Informational translation: If the versions differ, the German document is authoritative.
Trade mark notice: KULINSKI POLAND ADVISORY (KPA) is a brand of recruitIT Consulting.
Contact KPA:
michael.kulinski@niederlassung-polen.de
kpa-postfach@niederlassung-polen.de
Contact locations
1) Introduction and contact details of the person responsible
1.1 We are pleased that you are visiting our website and thank you for your interest. Below we inform you about the handling of your personal data when using our website. Personal data in this context is all data that can be used to personally identify you.
1.2 The person responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is Michael Kulinski, recruitIT Consulting, Tal 44, 80331 Munich, Germany, Tel.: +49 89 54197225, Email: michael.kulinski@niederlassung-polen.de. The person responsible for the processing of personal data is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data.
2) Data collection when visiting our website
2.1 For merely informational use of our website, that is, if you do not register or otherwise convey information to us, we only collect such data that your browser transmits to the page server (so-called “server log files”). When you access our website, we collect the following data, which is technically necessary for us to display the website to you:
- Our visited website
- Date and time at the moment of access
- Amount of data sent in bytes
- Source/referral from which you reached the page
- Browser used
- Operating system used
- IP address used (if applicable: in anonymized form)
Processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR based on our legitimate interest in improving the stability and functionality of our website. There is no transfer or other use of the data. However, we reserve the right to subsequently review the server log files if there are concrete indications of unlawful use.
2.2 For security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the controller), this website uses SSL or TLS encryption. You can recognize an encrypted connection by the “https://” prefix and the lock icon in your browser’s address bar.
3) Hosting & Content Delivery Network
3.1 Cloudflare
For hosting our website and displaying the page content, we use the system of the following provider: Cloudflare Inc., 101 Townsend St. San Francisco, CA 94107, USA
All data collected on our website is processed on the provider’s servers.
We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision by the European Commission, ensures compliance with the European level of data protection.
3.2 Cloudflare
We use a content delivery network from the following provider: Cloudflare Inc., 101 Townsend St. San Francisco, CA 94107, USA
This service allows us to deliver large media files such as graphics, page content, or scripts faster via a network of regionally distributed servers. The processing is carried out to protect our legitimate interest in improving the stability and functionality of our website according to Art. 6 para. 1 lit. f GDPR. We have concluded a data processing agreement with the provider, which ensures the protection of our site visitors’ data and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision by the European Commission, ensures compliance with the European level of data protection.
4) Cookies
To make visiting our website attractive and to enable the use of certain functions, we use cookies, which are small text files that are stored on your device. Some of these cookies are automatically deleted when the browser is closed (so-called “session cookies”), while others remain on your device longer and allow the storage of page settings (so-called “persistent cookies”). In the latter case, you can refer to the overview of the cookie settings in your web browser to see the storage duration.
If personal data is also processed through individual cookies used by us, the processing is carried out in accordance with Art. 6 para. 1 lit. b GDPR either for the performance of the contract, in accordance with Art. 6 para. 1 lit. a GDPR in the case of given consent, or in accordance with Art. 6 para. 1 lit. f GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the site visit.
You can set your browser so that you are informed about the setting of cookies and decide individually on their acceptance or exclude the acceptance of cookies for certain cases or in general.
Please note that if cookies are not accepted, the functionality of our website may be limited.
5) Contact
5.1 Hubspot
For the provision of an online appointment booking function, we use the services of the following provider: HubSpot Ireland Ltd., 2nd Floor 30 North Wall Quay, Dublin 1, Ireland
For the purpose of scheduling appointments, in accordance with Art. 6 para. 1 lit. b GDPR, first and last names as well as email address (and, if applicable, the phone number, if a telephone appointment is desired) are collected and, in accordance with Art. 6 para. 1 lit. f GDPR, transmitted to the provider on the basis of our legitimate interest in effective customer management and efficient appointment administration and stored there for appointment organization.
After the appointment has taken place or after the agreed appointment period has expired, your data will be deleted by the provider.
We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.
5.2 In the context of contacting us (e.g., via contact form or email), personal data is collected. Which data is collected in the case of using a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of answering your inquiry or for contacting you and the associated technical administration.
