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Preamble

With the following privacy policy we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, for which purposes and to what extent in the context of providing our application.

The terms used are not gender-specific.

Last Update: 12. October 2022

Controller

ASC Oncology GmbH
Robert-Rössle-Str. 10
13125 Berlin, Deutschland

Authorised Representatives:

Dr. Christian Regenbrecht and Quirin Graf Adelmann
E-mail address: info@asc-admin.com
Phone: +49 30 2359467 88

Contact information of the data protection officer

Knittel Akademie für Datenschutz & Compliance
Patrick Knittel
dsb@knittel-compliance.de

Overview of processing operations

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.

Categories of Processed Data

  • Inventory data
  • Payment Data
  • Location data
  • Contact data
  • Content data
  • Contract data
  • Usage data
  • Meta/communication data
  • Job applicant details

Special Categories of Data

  • Health Data

Categories of Data Subjects

  • Customers
  • Employees
  • Prospective customers
  • Communication partner
  • Users
  • Job applicants
  • Members
  • Business and contractual partners
  • Patients
  • Persons depicted

Purposes of Processing

  • Provision of contractual services and customer support
  • Contact requests and communication
  • Security measures
  • Office and organisational procedures
  • Managing and responding to inquiries
  • Job Application Process
  • Feedback
  • Marketing
  • Provision of our online services and usability
  • Information technology infrastructure

Legal Bases for the Processing

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

  • Consent (Article 6 (1) (a) GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR) – 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.
  • Compliance with a legal obligation (Article 6 (1) (c) GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate Interests (Article 6 (1) (f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
  • Job application process as a pre-contractual or contractual relationship (Article 6 (1)(b) GDPR) – If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can carry out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, their processing shall be carried out in accordance with Article 9 (2)(b) GDPR , in the case of the protection of vital interests of applicants or other persons on the basis of Article 9 (2)(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 administration of systems and services in the health or social sector in accordance with Article 9 (2)(d) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (2)(a) GDPR.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations apply to data protection in Germany. This includes in particular the Law on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions on the right to access, the right to erase, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, execution or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.

Security Precautions

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security 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, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.

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

Transmission of Personal Data

In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such a case, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data.

Data Transmission within the Group of Companies: We may transfer personal data to other companies within our group of companies or otherwise grant them access to this data. Insofar as this disclosure is for administrative purposes, the disclosure of the data is based on our legitimate business and economic interests or otherwise, if it is necessary to fulfill our contractual obligations or if the consent of the data subjects or otherwise a legal permission is present.

Data Transfer within the Organization: We may transfer or otherwise provide access to personal information to other locations within our organization. Insofar as this disclosure is for administrative purposes, the disclosure of the data is based on our legitimate business and economic interests or otherwise, if it is necessary to fulfill our contractual obligations or if the consent of those concerned or otherwise a legal permission is present.

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 disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements. 

Subject to express consent or transfer required by contract or law, we process or have processed the data only in third countries with a recognised level of data protection, on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission or if certifications or binding internal data protection regulations justify the processing (Article 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Erasure of data

The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose). If the data is not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. In the context of our information on data processing, we may provide users with further information on the deletion and retention of data that is specific to the respective processing operation.

Use of Cookies

Cookies are small text files or other data records that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the contents accessed or the functions used. 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.

Information on consent: We use cookies in accordance with the statutory provisions. 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 strictly necessary in order to provide an information society service explicitly requested by the subscriber or user. The revocable consent will be clearly communicated to the user and will contain the information on the respective cookie use.

Information on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the use of 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 services 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. For which purposes the cookies are processed by us, we do clarify in the course of this privacy policy or in the context of our consent and processing procedures.

Retention period: With regard to the retention period, a distinction is drawn between the following types of cookies:

  • Temporary cookies (also known as “session cookies”): Temporary cookies are deleted at the latest after a user has left an online service and closed his or her end device (i.e. 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, 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 information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also file an objection to processing in accordance with the legal requirements in Article 21 GDPR. Users can also declare their objection by means of the settings of their browser, 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/.

