Privacy Policy Preamble
With the following privacy policy we would like to inform you which
types of your personal data (hereinafter also abbreviated as "data")
we process for which purposes and in which scope. The privacy
statement applies to all processing of personal data carried out by
us, both in the context of providing our services and in particular on
our websites, in mobile applications and within external online
presences, such as our social media profiles (hereinafter collectively
referred to as "online services").
The terms used are not gender-specific.
Last Update: 2. August 2021
Table of contents
- Preamble
- Controller
- Overview of processing operations
- Legal Bases for the Processing
- Security Precautions
- Erasure of data
- Business services
- Provision of online services and web hosting
- Blogs and publication media
- Contacting us
- Communication via Messenger
-
Video Conferences, Online Meetings, Webinars and Screen-Sharing
- Musik & Podcats
- Cloud Services
- Newsletter and Electronic Communications
- Web Analysis, Monitoring and Optimization
- Profiles in Social Networks (Social Media)
- Management, Organization and Utilities
- Changes and Updates to the Privacy Policy
- Rights of Data Subjects
- Terminology and Definitions
Controller
Jürgen Alker
Friedensallee 54a
22765 Hamburg
Germany
Authorised Representatives: Jürgen Alker.
E-mail address: mail@alker.io.
Phone: +49 40 288 033 09.
Legal Notice: https://alker.io/imprint.
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 (e.g. names, addresses).
- Content data (e.g. text input, photographs, videos).
- Contact data (e.g. e-mail, telephone numbers).
-
Meta/communication data (e.g. device information, IP addresses).
-
Usage data (e.g. websites visited, interest in content, access
times).
-
Contract data (e.g. contract object, duration, customer category).
- Payment Data (e.g. bank details, invoices, payment history).
Special Categories of Data
- Data revealing racial or ethnic origin.
Categories of Data Subjects
- Employees (e.g. Employees, job applicants).
- Business and contractual partners.
- Prospective customers.
- Communication partner (Recipients of e-mails, letters, etc.).
- Customers.
- Users (e.g. website visitors, users of online services).
Purposes of Processing
- Provision of our online services and usability.
-
Conversion tracking (Measurement of the effectiveness of marketing
activities).
- Office and organisational procedures.
- Content Delivery Network (CDN).
- Direct marketing (e.g. by e-mail or postal).
- Feedback (e.g. collecting feedback via online form).
- Marketing.
- Contact requests and communication.
-
Profiles with user-related information (Creating user profiles).
-
Web Analytics (e.g. access statistics, recognition of returning
visitors).
- Provision of contractual services and customer support.
- Managing and responding to inquiries.
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.
National data protection regulations in Germany: 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.
SSL encryption (https): In order to protect your data
transmitted via our online services in the best possible way, we use
SSL encryption. You can recognize such encrypted connections by the
prefix https:// in the address bar of your browser.
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.
Business services
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 fulfil our contractual obligations,
safeguard our rights and for the purposes of the administrative tasks
associated with this data and the business-related organisation. We
will only pass on the data of the contractual partners within the
scope of the applicable law to third parties insofar as this is
necessary for the aforementioned purposes or for the fulfilment of
legal obligations or with the consent of data subjects concerned (e.g.
telecommunications, transport and other auxiliary services as well as
subcontractors, banks, tax and legal advisors, payment service
providers or tax authorities). The contractual partners will be
informed about further processing, e.g. for marketing purposes, as
part 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 (e.g., as a rule 10 years for tax purposes). In the case
of data disclosed to us by the contractual partner within the context
of an assignment, we delete the data in accordance with the
specifications of the assignment, in general after the end of the
assignment.
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.
Coaching: 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, accounting
offices and in the field of IT, office or comparable services, in
compliance with professional regulations.
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.
Consulting: Insofar as it is necessary for our
contractual performance or required by law, or if the consent of the
customer has been obtained, we disclose or transfer the customer's
data to third parties or agents, such as authorities, courts or in the
field of IT, office or comparable services, in compliance with the
contractual and legal requirements.
- 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 related to sexual preferences, sex life, and/or sexual
orientation (Article 9 (1) GDPR), Rreligious or philosophical beliefs
(Article 9 (1) GDPR), Data revealing racial or ethnic origin.
