Privacy Policy


Scope

The protection of your data is one of our essential maxims. With the following privacy policy we would like to inform you about the types of personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile and web applications and within external online presences, such as our social media profiles (hereinafter also referred to collectively as “online offer”).

The terms used are not gender-specific.

Status: August 25, 2020


1. Data controller

Contact

AppNavi GmbH
Atelierstraße 29
81671 Munich I Germany
info@appnavi.eu
+49 89 21750050

If you wish to assert legal rights or have general questions about AppNavi or our data protection activities, please contact datenschutz@appnavi.eu or send us a message using the contact form.


2. Overview of the processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Overview of the processed data

  • General data (e.g. names, addresses)
  • Applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other information about the applicant’s person or qualification, either with regard to a specific position or voluntarily provided by the applicant)
  • Content data (e.g. text entries, photographs, videos)
  • Contact details (e.g. e-mail, telephone numbers)
  • Meta/communication data (e.g. device information, IP addresses)
  • Usage data (e.g. websites visited, interest in content, access times)
  • Contract data (e.g. object of contract, duration, customer category)
  • Payment data (e.g. bank details, invoices, payment history)

Categories of data subjects

  • Employees (e.g. employees, applicants, former employees).
  • Applicants
  • Business and contractual partners
  • Interested parties
  • Communication partners
  • Customers
  • Users (e.g. website visitors, users of online services)

Purpose of the processing

  • Provision of our online offer and a positive user experience
  • Visitor activity evaluation
  • Application procedure (justification and possible later implementation and possible later termination of employment)
  • Office and organizational procedures
  • Content Delivery Network (CDN)
  • Cross-device tracking (cross-device processing of user data for marketing purposes)
  • Direct marketing (e.g. by e-mail or mail)
  • Feedback (e.g. collecting feedback via online form)
  • Interest based and behavioral marketing
  • Contact requests and communication
  • Conversion measurement (measuring the effectiveness of marketing measures)
  • Profiling (creation of user profiles)
  • Remarketing
  • Range measurement (e.g. access statistics, recognition of returning visitors)
  • Security measures
  • Tracking (e.g. interest/behavioral profiling, use of cookies)
  • Contractual benefits and service
  • Management and answering of inquiries
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content)

Applicable legal basis

In the following, we provide the legal basis of the General Data Protection Regulation (GDPR, german: Datenschutz-Grundverordnung I DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile. Should more specific legal regulations apply in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 sentence 1 letter a DSGVO) – The data subject has given his or her consent to the processing of personal data concerning him or her for one or more specific purposes.
  • Fulfilment of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 letter b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 sentence 1 letter c. DSGVO) – The processing is necessary for the performance of a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO) – The processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh these.
  • 9 para. 1 sentence 1 lit. b DSGVO (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 para. 1 DSGVO (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants in the context of the application procedure, so that the data controller or the data subject can make the necessary arrangements to protect the personal data held by him or her or the data subject. to exercise the rights and fulfil his or her obligations under labour law and social security and social protection law, the processing shall be carried out in accordance with Art. 9, paragraph 2, letter b. DSGVO, in the case of protection of vital interests of applicants or other persons according to art. 9 par. 2 letter c. DSGVO or for the purposes of health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector in accordance with Art. 9 para. 2 lit. h. DSGVO. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of art. 9, paragraph 2, letter a. DSGVO).

National data protection regulations in Germany: In addition to the data protection regulations of the DSGVO, national regulations on data protection apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.


3. Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

Such measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, security of availability and separation of data relating to them. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted, and responses are made to any threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, by designing technology and by using data protection-friendly default settings.

SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.


4. Transmission and disclosure of personal data

In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Transfer of data within the organization: We may transfer personal data to other entities within our organization or grant them access to such data. If this transfer is for administrative purposes, the transfer of the data is based on our legitimate business and economic interests or takes place if it is necessary to fulfill our contractual obligations or if there is a consent of the persons concerned or a legal permission.


5. Data processing in third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of services of third parties or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).


6. Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”)

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users used for reach measurement or marketing purposes can also be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • Third party cookies (also: third party cookies): Third party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
  • Statistical, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement and when the interests of a user or his or her behavior (e.g. viewing certain content, using functions, etc.) on individual web pages are stored in a user profile. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also known as “tracking”, i.e. following the potential interests of users. If we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or when you give your consent.

Information on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for your consent. If this is the case and you agree to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Duration of storage: Unless we give you explicit information about the duration of storage of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (Opt-Out): Depending on whether the processing is based on consent or legal permission, you have the possibility to revoke a given consent or to object to the processing of your data by cookie technologies at any time (collectively referred to as “Opt-Out”). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further notices of objection in the context of the information on the service providers and cookies used.

Processing of cookie data based on consent: Before we process or have processed data in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has not been given, we will only use cookies that are absolutely necessary for the operation of our online service.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


7. Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the scope of contractual and comparable legal relationships and associated measures and within the scope of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data for the purpose of fulfilling our contractual obligations, securing our rights and for the purposes of the administrative tasks associated with this data as well as for business organization. Within the framework of the applicable law, we will only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the persons concerned (e.g. to involved telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We will inform the contractual partners which data is required for the above-mentioned purposes before or within the scope of data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or personally.

We delete the data after expiration of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). We will delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.

If we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, in short “customer account”). If the registration of a customer account is required, contractual partners are informed of this as well as of the information required for registration. The customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and prevent possible misuse of the customer account.

If customers have cancelled their customer account, the data concerning the customer account will be deleted, subject to the retention of such data being required by law. It is the responsibility of customers to secure their data when they cancel their customer account.

Education and training services: We process the data of the participants of our education and training offers (uniformly referred to as “trainees”) in order to provide them with our training services. The data processed, the type, scope, purpose and necessity of their processing are determined by the underlying contractual and training relationship. The forms of processing also include the performance assessment and evaluation of our services and those of the instructors.

Within the scope of our activities, we may also process special categories of data, in particular data relating to the health of those undergoing training and further training as well as data revealing ethnic origin, political opinions, religious or ideological beliefs. For this purpose, we obtain the express consent of the persons to be trained, if necessary, and otherwise process the special categories of data only if it is necessary for the provision of training services, for purposes of health care, social protection or the protection of vital interests of the persons to be trained.

As far as it is necessary for the fulfillment of our contract, for the protection of vital interests or legally required, or if the consent of the person to be trained has been obtained, we disclose or transfer the data of the persons to be trained to third parties or agents, such as public authorities or in the field of IT, office or comparable services, in compliance with the requirements of professional law.

Consulting: We process the data of our clients, clients as well as interested parties and other clients or contractual partners (uniformly referred to as “clients”) in order to provide them with our consulting services. The processed data, the nature, scope, purpose and necessity of their processing are determined by the underlying contractual and client relationship.

As far as it is necessary for our performance of the contract, for the protection of vital interests or legally required, or as far as the consent of the clients is available, we disclose or transfer the data of the clients to third parties or agents, such as authorities, subcontractors or in the field of IT, office or comparable services, in compliance with the requirements of professional law.

Project and development services: We process the data of our clients as well as principals (hereinafter uniformly referred to as “clients”) in order to enable them to select, acquire or commission the selected services or works as well as related activities, as well as to pay for them and make them available or execute or perform them.

The required information is identified as such within the scope of the order, purchase order or comparable contract conclusion and includes the information required for the provision of services and invoicing as well as contact information in order to be able to make any necessary arrangements. Insofar as we have access to information from end customers, employees or other persons, we process this information in accordance with the legal and contractual requirements.

Offer of software and platform services: We process the data of our users, registered users and any test users (hereinafter uniformly referred to as “users”) in order to be able to provide them with our contractual services and on the basis of legitimate interests in order to guarantee the security of our offer and to be able to further develop it. The required information is identified as such within the scope of the conclusion of the order, contract or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to make any necessary arrangements.

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Interested parties, business and contractual partners, customers.
  • Purposes of processing: contractual services and performance, contact requests and communication, office and organizational procedures, administration and answering of requests, security measures.
    Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


8. Provision of the online offer and web hosting

In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security and technical maintenance services.

