Data Protection Regulation

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as "Data") in the course of the provision of our services, as well as our online services and related websites, features and content, and external online presence, such as web sites. our Social Media Profile (collectively referred to as the "Online Offering"). With regard to the terminology used, e.g. "Processing" or "Responsible", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

 

Responsible

Evert Johannes Wind - WIRC GmbH

Henri - Dunant street 20

40474 Dusseldorf

Germany

 

hwind@wirc.eu

Evert Johannes Wind

WIRC GmbH

General Manager

 

Link to the imprint

 

Types of processed data

  • Inventory data (e.g., person master data, name or address).
  • contact information (e.g., e-mail, phone numbers).
  • content data (e.g., text input, photographs, videos).
  • usage data (e.g., websites visited, interest in content, access times).
  • Meta / communication data (e.g., device information, IP addresses).

 

Categories of affected persons

Visitors and users of the online offer (hereinafter we refer to the affected persons as “users").

 

Purpose of processing

  • Provision of the online offer, its functions and contents.
  • Answering contact requests and communicating with users.
  • Safety measures.
  • Reach Measurement / Marketing

 

Used terms

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "data subject"); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

 

"Processing" means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.

"Pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.

 

"Profiling" means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.

 

"Responsible person" means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.

 

"Processor" means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller

 

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. For users within the scope of the General Data Protection Regulation (DSGVO), i. the EU and the EEC, unless the legal basis in the data protection declaration is mentioned:

The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR;

The legal basis for the processing for the fulfillment of our services and the execution of contractual measures as well as the answer to inquiries is Art. 6 para. 1 lit. b DSGVO;

The legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c DSGVO;

 

In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis.

The legal basis for the processing required to perform a task in the public interest or in the exercise of official authority which has been delegated to the controller is Article 6 (1) lit. e DSGVO.

The legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO.

The processing of data for purposes other than those to which they have been granted is governed by the provisions of Article 6 (4) GDPR.

The processing of special categories of data (according to Art. 9 (1) GDPR) is governed by the provisions of Art. 9 (2) GDPR.

 

Safety measures

We will take appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing and the different likelihood and severity of the risk to the rights and freedoms of individuals to ensure a level of protection appropriate to the risk.

 

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings.

 

Collaboration with contract processors, joint controllers and third parties

If, in the course of our processing, we disclose data to other persons and companies (contract processors, joint controllers or third parties), transmit them to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (eg if the data is transmitted to third parties, such as to payment service providers, to fulfill the contract), users have consented to a legal obligation to do so or on the basis of our legitimate interests (eg the use of agents, web hosts, etc.).

 

If we disclose data to other companies in our group, convey it or otherwise grant access to it, this is done in particular for administrative purposes as a legitimate interest and, moreover, based on a legal basis.

 

Transfers to third countries

If we process data in a third country (ie outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or in the context of the use of third party services or disclosure, or transfer of data to other persons or companies This will only happen if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only in the presence of legal requirements. That the processing is e.g. based on specific guarantees, such as the officially recognized level of data protection (for example, the US Privacy Shield) or compliance with officially recognized specific contractual obligations.

 

Rights of the data subjects

You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and copying of the data in accordance with legal requirements.

 

You have accordingly. the legal requirements to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

 

In accordance with the statutory provisions, they have the right to demand that the relevant data be deleted immediately, or alternatively to demand a restriction of the processing of the data in accordance with the statutory provisions.

 

You have the right to request that the data relating to you provided to us be obtained in accordance with legal requirements and to request their transmission to other persons responsible.

 

They also have the right, in accordance with the legal requirements, to submit a complaint to the competent supervisory authority.

 

 

 

Talent Pool

 

As part of the application, we offer applicants the opportunity to work in our "Talent Pool" for a period of two years on the basis of a consent in accordance with Art. 6 para. 1 lit. a. and Art. 7 DSGVO.

 

The application documents in the Talent Pool are processed solely as part of future job advertisements and job search and will be destroyed at the latest after the deadline. Candidates are informed that their consent to be admitted to the talent pool is voluntary, has no influence on the current application process and that they can revoke this consent at any time in the future and declare an objection within the meaning of Art. 21 GDPR.

 

contact

 

When contacting us (for example, by contact form, e-mail, telephone or via social media) the information of the user to process the contact request and its processing in accordance with. Art. 6 para. 1 lit. b. (in the context of contractual / pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) DSGVO processed .. User information can be stored in a Customer Relationship Management System ("CRM System") or similar request organization.

 

We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, the legal archiving obligations apply.

 

Withdrawal

You have the right to withdraw granted consent with effect for the future.

 

Right to withdraw

You may object to the future processing of your data in accordance with legal requirements at any time. The objection may in particular be made against processing for direct marketing purposes.

 

Cookies and right to object in direct mail

"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or a login status are saved. The term "permanent" or "persistent" refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A "third-party cookie" refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, this is called "first-party cookies").

 

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

 

If users do not want cookies stored on their computer, they will be asked to disable the option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

 

A general objection to the use of cookies used for online marketing purposes can be found in a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/ will be explained. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all features of this online offer may be used.

