Privacy – E&S- SmartRecruiter

1. Privacy

General information

E&S Smart Recruiter” Ltd
EIK 207051825, ELIN PELIN No. 18, Apt. 15-p.k. 8000 Blvd. Burgas, Bulgaria

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is all data with which you can be personally identified. Detailed information on the subject of data protection can be found in our data protection declaration listed under this text.

Data collection on this website

Who is responsible for data collection on this website?

The data processing on this website is carried out by the website operator. You can find their contact details in the section “Notice on the responsible body” in this data protection declaration.

How do we collect your data?

On the one hand, your data is collected when you communicate it to us. This can be z. B. be data that you enter in a contact form.

Other data is collected automatically or with your consent by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time of the page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure that the website is provided without errors. Other data can be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right to receive information about the origin, recipient and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request that the processing of your personal data be restricted. You also have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time if you have any further questions on the subject of data protection.

Analysis tools and third-party tools

When you visit this website, your surfing behavior can be statistically evaluated. This is mainly done with so-called analysis programs.

Detailed information on these analysis programs can be found in the following data protection declaration.

2. Hosting

External hosting

This website is hosted by an external service provider (hoster). The personal data collected on this website is stored on the host’s servers. This can primarily be IP addresses, contact requests, meta and communication data, contract data, contact data, names, website access and other data generated via a website.

The hoster is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 Para. 1 lit. b DSGVO) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6 Para 1 lit. f GDPR).

Our hoster will only process your data to the extent that this is necessary to fulfill its performance obligations and will follow our instructions in relation to this data.

We use the following hoster:

STRATO AG
Otto-Ostrowski-Strasse 7
10249 Berlin

order processing

We have concluded an order processing contract (AVV) with the above-mentioned provider. This is a contract required by data protection law, which ensures that the personal data of our website visitors is only processed according to our instructions and in compliance with the GDPR.

3. General information and mandatory information

privacy

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this data protection declaration.

If you use this website, various personal data will be collected. Personal data is data with which you can be personally identified. This data protection declaration explains what data we collect and what we use it for. It also explains how and for what purpose this happens.

We would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. A complete protection of the data against access by third parties is not possible.

Note on the responsible body

The responsible body for data processing on this website is:

Select GmbH – company for personnel services
Am Mantel 1
76646 Bruchsal

Telephone: +49 7251/9170-0
Email: datenschutz@select-gmbh.de

The responsible body is the natural or legal person who, alone or together with others, decides on the purposes and means of processing personal data (e.g. names, e-mail addresses, etc.).

storage duration

Unless a specific storage period has been specified in this data protection declaration, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial law retention periods); in the latter case, the data will be deleted once these reasons have ceased to exist.

Legally required data protection officer

We have appointed a data protection officer for our company.

Michaela Helbig
Helbig Data Protection GmbH
Bräunleinsberg 51
91233 Neunkirchen aS

Telephone: +49 9123/70275-0
Email: datenschutz@select-gmbh.de

Note on data transfer to the USA and other third countries

Among other things, we use tools from companies based in the USA or other third countries that are not secure under data protection law. If these tools are active, your personal data can be transferred to these third countries and processed there. We would like to point out that in these countries no level of data protection comparable to that of the EU can be guaranteed. For example, US companies are obliged to release personal data to security authorities without you as the person concerned being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. secret services) will process, evaluate and permanently store your data on US servers for monitoring purposes. We have no influence on these processing activities.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke consent that you have already given at any time. The legality of the data processing that took place up until the revocation remains unaffected by the revocation.

Right to object to data collection in special cases and to direct advertising (Art. 21 GDPR)

IF THE DATA PROCESSING IS BASED ON ART. 6 ABS. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH A PROCESSING IS BASED CAN BE FOUND IN THIS DATA PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR CONCERNED PERSONAL DATA UNLESS WE CAN PROVE COMPREHENSIVE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOM OBJECTION ACCORDING TO ARTICLE 21 (1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR SUCH ADVERTISING PURPOSES; THIS ALSO APPLIES TO PROFILING TO THE EXTENT RELATED TO SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION ACCORDING TO ART. 21 (2) GDPR).