Further information on processing methods, procedures and services used:

  • Processing Cookie Data on the Basis of Consent: We use a cookie management solution in which users’ consent to the use of cookies, or the procedures and providers mentioned in the cookie management solution, can be obtained, managed and revoked by the users. The declaration of consent is stored so that it does not have to be retrieved again and the consent can be proven in accordance with the legal obligation. Storage can take place server-sided and/or in a cookie (so-called opt-out cookie or with the aid of comparable technologies) in order to be able to assign the consent to a user or and/or his/her device. Subject to individual details of the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. In this case, a pseudonymous user identifier is formed and stored with the date/time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and used end device.
  • Cookiebot: Cookie-Consent Manager; Service provider: Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark; Website: https://www.cookiebot.com; Privacy Policy: https://www.cookiebot.com/en/privacy-policy/; Further Information: Stored data (on the server of the service provider): The IP number of the user in anonymous form (the last three digits are set to 0), date and time of the consent, user agent of the user’s browser, the URL from which the consent was sent, An anonymous, random and encrypted key value; the consent status of the user.
  • Usercentrics: Cookie-Consent Manager; Service provider: Usercentrics GmbH, Sendlinger Strasse 7, 80331 Munich, Germany; Website: https://usercentrics.com/Privacy Policy: https://usercentrics.com/privacy-policy/.

Performing tasks in accordance with statutes or rules of procedure

We process the data of our members, supporters, prospects, business partners or other persons (collectively, ” data subjects “) when we have a membership or other business relationship with them and perform our functions and are recipients of benefits and benefits. Otherwise, we process the data of data subjects on the basis of our legitimate interests, e.g. when it concerns administrative tasks or public relations.

The data processed, the type, scope and purpose and the necessity of their processing, are determined by the underlying membership or contractual relationship, from which the necessity of any data information arises (otherwise we refer to necessary data).

We delete data that is no longer required for the performance of our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. We retain the data for as long as it may be relevant for the purpose of conducting business and with regard to any warranty or liability obligations on the basis of our legitimate interest in their regulation. The necessity of storing the data is checked regularly; otherwise the statutory storage obligations apply.

  • Processed data types: 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. contract object, duration, customer category).
  • Data subjects: Users (e.g. website visitors, users of online services); Members; Business and contractual partners.
  • Purposes of Processing: Provision of contractual services and customer support; Contact requests and communication; Managing and responding to inquiries.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).

Business services

Bei der Kontaktaufnahme mit uns (z.B. per Post, Kontaktformular, E-Mail, Telefon oder via soziale Medien) sowie im Rahmen bestehender Nutzer- und Geschäftsbeziehungen werden die Angaben der anfragenden Personen verarbeitet soweit dies zur Beantwortung der Kontaktanfragen und etwaiger angefragter Maßnahmen erforderlich ist.

  • Verarbeitete Datenarten: Kontaktdaten (z.B. E-Mail, Telefonnummern); Inhaltsdaten (z.B. Eingaben in Onlineformularen); Nutzungsdaten (z.B. besuchte Webseiten, Interesse an Inhalten, Zugriffszeiten); Meta-, Kommunikations- und Verfahrensdaten (z. B. IP-Adressen, Zeitangaben, Identifikationsnummern, Einwilligungsstatus).
  • Betroffene Personen: Kommunikationspartner.
  • Zwecke der Verarbeitung: Kontaktanfragen und Kommunikation; Verwaltung und Beantwortung von Anfragen; Feedback (z.B. Sammeln von Feedback via Online-Formular); Bereitstellung unseres Onlineangebotes und Nutzerfreundlichkeit.
  • Rechtsgrundlagen: Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Vertragserfüllung und vorvertragliche Anfragen (Art. 6 Abs. 1 S. 1 lit. b) DSGVO).

Weitere Hinweise zu Verarbeitungsprozessen, Verfahren und Diensten:Kontaktformular: Wenn Nutzer über unser Kontaktformular, E-Mail oder andere Kommunikationswege mit uns in Kontakt treten, verarbeiten wir die uns in diesem Zusammenhang mitgeteilten Daten zur Bearbeitung des mitgeteilten Anliegens; Rechtsgrundlagen: Vertragserfüllung und vorvertragliche Anfragen (Art. 6 Abs. 1 S. 1 lit. b) DSGVO), Berechtigte Interessen (Art. 6 Abs. 1 S. 1 lit. f) DSGVO).

Webanalyse, Monitoring und Optimierung

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

We process this data in order to fulfill our contractual obligations. These include, 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 economical 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 privacy policy.

Which data are necessary for the aforementioned purposes, we inform the contracting partners before or in the context of the data collection, e.g. in online forms by special marking (e.g. colors), and/or symbols (e.g. asterisks or the like), or personally.

We delete the data after expiry of statutory warranty and comparable obligations, i.e. in principle after expiry of 4 years, unless the data is stored in a customer account or must be kept for legal reasons of archiving. The statutory retention period for documents relevant under tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period begins 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 sent, or the accounting document was created, furthermore the record was made or the other documents were created. 