 

Deletion of data

The data processed by us will be deleted or restricted in accordance with legal requirements. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements.

 

Unless the data is deleted because it is required for other and legitimate purposes, its processing will be restricted. That The data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.

 

Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adjust the privacy policy as soon as the changes to the data processing we make require it. We will notify you as soon as the changes require your participation (eg consent) or other individual notification.

 

Privacy policy in the application process

We process the applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. The processing of the applicant data takes place in order to fulfill our (pre-) contractual obligations in the context of the application process within the meaning of Art. 6 para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO if the data processing e.g. is required for us in the context of legal proceedings (in Germany, § 26 BDSG applies additionally).

 

The application process requires applicants to provide us with the applicant data. The necessary applicant data are, as far as we offer an online form marked, otherwise result from the job descriptions and basically include the information on the person, postal and contact addresses and the application documents, such as cover letter, CV and the certificates. In addition, applicants can voluntarily provide us with additional information.

 

By submitting the application to us, the applicants agree to the processing of their data for the purposes of the application process in accordance with the nature and scope set forth in this Privacy Policy.

 

Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily communicated within the framework of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b DSGVO (e.g., health information such as disability or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the context of the application procedure, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (for example health data, if necessary for the profession).

 

If provided, applicants can submit their applications to us via an online form on our website. The data will be encrypted and transmitted to us according to the state of the art.

Furthermore, applicants can send us their applications via e-mail. However, please note that e-mails are generally not sent in encrypted form and that applicants themselves must provide encryption. We can therefore take no responsibility for the transmission of the application between the sender and the reception on our server and therefore recommend rather to use an online form or the postal delivery. Instead of applying via the online form and e-mail, applicants still have the opportunity to send us the application by post.

 

The data provided by the applicants may be further processed by us in the event of a successful application for employment purposes. Otherwise, if the application for a job offer is not successful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which the applicants are entitled to at any time.

 

The deletion is subject to a legitimate cancellation of the candidate, after the expiration of a period of six months, so that we can answer any follow-up questions to the application and meet our obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with the tax regulations.

 

CRM System Zendesk

We use Zendesk's CRM system, Zendesk, Inc., 989 Market Street # 300, San Francisco, CA 94102, USA, to handle requests from users faster and more efficiently (legitimate interest in accordance with Art. 6) Para. 1 lit. f. DSGVO).

 

Zendesk is certified under the Privacy Shield Agreement, providing an additional guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000TOjeAAG&status=Active).

 

Zendesk uses the users' data only for the technical processing of inquiries and does not pass them on to third parties. The use of Zendesk requires at least the specification of a correct e-mail address. A pseudonymous use is possible. During the processing of service requests it may be necessary to collect further data (name, address).

 

If users disagree with Zendesk's data collection and data storage in the external system, we offer alternative contact options for submitting service requests by email, phone, fax or post.

 

Further information is available to users in the Zendesk Privacy Policy: https://www.zendesk.com/company/customers-partners/privacy-policy/.

 

Newsletter

 

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.

 

Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter "newsletter") only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletter contains information about our services and us.

 

Double opt-in and logging: Registration for our newsletter is done in a so-called double-opt-in procedure. That After registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged.

 

Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.

 

The dispatch of the newsletter and the associated performance measurement are based on a consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 DSGVO i.V.m § 7 Abs. 2 No. 3 UWG or if consent is not required, based on our legitimate interests in the direct marketing acc. Art. 6 para. 1 lt. F. DSGVO i.V.m. § 7 Abs. 3 UWG.

 

The logging of the registration process is based on our legitimate interests in accordance with. Art. 6 para. 1 lit. f DSGVO. Our interest lies in the use of a user-friendly and secure newsletter system, which serves both our business interests and the expectations of the users and also allows us to prove our consent.

 

Termination / Revocation - You may terminate the receipt of our newsletter at any time, ie. Revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may save the submitted email addresses for up to three years based on our legitimate interests before we delete them to provide prior consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.

 

Newsletter - Mail Chimp

The newsletters will be sent by MailChimp, a mail-order service provider of Rocket Science Group, LLC, 675 Ponce De Leon Ave # 5000, Atlanta, GA 30308, USA. The privacy policy of the shipping service provider can be viewed here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection standards (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). The shipping service provider is based on our legitimate interests acc. Art. 6 para. 1 lit. f. DSGVO and a contract processing agreement acc. Art. 28 (3) sentence 1 DSGVO.

 

The shipping service provider may use the data of the recipients in pseudonymous form, i. without assignment to a user, to optimize or improve their own services, e.g. for the technical optimization of shipping and the presentation of newsletters or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to address them themselves or to pass the data on to third parties.

 

Google Analytics

 

Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), Google Analytics uses a web analytics service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offer by the users are usually transmitted to a Google server in the USA and stored there.

 

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

 

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.

 

We only use Google Analytics with activated IP anonymization. This means that the IP address of the users 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. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.