- Data subjects: Prospective customers, Business and contractual
partners, Customers.
- 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).
Provision of online services and web hosting
In order to provide our online services securely and efficiently, we
use the services of one or more web hosting providers from whose
servers (or servers they manage) the online services can be accessed.
For these purposes, we may use infrastructure and platform services,
computing capacity, storage space and database services, as well as
security and technical maintenance services.
The data processed within the framework of the provision of the
hosting services may include all information relating to the users of
our online services that is collected in the course of use and
communication. This regularly includes the IP address, which is
necessary to be able to deliver the contents of online services to
browsers, and all entries made within our online services or from
websites.
Collection of Access Data and Log Files: We,
ourselves or our web hosting provider, collect data on the basis of
each access to the server (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 .
Content-Delivery-Network: We use a so-called "Content
Delivery Network" (CDN). A CDN is a service with whose help contents
of our online services, in particular large media files, such as
graphics or scripts, can be delivered faster and more securely with
the help of regionally distributed servers connected via the Internet.
- Processed data types: Content data (e.g. 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: Provision of our online services
and usability, Content Delivery Network (CDN).
- Legal Basis: Legitimate Interests (Article 6 (1) (f)
GDPR).
Services and service providers being used:
Blogs and publication media
We use blogs or comparable means of online communication and
publication (hereinafter "publication medium"). Readers' data will
only be processed for the purposes of the publication medium to the
extent necessary for its presentation and communication between
authors and readers or for security reasons. For the rest, we refer to
the information on the processing of visitors to our publication
medium within the scope of this privacy policy.
- 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: Users (e.g. website visitors, users of
online services).
- Purposes of Processing: Provision of contractual services
and customer support, Feedback (e.g. collecting feedback via online form).
- Legal Basis: Performance of a contract and prior requests
(Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Services and service providers being used:
Contacting us
When contacting us (e.g. by contact form, e-mail, telephone or via
social media), the data of the inquiring persons are processed insofar
as this is necessary to answer the contact enquiries and any requested
activities.
The response to contact enquiries within the framework of contractual
or pre-contractual relationships is made in order to fulfil our
contractual obligations or to respond to (pre)contractual enquiries
and otherwise on the basis of the legitimate interests in responding
to the enquiries.
- 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).
- Data subjects: Communication partner (Recipients of
e-mails, letters, etc.).
- Purposes of Processing: Contact requests and communication.
- Legal Basis: Performance of a contract and prior requests
(Article 6 (1) (b) GDPR), Legitimate Interests (Article 6 (1) (f) GDPR).
Communication via Messenger
We use messenger services for communication purposes and therefore ask
you to observe the following information regarding the functionality
of the messenger services, encryption, use of the metadata of the
communication and your objection options.
You can also contact us by alternative means, e.g. telephone or
e-mail. Please use the contact options provided to you or use the
contact options provided within our online services.
In the case of encryption of content (i.e. the content of your message
and attachments), we point out that the communication content (i.e.
the content of the message and attachments) is encrypted end-to-end.
This means that the content of the messages is not visible, not even
by the messenger service providers themselves. You should always use a
current version of the messenger service with activated encryption, so
that the encryption of the message contents is guaranteed.
However, we would like to point out to our communication partners that
although messenger service providers do not see the content, they can
find out that and when communication partners communicate with us and
process technical information on the communication partner's device
used and, depending on the settings of their device, also location
information (so-called metadata).
Information on Legal basis: If we ask communication partners
for permission before communicating with them via messenger services, the
legal basis of our processing of their data is their consent. Otherwise,
if we do not request consent and you contact us, for example, voluntarily,
we use messenger services in our dealings with our contractual partners
and as part of the contract initiation process as a contractual measure
and in the case of other interested parties and communication partners
on the basis of our legitimate interests in fast and efficient communication
and meeting the needs of our communication partners for communication via
messenger services. We would also like to point out that we do not transmit
the contact data provided to us to the messenger service providers for
the first time without your consent.