The data processed within the framework of the provision of the hosting offer may include all data relating to the users of our online offer, which are generated within the framework of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as other information concerning the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent encrypted. As a rule, e-mails are encrypted in transit, but (unless an end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, date and time of access, data volume transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the capacity utilization of the servers and their stability.

Content Delivery Network: We use a “Content Delivery Network” (CDN). A CDN is a service that allows the content of an online offering, especially large media files such as graphics or program scripts, to be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.

  • Processed data types: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Content Delivery Network (CDN).
  • Legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Used services and service providers:


9. Special notes on applications

We process the data of the users of our application to the extent necessary to provide the users with the application and its functionalities, to monitor its security and to develop it further. We may also contact users in compliance with legal requirements if the communication is necessary for purposes of administration or use of the application. For further information on the processing of user data, please refer to the data protection information in this privacy policy.

Legal basis: The processing of data required for the provision of the functionalities of the application serves to fulfill contractual obligations. This also applies if the provision of the functions requires the authorization of the users (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimizing the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly asked to give their consent to the processing of their data, the data covered by the consent is processed on the basis of the consent.

Commercial use: We process the data of the users of our application, registered and possible test users (hereinafter uniformly referred to as “users”) in order to be able to provide them with our contractual services and on the basis of legitimate interests, in order to guarantee the security of our application and to be able to further develop it. The required information is identified as such within the scope of the conclusion of the use, order, purchase order or comparable contract and may include the information required for the provision of services and for possible invoicing as well as contact information in order to be able to hold any consultations.

Storage of a pseudonymous identifier: We use a pseudonymous identifier so that we can provide the application and ensure its functionality. The identifier is a mathematical value (i.e. no clear data such as names are used) that is assigned to a device and/or the installation of the application installed on it. This identifier is generated during the installation of this application, remains stored between the start of the application and its updates and is deleted when users remove the application from the device.

No location history and no motion profiles: The location data is only used selectively and is not processed to create a location history or a motion profile of the used devices or their users.

  • Processed data types: inventory data (e.g. names, addresses), meta/communication data (e.g. device information, IP addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, duration, customer category), location data (data indicating the location of an end user’s terminal device).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contractual and service purposes.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Fulfilment of contract and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


10. Purchase of applications via Appstores

Our application can be obtained from special online platforms operated by other service providers (so-called “AppStores”). In this context, the privacy policy of the respective AppStores applies in addition to our privacy policy. This applies in particular with regard to the methods used on the platforms for measuring reach and for interest-based marketing as well as possible cost obligations.


11. Registration, login and user account

A special group of users, so-called authors, can create a user account. In the course of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligations. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration is used for the purposes of using the user account and its purpose.

Users can be informed by e-mail about processes relevant to their user account, such as technical changes. If users have cancelled their user account or the underlying contract has been terminated, the data of these users with regard to the user account will be deleted, subject to a legal obligation to retain data. It is the responsibility of the users to save their data in case of termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the contract period.

Within the scope of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. authors, users of online services).
  • Purposes of processing: contractual and service performance, security measures, management and response to requests.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


12. Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers’ data are processed for the purposes of the publication medium only to the extent necessary for its presentation and for communication between authors and readers or for security reasons. In addition, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contractual services and service, feedback (e.g. collecting feedback via online form).
  • Legal basis: Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


13. Video conferences, online meetings, webinars and screen sharing

We use third-party platforms and applications (hereinafter referred to as “Third Party Providers”) for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings. When selecting third-party providers and their services, we observe the legal requirements.

In this context, data of the communication participants will be processed and stored on the servers of the third party providers, as far as they are part of communication processes with us. This data may include, in particular, registration and contact data, visual and vocal contributions, as well as entries in chats and shared screen content.