 

The IP address submitted by the user's browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to its use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: http: // tools .google.com / dlpage / gaoptout? hl = en.

 

For more information about Google's data usage, hiring and disparaging options, please read Google's Privacy Policy (https://policies.google.com/privacy) and Google's Ads Ads Settings (https: // adssettings. google.com/authenticated).

 

The personal data of users will be deleted or anonymized after 14 months.

 

Google AdWords and conversion measurement

 

 

We use based on our legitimate interests (ie, interest in the analysis, optimization and cost-effective operation of our reserves within the meaning of Art. 6 para. 1 lit. f. DSGVO) the services provided by Google, LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 , USA, ("Google").

 

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

 

We use Google's online AdWords marketing tool "AdWords" to place ads on the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a suspected interest in the ads. This allows us to more specifically display ads for and within our online offering so that we only present ads to users that potentially match their interests. If a user e.g. Showing ads for products he's been looking for on other online offers is called remarketing. For these purposes, upon access to our and other websites where the Google Advertising Network is active, Google will immediately execute a Google code and become so-called (re) marketing tags (invisible graphics or code, also known as ")." Web beacons ") incorporated into the website. With their help, the user is provided with an individual cookie, i. a small file is saved (instead of cookies, comparable technologies can also be used). In this file is noted which websites the user visited, for what content he is interested and what offers the user has clicked, as well as technical information about the browser and operating system, referring websites, visit time and other information on the use of the online offer.

 

Furthermore, we receive an individual "conversion cookie". The information obtained through the cookie is used by Google to generate conversion statistics for us. However, we only hear the anonymous total number of users who clicked on our ad and were redirected to a conversion tracking tag page. However, we do not receive any information that personally identifies users.

 

The data of the users are pseudonym processed within the Google advertising network. That Google stores and processes e.g. not the name or e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. That from the perspective of Google, the ads are not managed and displayed to a specifically identified person, but to the cookie owner, regardless of who that cookie owner is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google's servers in the United States.

 

For more information about Google's data usage, hiring and disparaging options, please read Google's Privacy Policy (https://policies.google.com/technologies/ads) and Google's Ads Ads Settings (https: // adssettings.google.com/authenticated)

 

etracker

Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO) we set the analysis service "etracker" of etracker GmbH, Erste Brunnenstraße 1 20459 Hamburg, on.

 

The data collected are analyzed exclusively pseudonymically, stored solely on servers in Germany, not combined with other data or passed on to third parties.

 

When storing the user data, in particular, the IP addresses, device and domain data of the users are only shortened stored or encrypted, so that a conclusion on the individual user is not possible. The shortening of the IP address takes place at the earliest possible date and automatically by default. From the data processed by etracker, pseudonymous user profiles are created using cookies. However, identifiers for recognizing an app user, performing session and cross-device tracking, and providing behavioral data for remarketing are certainly pseudonymized or encrypted. Furthermore etracker secures the protection of the processed data of the users contractually by the conclusion of a contract processing agreement acc. Art. 28 (3) sentence 1 DSGVO.

 

You can object to the data collection and storage at any time with effect for the future. In order to counter data collection and storage of your visitor data for the future, you can obtain an opt-out cookie from etracker under the following link, which ensures that no visitor data from your browser will be collected and stored by etracker in the future: http: // www .etracker.de / privacy? et = [PLEASE PUT YOUR-account ID].

 

The opt-out sets an opt-out cookie with the name "cntcookie" by etracker. Please do not delete this cookie as long as you want to maintain your opposition.

 

For more information, see the etracker Privacy Policy: https://www.etracker.com/datenschutz.

 

Integration of services and contents of third parties

Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. DSGVO), we make use of content or services offered by third-party providers in order to provide their content and services Services, such as Include videos or fonts (collectively referred to as "content").

 

This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.

 

Google ReCaptcha

We bind the function to detect bots, e.g. when entering into online forms ("ReCaptcha") of the provider Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

 

 

 

Xing

Within our online offer functions and contents of the service Xing, offered by XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany, can be integrated. For this, e.g. Content such as images, videos, or text and buttons that allow users to share content from this online offering within Xing. If the users are members of the platform Xing, Xing can call the o.g. Assign contents and functions to the profiles of the users there. Xing's Privacy Policy: https://privacy.xing.com/en/ privacy_policy.

 

LinkedIn

Within our online offering, features and content of the LinkedIn service offered by the LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, may be incorporated. For this, e.g. Content such as images, videos, or text and buttons that allow users to share content from this online offering within LinkedIn. If the users are members of the platform LinkedIn, LinkedIn can call the o.g. Assign contents and functions to the profiles of the users there. LinkedIn privacy statement: https://www.linkedin.com/legal/privacy-policy. LinkedIn is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https: //www.privacyshield. gov / participant? id = a2zt0000000L0UZAA0 & status = Active). Privacy Policy: https://www.linkedin.com/legal/privacy-policy, opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Created with Datenschutz-Generator.de by RA Dr. med. Thomas Schwenke

 

 

 

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