Privacy Policy

1. An Overview of Data Protection

General Information

The following information will provide you with an easy-to-navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data Recording on This Website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under the section “Information about the responsible party (referred to as the ‘controller’ in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance, be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error-free provision of the website. Other data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data be rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection-related issues.

Analysis Tools and Tools Provided by Third Parties

There is a possibility that your browsing patterns will be statistically analyzed when you visit this website. Such analyses are performed primarily with what we refer to as analysis programs. For detailed information about these analysis programs, please consult our Data Protection Declaration below.

2. Hosting

RAIDBOXES

We are hosting the content of our website at the following provider: RAIDBOXES GmbH, Hafenstr. 32, 48151 Münster, Germany. Whenever you visit our website, RAIDBOXES will record a variety of logfiles, including your IP addresses.

For details, please refer to the Data Privacy Policy of RAIDBOXES: https://raidboxes.io/legal/privacy/

We use RAIDBOXES on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest in making the depiction of our website as dependable as possible. If you have been asked for your respective consent, processing shall occur exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG. Such consent may be revoked at any time.

Data Processing Agreement

We have concluded a Data Processing Agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

3. General Information and Mandatory Information

Data Protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the Responsible Party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

Implico GmbH
Poßmoorweg 2
22301 Hamburg
Germany

Phone: +49 (0)40 / 27 09 36-0
E-mail: contact@implico.com

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage Duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General Information on the Legal Basis for the Data Processing on This Website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, if special categories of data are processed according to Art. 9(1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25(1) TTDSG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. The data processing may also be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR.

Designation of a Data Protection Officer

We have appointed a data protection officer:

Christian Hammerbacher
SPH + IT Consulting & Co. KG
Bartholomäusstr. 26 (Haus D)
90489 Nürnberg
E-mail: legal@implico.com

Information on Data Transfers to Third-Party Countries and to US Companies Not DPF-Certified

We use, among other technologies, tools from companies located in third-party countries that are not safe under data protection law, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). If these tools are enabled, your personal data may be transferred to and processed in these countries. We would like you to note that no level of data protection comparable to that in the EU can be guaranteed in third countries that are insecure in terms of data protection law.

We would like to point out that the US, as a secure third-party country, generally has a level of data protection comparable to that of the EU. Data transfer to the US is therefore permitted if the recipient is certified under the “EU-US Data Privacy Framework” (DPF) or has appropriate additional assurances. Information on transfers to third-party countries, including the data recipients, can be found in this Privacy Policy.

Recipients of Personal Data

In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so, if we have a legitimate interest in the disclosure pursuant to Art. 6(1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing.

Revocation of Your Consent to the Processing of Data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to Object to the Collection of Data in Special Cases; Right to Object to Direct Advertising (Art. 21 GDPR)

In the event that data are processed on the basis of Art. 6(1)(e) or (f) GDPR, you have the right to at any time object to the processing of your personal data based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. To determine the legal basis on which any processing of data is based, please consult this Data Protection Declaration. If you log an objection, we will no longer process your affected personal data, unless we are in a position to present compelling protection-worthy grounds for the processing of your data that outweigh your interests, rights and freedoms, or if the purpose of the processing is the claiming, exercising or defense of legal entitlements (objection pursuant to Art. 21(1) GDPR).

If your personal data is being processed in order to engage in direct advertising, you have the right to object to the processing of your affected personal data for the purposes of such advertising at any time. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes (objection pursuant to Art. 21(2) GDPR).

Right to Log a Complaint with the Competent Supervisory Agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work, or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, Rectification and Eradication of Data

Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to Demand Processing Restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

• In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
• If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.
• If we do not need your personal data any longer and you need it to exercise, defend, or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
• If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise, or defend legal entitlements or to protect the rights of other natural persons or legal entities, or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS Encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

4. Recording of Data on This Website

Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them or they are automatically eradicated by your web browser.

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites.

Cookies that are required for the performance of electronic communication transactions, for the provision of certain functions you want to use, or those that are necessary for the optimization of the website shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25(1) TTDSG); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general, or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

Consent with Borlabs Cookie

Our website uses the Borlabs consent technology to obtain your consent to the storage of certain cookies in your browser or for the use of certain technologies and for their data privacy protection-compliant documentation. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg, Germany.