If users are referred to the third party providers or their software or platforms in the course of communication, business or other relationships with us, the third party providers may process usage data and metadata for security, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

Notes on legal basis: If we ask users for their consent to use the third-party providers or certain functions (e.g. consent to a recording of conversations), the legal basis for processing is consent. Furthermore, their use can be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed upon in this context. Otherwise, user data is processed on the basis of our legitimate interest in efficient and secure communication with our communication partners. In this context, we would like to refer you additionally to the information on the use of cookies in this privacy policy.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners, users (e.g. website visitors, users of online services).
  • Purposes of processing: contractual services and performance, contact requests and communication, office and organizational procedures, direct marketing (e.g. by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Used services and service providers:


14. Application process

The application procedure requires that applicants provide us with the data necessary for their assessment and selection. Which information is required can be found in the job description or, in the case of online forms, in the information provided there.

In principle, the required data includes personal information such as name, address, contact details and proof of the qualifications required for a position. Upon request, we will also be happy to provide you with information on what information is required.

If provided, applicants can send us their applications using an online form. The data will be encrypted according to the state of the art and transmitted to us. Applicants can also send us their applications by e-mail. Please note, however, that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the application between the sender and the reception on our server.

For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management or recruitment software and platforms and services of third parties, subject to legal requirements.

Applicants are welcome to contact us regarding the method of application submission or to send us their application by mail.

Processing of special categories of data: If special categories of personal data within the meaning of Art. 9 para. 1 DSGVO (e.g. health data, such as severely disabled persons or ethnic origin) are requested from applicants in the context of the application procedure so that the person responsible or the data subject can exercise the rights arising to him or her from employment law and social security and social protection law and fulfil his or her obligations in this respect, their processing is carried out in accordance with Art. 9 para. 2 letter b. DSGVO, in the case of protection of vital interests of applicants or other persons according to art. 9 par. 2 letter c. DSGVO or for the purposes of health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, for health or social care or treatment or for the management of health or social care systems and services in accordance with Art. 9 Par. 2 lit. h. DSGVO. In the case of communication of the special categories of data based on voluntary consent, their processing is carried out on the basis of art. 9, paragraph 2, letter a. DSGVO.

Deletion of data: The data provided by applicants may be processed by us for the purposes of the employment relationship in the event of a successful application. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. The applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to do at any time. Subject to a justified revocation by the applicants, the data will be deleted after a period of six months at the latest so that we can answer any follow-up questions regarding the application and comply with our obligation to provide evidence under the regulations on the equal treatment of applicants. Invoices for any travel expense reimbursement will be archived in accordance with tax law requirements.

Admission to an applicant pool: Admission to an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the current application process and that they can withdraw their consent at any time in the future.

Duration of data retention in the applicant pool in months: 12

  • Processed data types: Applicant data (e.g. personal details, postal and contact addresses, the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates and other information about the applicant’s person or qualification provided by applicants with regard to a specific position or voluntarily).
  • Data subjects: Applicants
  • Purpose of the processing: application procedure (establishment and possible subsequent implementation and possible subsequent termination of the employment relationship).
  • Legal basis: Art. 9 para. 1 sentence 1 lit. b DSGVO (application procedure as a pre-contractual or contractual relationship) (Insofar as special categories of personal data within the meaning of Art. 9 para. 1 DSGVO (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants so that the responsible person or the data subject can exercise the rights arising to him or her from employment law and social security and social protection law and fulfil his or her obligations in this respect, their processing is carried out in accordance with Art. 9 Paragraph 2 letter b. DSGVO, in the case of protection of vital interests of applicants or other persons according to art. 9 par. 2 letter c. DSGVO or for the purposes of health care or occupational medicine, for the assessment of the employee’s ability to work, for medical diagnosis, care or treatment in the health or social sector or for the management of systems and services in the health or social sector in accordance with Art. 9 para. 2 lit. h. DSGVO. In the case of communication of special categories of data based on voluntary consent, their processing is carried out on the basis of art. 9, paragraph 2, letter a. DSGVO).


15. Cloud services

We use software services accessible via the Internet and running on the servers of their providers (so-called “cloud services”, also referred to as “software as a service”) for the following purposes: document storage and management, calendar management, e-mailing, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chatting and participating in audio and video conferences.

In this context, personal data may be processed and stored on the servers of the providers if they are part of communication processes with us or otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact details of users, data on procedures, contracts, other processes and their contents. The providers of cloud services also process usage data and metadata that they use for security purposes and service optimization.