Right of appeal to the competent supervisory authority

In the event of violations of the GDPR, those affected have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged violation. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to data portability

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

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data that you transmit to us cannot be read by third parties.

Encrypted payment transactions on this website

If, after the conclusion of a fee-based contract, there is an obligation to send us your payment data (e.g. account number for direct debit authorization), this data is required for payment processing.

Payment transactions using the usual means of payment (Visa/MasterCard, direct debit) are carried out exclusively via an encrypted SSL or TLS connection. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

With encrypted communication, your payment data that you transmit to us cannot be read by third parties.

Information, deletion and correction

Within the framework of the applicable legal provisions, you have the right to free information about your stored personal data, its origin and recipient and the purpose of the data processing and, if necessary, a right to correction or deletion of this data at any time. You can contact us at any time if you have any further questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to check this. For the duration of the examination, you have the right to request that the processing of your personal data be restricted.
If the processing of your personal data happened/is happening unlawfully, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to demand that the processing of your personal data be restricted instead of being deleted.
If you have lodged an objection in accordance with Art. 21 (1) GDPR, your interests and ours must be weighed up. As long as it has not yet been determined whose interests prevail, you have the right to demand that the processing of your personal data be restricted.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be used with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State are processed.

Objecting to Promotional Emails

We hereby object to the use of contact data published as part of the imprint obligation to send unsolicited advertising and information material. The site operators expressly reserve the right to take legal action in the event of unsolicited advertising being sent, such as spam e-mails.

4. Data collection on this website

cookies

Our website uses so-called “cookies”. Cookies are small text files and do not cause any damage to your end device. They are stored on your end device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted after your visit. Permanent cookies remain stored on your end device until you delete them yourself or until they are automatically deleted by your web browser.

In some cases, cookies from third-party companies can also be stored on your end device when you enter our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).

Cookies have different functions. Numerous cookies are technically necessary because certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies are used to evaluate user behavior or to display advertising.

Cookies that are required to carry out the electronic communication process (necessary cookies) or to provide certain functions you want (functional cookies, e.g. for the shopping cart function) or to optimize the website (e.g. cookies for measuring web audience). are stored on the basis of Art. 6 Para. 1 lit. f GDPR, unless another legal basis is given. The website operator has a legitimate interest in the storage of cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies was requested, the relevant cookies are stored exclusively on the basis of this consent (Article 6 (1) (a) GDPR); the consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when the browser is closed. If cookies are deactivated, the functionality of this website may be restricted.

If cookies are used by third-party companies or for analysis purposes, we will inform you of this separately in this data protection declaration and, if necessary, ask for your consent.

Cookie consent with Borlabs Cookie

Our website uses Borlabs Cookie’s cookie consent technology to obtain your consent to the storage of certain cookies in your browser and to document this in compliance with data protection regulations. The provider of this technology is Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg (hereinafter referred to as Borlabs).

When you enter our website, a Borlabs cookie is stored in your browser, which stores the consent you have given or the withdrawal of this consent. This data is not passed on to the provider of Borlabs Cookie.

The collected data is stored until you ask us to delete it or delete the Borlabs cookie yourself or the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. Details on data processing by Borlabs Cookie can be found at https://de.borlabs.io/kb/which-data-stores-borlabs-cookie/ .

Borlabs cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Article 6 (1) (c) GDPR.

Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

Browser type and browser version
operating system used
Referrer URL
Host name of the accessing computer
Time of server request
IP address

This data is not merged with other data sources.

This data is collected on the basis of Article 6 (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – the server log files must be recorded for this purpose.

contact form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We do not pass on this data without your consent.

This data is processed on the basis of Article 6 (1) (b) GDPR if your request is related to the fulfillment of a contract or 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 inquiries addressed to us (Art. 6 Para. 1 lit. f GDPR) or on your consent (Art. 6 Para. 1 lit. a GDPR) if this was queried.

The data you enter in the contact form will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory legal provisions – in particular retention periods – remain unaffected.

Inquiry by e-mail, telephone or fax

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

The data you sent to us via contact requests will remain with us until you request deletion, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory legal provisions – in particular statutory retention periods – remain unaffected.