Whenever you visit our website, a Borlabs cookie will be stored in your browser, which archives any declarations or revocations of consent you have entered. These data are not shared with the provider of the Borlabs technology.

The recorded data shall remain archived until you ask us to eradicate them, delete the Borlabs cookie on your own, or the purpose of storing the data no longer exists. For details on Borlabs data processing, please visit: https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/

We use the Borlabs cookie consent technology to obtain the declarations of consent mandated by law for the use of cookies. The legal basis for the use of such cookies is Art. 6(1)(c) GDPR.

Contact Form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data, or if the purpose for which the information is being archived no longer exists. Mandatory legal provisions – in particular retention periods – remain unaffected.

Request by E-mail, Telephone, or Fax

If you contact us by e-mail, telephone, or fax, your request, including all resulting personal data (name, request), will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained.

Google reCAPTCHA v2

We use “Google reCAPTCHA v2” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

The purpose of reCAPTCHA is to determine whether data entered on this website (e.g., information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyzes the behavior of the website visitors based on various parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For the analysis, reCAPTCHA evaluates various data (e.g., IP address, the time the visitor spent on the website, or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google.

The storage and analysis of the data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting the operator’s web offerings against abusive automated spying and against spam. If appropriate consent has been obtained, the processing occurs exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, insofar as the consent includes the storage of cookies or the access to information in the user’s end device. This consent can be revoked at any time.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF).

For more information about Google reCAPTCHA, please refer to Google’s Privacy Policy and Terms of Use:
https://policies.google.com/privacy?hl=en
https://policies.google.com/terms?hl=en

5. Analysis Tools and Advertising

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that allows us to integrate tracking or statistics tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in a quick and uncomplicated integration and management of various tools on the website. If appropriate consent has been obtained, the processing occurs exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG. This consent can be revoked at any time.

For more information on the Google Tag Manager, please refer to: https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system, and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing user behavior patterns possible (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule, transferred to a Google server in the United States, where it is stored.

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF).

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en

Browser Plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

Facebook Pixel

This website uses the visitor action pixel from Facebook/Meta for conversion measurement purposes. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook, however, the data collected is also transferred to the USA and other third countries.

This allows the behavior of site visitors to be tracked after they have been redirected to the provider’s website by clicking on a Facebook advertisement. This allows the effectiveness of Facebook advertisements to be evaluated for statistical and market research purposes and future advertising measures to be optimized.

The data collected in this way is anonymous to us as operators of this website; we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook data usage policy.

The use of this service is based on your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 GDPR). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://www.facebook.com/legal/EU_data_transfer_addendum
https://de-de.facebook.com/help/566994660333381

If you do not wish to use the “Custom Audiences” remarketing function, you can disable it here (Facebook login required): https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen

If you do not have a Facebook account, you can deactivate usage-based advertising from Facebook on the European Interactive Digital Advertising Alliance website: http://www.youronlinechoices.com/de/praferenzmanagement/

LinkedIn Insight Tag

This website uses the Insight tag from LinkedIn. This service is provided by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Data Processing by LinkedIn Insight Tag

We use the LinkedIn Insight tag to obtain information about visitors to our website. Once a website visitor is registered with LinkedIn, we can analyze the key occupational data (e.g., career level, company size, country, location, industry, job title) of our website visitors to help us better target our site to the relevant audience. We can also use LinkedIn Insight tags to measure whether visitors to our websites perform certain actions (conversion measurement). LinkedIn Insight Tag also features a retargeting function that allows us to display targeted advertising to visitors to our website outside of the website.

LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser characteristics, and time of access). The IP addresses are shortened or (if they are used to reach LinkedIn members across devices) hashed (pseudonymized). The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymized data will then be deleted within 180 days.

For details, please see LinkedIn’s privacy policy at: https://www.linkedin.com/legal/privacy-policy#choices-oblig

Legal Basis

If your approval (consent) has been obtained, the use of the above-mentioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TTDSG. Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of Art. 6(1)(f) GDPR; the website operator has a legitimate interest in effective advertising promotions that include the utilization of social media. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission.

Objection to the Use of LinkedIn Insight Tag

You can object to LinkedIn’s analysis of user behavior and targeted advertising at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

Data Processing Agreement

We have concluded a Data Processing Agreement (DPA) for the use of the above-mentioned service.

6. Newsletter and Marketing Emails

Newsletter Data

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allows us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address, and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe. After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us in a blacklist to prevent future mailings. You may object to the storage if your interests outweigh our legitimate interest.