Withdrawal, objection and deletion: You can withdraw your
consent or object to communication with us via messenger services at any
time.In the case of communication via messenger services, we delete the
messages in accordance with our general data retention policy (i.e. as
described above after the end of contractual relationships, archiving requirements,
etc.) and otherwise as soon as we can assume that we have answered any
information provided by the communication partners, if no reference to
a previous conversation is to be expected and there are no legal obligations
to store the messages to prevent their deletion.
Reservation of reference to other means of communication:
Finally, we would like to point out that we reserve the right,
for reasons of your safety, not to answer inquiries about messenger services.
This is the case if, for example, internal contractual matters require
special secrecy or if an answer via the messenger services does not meet
the formal requirements. In such cases we refer you to more appropriate
communication channels.
- Processed data types: Contact data (e.g. e-mail, telephone
numbers), Usage data (e.g. websites visited, interest in content, access
times), Meta/communication data (e.g. device information, IP addresses),
Content data (e.g. text input, photographs, videos).
- Data subjects: Communication partner (Recipients of
e-mails, letters, etc.).
- Purposes of Processing: Contact requests and communication,
Direct marketing (e.g. by e-mail or postal).
- Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate
Interests (Article 6 (1) (f) GDPR).
Services and service providers being used:
- Signal: Signal Messenger with end-to-end encryption;
Service provider: Privacy Signal Messenger, LLC 650 Castro Street, Suite
120-223 Mountain View, CA 94041, USA; Website:
https://signal.org/; Privacy
Policy:
https://signal.org/legal/ .
- Slack: Slack Messenger ohne end-to-end encryption; Service
provider: Slack Technologies, Inc., 500 Howard Street, San Francisco,
CA 94105, USA; Website:
https://slack.com/ ; Privacy
Policy:
https://slack.com/intl/en-de/legal
.
- WhatsApp: WhatsApp Messenger with end-to-end encryption;
Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay, Dublin
2, D02 KH28, Ireland; Website:
https://www.whatsapp.com/;
Privacy Policy:
https://www.whatsapp.com/legal
.
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).
- Purposes of Processing: Provision of contractual services
and customer support, Contact requests and communication, Office and
organisational procedures.
- 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).
Services and service providers being used:
- Google Hangouts / Meet: Messenger and conference software;
Service provider: Google Ireland Limited, Gordon House, Barrow Street,
Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway,
Mountain View, CA 94043, USA; Website:
https://hangouts.google.com/
; Privacy Policy:
https://policies.google.com/privacy
.
- Microsoft Teams: Messenger and conference software;
Service provider: Microsoft Corporation, One Microsoft Way, Redmond,
WA 98052-6399 USA; Website:
https://products.office.com
; Privacy Policy:
https://privacy.microsoft.com/de-de/privacystatement
, Security information:
https://www.microsoft.com/de-de/trustcenter
.
- Slack: Messenger and conference software; Service provider:
Slack Technologies, Inc., 500 Howard Street, San Francisco, CA 94105,
USA; Website:
https://slack.com/; Privacy Policy:
https://slack.com/intl/en-de/legal
.
- Zoom: Video Conferencing, Web Conferencing and Webinars;
Service provider: Zoom Video Communications, Inc., 55 Almaden Blvd.,
Suite 600, San Jose, CA 95113, USA; Website:
https://zoom.us; Privacy Policy:
https://zoom.us/docs/de-de/privacy-and-legal.html
; Standard Contractual Clauses (Safeguarding the level of data
protection when processing data in third countries):
https://zoom.us/docs/de-de/privacy-and-legal.html
(referred to as Global DPA).
Music & Podcasts
We use hosting and analysis services of service providers to offer our
audio content for listening to or downloading and to obtain
statistical information on the request of the audio content.
- Processed data types: Usage data (e.g. websites visited,
interest in content, access times), Meta/communication data (e.g. device
information, IP addresses).
- Data subjects: Users (e.g. website visitors, users of
online services).
- Purposes of Processing: Web Analytics (e.g. access statistics,
recognition of returning visitors), Conversion tracking (Measurement
of the effectiveness of marketing activities), Profiles with user-related
information (Creating user profiles).
