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 Neustrasse 1

40789 Monheim am RHein

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 Lochnerstrasse 33 40878 Ratingen

Phone: +49 (0) 15758254305 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:

https://stripe.com/de/privacy

.

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.

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