If we use the cloud services to provide other users or publicly accessible websites with forms or other documents and content, the providers may store cookies on the users’ devices for web analysis purposes or to remember user settings (e.g. in the case of media control).

Notes on legal bases: If we ask for consent to use the cloud services, the legal basis for processing is consent. Furthermore, their use can be a component of our (pre)contractual services, provided that the use of the cloud services has been agreed in this context. Otherwise, user data is processed on the basis of our legitimate interests (i.e., interest in efficient and secure administration and collaboration processes).

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers, employees (e.g. employees, applicants, former employees), interested parties, communication partners.
  • Purposes of processing: office and organizational procedures.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Eingesetzte Dienste und Diensteanbieter:


16. Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletters”) only with the consent of the recipients or a legal permission. If, in the course of registering for the newsletter, its contents are specifically described, they are decisive for the consent of the users. Furthermore, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of personal contact in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: The registration for our newsletter is always carried out in a so-called Double-Opt-In-Procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with foreign e-mail addresses. The newsletter registrations are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing: We may store the deleted e-mail addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time. In case of obligations to permanently observe contradictions, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

The logging of the registration procedure is based on our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Information on legal bases: The dispatch of newsletters is based on the consent of the recipients or, if consent is not required, on our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of advertising to existing customers. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process will be recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.

Content: Information about us, our services, release notes, news, promotions and offers.

Analysis and measurement of success: The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from their server. Within the scope of this retrieval, technical information such as information on the browser and your system, as well as your IP address and the time of retrieval, is initially collected.

This information is used for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined by means of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider to observe individual users. Rather, the evaluations serve to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the measurement of success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.

Unfortunately, a separate revocation of the performance measurement is not possible. In this case, the entire newsletter subscription must be cancelled or objected to.

  • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Communication partner
  • Purposes of processing: direct marketing (e.g. by e-mail or by post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
  • Right to object (Opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options listed above, preferably e-mail.

Used services and service providers:


17. Advertising communication via e-mail, mail, fax or telephone

We process personal data for purposes of advertising communication, which can be done via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements.

Recipients have the right to revoke their consent at any time or to object to promotional communication at any time.

After revocation or objection, we may store the data required to prove consent for up to three years on the basis of our legitimate interests before we delete it. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.

  • Processed data types: general data (e.g. names, addresses), contact data (e.g. e-mail, phone numbers).
  • Data subjects: Communication partner
  • Purposes of processing: direct marketing (e.g. by e-mail or by post).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).


18. Surveys and questionnaires

The surveys and questionnaires we conduct (hereinafter referred to as “surveys”) are evaluated anonymously. Personal data will only be processed to the extent necessary for the provision and technical implementation of the surveys (e.g. processing of the IP address to display the survey in the user’s browser or to enable a resumption of the survey by means of a temporary cookie (session cookie)) or if users have consented to this.

Information on legal basis: If we ask the participants for their consent to the processing of their data, this is the legal basis for the processing, otherwise the processing of the participants’ data is based on our legitimate interest in conducting an objective survey.

  • Processed data types: contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partner
  • Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


19. Web analysis, monitoring and optimization

Web analysis (also known as “reach measurement”) is used to evaluate the streams of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the range analysis we can, for example, identify at what time our online offer or its functions or contents are most frequently used or invite reuse. We can also understand which areas require optimization.

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online offer or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, content viewed, web pages visited and elements used there, and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data may also be processed, depending on the provider.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect the users. In general, in the context of web analysis, A/B testing and optimization, no clear user data (such as e-mail addresses or names) are stored, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavioral profiling, use of cookies), visitor action evaluation, profiling (creation of user profiles), interest-based and behavioral marketing.
  • Security Measures: IP-Masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Used services and service providers:


20. Online marketing

We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of its effectiveness.

For these purposes, so-called user profiles are created and stored in a file (a so-called “cookie”) or similar procedures are used, by means of which user data relevant to the presentation of the aforementioned content is stored. This information may include, for example, the content viewed, web pages visited, online networks used, but also communication partners and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data may also be processed.