Services and service providers being used:
Cloud Services
We use Internet-accessible software services (so-called "cloud
services", also referred to as "Software as a Service") provided on
the servers of its providers for the following purposes: document
storage and administration, calendar management, e-mail delivery,
spreadsheets and presentations, exchange of documents, content and
information with specific recipients or publication of websites, forms
or other content and information, as well as chats and participation
in audio and video conferences.
Within this framework, personal data may be processed and stored on
the provider's servers insofar as this data is part of communication
processes with us or is otherwise processed by us in accordance with
this privacy policy. This data may include in particular master data
and contact data of data subjects, data on processes, contracts, other
proceedings and their contents. Cloud service providers also process
usage data and metadata that they use for security and service
optimization purposes.
If we use cloud services to provide documents and content to other
users or publicly accessible websites, forms, etc., providers may
store cookies on users' devices for web analysis or to remember user
settings (e.g. in the case of media control).
Information on legal basis - If we ask for permission
to use cloud services, the legal basis for processing data is consent.
Furthermore, their use can be a component of our (pre)contractual services,
provided that the use of cloud services has been agreed in this context.
Otherwise, user data will be processed on the basis of our legitimate interests
(i.e. interest in efficient and secure administrative and collaboration
processes).
- 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), Contract data (e.g. contract object, duration, customer
category).
- Data subjects: Customers, Employees (e.g. Employees,
job applicants), Prospective customers, Communication partner (Recipients
of e-mails, letters, etc.).
- Purposes of Processing: Office and organisational procedures.
- 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).
Services and service providers being used:
- Apple iCloud: Cloud storage services; Service provider:
Apple Inc., Infinite Loop, Cupertino, CA 95014, USA; Website:
https://www.apple.com; Privacy
Policy:
https://www.apple.com/legal/privacy/en-ww/
.
- Dropbox: Cloud storage services; Service provider: Dropbox,
Inc., 333 Brannan Street, San Francisco, California 94107, USA; Website:
https://www.dropbox.com;
Privacy Policy:
https://www.dropbox.com/privacy
; Standard Contractual Clauses (Safeguarding the level of data
protection when processing data in third countries):
https://assets.dropbox.com/documents/en/legal/data-processing-agreement-dfb-013118.pdf
.
- Google Cloud Services: Cloud storage services; Service
provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin
4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain
View, CA 94043, USA; Website:
https://cloud.google.com/ ;
Privacy Policy:
https://www.google.com/policies/privacy, Security information:
https://cloud.google.com/security/privacy.
Newsletter and Electronic Communications
We send newsletters, e-mails and other electronic communications
(hereinafter referred to as "newsletters") only with the consent of
the recipient or a legal permission. Insofar as the contents of the
newsletter are specifically described within the framework of
registration, they are decisive for the consent of the user.
Otherwise, our newsletters contain information about our services and
us.
In order to subscribe to our newsletters, it is generally sufficient
to enter your e-mail address. We may, however, ask you to provide a
name for the purpose of contacting you personally in the newsletter or
to provide further information if this is required for the purposes of
the newsletter.
Double opt-in procedure: The registration to our newsletter
takes place in general in a so-called Double-Opt-In procedure. This means
that you will receive an e-mail after registration asking you to confirm
your registration. This confirmation is necessary so that no one can register
with external e-mail addresses.
The registrations for the newsletter are logged in order to be able to
prove the registration process according to the legal requirements.
This includes storing the login and confirmation times as well as the
IP address. Likewise the changes of your data stored with the dispatch
service provider are logged.
Deletion and restriction of processing: We may store the
unsubscribed email addresses for up to three years based on our legitimate
interests before deleting them to provide evidence of prior consent. The
processing of these data is limited to the purpose of a possible defense
against claims. An individual deletion request is possible at any time,
provided that the former existence of a consent is confirmed at the same
time. In the case of an obligation to permanently observe an objection,
we reserve the right to store the e-mail address solely for this purpose
in a blocklist.
Information on legal bases: The sending of the newsletter
is based on the consent of the recipients or, if consent is not required,
on the basis of our legitimate interests in direct marketing. Insofar as
we engage a service provider for sending e-mails, this is done on the basis
of our legitimate interests. The registration procedure is recorded on
the basis of our legitimate interests for the purpose of demonstrating
that it has been conducted in accordance with the law.