Registration on this site

You can register on this website to use additional functions on the site. We use the data entered for this purpose only for the purpose of using the respective offer or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise we will refuse the registration.

For important changes, such as the scope of the offer or technically necessary changes, we use the e-mail address provided during registration to inform you in this way.

The data entered during registration is processed for the purpose of implementing the user relationship established by registration and, if necessary, for initiating further contracts (Article 6 (1) (b) GDPR).

The data collected during registration will be stored by us as long as you are registered on this website and will then be deleted. Statutory retention periods remain unaffected.

5. Social Media

Social media plugins with Shariff

Social media plugins are used on this website (e.g. Facebook, Twitter, Instagram, Pinterest, XING, LinkedIn, Tumblr).

You can usually recognize the plugins by the respective social media logos. To ensure data protection on this website, we only use these plugins together with the so-called “Shariff” solution. This application prevents the plugins integrated on this website from transferring data to the respective provider when you first enter the site.

A direct connection to the provider’s server is only established (consent) when you activate the respective plugin by clicking on the associated button. As soon as you activate the plugin, the respective provider receives the information that you have visited this website with your IP address. If you are logged into your respective social media account (e.g. Facebook) at the same time, the respective provider can assign the visit to this website to your user account.

Activating the plugin represents consent within the meaning of Article 6 Paragraph 1 lit. a GDPR. You can revoke this consent at any time with effect for the future.

6. Analysis Tools and Advertising

Google Analytics

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

Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as B. Page views, length of stay, operating systems used and origin of the user. This data may be summarized by Google in a profile that is assigned to the respective user or their device.

Google Analytics uses technologies that enable the user to be recognized for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is usually transmitted to a Google server in the USA and stored there.

This analysis tool is used on the basis of Article 6 (1) (f) GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. If a corresponding consent was requested (e.g. consent to the storage of cookies), the processing takes place exclusively on the basis of Article 6 Paragraph 1 lit. the consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/ .

IP anonymization

We have activated the IP anonymization function on this website. As a result, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before it is transmitted to the USA. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

browser plug-in

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

You can find more information on how Google Analytics handles user data in Google’s data protection declaration: https://support.google.com/analytics/answer/6004245?hl=de .

order processing

We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Demographic characteristics in Google Analytics

This website uses the “demographic characteristics” function of Google Analytics in order to be able to show website visitors relevant advertisements within the Google advertising network. This allows reports to be created that contain statements about the age, gender and interests of the site visitors. This data comes from interest-based advertising from Google and visitor data from third-party providers. This data cannot be assigned to a specific person. You can deactivate this function at any time via the ad settings in your Google account or generally prohibit the collection of your data by Google Analytics as described in the point “Objection to data collection”.

storage duration

Data stored by Google at the user and event level that is linked to cookies, user IDs (e.g. User ID) or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) are anonymised after 14 months or deleted. You can find details on this under the following link: https://support.google.com/analytics/answer/7667196?hl=de

Google Ads

The website operator uses Google Ads. Google Ads is an online advertising program from Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters certain search terms on Google (keyword targeting). Furthermore, targeted advertisements can be displayed based on the user data (e.g. location data and interests) available from Google (target group targeting). As the website operator, we can evaluate this data quantitatively, for example by analyzing which search terms led to the display of our advertisements and how many advertisements led to corresponding clicks.

Google Ads is used on the basis of Article 6 (1) (f) GDPR. The website operator has a legitimate interest in marketing its service products as effectively as possible.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/ .

Google Remarketing

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

Google Remarketing analyzes your user behavior on our website (e.g. clicking on certain products) in order to classify you in certain advertising target groups and then to display suitable web messages when you visit other online offers (remarketing or retargeting).

Furthermore, the advertising target groups created with Google Remarketing can be linked to Google’s cross-device functions. In this way, interest-related, personalized advertising messages that have been adapted to you depending on your previous usage and surfing behavior on one end device (e.g. mobile phone) can also be displayed on another of your end devices (e.g. tablet or PC).

If you have a Google account, you can object to personalized advertising using the following link: https://www.google.com/settings/ads/onweb/ .

