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 section “Information Required by Law” on this website.
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 rght 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 are 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 under the address disclosed in section
“Information Required by Law” on this website 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 your
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 and Content Delivery Networks (CDN)
External Hosting
This website is hosted by an external service provider (host). Personal data collected on
this website are stored on the servers of the host. These may include, but are not limited
to, IP addresses, contact requests, metadata and communications, contract information,
contact information, names, web page access, and other data generated through a web
site.
The host is used for the purpose of fulfilling the contract with our potential and existing
customers (Art. 6 para. 1 lit. b GDPR) and in the interest of secure, fast and efficient
provision of our online services by a professional provider (Art. 6 para. 1 lit. f GDPR).
Our host will only process your data to the extent necessary to fulfil its performance
obligations and to follow our instructions with respect to such data.
Execution of a contract data processing agreement
In order to guarantee processing in compliance with data protection regulations, we have
concluded an order processing contract with our host.
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
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:
AET Aviation Training & Consulting GmbH
Fliederweg 28
52078 Aachen
Phone: +49 (0) 15735803194
E-mail: info@aet-aviation.de
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.).
Designation of a data protection officer as mandated by law
We have appointed a data protection officer for our company.
Henning Kempe
Phone: +49 (0) 15678 573890
E-mail: coo@aet-aviation.de
Information on data transfer to the USA
Our website uses, in particular, tools from companies based in the USA. When these tools
are active, your personal information may be transferred to the US servers of these
companies. We must point out that the USA is not a safe third country within the meaning
of EU data protection law. US companies are required to release personal data to security
authorities without you as the data subject being able to take legal action against this.
The possibility cannot therefore be excluded that US authorities (e.g. secret services) may
process, evaluate and permanently store your data on US servers for monitoring
purposes. We have no influence over these processing activities.
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 SECT. 1 LIT. 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
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
DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21 SECT. 1 GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT
ADVERTISING, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF
YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING. 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 SECT. 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 demand that we hand over any data we automatically process on
the basis of your consent or in order to fulfil a contract be handed over to you or a third
party in a commonly used, 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.
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.
Encrypted payment transactions on this website
If you are under an obligation to share your payment information (e.g. account number if
you give us the authority to debit your bank account) with us after you have entered into
a fee-based contract with us, this information is required to process payments.
Payment transactions using common modes of paying (Visa/MasterCard, debit to your
bank account) are processed exclusively via encrypted SSL or TLS connections. 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 communication with us is encrypted, third parties will not be able to read the
payment information you share with us.
Information about, rectification and eradication of data
information about your archived personal data, their source and recipients as well as the
purpose of the processing of your data. 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 at the
address provided in section “Information Required by Law.”
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 at the address
provided in section “Information Required by Law.” 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 in lieu 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 Sect. 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.
4.
Recording of data on this website
Cookies
Our websites and pages use what the industry refers to as “cookies.” Cookies are small
text files 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.
In some cases it is possible that third party cookies are stored on your device once you
enter our site (third party cookies). These cookies enable you or us to take advantage of
certain services offered by the third party (e.g. cookies for the processing of payment
services).
Cookies have a variety of functions. Many cookies are technically essential since certain
website functions would not work in the absence of the cookies (e.g. the shopping cart
function or the display of videos). The purpose of other cookies may be the analysis of
user patterns or the display of promotional messages.
Cookies, which are required for the performance of electronic communication transactions
(required cookies) or for the provision of certain functions you want to use (functional
cookies, e.g. for the shopping cart function) or those that are necessary for the
optimization of the website (e.g. cookies that provide measurable insights into the web
audience), shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR, unless a different legal
basis is cited. The operator of the website has a legitimate interest in the storage of
cookies to ensure the technically error free and optimized provision of the operator’s
services. If your consent to the storage of the cookies has been requested, the respective
cookies are stored exclusively on the basis of the consent obtained (Art. 6 Sect. 1 lit. a
GDPR); 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.
In the event that third party cookies are used or if cookies are used for analytical
purposes, we will separately notify you in conjunction with this Data Protection Policy and,
if applicable, ask for your consent.
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 para. 1 lit. 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 Para. 1 lit. f GDPR) or on your
agreement (Art. 6 Para. 1 lit. 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 (e.g. after we have concluded our
response to your inquiry). This shall be without prejudice to any mandatory legal
provisions – in particular retention periods.
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 Sect. 1 lit. 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 Sect. 1 lit. f
GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it has been obtained.