The legal basis for the processing of this data is our legitimate interest in responding to your request in accordance with Art. 6 para. 1 lit. f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 para. 1 lit. b GDPR. Your data will be deleted after your request has been fully processed. This is the case if the circumstances indicate that the relevant matter has been conclusively resolved and as long as no statutory retention obligations oppose this.
6) Online Marketing
HubSpot
This website uses the software-based marketing service of the following provider for the delivery and synchronization of various customer management services: HubSpot Ireland Ltd., 2nd Floor 30 North Wall Quay, Dublin 1, Ireland
The service enables the automated processing of feed activities, the control of advertising in deployed marketing channels, and the success analysis of marketing measures, as well as central e-mail marketing and contact management.
To fulfill the various functions, cookies are used, i.e., small text files that are stored locally in the cache of your web browser on your device and allow us to analyze your use of the website. In this process, the cookies collect certain information, such as the IP address, location, and the time of the page visit.
All processing described above, in particular the setting of cookies for reading information on the device used, is only carried out if you have given us your explicit consent in accordance with Art. 6 Para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the “Cookie-Consent-Tool” provided on the website.
Other legal bases for data processing that are applied within the framework of specific service functions (such as the necessity of explicit consent according to Art. 6 Para. 1 lit. a GDPR when sending newsletters) remain unaffected by this.
We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.
7) Web analytics services
7.1 Google Analytics 4
This website uses Google Analytics 4, a web analytics service from Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”), which allows an analysis of your use of our website.
By default, cookies are set by Google Analytics 4 when visiting the website. These are small text files stored on your device and collect certain information. This information also includes your IP address, which, however, is shortened by Google at the last digits to exclude a direct personal reference.
The information is transmitted to Google servers and further processed there. Transfers to Google LLC based in the USA are also possible.
Google uses the information collected on our behalf to analyze your use of the website, to compile reports on website activities for us, and to provide other services related to website and Internet usage. The IP address transmitted and shortened by your browser as part of Google Analytics is not merged with other Google data. The data collected through the use of Google Analytics 4 is stored for a period of two months and then deleted.
All of the above-described processing, in particular the placing of cookies on the device used, only takes place if you have given us your explicit consent for this in accordance with Art. 6 para. 1 lit. a GDPR.
Without your consent, the use of Google Analytics 4 will not take place during your visit to the site. You can withdraw your given consent at any time with effect for the future. To exercise your right of withdrawal, please disable this service via the “Cookie Consent Tool” provided on the website.
We have concluded a data processing agreement with Google that ensures the protection of our site visitors’ data and prohibits unauthorized disclosure to third parties.
Further legal information about Google Analytics 4 can be found at https://business.safety.google
Demographic characteristics
Google Analytics 4 uses the special function “demographics” and can create statistics that make statements about the age, gender, and interests of website visitors. This is done through the analysis of advertising and information from third-party providers. This allows target groups for marketing activities to be identified. However, the collected data cannot be assigned to a specific person and is deleted after being stored for a period of two months.
Google Signals
As an extension to Google Analytics 4, Google Signals can be used on this website to create cross-device reports. If you have enabled personalized ads and linked your devices to your Google account, Google can, subject to your consent to the use of Google Analytics pursuant to Art. 6 para. 1 lit. a GDPR, analyze your usage behavior across devices and create database models, including for cross-device conversions. We do not receive any personal data from Google, only statistics. If you want to stop cross-device analysis, you can disable the “Personalized ads” feature in your Google account settings. To do this, follow the instructions on this page: https://support.google.com
Further information about Google Signals can be found at the following link: https://support.google.com
UserIDs
As an extension to Google Analytics 4, the ‘UserIDs’ feature can be used on this website. If you have consented to the use of Google Analytics 4 in accordance with Art. 6 para. 1 lit. a GDPR, created an account on this website, and log in with this account on different devices, your activities, including conversions, can be analyzed across devices.
Collection of data provided by users
To improve analysis results for users whose contact details we have received in the context of business or business-like relationships, we use the feature of ‘Collection of data provided by users’.
Subject to your explicit consent pursuant to Art. 6 para. 1 lit. a GDPR, we transmit, within the scope of this function, one or more files with customer data aggregated to your person (especially email address and phone number) electronically to Google. Google does not gain access to clear data in this process, but automatically encrypts the information in the customer files during the transmission process using a special algorithm. The encrypted information can then only be used by Google to match it to existing Google accounts that the data subjects have set up.