If we use third-party providers or platforms to provide our services, the terms and conditions and privacy policies of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

  • Processed data types: 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. contract object, duration, customer category).
  • Special categories of personal data: Health Data (Article 9 (1) GDPR).
  • Data subjects: Prospective customers; Business and contractual partners; Patients.
  • Purposes of Processing: Provision of contractual services and customer support; Contact requests and communication; Office and organisational procedures; Managing and responding to inquiries.
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Compliance with a legal obligation (Article 6 (1) (c) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Medical Services: We process the data of our patients in order to provide them with our services. The data processed, the type, scope and purpose of their processing and the necessity of their processing are determined by the underlying contractual and patients relationship and will be communicated to the patients in a timely manner.Within the scope of our services, we may also process special categories of data, here in particular information on the health of patients, possibly with reference to their sexual life or sexual orientation and data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs. To this end, we obtain the express consent of patients where necessary and process the special categories of data otherwise for the purposes of health care, contract performance or protection of the vital interests of patients. Consents to the processing of this data are given in accordance with Article 9(2)(a) of the GDPR; otherwise, processing is carried out in accordance with Article 9(2)(h) of the GDPR, in particular for preventive health care and in conjunction with applicable national regulations.Insofar as it is necessary for the fulfilment of our contractual obligations, the protection of vital interests or by law (e.g. for the fulfillment of obligations under social law and reporting requirements), or with the patient’s consent, we disclose or transfer the patients’s data to third parties or agents, such as public authorities, medical facilities or professional experts, accounting offices and in the field of IT, office or comparable services, in compliance with professional regulations.Your data will be retained for as long as is necessary for the provision of our services and any follow-up care. As a rule, the retention period is ten years, but may deviate in special cases due to special regulations, e.g. the requirements of the Radiation protection law; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Consulting: We process the data of our clients, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to provide them with our consulting services. The data processed, the type, scope and purpose of the processing and the necessity of its processing are determined by the underlying contractual and client relationship.Insofar as 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, courts, subcontractors or in the field of IT, office or comparable services, taking into account the professional requirements; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).
  • Therapeutic Services: We process the data of our clients and interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to provide them with our services. The data processed, the type, scope and purpose of their processing and the necessity of their processing are determined by the underlying contractual and client relationship.Within the scope of our services, we may also process special categories of data, here in particular information on the health of clients, possibly with reference to their sexual life or sexual orientation and data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs.  To this end, we obtain the express consent of clients where necessary and process the special categories of data otherwise for the purposes of health care, if the data is public or wit an other legal persmission.Insofar as it is necessary for the fulfilment of our contractual obligations, the protection of vital interests or by law, or with theclients’s consent, we disclose or transfer the clients’s data to third parties or agents, such as public authorities, medical facilities or professional experts, accounting offices and in the field of IT, office or comparable services, in compliance with professional regulations; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Providers and services used in the course of business

As part of our business activities, 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, legal and economic management of our business operations and internal organization.

  • Processed data types: 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. text input, photographs, videos); Contract data (e.g. contract object, duration, customer category).
  • Data subjects: Customers; Prospective customers; Users (e.g. website visitors, users of online services); Business and contractual partners; Employees (e.g. Employees, job applicants).
  • Purposes of Processing: Provision of contractual services and customer support; Office and organisational procedures.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Provision of online services and web hosting

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

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Content data (e.g. text input, photographs, videos).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).); Security measures.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Provision of online offer on rented hosting space: For the provision of our online services, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also referred to as a “web hoster”); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Collection of Access Data and Log Files: The access to our online services is logged in the form of so-called “server log files”. Server log files may include the address and name of the web pages and files accessed, the 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 general rule, IP addresses and the requesting provider.The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability and optimal load balancing of the servers; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Retention period: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.
  • United Domains: Services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacities); Service provider: united-domains AG, Gautinger Straße 10, 82319 Starnberg, Germany; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.united-domains.de; Privacy Policy: https://www.united-domains.de/unternehmen/datenschutz/; Data Processing Agreement: https://www.united-domains.de/help/faq-article/wie-erhalte-ich-den-auftragsverarbeitungs-vertrag-avv-nach-dsgvo.
  • WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online services; Service provider: Aut O’Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://wordpress.com; Privacy Policy: https://automattic.com/privacy/; Data Processing Agreement: https://wordpress.com/support/data-processing-agreements/.

Special Notes on Applications (Apps)

We process the data of the users of our application to the extent necessary to provide the users with the application and its functionalities, to monitor its security and to develop it further. Furthermore, we may contact users in compliance with the statutory provisions if communication is necessary for the purposes of administration or use of the application. In addition, we refer to the data protection information in this privacy policy with regard to the processing of user data.