Google Remarketing is used on the basis of Art. 6 Para. 1 lit. f GDPR. The website operator has a legitimate interest in marketing its products as effectively as possible. If a corresponding consent has been requested, the processing takes place exclusively on the basis of Article 6 (1) (a) GDPR; the consent can be revoked at any time.

Further information and the data protection regulations can be found in Google’s data protection declaration at: https://policies.google.com/technologies/ads?hl=de .

Google conversion tracking

This website uses Google Conversion Tracking. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With the help of Google Conversion Tracking, we and Google can recognize whether the user has carried out certain actions. For example, we can evaluate which buttons on our website were clicked how often and which products were viewed or purchased particularly frequently. This information is used to generate conversion statistics. We learn the total number of users who have clicked on our ads and what actions they have taken. We do not receive any information with which we can personally identify the user. Google itself uses cookies or comparable recognition technologies for identification.

Google conversion tracking is used on the basis of Article 6 (1) (f) GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. If a corresponding consent was requested (e.g. consent to the storage of cookies), the processing takes place exclusively on the basis of Article 6 Paragraph 1 lit. the consent can be revoked at any time.

You can find more information on Google conversion tracking in Google’s data protection regulations: https://policies.google.com/privacy?hl=de .

Facebook pixels

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

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

The data collected is anonymous to us as the operator of this website, we cannot draw any conclusions about the identity of the user. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook data usage guidelines. This enables Facebook to place advertisements on Facebook pages and outside of Facebook. This use of the data cannot be influenced by us as the site operator.

The use of Facebook pixels is based on Art. 6 Para. 1 lit. f GDPR. The website operator has a legitimate interest in effective advertising measures, including social media. If a corresponding consent was requested (e.g. consent to the storage of cookies), the processing takes place exclusively on the basis of Article 6 Paragraph 1 lit. the consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381 .

Insofar as personal data is collected on our website and forwarded to Facebook using the tool described here, we and Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Article 26 GDPR ). Joint responsibility is limited to collecting the data and passing it on to Facebook. The processing by Facebook after the forwarding is not part of the joint responsibility. Our joint obligations have been set out in a joint processing agreement. The wording of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for issuing data protection information when using the Facebook tool and for implementing the tool on our website in a secure manner in accordance with data protection law. Facebook is responsible for the data security of Facebook products. You can assert your rights (e.g. requests for information) regarding the data processed by Facebook directly on Facebook. If you assert the rights of data subjects with us, we are obliged to forward them to Facebook.

You will find further information on protecting your privacy in Facebook’s data protection information: https://de-de.facebook.com/about/privacy/ .

You can also disable the “Custom Audiences” remarketing feature in the Ads Settings section at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen . To do this, you must be logged in to Facebook.

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

7. Newsletters

newsletter data

If you would like to receive the newsletter offered on the website, we need an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter . Further data is not collected or only collected on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.

The processing of the data entered in the newsletter registration form takes place exclusively on the basis of your consent (Art. 6 Para. 1 lit. a DSGVO). You can revoke your consent to the storage of the data, the e-mail address and their use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter. The legality of the data processing operations that have already taken place remains unaffected by the revocation.

The data you have stored with us for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after it no longer serves any purpose. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6 Para. 1 lit. f GDPR.

After you have been removed from the newsletter distribution list, your e-mail address may be stored in a blacklist by us or the newsletter service provider in order to prevent future mailings. The data from the blacklist is only used for this purpose and is 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). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interests.

CleverReach

This website uses CleverReach to send newsletters. The provider is CleverReach GmbH & Co. KG, Schafjückenweg 2, 26180 Rastede, Germany (hereinafter: “CleverReach”). CleverReach is a service that can be used to organize and analyze the sending of newsletters. The data you enter for the purpose of subscribing to the newsletter (e.g. email address) will be stored on the CleverReach servers in Germany or Ireland.

Our newsletters sent with CleverReach enable us to analyze the behavior of the newsletter recipients. Among other things, it can be analyzed here how many recipients have opened the newsletter message and how often which link in the newsletter was clicked. With the help of so-called conversion tracking, it can also be analyzed whether a previously defined action (e.g. purchase of a product on this website) took place after clicking on the link in the newsletter. Further information on data analysis by the CleverReach newsletter is available at: https://www.cleverreach.com/de/funktions/reporting-und-tracking/ .