Contents: Industry news, Information about us and our services.
Measurement of opening rates and click rates: The
newsletters contain a so-called "web-beacon", i.e. a pixel-sized file,
which is retrieved from our server when the newsletter is opened or,
if we use a mailing service provider, from its server. Within the
scope of this retrieval, technical information such as information
about the browser and your system, as well as your IP address and time
of retrieval are first collected.
This information is used for the technical improvement of our
newsletter on the basis of technical data or target groups and their
reading behaviour on the basis of their retrieval points (which can be
determined with the help of the IP address) or access times. This
analysis also includes determining whether newsletters are opened,
when they are opened and which links are clicked. This information is
assigned to the individual newsletter recipients and stored in their
profiles until the profiles are deleted. The evaluations serve us much
more to recognize the reading habits of our users and to adapt our
content to them or to send different content according to the
interests of our users.
The measurement of opening rates and click rates as well as the
storage of the measurement results in the profiles of the users and
their further processing are based on the consent of the users.
A separate objection to the performance measurement is unfortunately
not possible, in this case the entire newsletter subscription must be
cancelled or objected to. In this case, the stored profile information
will be deleted.
- Processed data types: Inventory data (e.g. names, addresses),
Contact data (e.g. e-mail, telephone numbers), Meta/communication data
(e.g. device information, IP addresses), Usage data (e.g. websites visited,
interest in content, access times).
- Data subjects: Communication partner (Recipients of
e-mails, letters, etc.).
- Purposes of Processing: Direct marketing (e.g. by e-mail
or postal).
- Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate
Interests (Article 6 (1) (f) GDPR).
- Opt-Out: You can cancel the receipt of our newsletter
at any time, i.e. revoke your consent or object to further receipt. You
will find a link to cancel the newsletter either at the end of each newsletter
or you can otherwise use one of the contact options listed above, preferably
e-mail.
Services and service providers being used:
Web Analysis, Monitoring and Optimization
We want to process as little personal information as possible when you
use our website. That's why we've chosen Fathom Analytics for our
website analytics, which doesn't use cookies and complies with the
GDPR, ePrivacy (including PECR), COPPA and CCPA. Using this
privacy-friendly website analytics software, your IP address is only
briefly processed, and we (running this website) have no way of
identifying you. As per the CCPA, your personal information is
de-identified. You can read more about this on
Fathom Analytics' website
.
The purpose of us using this software is to understand our website
traffic in the most privacy-friendly way possible so that we can
continually improve our website and business. The lawful basis as per
the GDPR is "f); where our legitimate interests are to improve our
website and business continually." As per the explanation, no personal
data is stored over time.
Processed data types: Usage data (e.g. websites visited,
interest in content, access times), Meta/communication data (e.g. device
information, IP addresses).
-
Data subjects: Users (e.g. website visitors, users of online
services).
-
Purposes of Processing: Web Analytics (e.g. access statistics,
recognition of returning visitors), Profiles with user-related
information (Creating user profiles).
-
Security measures: IP Masking (Pseudonymization of the IP address).
-
Legal Basis: Consent (Article 6 (1) (a) GDPR), Legitimate Interests
(Article 6 (1) (f) GDPR).
Services and service providers being used:
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
networs 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.
Facebook: We are jointly responsible (so called
"joint controller") with Facebook Ireland Ltd. 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
).
- 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).
Services and service providers being used:
- Instagram: Social network; Service provider: Instagram
Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, , Mutterunternehmen:
Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website:
https://www.instagram.com;
Privacy Policy:
https://instagram.com/about/legal/privacy
.
- Facebook: Social network; Service provider: Facebook
Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland,
parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website:
https://www.facebook.com;
Privacy Policy:
https://www.facebook.com/about/privacy
; Opt-Out: Settings for advertisements:
https://www.facebook.com/adpreferences/ad_settings
(login at Facebook is required).
- LinkedIn: Social network; Service provider: LinkedIn
Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Website:
https://www.linkedin.com;
Privacy Policy:
https://www.linkedin.com/legal/privacy-policy
; Opt-Out:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
.