The data sent by you to us via contact requests remain with us until you request us to
delete, revoke your consent to the storage or the purpose for the data storage lapses
(e.g. after completion of your request). Mandatory statutory provisions - in particular
statutory retention periods - remain unaffected.
Registration on this website
You have the option to register on this website to be able to use additional website
functions. We shall use the data you enter only for the purpose of using the respective
offer or service you have registered for. The required information we request at the time
of registration must be entered in full. Otherwise we shall reject the registration.
To notify you of any important changes to the scope of our portfolio or in the event of
technical modifications, we shall use the e-mail address provided during the registration
process.
We shall process the data entered during the registration process on the basis of your
consent (Art. 6 Sect. 1 lit. a GDPR).
The data recorded during the registration process shall be stored by us as long as you are
registered on this website. Subsequently, such data shall be deleted. This shall be without
prejudice to mandatory retention obligations.
Registration with Facebook Connect
Instead of registering directly on this website, you also have the option to register using
Facebook Connect. The provider of this service is Facebook Ireland Limited, 4 Grand Canal
Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be
transferred to the USA and other third-party countries too.
If you decide to register via Facebook Connect and click on the “Login with Facebook”/
„Connect with Facebook” button, you will be automatically connected to the Facebook
platform. There, you can log in using your username and password. As a result, your
Facebook profile will be linked to this website or our services. This link gives us access to
the data you have archived with Facebook. These data comprise primarily the following:
Facebook name
Facebook profile photo and cover photo Facebook cover photo
E-mail address archived with Facebook Facebook-ID
Facebook friends lists
Facebook Likes (“Likes” information) Date of birth
Gender
Country
Language
This information will be used to set up, provide and customize your account.
The registration via Facebook Connect and the affiliated data processing transactions are
implemented on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke this
consent at any time, which shall affect all future transactions thereafter.
For more information, please consult the Facebook Terms of Use and the Facebook Data
Privacy Policies. Use these links to access this information:
https://www.facebook.com/about/privacy/
and
https://www.facebook.com/legal/terms/
.
5.
Social media
Facebook plug-ins (Like & Share button)
We have integrated plug-ins of the social network Facebook on this website. The provider
of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.
According to Facebook’s statement the collected data will be transferred to the USA and
other third-party countries too.
You will be able to recognize Facebook plug-ins by the Facebook logo or the “Like” button
on this website. An overview of the Facebook plug-ins is available under the following link:
https://developers.facebook.com/docs/plugins/
.
Whenever you visit this website and its pages, the plug-in will establish a direct
connection between your browser and the Facebook server. As a result, Facebook will
receive the information that you have visited this website with your plug-in. However, if
you click the Facebook “Like” button while you are logged into your Facebook account,
you can link the content of this website and its pages with your Facebook profile. As a
result, Facebook will be able to allocate the visit to this website and its pages to your
Facebook user account. We have to point out, that we as the provider of the website do
not have any knowledge of the transferred data and its use by Facebook. For more
detailed information, please consult the Data Privacy Declaration of Facebook at:
https://www.facebook.com/privacy/explanation
.
If you do not want Facebook to be able to allocate your visit to this website and its pages
to your Facebook user account, please log out of your Facebook account while you are on
this website.
The use of the Facebook plug-in is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the
website has a legitimate interest in being as visible as possible on social media. If a
respective declaration of consent has been obtained, the data shall be processed
exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR. This declaration of consent may be
revoked at any time.
Instagram plug-in
We have integrated functions of the public media platform Instagram into this website.
These functions are being offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA
94025, USA.
If you are logged into your Instagram account, you may click the Instagram button to link
contents from this website to your Instagram profile. This enables Instagram to allocate
your visit to this website to your user account. We have to point out that we as the
provider of the website and its pages do not have any knowledge of the content of the
data transferred and its use by Instagram.
Data are stored and analyzed on the basis of Art. 6 Sect. 1 lit. f GDPR. The website
operator has a legitimate interest in the highest possible visibility on social media. If a
respective declaration of consent has been obtained, the data will be processed
exclusively on the basis of Art. 6 Sect. 1 lit. a DGDPR. Any such consent may be revoked
at any time.
For more information on this subject, please consult Instagram’s Data Privacy Declaration
at:
https://instagram.com/about/legal/privacy/
.