The processing serves to refine measurement data, improves cross-device user tracking, and enables the integration of analytical results into advertising personalization and conversion tracking functions of Google Ads.
You can revoke your consent to us at any time with effect for the future. More information about Google’s data protection measures regarding the transmission of customer data can be found here: https://support.google.com
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision by the European Commission, ensures compliance with the European level of data protection.
7.2 Cloudflare Web Analytics
This website uses the web analytics service of the following provider: Cloudflare, Inc., 101 Townsend St. San Francisco, CA 94107, USA
To protect site visitors, the provider uses a pseudonymized visitor ID to enable various analyses of site usage within a short time window of a maximum of 24 hours. This visitor ID is a randomly generated, time-limited hash value created based on a reduced set of technical attributes. These include in particular the user agent (information about browser and operating system) as well as the anonymized IP address, which is processed only for the duration of the analysis and then discarded.
If, in individual cases, personal data is nevertheless processed, the processing is based on our legitimate interest in the statistical evaluation of user behavior for optimization purposes in accordance with Art. 6 para. 1 lit. f GDPR. In this case, you can permanently object to the collection and storage of your visitor data for the future by notifying us.
We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision by the European Commission, ensures compliance with the European level of data protection.
7.3 Google Tag Manager
This website uses the “Google Tag Manager,” a service of the following provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: “Google”).
The Google Tag Manager provides a technical basis for bundling various web applications, including tracking and analytics services, and for calibrating, controlling, and linking them to conditions via a unified user interface. The Google Tag Manager itself does not store any information on user devices or read such information. The service also does not perform independent data analyses. However, when a page is accessed, your IP address is transmitted to Google via the Google Tag Manager and may be stored there. Transmission to servers of Google LLC in the USA is also possible.
This processing is only carried out if you have given us your explicit consent in accordance with Art. 6 para. 1 lit. a GDPR. Without this consent, the use of Google Tag Manager during your visit to the site does not take place. You can revoke your consent at any time with effect for the future. To exercise your revocation, please deactivate this service in the “Cookie Consent Tool” provided on the website.
We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.
Further legal information on Google Tag Manager can be found at https://business.safety.google
8) Retargeting/Remarketing and Conversion Tracking
8.1 Google Ads Remarketing
This website uses retargeting technology from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
For this purpose, Google places a cookie in your device’s browser, which automatically enables interest-based advertising using a pseudonymous cookie ID and based on the pages you have visited. The information collected in this process generally also includes your IP address.
Further data processing only takes place if you have consented to Google linking your internet and app browsing history with your Google account and using information from your Google account to personalize ads you view on the web. In this case, if you are logged into Google while visiting our website, Google uses your data together with Google Analytics data to create and define audience lists for cross-device remarketing. For this purpose, your personal data is temporarily linked with Google Analytics data by Google to form audiences. As part of the use of Google Ads Remarketing, personal data may also be transmitted to the servers of Google LLC in the USA.
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your explicit consent in accordance with Art. 6 para. 1 lit. a GDPR. Without this consent, the use of retargeting technology during your visit to the site will not take place.
You can revoke your given consent at any time with effect for the future. To exercise your revocation, please deactivate this service in the “Cookie Consent Tool” provided on the website.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision by the European Commission, ensures compliance with the European level of data protection.
Details on the processing initiated by Google and Google’s handling of website data can be found here: https://policies.google.com
Further information on Google’s privacy policies can be found here: https://business.safety.google
8.2 LinkedIn Insight
This website uses retargeting technology from the following provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.
This allows visitors to our websites to be specifically targeted with personalized, interest-based advertising who have already shown interest in our offers. The display of the advertisements is based on a cookie-based analysis of past and current usage behavior.
In the cases of retargeting technology, a cookie is stored on your computer or mobile device to collect pseudonymized data about your interests and thus customize the advertising based on the stored information. These cookies are small text files that are stored on your computer or mobile device. This way, you are shown advertising that is highly likely to correspond to your product and information interests.