Legal basis: The processing of data necessary for the provision of the functionalities of the application serves to fulfil contractual obligations. This also applies if the provision of the functions requires user authorisation (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimising the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly requested to give their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent. 

  • Processed data types: Inventory data (e.g. names, addresses); Meta/communication data (e.g. device information, IP addresses).
  • Purposes of Processing: Provision of contractual services and customer support.
  • Legal Basis: Consent (Article 6 (1) (a) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Device authorizations for access to functions and data: The use of certain functions of our application may require access to the camera and the stored recordings of the users. By default, these authorizations must be granted by the user and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the user’s device and software. Users can contact us if they require further explanation. We would like to point out that the refusal or revocation of the respective authorizations can affect the functionality of our application.

Contact and Inquiry Management

When contacting us (e.g. via 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.

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.).
  • Purposes of Processing: Contact requests and communication; Managing and responding to inquiries; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Performance of a contract and prior requests (Article 6 (1) (b) GDPR).

Further information on processing methods, procedures and services used:

  • Contact form: When users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request; Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (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 using the Conference Platforms and their services, we comply with the legal requirements. 

Data processed by Conference Platforms: In the course of participation in a Conference, the Data of the participants listed below are processed. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific Conference (e.g., provision of access data or clear names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants’ Data may also be processed by the Conference Platforms for security purposes or service optimization. The processed Date includes personal information (first name, last name), contact information (e-mail address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants’ end devices, their operating system, the browser and its technical and linguistic settings, information on the content-related communication processes, i.e. entries in chats and 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 participants are registered as users with the Conference Platforms, then further data may be processed in accordance with the agreement with the respective Conference Provider.

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

Data protection measures of the participants: Please refer to the data privacy information of the Conference Platforms for details on the processing of your data and select the optimum security and data privacy settings for you within the framework of the settings of the conference platforms. Furthermore, please ensure data and privacy protection in the background of your recording for the duration of a Conference (e.g., by notifying roommates, locking doors, and using the background masking function, if technically possible). Links to the conference rooms as well as access data, should not be passed on to unauthorized third parties.

Notes on legal bases: Insofar as, in addition to the Conference Platforms, we also process users’ data and ask users for their consent to use contents from the Conferences or certain functions (e.g. consent to a recording of Conferences), the legal basis of the processing is this consent.  Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g. in participant lists, in the case of reprocessing of Conference results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services); Persons depicted.
  • Purposes of Processing: Provision of contractual services and customer support; Contact requests and communication; Office and organisational procedures.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Job Application Process

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 information contained therein. 

In principle, the required information includes personal information such as name, address, a contact option and proof of the qualifications required for a particular employment. Upon request, we will be happy to provide you with additional information.

If made available, applicants can submit their applications via an online form. The data will be transmitted to us encrypted according to the state of the art. Applicants can also send us their applications by e-mail. Please note, however, that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the application between the sender and the reception on our server. For the purposes of searching for applicants, submitting applications and selecting applicants, we may make use of the applicant management and recruitment software, platforms and services of 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 regular mail.

Processing of special categories of data: If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can exercise his/her rights arising from labour law and social security and social protection law and fulfil his/her duties in this regard, their processing shall be carried out in accordance with Article 9 (1)(b) GDPR, in the case of the protection of vital interests of applicants or other persons pursuant to Article 9 (1)(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 administration of systems and services in the health or social sector in accordance with Article 9 (1)(h) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (1)(a) GDPR.

Ereasure of data: In the event of a successful application, the data provided by the applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant’s data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, to which applicants are entitled at any time. Subject to a justified revocation by the applicant, 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 regarding the application and comply with our duty of proof under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.

Admission to a talent pool – Admission to an talent pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future.

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Job applicant details (e.g. Personal data, postal and contact addresses and the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, etc., as well as other information on the person or qualifications of applicants provided with regard to a specific job or voluntarily by applicants).
  • Data subjects: Job applicants.
  • Purposes of Processing: Job Application Process (Establishment and possible later execution as well as possible later termination of the employment relationship).
  • Legal Basis: Job application process as a pre-contractual or contractual relationship (Article 6 (1)(b) GDPR).

Profiles 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 entail risks for users, e.g. by making it more difficult to enforce users’ rights.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on).