LinkedIn plug-in
This website uses functions of the LinkedIn network. The provider is LinkedIn Corporation,
2029 Stierlin Court, Mountain View, CA 94043, USA.
Any time you access a page of this website that contains functions of LinkedIn, a
connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited
this website with your IP address. If you click on LinkedIn’s “Recommend” button and are
logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate
your visit to this website to your user account. We have to point out that we as the
provider of the websites do not have any knowledge of the content of the transferred
data and its use by LinkedIn.
The use of the LinkedIn plug-in is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the
website has a legitimate interest in being as visible as possible on social media. If a
respective declaration of consent has been obtained, the data shall be processed
exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR. This declaration of consent may be
revoked at any time.
For further information on this subject, please consult LinkedIn’s Data Privacy Declaration
at:
https://www.linkedin.com/legal/privacy-policy
6.
Analysis tools and advertising
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. Google may consolidate these data in a profile that is allocated to the respective
user or the user’s device.
Google Analytics uses technologies that make the recognition of the user for the purpose
of analyzing the user behavior patterns (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.
This analysis tool is used on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of this
website has a legitimate interest in the analysis of user patterns to optimize both, the
services offered online and the operator’s advertising activities. If a corresponding
agreement has been requested (e.g. an agreement to the storage of cookies), the
processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the
agreement can be revoked at any time.
IP anonymization
On this website, we have activated the IP anonymization function. As a result, your IP
address will be abbreviated by Google within the member states of the European Union or
in other states that have ratified the Convention on the European Economic Area prior to
its transmission to the United States. The full IP address will be transmitted to one of
Google’s servers in the United States and abbreviated there only in exceptional cases. On
behalf of the operator of this website, Google shall use this information to analyze your
use of this website to generate reports on website activities and to render other services
to the operator of this website that are related to the use of the website and the Internet.
The IP address transmitted in conjunction with Google Analytics from your browser shall
not be merged with other data in Google’s possession.
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
.
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
.
Contract data processing
We have executed a contract data processing agreement with Google and are
implementing the stringent provisions of the German data protection agencies to the
fullest when using Google Analytics.
Demographic parameters provided by Google Analytics
This website uses the “demographic characteristics” function of Google Analytics, to be
able to display to the website visitor compatible ads within the Google advertising
network. This allows reports to be created that contain information about the age, gender
and interests of the website visitors. The sources of this information are interest-related
advertising by Google as well as visitor data obtained from third party providers. This
data cannot be allocated to a specific individual. You have the option to deactivate this
function at any time by making pertinent settings changes for advertising in your Google
account or you can generally prohibit the recording of your data by Google Analytics as
explained in section “Objection to the recording of data”.
Archiving period
Data on the user or incident level stored by Google linked to cookies, user IDs or
advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or
deleted after 14 month. For details please click the following link:
https://support.google.com/analytics/answer/7667196?hl=en
Google Ads
The website operator uses Google Ads. Google Ads is an online promotional program of
Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Ads enables us to display ads in the Google search engine or on third party
websites, if the user enters certain search terms into Google (keyword targeting). It is also
possible to place targeted ads based on the user data Google has in its possession (e.g.
location data and interests; target group targeting). As the website operator, we can
analyze these data quantitatively, for instance by analyzing which search terms resulted
in the display of our ads and how many ads led to respective clicks.
The use of Google Ads is based on Art. 6 Sect. 1 lit. et seq. GDPR. The website operator
has a legitimate interest in marketing the operator’s services and products as effectively
as possible.
Google Remarketing
This website uses the functions of Google Analytics Remarketing. The provider of these
solutions is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4,
Ireland.
Google Remarketing analyzes your user patterns on our website (e.g. clicks on specific
products), to allocate a certain advertising target groups to you and to subsequently
display matching online offers to you when you visit other online offers (remarketing or
retargeting).
Moreover, it is possible to link the advertising target groups generated with Google
Remarketing to device encompassing functions of Google. This makes it possible to
display interest-based customized advertising messages, depending on your prior usage
and browsing patterns on a device (e.g. cell phone) in a manner tailored to you as well as
on any of your devices (e.g. tablet or PC).
If you have a Google account, you have the option to object to personalized advertising
under the following link:
https://www.google.com/settings/ads/onweb/
.
The use of Google Remarketing is based on Art. 6 1 lit. et seq. GDPR. The website
operator has a legitimate interest in the marketing of the operator’s products that is as
effective as possible. If a respective declaration of consent was requested, processing
shall occur exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR; the given consent may be
revoked at any time.
For further information and the pertinent data protection regulations, please consult the
Data Privacy Policies of Google at:
https://policies.google.com/technologies/ads?hl=en
.