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your explicit consent in accordance with Art. 6 para. 1 lit. a GDPR. Without this consent, the use of retargeting technology during your visit to the site will not take place.
You can revoke your given consent at any time with effect for the future. To exercise your revocation, please deactivate this service in the “Cookie Consent Tool” provided on the website.
The data may also be transferred to: LinkedIn Corp., USA
We have concluded a contract with the provider for order processing, which ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision by the European Commission, ensures compliance with the European level of data protection.
8.3 LinkedIn Marketing Solutions
This website uses retargeting technology from the following provider: LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland
This allows visitors to our websites to be specifically targeted with personalized, interest-based advertising who have already shown interest in our offers. The display of the advertisements is based on a cookie-based analysis of past and current usage behavior.
In the cases of retargeting technology, a cookie is stored on your computer or mobile device to collect pseudonymized data about your interests and thus customize the advertising based on the stored information. These cookies are small text files that are stored on your computer or mobile device. This way, you are shown advertising that is highly likely to correspond to your product and information interests.
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your explicit consent in accordance with Art. 6 para. 1 lit. a GDPR. Without this consent, the use of retargeting technology during your visit to the site will not take place.
You can revoke your given consent at any time with effect for the future. To exercise your revocation, please deactivate this service in the “Cookie Consent Tool” provided on the website.
The data may also be transferred to: LinkedIn Corp., USA
We have concluded a contract with the provider for order processing, which ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision by the European Commission, ensures compliance with the European level of data protection.
8.4 Google Ads Conversion Tracking
This website uses the online advertising program “Google Ads” and, as part of Google Ads, the conversion tracking of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”).
We use the Google Ads service to draw attention to our offers on external websites using advertising tools (so-called Google AdWords). We can determine, based on the data from the advertising campaigns, how successful the individual advertising measures are. Our goal is to show you advertising that is of interest to you, to make our website more interesting for you, and to achieve a fair calculation of the advertising costs incurred.
The cookie for conversion tracking is set when a user clicks on an ad placed by Google. Cookies are small text files that are stored on your device. These cookies generally expire after 30 days and are not used for personal identification. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can see that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Thus, cookies cannot be tracked across the websites of Google Ads customers. The information collected with the help of the conversion cookie, which also includes your IP address, is used to create conversion statistics for Google Ads customers who have opted for conversion tracking. The customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive information that would allow them to personally identify users.
As part of using Google Ads, it may also involve the transmission of personal data to the servers of Google LLC in the USA.
Details on the processing initiated by Google Ads conversion tracking and on how Google handles data from websites can be found here: https://policies.google.com
All processing described above, in particular the setting of cookies for reading information on the device used, is only carried out if you have given us your explicit consent in accordance with Art. 6 Para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the “Cookie-Consent-Tool” provided on the website.
You can also permanently object to the setting of cookies by Google Ads conversion tracking by downloading and installing the browser plug-in from Google available at the following link:
https://support.google.com
In order to address users whose data we have received within the scope of business or business-like relationships in a more interest-oriented advertising manner, we use a customer match function within Google Ads. For this purpose, we transmit one or more files with aggregated customer data (especially email addresses and phone numbers) electronically to Google. Google does not have access to the unencrypted data; instead, the information in the customer files is automatically encrypted during the transmission process using a special algorithm. The encrypted information can then only be used by Google to associate it with existing Google accounts that the individuals have set up. This enables personalized advertising to be displayed across all Google services linked to the respective Google account.
The transfer of customer data to Google only takes place if you have given us an explicit consent in accordance with Art. 6 Para. 1 lit. a GDPR. You can revoke this consent at any time with future effect. More information about Google’s data protection measures regarding the Customer Match function can be found here: https://support.google.com
Google’s privacy policy can be viewed here: https://business.safety.google
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.
8.5 Google Ads conversion tracking without cookies
This website uses the online advertising program “Google Ads” and, as part of Google Ads, the conversion tracking of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”).
We use the Google Ads service to draw attention to our offers on external websites using advertising tools (so-called Google AdWords). We can determine, based on the data from the advertising campaigns, how successful the individual advertising measures are. Our goal is to show you advertising that is of interest to you, to make our website more interesting for you, and to achieve a fair calculation of the advertising costs incurred.