The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. In general, no clear user data (such as e-mail addresses or names) are stored in the context of the online marketing process, but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

As a rule, the information in the profiles is stored in the cookies or by means of similar procedures. These cookies can later be read out and analyzed for the purpose of presenting content on other websites that use the same online marketing procedure, and can also be supplemented with additional data and stored on the server of the online marketing service provider.

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing methods we use and the network links the users’ profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

As a matter of principle, we only receive access to summarized information about the success of our advertisements. However, we can check in the context of so-called conversion measurements which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.

Unless otherwise stated, we ask you to assume that used cookies are stored for a period of two years.

Notes on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Target group formation with Google Analytics: We use Google Analytics in order to display the ads placed within the advertising services of Google and its partners only to those users who have also shown an interest in our online offer or who exhibit certain characteristics (e.g. interests in certain topics or products determined by the websites visited), which we transmit to Google (so-called “remarketing” or “Google Analytics Audiences”). With the help of remarketing audiences, we also want to ensure that our ads match the potential interest of users

Facebook pixel: With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel in order to display the Facebook ads placed by us only to those users on Facebook and within the services of partners cooperating with Facebook (so-called “Audience Network” https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offering or who exhibit certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of users and do not appear to be annoying. The Facebook pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion measurement”).

  • Processed data types: Usage data (e.g., web pages visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (data indicating the location of an end user’s end device).
  • Data subjects: Users (e.g., website visitors, users of online services), prospects, customers, employees (e.g., employees, applicants, former employees), communication partners.
  • Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behaviour-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
  • Security measures: IP-Masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
  • Right to object (Opt-Out): We refer to the data protection information of the respective providers and the possibilities of objection (so-called “Opt-Out”) indicated for the providers. If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas: a) Europe: https://www.youronlinechoices.eu.  b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Area-wide: https://optout.aboutads.info.

Used services and service providers:

  • Google Tag Manager and gtag: Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (for more information, please refer to this privacy policy). With the Tag Manager itself (which implements the tags), for example, no user profiles are created or cookies are stored. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy.
  • Google Analytics: Online marketing and web analysis; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com/intl/de/about/analytics/; Privacy policy: https://policies.google.com/privacy; Right to object (Opt-Out): Opt-Out-Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Google Ads and conversion measurement: We use the online marketing process “Google Ads” to place ads in the Google advertising network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. We also measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a so-called “conversion tracking tag”. However, we do not receive any information that can identify users. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy.
  • Google Ad Manager: We use the “Google Marketing Platform” (and services such as “Google Ad Manager”) to place ads on the Google advertising network (e.g., in search results, in videos, on web pages, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to display ads for and within our online offering in a more targeted manner, so that we can show users only ads that potentially match their interests. For example, if a user is shown ads for products that he or she has been interested in on other websites, this is called “remarketing”. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy policy: https://policies.google.com/privacy.
  • Facebook-Pixel: Service provider: https://www.facebook.com, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com; Datenschutzerklärung: https://www.facebook.com/about/privacy; Right to object (Opt-Out): https://www.facebook.com/settings?tab=ads.
  • LinkedIn: Insights tag / conversion measurement; Service provider: LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA; Website: https://www.linkedin.com; Security measures: IP Masking (pseudonymization of the IP address); Privacy policy: https://www.linkedin.com/legal/privacy-policy, Cookie policy: https://www.linkedin.com/legal/cookie_policy; Right to object (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • Twitter: Twitter marketing and advertising; Service provider: : Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Website: https://twitter.com/de; Privacy policy: https://www.facebook.com/about/privacy; Right to object (Opt-Out): https://twitter.com/personalization.


21. Presence in social networks (social media)

We maintain online presences within social networks and in this context we process user data in order to communicate with the users active there or to offer information about us.

Please note that user data may be processed outside the European Union. This can result in risks for the users, because the enforcement of the users’ rights could be made more difficult.

Furthermore, user data within social networks are usually processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behavior and the resulting interests of the users. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the right to  object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users in each case and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can contact us.