Formation of Target Groups with Customer Reconciliation
For the formation of target groups, we use, among other things, the Google Remarketing
customer reconciliation feature. To achieve this, we transfer certain customer data (e.g.
email addresses) from our customer lists to Google. If the respective customers are
Google users and are logged into their Google accounts, matching advertising messages
within the Google network (e.g. YouTube, Gmail or in a search engine) are displayed for
them to view.
Google Conversion-Tracking
This website uses Google Conversion Tracking. The provider of this service is Google
Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With the assistance of Google Conversion Tracking we are in a position to recognize
whether the user has completed certain actions. For instance, we can analyze the how
frequently which buttons on our website have been clicked and which products are
reviewed or purchased with particular frequency. The purpose of this information is to
compile conversion statistics. We learn how many users have clicked on our ads and
which actions they have completed. We do not receive any information that would allow
us to personally identify the users. Google as such uses cookies or comparable
recognition technologies for identification purposes.
We use Google Conversion Tracking on the basis of Art. 6 Sect. 1 lit. et seq. GDPR. The
operator of the website has a legitimate interest in the analysis of the user patterns with
the aim of optimizing both, the operator’s web presentation and advertising. If a
respective declaration of consent was requested (e.g. concerning the storage of cookies),
processing shall occur exclusively on the basis of Art. 6 Sect. 1 lit. a GDPR; the given
consent may be revoked at any time.
For more information about Google Conversion Tracking, please review Google’s data
protection policy at:
https://policies.google.com/privacy?hl=en
Google DoubleClick
This website uses features of Google DoubleClick. The provider is Google Ireland Limited
(“Google”), Gordon House, Barrow Street, Dublin 4, Ireland, (hereinafter “DoubleClick”).
DoubleClick is used to show you interest-based ads across the Google Network.
Advertisements can be tailored to the interests of the viewer using DoubleClick. For
example, our ads may appear in Google search results or in banners associated with
DoubleClick.
To be able to display interest adequate promotional content to users, DoubleClick must
recognize the respective visitor so that it can allocate the websites visited, the clicks and
other user pattern information to the user. To do this, DoubleClick deploys cookies or
comparable recognition technologies (e.g. device fingerprinting). The recorded
information is consolidated into a pseudonym user profile so that the respective user can
be shown interest adequate advertising.
The use of Google DoubleClick takes place in the interest of targeted advertising
measures. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f
GDPR. If a corresponding agreement has been requested (e.g. an agreement to the
storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1
lit. a GDPR; the agreement can be revoked at any time.
For further information on how to object to the advertisements displayed by Google,
please see the following links:
https://policies.google.com/technologies/ads
and
https://adssettings.google.com/authenticated
.
Facebook Pixel
To measure conversion rates, this website uses the visitor activity pixel of Facebook. The
provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2,
Ireland. According to Facebook’s statement the collected data will be transferred to the
USA and other third-party countries too.
This tool allows the tracking of page visitors after they have been linked to the website of
the provider after clicking on a Facebook ad. This makes it possible to analyze the
effectiveness of Facebook ads for statistical and market research purposes and to
optimize future advertising campaigns.
For us as the operators of this website, the collected data is anonymous. We are not in a
position to arrive at any conclusions as to the identity of users. However, Facebook
archives the information and processes it, so that it is possible to make a connection to
the respective user profile and Facebook is in a position to use the data for its own
promotional purposes in compliance with the
Facebook Data Usage Policy
. This enables Facebook to display ads on Facebook pages as
well as in locations outside of Facebook. We as the operator of this website have no
control over the use of such data.
The use of Facebook Pixel is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the
website has a legitimate interest in effective advertising campaigns, which also include
social media. If a corresponding agreement has been requested (e.g. an agreement to the
storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1
lit. a GDPR; the agreement can be revoked at any time.
In Facebook’s Data Privacy Policies, you will find additional information about the
protection of your privacy at:
https://www.facebook.com/about/privacy/
.
You also have the option to deactivate the remarketing function “Custom Audiences” in
the ad settings section under
https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen
. To do
this, you first have to log into Facebook.
If you do not have a Facebook account, you can deactivate any user based advertising by
Facebook on the website of the European Interactive Digital Advertising Alliance:
http://www.youronlinechoices.com/de/praferenzmanagement/
.
7.
Newsletter
MailChimp
This website uses the services of MailChimp to send out its newsletters. The provider is
the Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308,
USA.