This website uses Google Ads Conversion Tracking exclusively without the use of cookies, which means that the service does not set cookies on your device at any time.
Instead, your browser’s local storage is used to store an individual ID assigned by Google, which allows analysis of your use of the website. For this purpose, certain user information, including your IP address, is processed via the ID.
The ID is set when a user clicks on a Google advertisement. If the user visits certain pages of this website, Google and we can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Cookies cannot therefore be tracked across the websites of Google Ads customers. The information collected in this way is used to create conversion statistics for Google Ads customers who have opted for conversion tracking. The customers are informed of the total number of users who clicked on their ad and were redirected to a page equipped with a conversion tracking tag.
However, you will not receive any information that allows users to be personally identified. In the context of using Google Ads, there may also be a transmission of personal data to the servers of Google LLC in the USA. Details on the processing triggered by Google Ads conversion tracking and on how Google handles data from websites can be found here: https://policies.google.com
To the extent that the collected information has a personal reference, the processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in the statistical evaluation of the success of our advertising campaigns.
Google’s privacy policy can be viewed here: https://business.safety.google
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.
8.6 Google Ads Conversion Tracking
This website uses the online advertising program “Google Ads” and, as part of Google Ads, the conversion tracking of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). We use the Google Ads service to draw attention to our attractive offers on external websites using advertising materials (so-called Google AdWords). In relation to the data from the advertising campaigns, we can determine how successful the individual advertising measures are. Our aim is to display advertising that is of interest to you, make our website more attractive for you, and achieve a fair calculation of the advertising costs incurred.
The cookie for conversion tracking is set when a user clicks on an ad placed by Google. Cookies are small text files that are stored on your device. These cookies generally expire after 30 days and are not used for personal identification. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can see that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Thus, cookies cannot be tracked across the websites of Google Ads customers. The information collected with the help of the conversion cookie, which also includes your IP address, is used to create conversion statistics for Google Ads customers who have opted for conversion tracking. The customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that would allow them to personally identify users. In the context of using Google Ads, it may also result in the transfer of personal data to the servers of Google LLC in the USA.
Details on the processing initiated by Google Ads conversion tracking and on how Google handles data from websites can be found here: https://policies.google.com
All processing described above, in particular the setting of cookies for reading information on the device used, is only carried out if you have given us your explicit consent in accordance with Art. 6 Para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the “Cookie-Consent-Tool” provided on the website.
You can also permanently object to the setting of cookies by Google Ads conversion tracking by downloading and installing the browser plug-in from Google available at the following link:
https://support.google.com
Please note that certain functions of this website may not be available or may only be available to a limited extent if you have disabled the use of cookies.
Google’s privacy policy can be viewed here: https://business.safety.google
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.
8.7 Google Marketing Platform
This website uses the online marketing tool Google Marketing Platform operated by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“GMP”).
GMP uses cookies to display relevant ads to users, improve reports on campaign performance, or prevent a user from seeing the same ads multiple times. Using a cookie ID, Google records which ads are displayed in which browser and can thus prevent them from being shown multiple times. Additionally, GMP can use cookie IDs to record so-called conversions that relate to ad requests. This is the case, for example, when a user sees a GMP ad and later, while using the same browser, visits the advertiser’s website and makes a purchase through this website. According to Google, GMP cookies do not contain personal information.
Due to the marketing tools used, your browser automatically establishes a direct connection with Google’s server.
We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our knowledge as follows: By integrating GMP, Google receives the information that you have accessed the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible that the provider obtains and stores your IP address. In the context of using GMP, it may also result in the transmission of personal data to the servers of Google LLC in the USA.
All processing described above, in particular the setting of cookies for reading information on the device used, is only carried out if you have given us your explicit consent in accordance with Art. 6 Para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the “Cookie-Consent-Tool” provided on the website.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.
You can find the privacy policies of GMP by Google here: https://business.safety.google
8.8 Microsoft Advertising Universal Event Tracking
This website uses conversion tracking technology from the following provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA
For the use of Universal Event Tracking, a tag is placed on every page of our website that interacts with the conversion cookie set by Microsoft. This interaction makes user behavior on our website traceable and sends the information collected in this way to Microsoft. The purpose of this is to statistically capture and evaluate certain predefined goals, such as purchases or leads, in order to make the targeting and content of our offers more aligned with interests. The tags are at no time used for the personal identification of users.