- 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; Privacy Policy:
https://twitter.com/de/privacy
, (Settings)
https://twitter.com/personalization
.
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.
Information on legal basis: If we ask the users for their
consent to the use of third party providers, the legal basis of the processing
is consent. Furthermore, the processing can be a component of our (pre)contractual
services, provided that the use of the third party was agreed within this
context. Otherwise, user data will be processed on the basis of our legitimate
interests (i.e. interest in efficient, economic and recipient friendly
services). In this context, we would also like to refer you to the information
on the use of cookies in this privacy policy.
- 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), Business and contractual partners.
- Purposes of Processing: Office and organisational procedures,
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).
Services and service providers being used:
- Asana: Project management - organization and administration
of teams, groups, workflows, projects and processes; Service provider:
Asana, Inc, 1550 Bryant Street, Suite 200, San Francisco, CA 94103, USA;
Website:
https://asana.com/de; Privacy
Policy:
https://asana.com/terms#privacy-policy
.
- calendly: Online scheduling; Service provider: Calendly
LLC., 271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, USA; Website:
https://calendly.com; Privacy
Policy:
https://calendly.com/pages/privacy
.
- DocuSign: DocuSign provides a digital transaction management
platform to facilitate digital transactions that include the signing
process of contractual documents and other documents; Service provider:
DocuSign, Inc., 221 Main Street Suite 1000 San Francisco, CA 94105, USA;
Website:
https://www.docusign.com/ ;
Privacy Policy:
https://www.docusign.com/company/privacy-policy
; The processing as processor and controller is carried out on
the basis of approved Binding Corporate Rules, which ensure a level
of data protection in accordance with the requirements of the GDPR
(Article 47 GDPR):
https://www.docusign.com/trust/privacy/binding-corporate-rules
.
- Miro: Online whiteboard and collaboration platform;
Service provider: Realtimeboard Inc. dba Miro, 201 Spear Street Suite
1100, San Francisco, California 94105, USA; Website:
https://miro.com/ ; Privacy Policy:
https://miro.com/legal/privacy-policy/
.
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.
Supervisory authority competent for us:
The Hamburg Commissioner for Data Protection and Freedom of
InformationUlrich Kühn (V.i.A.)Ludwig-Erhard-Str. 22 7.OG20459
HamburgPhone: +49 40 428 54 40 40
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.
- Content Delivery Network (CDN): A "Content Delivery
Network" (CDN) is a service with whose help contents of our online services,
in particular large media files, such as graphics or scripts, can be
delivered faster and more securely with the help of regionally distributed
servers connected via the Internet.
- 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.
- Conversion tracking: Conversion tracking is a method
used to evaluate the effectiveness of marketing measures. For this purpose,
a cookie is usually stored on the devices of the users within the websites
on which the marketing measures take place and then called up again on
the target website (e.g. we can thus trace whether the advertisements
placed by us on other websites were successful).
- IP Masking: IP masking is a method by which the last
octet, i.e. the last two numbers of an IP address, are deleted so that
the IP address alone can no longer be used to uniquely identify a person.
IP masking is therefore a means of pseudonymising processing methods,
particularly in online marketing.
- 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.
- Profiles with user-related information: The processing
of "profiles with user-related information", or "profiles" for short,
includes any kind of automated processing of personal data that consists
of using these personal data to analyse, evaluate or predict certain
personal aspects relating to a natural person (depending on the type
of profiling, this may include different information concerning demographics,
behaviour and interests, such as interaction with websites and their
content, etc.) (e.g. interests in certain content or products, click
behaviour on a website or location). Cookies and web beacons are often
used for profiling purposes.
- Web Analytics: Web Analytics serves the evaluation of
visitor traffic of online services and can determine their behavior or
interests in certain information, such as content of websites. With the
help of web analytics, website owners, for example, can recognize at
what time visitors visit their website and what content they are interested
in. This allows them, for example, to optimize the content of the website
to better meet the needs of their visitors. For purposes of web analytics,
pseudonymous cookies and web beacons are frequently used in order to
recognise returning visitors and thus obtain more precise analyses of
the use of an online service.