The data processing takes place on the basis of your consent (Art. 6 Para. 1 lit. a DSGVO). You can revoke this consent at any time by unsubscribing from the newsletter. The legality of the data processing operations that have already taken place remains unaffected by the revocation.

If you do not want an analysis by CleverReach, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.

For more information, see CleverReach’s privacy policy at: https://www.cleverreach.com/de/datenschutz/ .

order processing

8. Plugins and Tools

YouTube with enhanced privacy

This website includes videos from YouTube. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in the extended data protection mode. According to YouTube, this mode means that YouTube does not store any information about visitors to this website before they watch the video. However, the extended data protection mode does not necessarily exclude the transfer of data to YouTube partners. This is how YouTube establishes a connection to the Google DoubleClick network, regardless of whether you are watching a video.

As soon as you start a YouTube video on this website, a connection to the YouTube servers is established. The YouTube server is informed which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

Furthermore, YouTube can save various cookies on your end device after starting a video or use comparable recognition technologies (e.g. device fingerprinting). In this way, YouTube can receive information about visitors to this website. This information is used, among other things, to collect video statistics, to improve user-friendliness and to prevent attempts at fraud.

If necessary, after the start of a YouTube video, further data processing operations can be triggered over which we have no influence.

YouTube is used in the interest of an attractive presentation of our online offers. This represents a legitimate interest within the meaning of Article 6 Paragraph 1 Letter f GDPR. If a corresponding consent has been requested, the processing takes place exclusively on the basis of Article 6 Paragraph 1 Letter a GDPR; the consent can be revoked at any time.

You can find more information about data protection on YouTube in their data protection declaration at: https://policies.google.com/privacy?hl=de .

Google Web Fonts (local hosting)

This site uses so-called web fonts provided by Google for the uniform display of fonts. The Google Fonts are installed locally. There is no connection to Google servers.

Further information on Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s data protection declaration: https://policies.google.com/privacy?hl=de .

Google Maps

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

In order to use the functions of Google Maps, it is necessary to save your IP address. This information is usually transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. If Google Maps is activated, Google can use Google Web Fonts for the purpose of uniform display of fonts. When you call up Google Maps, your browser loads the required web fonts into your browser cache in order to display text and fonts correctly.

Google Maps is used in the interest of an attractive presentation of our online offers and to make it easier to find the places we have indicated on the website. This represents a legitimate interest within the meaning of Article 6 Paragraph 1 Letter f GDPR. If a corresponding consent has been requested, the processing takes place exclusively on the basis of Article 6 Paragraph 1 Letter a GDPR; the consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/ .

You can find more information on handling user data in Google’s data protection declaration: https://policies.google.com/privacy?hl=de .

9. eCommerce and Payment Providers

Processing of data (customer and contract data)

We collect, process and use personal data only insofar as they are necessary for the establishment, content or change of the legal relationship (inventory data). This is based on Article 6 Paragraph 1 Letter b GDPR, which allows the processing of data to fulfill a contract or pre-contractual measures. We collect, process and use personal data about the use of this website (usage data) only to the extent necessary to enable the user to use the service or to bill the user.

The collected customer data will be deleted after completion of the order or termination of the business relationship. Statutory retention periods remain unaffected.

Data transmission upon conclusion of contract for online shops, dealers and goods dispatch

We only transmit personal data to third parties if this is necessary in the context of contract processing, for example to the company entrusted with the delivery of the goods or the bank responsible for processing the payment. Any further transmission of the data does not take place or only if you have expressly consented to the transmission. Your data will not be passed on to third parties without your express consent, for example for advertising purposes.

The basis for data processing is Art. 6 Paragraph 1 lit. b GDPR, which allows the processing of data to fulfill a contract or pre-contractual measures.

payment services

We integrate payment services from third party companies on our website. If you make a purchase from us, your payment details (e.g. name, payment amount, account details, credit card number) will be processed by the payment service provider for the purpose of payment processing. The respective contract and data protection provisions of the respective provider apply to these transactions. The payment service providers are used on the basis of Art. 6 Para. 1 lit. b GDPR (contract processing) and in the interest of a payment process that is as smooth, convenient and secure as possible (Art. 6 Para. 1 lit. f GDPR). Insofar as your consent is requested for certain actions, Article 6 (1) (a) GDPR is the legal basis for data processing; Consent can be revoked at any time for the future.