All processing described above, in particular the setting of cookies to read information on the device used, will only be carried out if you have given us your explicit consent in accordance with Art. 6 para. 1 lit. a GDPR. Without this consent, the use of retargeting technology during your visit to the site will not take place.
You can revoke your given consent at any time with effect for the future. To exercise your revocation, please deactivate this service in the “Cookie Consent Tool” provided on the website.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision by the European Commission, ensures compliance with the European level of data protection.
9) Page functionalities
9.1 Facebook plugins
On our website, plugins of the social network of the following provider are used: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
These plugins enable direct interactions with content on the social network.
To increase the protection of your data when visiting our website, the plugins are initially disabled and integrated into the page using a so-called ‘2-click’ or ‘Shariff’ solution.
This integration ensures that when a page on our website containing such plugins is accessed, no connection to the provider’s servers is established yet.
Only when you activate the plugins and thereby give your consent to the data transmission in accordance with Art. 6 para. 1 lit. a GDPR does your browser establish a direct connection to the provider’s servers. In this process, independent of logging into an existing user profile, information about your device (including your IP address), your browser, and your browsing history is transmitted to the provider to a certain extent and may be further processed there.
If you are logged into an existing user profile on the provider’s social network, information about interactions conducted via the plugins is also published there and shown to your contacts.
You can revoke your consent at any time by deactivating the activated plugin by clicking on it again. However, the revocation has no effect on the data that has already been transmitted to the provider.
Data can also be transferred to: Meta Platforms Inc., USA
We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision by the European Commission, ensures compliance with the European level of data protection.
9.2 Instagram plugins
On our website, plugins of the social network of the following provider are used: Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
These plugins enable direct interactions with content on the social network.
To increase the protection of your data when visiting our website, the plugins are initially disabled and integrated into the page using a so-called ‘2-click’ or ‘Shariff’ solution.
This integration ensures that when a page on our website containing such plugins is accessed, no connection to the provider’s servers is established yet.
Only when you activate the plugins and thereby give your consent to the data transmission in accordance with Art. 6 para. 1 lit. a GDPR does your browser establish a direct connection to the provider’s servers. In this process, independent of logging into an existing user profile, information about your device (including your IP address), your browser, and your browsing history is transmitted to the provider to a certain extent and may be further processed there.
If you are logged into an existing user profile on the provider’s social network, information about interactions conducted via the plugins is also published there and shown to your contacts.
You can revoke your consent at any time by deactivating the activated plugin by clicking on it again. However, the revocation has no effect on the data that has already been transmitted to the provider.
Data can also be transferred to: Meta Platforms Inc., USA
We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.
9.3 LinkedIn plugins
On our website, plugins of the social network of the following provider are used: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland
These plugins enable direct interactions with content on the social network.
To increase the protection of your data when visiting our website, the plugins are initially disabled and integrated into the page using a so-called ‘2-click’ or ‘Shariff’ solution.
This integration ensures that when a page on our website containing such plugins is accessed, no connection to the provider’s servers is established yet.
Only when you activate the plugins and thereby give your consent to the data transmission in accordance with Art. 6 para. 1 lit. a GDPR does your browser establish a direct connection to the provider’s servers. In this process, independent of logging into an existing user profile, information about your device (including your IP address), your browser, and your browsing history is transmitted to the provider to a certain extent and may be further processed there.
If you are logged into an existing user profile on the provider’s social network, information about interactions conducted via the plugins is also published there and shown to your contacts.
You can revoke your consent at any time by deactivating the activated plugin by clicking on it again. However, the revocation has no effect on the data that has already been transmitted to the provider.
Data can also be transferred to: LinkedIn Corp., USA
We have concluded a data processing agreement with the provider, which ensures the protection of our website visitors’ data and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision by the European Commission, ensures compliance with the European level of data protection.
9.4 YouTube
This website uses plugins to display and play videos from the following provider: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.
Data can also be transmitted to: Google LLC, USA.
When you visit a page of our website that contains such a plugin, your browser establishes a direct connection to the provider’s servers at the latest at the time of video playback in order to load the content. In this process, certain information, including your IP address, is transmitted to the provider.