Among other things, MailChimp is a service that can be deployed to organize and analyze
the sending of newsletters. Whenever you enter data for the purpose of subscribing to a
newsletter (e.g. your e-mail address), the information is stored on MailChimp servers in
the United States.
With the assistance of the MailChimp tool, we can analyze the performance of our
newsletter campaigns. If you open an e-mail that has been sent through the MailChimp
tool, a file that has been integrated into the e- mail (a so-called web-beacon) connects to
MailChimp’s servers in the United States. As a result, it can be determined whether a
newsletter message has been opened and which links the recipient possibly clicked on.
Technical information is also recorded at that time (e.g. the time of access, the IP address,
type of browser and operating system). This information cannot be allocated to the
respective newsletter recipient. Their sole purpose is the performance of statistical
analyses of newsletter campaigns. The results of such analyses can be used to tailor
future newsletters to the interests of their recipients more effectively.
If you do not want to permit an analysis by MailChimp, you must unsubscribe from the
newsletter. We provide a link for you to do this in every newsletter message. Moreover,
you can also unsubscribe from the newsletter right on the website.
The data is processed based on your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke
any consent you have given at any time by unsubscribing from the newsletter. This shall
be without prejudice to the lawfulness of any data processing transactions that have
taken place prior to your revocation.
The data deposited with us for the purpose of subscribing to the newsletter will be stored
by us until you unsubscribe from the newsletter or the newsletter service provider and
deleted from the newsletter distribution list after you unsubscribe from the newsletter.
Data stored for other purposes with us remain unaffected.
After you unsubscribe from the newsletter distribution list, your e-mail address may be
stored by us or the newsletter service provider in a blacklist to prevent future mailings.
The data from the blacklist is used only for this purpose and not merged with other data.
This serves both your interest and our interest in complying with the legal requirements
when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f
GDPR). The storage in the blacklist is indefinite.
You may object to the storage if your
interests outweigh our legitimate interest.
For more details, please consult the Data Privacy Policies of MailChimp at:
https://mailchimp.com/legal/terms/
.
Execution of a contract data processing agreement
We have executed a so-called “Data Processing Agreement” with MailChimp, in which we
mandate that MailChimp undertakes to protect the data of our customers and to refrain
from sharing it with third parties.
8.
eCommerce and payment service providers
Processing of data (customer and contract data)
We collect, process and use personal data only to the extent necessary for the
establishment, content organization or change of the legal relationship (data inventory).
These actions are taken on the basis of Art. 6 Sect. 1 lit. b GDPR, which permits the
processing of data for the fulfilment of a contract or pre-contractual actions. We collect,
process and use personal data concerning the use of this website (usage data) only to the
extent that this is necessary to make it possible for users to utilize the services and to bill
for them.
The collected customer data shall be eradicated upon completion of the order or the
termination of the business relationship. This shall be without prejudice to any statutory
retention mandates.
Data transfer upon closing of contracts for services and digital
content
We share personal data with third parties only if this is necessary in conjunction with the
handling of the contract; for instance, with the financial institution tasked with the
processing of payments.
Any further transfer of data shall not occur or shall only occur if you have expressly
consented to the transfer. Any sharing of your data with third parties in the absence of
your express consent, for instance for advertising purposes, shall not occur.
The basis for the processing of data is Art. 6 Sect. 1 lit. b GDPR, which permits the
processing of data for the fulfilment of a contract or for pre-contractual actions.
Stripe
Among other services, we offer payment processing via Stripe on this website. The
provider for customers within the EU is Stripe Payments Europe, Ltd.,1 Grand Canal Street
Lower, Grand Canal Dock, Dublin, Ireland (hereinafter referred to as “Stripe”).
When you make a payment using Stripe, your payment data are forwarded to Stripe via
an interface on our website so that the payment can be processed. For details about this
process, please consult Stripe’s Data Protection Policy under the following link:
.
Your data are transferred to Stripe on the basis of Art. 6 Sect. 1 lit. b GDPR (contract
management) as well as based on our legitimate interest in the use of dependable and
secure payment processes (Art. 6 Sect. 1 lit. f GDPR).
PayPal
Among other options, we offer payment via PayPal on this website. The provider of this
payment processing service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard
Royal, L-2449 Luxembourg (hereinafter referred to as “PayPal”).
If you choose payment via PayPal, we will share the payment information you enter with
PayPal.
The legal basis for the sharing of your data with PayPal is Art. 6 Sect. 1 lit. a GDPR
(consent) as well as Art. 6 Sect. 1 lit. b GDPR (processing for the fulfilment of a contract).
