures and services:

LinkedIn: social network; LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (ensuring level of data protection for processing in third countries): https://legal.linkedin.com/dpa; 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 p. 1 lit. f) GDPR); Website: https://www.xing.de; Privacy policy: https://privacy.xing.com/de/datenschutzerklaerung.

Modification and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

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

Rights of Persons Concerned

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 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 at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
Right to withdraw consent: You have the right to revoke any consent given at any time.
Right to information: you have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
Right to rectification: you have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data.
Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand its transfer to another responsible party.
Complaint to the supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, 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 requirements of the GDPR.

Supervisory authority responsible for us:

Berlin Commissioner for Data Protection and Freedom of Information
Alt-Moabit 59-61
10555 Berlin
Entrance: Alt-Moabit 60

Phone: +49 30 13889-0
Fax: +49 30 21550
mailbox@datenschutz-berlin.de

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