We use the following payment services/payment service providers on this website:

PayPal

The provider of this payment service is PayPal (Europe) S.à.rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full .

Details can be found in PayPal’s data protection declaration: https://www.paypal.com/de/webapps/mpp/ua/privacy-full .

10. Audio and Video Conferencing

data processing

We use online conference tools, among other things, to communicate with our customers. The specific tools we use are listed below. If you communicate with us via video or audio conference over the Internet, your personal data will be collected and processed by us and the provider of the respective conference tool.

The conference tools collect all data that you provide/use to use the tools (e-mail address and/or your telephone 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” in connection with the communication process (metadata).

Furthermore, the provider of the tool processes all technical data that is required to process 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.

If content is exchanged, uploaded or provided in any other way within the tool, this is also stored on the servers of the tool providers. Such content includes but is not limited to cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared while using the Service.

Please note that we do not have full influence on the data processing operations of the tools used. Our options are largely based on 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, 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 lit. b DSGVO). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest within the meaning of Art. 6 Para. 1 lit. f DSGVO). If consent has been requested, the tools in question will be used on the basis of this consent; the consent can be revoked at any time with effect for the future.

storage duration

The data collected directly by us via the video and conference tools will be deleted from our systems as soon as you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Saved cookies remain on your end device until you delete them. Mandatory statutory retention periods remain unaffected.

We have no influence on the storage period of your data, which is stored by the operators of the conference tools for their own purposes. For details, please contact the operators of the conference tools directly.

Conference tools used

We use the following conference tools:

Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Details on data processing can be found in the Microsoft Teams data protection declaration: https://privacy.microsoft.com/de-de/privacystatement .

order processing

11. Own Services

Handling applicant data

We offer you the opportunity to apply to us (e.g. by e-mail, by post or via the online application form). In the following we will inform you about the scope, purpose and use of your personal data collected as part of the application process. We assure you that the collection, processing and use of your data takes place in accordance with the applicable data protection law and all other statutory provisions and that your data will be treated with the utmost confidentiality.

Scope and Purpose of Data Collection

If you send us an application, we will process your associated personal data (e.g. contact and communication data, application documents, notes from job interviews, etc.) insofar as this is necessary to make a decision on the establishment of an employment relationship. The legal basis for this is § 26 BDSG under German law (initiation of an employment relationship), Article 6 Paragraph 1 lit. b GDPR (general contract initiation) and – if you have given your consent – Article 6 Paragraph 1 lit. a GDPR. The consent can be revoked at any time. Within our company, your personal data will only be passed on to people who are involved in processing your application.

If the application is successful, the data you submit will be stored in our data processing systems on the basis of Section 26 BDSG and Article 6 Paragraph 1 lit. b GDPR for the purpose of carrying out the employment relationship.

retention period of the data

If we are unable to make you a job offer, you reject a job offer or withdraw your application, we reserve the right to store the data you have transmitted on the basis of our legitimate interests (Art. 6 Para. 1 lit. f GDPR) for up to 6 months to be kept with us from the end of the application process (rejection or withdrawal of the application). The data will then 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 apparent that the data will be required after the 6-month period has expired (e.g. due to an impending or pending legal dispute), it will only be deleted if the purpose for further storage no longer applies.

A longer storage can also take place if you have given your consent (Art. 6 Para. 1 lit. a DSGVO) or if statutory storage obligations prevent the deletion.

Admission to the pool of applicants

If we do not make you a job offer, it may be possible to include you in our pool of applicants. If you are accepted, all documents and information from the application will be transferred to the applicant pool so that you can be contacted if there are suitable vacancies.

Inclusion in the pool of applicants takes place exclusively on the basis of your express consent (Article 6 (1) (a) GDPR). Giving your consent is voluntary and has no connection to the ongoing application process. The person concerned can revoke their consent at any time. In this case, the data will be irrevocably deleted from the applicant pool, provided there are no legal reasons for retention.

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

Source: eRecht24