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

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • 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 (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.instagram.comPrivacy Policy: https://instagram.com/about/legal/privacy.
  • Facebook-Seiten: Profiles within the social network Facebook – We are jointly responsible (so called “joint controller”) with Meta Platforms Ireland Limited for the collection (but not the further processing) of data of visitors to our Facebook page. This data includes information about the types of content users view or interact with, or the actions they take (see “Things that you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), and information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie information; see “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How we use this information?” Facebook also collects and uses information to provide analytics services, known as “page insights,” to site operators to help them understand how people interact with their pages and with content associated with them. We have concluded a special agreement with Facebook (“Information about Page-Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular the security measures that Facebook must observe and in which Facebook has agreed to fulfill the rights of the persons concerned (i.e. users can send information access or deletion requests directly to Facebook). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.facebook.comPrivacy Policy: https://www.facebook.com/about/privacyStandard Contractual Clauses (Safeguarding the level of data protection when processing data in third countries): https://www.facebook.com/legal/EU_data_transfer_addendumFurther Information: Joint Controllership Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint controllership is limited to the collection and transfer of the data to Meta Platforms Ireland Limited, a company located in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • Facebook events: Event profiles within the social network Facebook – We use the “Events” function of the Facebook platform to refer to events and dates as well as to get in touch with users (participants and interested parties) and to exchange information. In doing so, we process personal data of the users of our event pages, as far as this is necessary for the purpose of the event page as well as its moderation. These data include information on first and last names, as well as published or privately communicated content, as well as values on the status of participation and the time information on the aforementioned data. Furthermore, we refer to the processing of data of users by Facebook itself. This data includes information about the types of content users view or interact with, or the actions they take (see under “Things You and Others Do and Provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, known as “insights,” to event providers to provide them with insights about how people interact with their event pages and with content associated with them; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.facebook.comPrivacy Policy: https://www.facebook.com/about/privacy.
  • Twitter: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal Basis:Legitimate Interests (Article 6 (1) (f) GDPR); Privacy Policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Privacy Policy: https://policies.google.com/privacyOpt-Out: https://adssettings.google.com/authenticated.

Plugins and embedded functions and content

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as “Content”).

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Location data (Information on the geographical position of a device or person).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of Processing: Provision of our online services and usability; Provision of contractual services and customer support.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

  • Google Fonts (Provision on own server): Obtaining fonts (“Google Fonts”) for the purpose of a user-friendly appearance of our online services; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).
  • Google Maps: We integrate the maps of the service “Google Maps” from the provider Google. The data processed may include, in particular, IP addresses and location data of users; Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://mapsplatform.google.com/Privacy Policy: https://policies.google.com/privacy.
  • OpenStreetMap: We integrate the maps of the service “OpenStreetMap”, which are offered based on the Open Data Commons Open Database License (ODbL) by the OpenStreetMap Foundation (OSMF). OpenStreetMap uses user data exclusively for the purpose of displaying map functions and temporarily storing the selected settings. This data may include, in particular, IP addresses and location data of users, which are not collected without their consent (usually within the context of the settings of their mobile devices); Service provider: OpenStreetMap Foundation (OSMF); Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.openstreetmap.deTerms & Conditions: https://wiki.osmfoundation.org/wiki/Privacy_PolicyPrivacy Policy: https://wiki.osmfoundation.org/wiki/Privacy_Policy.
  • YouTube videos: Video contents; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, , parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Website: https://www.youtube.comPrivacy Policy: https://policies.google.com/privacyOpt-Out:Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=en,  Settings for the Display of Advertisements: https://adssettings.google.com/authenticated.

Management, Organization and Utilities

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

Within this context, personal data may be processed and stored on the servers of third-party providers. This may include 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 processes, contracts, other processes and their contents.

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 provider processing may process usage data and metadata that can be processed by them for security purposes, service optimisation or marketing purposes. We therefore ask you to read the data protection notices of the respective third party providers.

  • Processed data types: Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Contract data (e.g. contract object, duration, customer category).
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services); Business and contractual partners.
  • Purposes of Processing: Contact requests and communication; Provision of contractual services and customer support; Office and organisational procedures.
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR).

Further information on processing methods, procedures and services used:

Changes and Updates to the Privacy Policy

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

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

Rights of Data Subjects

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

  • Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to revoke consents at any time.
  • Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law.
  • Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
  • Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data 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 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 request its transmission to another controller.
  • Complaint to the supervisory authority: In accordance with the law 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 where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

Terminology and Definitions

This section provides an overview of the terms used in this privacy policy. Many of the terms are drawn from the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended above all for the purpose of comprehension. The terms are sorted alphabetically.

  • Controller: “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. 
  • Location data: Location data is created when a mobile device (or another device with the technical requirements for a location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data serve to indicate the geographically determinable position of the earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location. 
  • Personal Data: “personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 
  • Processing: The term “processing” covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure. 

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