  • Processed data types: general data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Used services and service providers:


22. Plugins and embedded functions and content

We include in our online offer functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third party providers”). These can be, for example, graphics, videos or social media buttons and contributions (hereinafter referred to uniformly as “content”).

The integration always assumes that the third party providers of such content process the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required for the display of these contents or functions. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known 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 contain technical information about the browser and operating system, the websites to be linked, the time of visit and other details about the use of our online offer as well as being linked to such information from other sources.

Notes on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g. function libraries that we use for the purpose of displaying or making our online offering user-friendly). The respective provider collects the IP address of the user and may process this information for the purpose of transmitting the software to the user’s browser, for security purposes and for the evaluation and optimization of their offer.

  • Processed data types: Usage data (e.g., web pages visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses), location data (data indicating the location of an end user’s terminal device), contact data (e.g., e-mail, phone numbers), content data (e.g., text entries, photographs, videos), general data (e.g., names, addresses).
  • Data subjects: Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offer and user-friendliness, contractual services and service, contact inquiries and communication, direct marketing (e.g. by e-mail or postal mail), tracking (e.g. interest/behavioural profiling, use of cookies), interest-based and behavioural marketing, profiling (creation of user profiles), security measures, administration and answering of inquiries.
  • Legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a DSGVO), fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO)

Eingesetzte Dienste und Diensteanbieter:


23. Planning, organization and support tools

We use the services, platforms and software of other providers (hereinafter referred to as “third party providers”) for the purposes of organizing, managing, planning and providing our services. When selecting third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of the third party providers. This may affect various data which we process in accordance with this privacy policy. This data may include, in particular, master data and contact details of users, data on procedures, contracts, other processes and their contents.

If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relations with us, the third-party providers may process usage data and metadata for security purposes, service optimization or marketing purposes. We therefore request that you observe the data protection notices of the respective third-party providers.

Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Furthermore, their use can be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed in this context. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Processed data types: general data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners, users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Fulfilment of contract and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).


24. Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for which the data were processed ceases to apply or if they are not necessary for the purpose).

Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or that must be stored for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person.

Further information on the deletion of personal data may also be provided in the individual data protection notes of this privacy policy.


25. Amendment and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to act in a cooperative manner (e.g., to give your consent) or to provide other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.


26. Rights of data subjects

As a data subject, you are entitled to various rights under the DSGVO, which result in particular from Art. 15 to 21 DSGVO:

  • Right to object: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you, which is carried out on the basis of art. 6 paragraph 1 letter e or f of the DPA; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
  • Right to withdraw consent: You have the right to revoke your consent at any time.
  • Right to access to personal data: You have the right to request confirmation as to whether data in question is being processed and to receive information about this data and further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right to ask for the completion of the data concerning you or the correction of incorrect data concerning you in accordance with the law.
  • Right to erasure and limitation of processing: You have the right to request, in accordance with the law, the immediate deletion of data concerning you or, alternatively, in accordance with the law, the limitation of processing of the data.
  • Right to receive personal data in a machine-readable format: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another person responsible.
  • Complaint to the supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the suspected infringement, if you believe that the processing of personal data relating to you is in breach of the DSGVO.


27. Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

  • Conversion tracking: Conversion tracking is a method of determining the effectiveness of marketing activities. For this purpose, a cookie is usually stored on the user’s device within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can use this information to determine whether the ads we placed on other websites were successful).
  • Content Delivery Network (CDN): A “Content Delivery Network” (CDN) is a service that enables the content of an online offering, especially large media files such as graphics or program scripts, to be delivered more quickly and securely using servers distributed regionally and connected via the Internet.
  • Cross-Device Tracking: Cross-Device Tracking is a form of tracking in which behavioral and interest information of users is recorded in so-called profiles across devices by assigning users an online identifier. This allows the user information to be analyzed for marketing purposes, regardless of the browser or device used (e.g., cell phone or desktop computer). With most providers, the online ID is not linked to clear data, such as names, postal or e-mail addresses.
  • IP-Masking: IP-Masking is a method in which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymizing processing methods, especially in online marketing
  • Interest-based and behavioral marketing: We speak of interest-based and/or behavioral marketing when the potential interests of users in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behavior (e.g., visiting and spending time on certain websites, purchasing behavior or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
  • Conversion measurement: Conversion measurement is a method to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, this enables us to track whether the ads we have placed on other websites have been successful.
  • Personal data: “Personal data” shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: “Profiling” is any automated processing of personal data which consists of using personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information about age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Remarketing: One speaks of “remarketing” or “retargeting”, for example, when it is noted for advertising purposes in which products a user has been interested on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Tracking: One speaks of “tracking” when the behavior of users can be traced across several online offers. As a rule, behavioral and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Person responsible: The term “person responsible” refers to the natural or legal person, authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: “Processing” shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers practically all handling of data, whether it be collection, analysis, storage, transmission or deletion.
  • Target group formation: One speaks of target group formation (or “custom audiences”) when target groups are determined for advertising purposes, e.g. the insertion of advertisements. For example, based on a user’s interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online store where he/she viewed the products. In turn, one speaks of “Lookalike Audiences” (or similar target groups) if the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used to create custom audiences and lookalike audiences.

Let’s work together.

Imprint details according to section 5 Telemedia Act & Data Protection (Telemediengesetz & Datenschutz)

AppNavi GmbH
Register court: Amtsgericht München HRB 216915
VAT-ID: DE298859635

Phone: +49 89 21750050
Email: info@appnavi.eu
Web: https://appnavi.eu

Registered office of the company

Atelierstr. 29
81671 Munich I Germany

Management

AppNavi GmbH Carsten Neumann

Copyright © 2020 – All rights reserved

Disclaimer of Liability

Liability for contents

All contents of our website have been created with the greatest care and to the best of our knowledge. For the correctness, completeness and topicality of the contents we can take over however no guarantee. As a service provider we are responsible according to § 7 Abs.1 TMG for own contents on these sides after the general laws. According to §§ 8 to 10 TMG we are not obliged as a service provider to monitor transmitted or stored third-party information or to investigate circumstances that indicate illegal activity. Obligations to remove or block the use of information in accordance with general laws remain unaffected by this.

However, liability in this respect is only possible from the point in time at which we become aware of a concrete violation of the law. As soon as we become aware of the above-mentioned infringements, we will remove these contents immediately.

Limtation of liability for external links

Our website contains links to external websites of third parties. We have no influence on the contents of these directly or indirectly linked websites. Therefore, we cannot guarantee the correctness of the contents of the “external links”. The respective providers or operators (authors) of the pages are responsible for the contents of the external links.

The external links were checked for possible violations of the law at the time the links were created and were free of illegal content at the time the links were created. It is not possible to constantly check the content of external links without concrete evidence of a violation of the law. In the case of direct or indirect links to the websites of third parties which lie outside our area of responsibility, liability would only arise in the event that we become aware of the content and it would be technically possible and reasonable for us to prevent use in the event of illegal content.

This disclaimer also applies to links and references placed within our own website “appnavi.eu” by questioners, bloggers and guests of the discussion forum. For illegal, incorrect or incomplete contents and especially for damages resulting from the use or non-use of such information, only the service provider of the page to which reference was made is liable, not the one who merely refers to the respective publication via links.

If we become aware of any legal infringements, we will remove the external links immediately.

Copyright

The contents and works published on our website are subject to German copyright law (http://www.gesetze-im-internet.de/bundesrecht/urhg/gesamt.pdf). The duplication, processing, distribution and any kind of exploitation of intellectual property in the ideal and material view of the author outside the limits of copyright law require the prior written consent of the respective author within the meaning of copyright law (http://www.gesetze-im-internet.de/bundesrecht/urhg/gesamt.pdf ). Downloads and copies of these pages are only permitted for private and non-commercial use. If the contents of our website have not been created by us, the copyrights of third parties must be observed. The contents of third parties are marked as such. Should you nevertheless become aware of a copyright infringement, please inform us accordingly. We will remove such content immediately upon becoming aware of any infringements.

This imprint was kindly provided by www.jurarat.de.

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