You have the option to at any time revoke your consent to the processing of your data.
Such a revocation shall not have any impact on the effectiveness of data processing
transactions that occurred in the past.
instant transfer
Sofort
Among other options, we offer the payment service called “instant transfer Sofort” on this
website. The provider of this payment option is the Sofort GmbH, Theresienhöhe 12,
80339 München, Germany (hereinafter referred to as “Sofort GmbH”).
With the assistance of the “instant transfer Sofort” tool, we receive a payment
confirmation from the Sofort GmbH in real time, which allows us to instantly start to fulfil
our obligations to you.
When you choose the “instant transfer Sofort” payment option, you must send a PIN and
a valid TAN to the Sofort GmbH, which allows the company to log into your online banking
account. Upon logging in, the Sofort GmbH will verify your account balance and will
execute the bank transfer to us with the assistance of the TAN you provided.
Subsequently, the company sends us an immediate transaction confirmation. After Sofort
GmbH has logged in, the system will also automatically verify your revenues and check
the credit limit of your pre-approved overdraft credit line and the existence of other
accounts along with their balances.
Along with the PIN and TAN numbers, the system also transfers the payment information
you entered along with personal data to the Sofort GmbH. Your personal data comprise
your first and last name, address, phone number(s), e-mail address, IP address as well as
any other data required for the processing of the payment transaction. This data must be
transferred in order to be able to determine your identity with absolute certainty and to
prevent attempts to commit fraud.
The legal basis for the sharing of your information with the Sofort GmbH is Art. 6 Sect. 1
lit. a GDPR (consent) as well as Art. 6 Sect. 1 lit. b GDPR (processing for fulfilment of a
contract). You have the option to at any time revoke your consent to the processing of
your data. Such a revocation shall not have any impact on the effectiveness of data
processing transactions that occurred in the past.
For details on payments made with the instant transfer option, please follow these links:
https://www.sofort.de/datenschutz.html
and
https://www.klarna.com/sofort/
.
9.
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 (email 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).
Furthermore, the provider of the tool processes all the technical data required for the
processing of the online communication. This includes, in particular, IP addresses, MAC
addresses, device IDs, device type, operating system type and version, client version,
camera type, microphone or loudspeaker and the type of connection.
Should content be exchanged, uploaded or otherwise made available within the tool, it is
also stored on the servers of the tool provider. Such content includes, but is not limited to,
cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files,
whiteboards and other information shared while using the service.
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. Further information on data processing by the conference tools can
be found in the data protection declarations of the tools used, and which we have listed
below this text.
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 para. 1 sentence 1 lit. 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 para.
1 lit. 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 with effect from that
date.
Duration of storage
Data collected directly by us via the video and conference tools will be deleted from our
systems immediately after you request us to delete it, revoke your consent to storage, or
the reason for storing the data no longer applies. Stored cookies remain on your end
device until you delete them. Mandatory legal retention periods remain unaffected.
We have no influence on the duration of storage of your data that is stored by the
operators of the conference tools for their own purposes. For details, please contact
directly the operators of the conference tools.
Conference tools used
We employ the following conference tools:
Zoom
We use Zoom. The provider of this service is Zoom Communications Inc, San Jose, 55
Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. For details on data processing,
please refer to Zoom's privacy policy:
https://zoom.us/en-us/privacy.html
.
Execution of a contract data processing agreement
We have entered into a contract data processing agreement with the provider of Zoom
and implement the strict provisions of the German data protection agencies to the fullest
when using Zoom.
10.
Custom Services
Job Applications
We offer website visitors the opportunity to submit job applications to us (e.g. via e-mail,
via postal services on 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 or
an employment relationship. The legal grounds for the aforementioned are § 26 New
GDPR according to German Law (Negotiation of an Employment Relationship), Art. 6 Sect.
1 lit. b GDPR (General Contract Negotiations) and – provided you have given us your
consent – Art. 6 Sect. 1 lit. 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 New GDPR and Art. 6 Sect. 1 lit. b GDPR for the
purpose of implementing the employment relationship in our data processing system.
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 para. 1 lit. 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.
Longer storage may also take place if you have given your agreement (Article 6 (1) (a)
GDPR) or if statutory data retention requirements preclude the deletion.
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
para. 1 lit. a GDPR). The submission agreement is voluntary and has no relation to the
ongoing application procedure.
The affected person can revoke his agreement 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.