Brevo

Our newsletters and marketing emails are sent via the service Brevo. The provider is Brevo SAS (formerly Sendinblue), 7 rue de Madrid, 75008 Paris, France.

Brevo is a service that can be used, among other things, to organize and analyze the sending of newsletters and marketing emails. The data you enter for the purpose of subscribing to the newsletter is stored on Brevo’s servers within the European Union.

With the help of Brevo, we are able to analyze our newsletter campaigns. For example, we can see whether a newsletter message has been opened and which links, if any, have been clicked. In this way, we can determine which links have been clicked particularly often. We can also see when you opened the newsletter messages and whether certain predefined actions were performed after opening/clicking (conversion rate).

Data processing is based on your consent (Art. 6(1)(a) GDPR). You may revoke this consent at any time by unsubscribing from the newsletter. The lawfulness of data processing operations already carried out remains unaffected by the revocation.

If you do not want Brevo to analyze your data, you must unsubscribe from the newsletter. We provide a corresponding link in every newsletter message for this purpose.

For more information on data processing by Brevo, please visit: https://www.brevo.com/en/legal/privacypolicy/

Data Processing Agreement

We have concluded a Data Processing Agreement (DPA) with Brevo. This is a contract mandated by data privacy laws that guarantees that Brevo processes the personal data of our website visitors only based on our instructions and in compliance with the GDPR.

7. Plug-ins and Tools

Google Maps

This website uses the mapping service Google Maps. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer.

We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6(1)(f) GDPR. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG. This consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF).

For more information on the handling of user data, please review Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en

8. Online-Based Audio and Video Conferences (Conference Tools)

Data Processing

We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (e-mail address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants, and other “context information” related to the communication process (metadata).

Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider.

Purpose and Legal Bases

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time.

Microsoft Teams

We use Microsoft Teams. The provider is the Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland.

For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF).

Data Processing Agreement

We have concluded a Data Processing Agreement (DPA) for the use of the above-mentioned service.

9. Handling Applicant Data

Applicant Data

We offer website visitors the opportunity to submit job applications to us (e.g., via e-mail, via postal services, or by submitting the online job application form). Below, we will brief you on the scope, purpose, and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

Scope and Purpose of the Collection of Data

If you submit a job application to us, we will process any affiliated personal data (e.g., contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment of an employment relationship. The legal grounds for the aforementioned are § 26 BDSG according to German Law (Negotiation of an Employment Relationship), Art. 6(1)(b) GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6(1)(a) GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of § 26 BDSG and Art. 6(1)(b) GDPR for the purpose of implementing the employment relationship in our data processing system.

WhatsApp for Applicant Communication

We also use the messenger service WhatsApp to communicate with applicants. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Communication takes place via end-to-end encryption, which prevents WhatsApp or any third parties from accessing the content of these communications. WhatsApp does, however, gain access to metadata generated in the course of the communication process (e.g., sender, recipient, and time).

Please note that WhatsApp is a US-based company and your data may be transferred to the USA or other third countries where no comparable level of data protection to the EU can be guaranteed. WhatsApp transfers user data to third countries based on appropriate safeguards, such as EU Standard Contractual Clauses.

The use of WhatsApp for applicant communication is based on Art. 6(1)(b) GDPR (initiation of an employment relationship) as well as our legitimate interest in fast and effective communication with applicants (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR. This consent can be revoked at any time.

We ask you to use a more secure transmission channel (e.g., e-mail or postal mail) for submitting sensitive application documents (e.g., health information, disability certificates), as WhatsApp is not suitable for transmitting such data.

For details on data processing, please refer to the WhatsApp Privacy Policy: https://www.whatsapp.com/legal/privacy-policy-eea

Data Archiving Period

If we are unable to make you a job offer, or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6(1)(f) GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g., due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Admission to the Applicant Pool

If we do not make you a job offer, you may be able to join our applicant pool. In case of admission, all documents and information from the application will be transferred to the applicant pool in order to contact you in case of suitable vacancies.

Admission to the applicant pool is based exclusively on your express agreement (Art. 6(1)(a) GDPR). The submission agreement is voluntary and has no relation to the ongoing application procedure. You may revoke your consent at any time. In this case, the data from the applicant pool will be irrevocably deleted, provided there are no legal reasons for storage.

The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.