If the playback of embedded videos is started via the plugin, the provider also uses cookies to collect information about user behavior, create playback statistics, and prevent abuse.
If you are logged into a user account with the provider during your visit to the site, your data will be directly associated with your account when you click on a video. If you do not want the association with your account, you must log out before activating the play button.
All of the aforementioned processing, in particular the setting of cookies to read information on the device used, only takes place if you have given us your explicit consent in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke the consent you have given at any time with effect for the future by deactivating this service via the “Cookie Consent Tool” provided on the website.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.
9.5 Google Web Fonts
This page uses so-called web fonts from the following provider for consistent display of fonts: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland
When a page is accessed, your browser loads the required web fonts into its browser cache to display texts and fonts correctly and establishes a direct connection to the provider’s servers. In this process, certain browser information, including your IP address, is transmitted to the provider.
Data can also be transmitted to: Google LLC, USA
The processing of personal data in the course of establishing a connection with the provider of the fonts is only carried out if you have given us your explicit consent in accordance with Art. 6(1)(a) GDPR. You can revoke your granted consent at any time with effect for the future by deactivating this service via the “Cookie Consent Tool” provided on the website. If your browser does not support web fonts, a standard font from your computer will be used.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.
Further information on Google’s privacy policy can be found here: https://business.safety.google
9.6 Google Customer Reviews (formerly Google Certified Merchant Program)
We work with Google within the framework of the “Google Customer Reviews” program. The provider is Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). This program gives us the opportunity to collect customer reviews from users of our website. In this process, you will be asked on our website, after using our services, whether you would like to participate in an email survey from Google.
If you give your consent pursuant to Art. 6 para. 1 lit. a GDPR, we will transmit your email address to Google. You will receive an email from Google Customer Reviews asking you to rate your purchase experience on our website. The review you submit will then be combined with our other reviews and displayed in our Google Customer Reviews logo as well as in our Merchant Center dashboard. In addition, your review will be used for Google seller ratings. As part of the use of Google Customer Reviews, it may also involve the transfer of personal data to the servers of Google LLC in the USA.
You can revoke your consent at any time by sending a message to the person responsible for data processing or directly to Google.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.
Further information on Google’s privacy policy can be found here: https://business.safety.google
9.7 Microsoft Teams
For the conduct of online meetings, video conferences and/or webinars, we use this provider: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA
The provider processes various data, whereby the extent of the data processed depends on which data you provide before or during participation in an online meeting, a video conference, or a webinar. Your data is processed as a communication participant and stored on the provider’s servers. This can particularly include your registration data (name, email address, phone number (optional), and password) and session data (topic, participant IP address, device information, description (optional)).
In addition, participants’ image and audio contributions as well as voice inputs in chats may be processed.
For the processing of personal data that is necessary for the fulfillment of a contract with you (this also applies to processing operations required for the implementation of pre-contractual measures), Art. 6 para. 1 lit. b GDPR serves as the legal basis. Insofar as you have given us consent for the processing of your data, the processing is carried out on the basis of Art. 6 para. 1 lit. a GDPR. A given consent can be revoked by you at any time with effect for the future.
Otherwise, the legal basis for data processing in the implementation of online meetings, video conferences, or webinars is our legitimate interest according to Art. 6 para. 1 lit. f GDPR in the effective conduct of the online meeting, webinar, or video conference.
We have concluded a data processing agreement with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.
For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which ensures compliance with the European data protection level based on an adequacy decision by the European Commission.
10) Tools and Miscellaneous
Cookie Consent Tool
This website uses a so-called “Cookie Consent Tool” to obtain effective user consents for cookies requiring consent and cookie-based applications. The “Cookie Consent Tool” is displayed to users when accessing the website in the form of an interactive user interface, on which consents for specific cookies and/or cookie-based applications can be granted by ticking boxes. With the use of the tool, all cookies/services requiring consent are only loaded if the respective user has granted the corresponding consent by ticking boxes. This ensures that such cookies are only set on the respective user’s device in the case of given consent.
The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed in this context.
If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, linking, or logging cookie settings, this is done in accordance with Art. 6(1)(f) GDPR based on our legitimate interest in legally compliant, user-specific, and user-friendly consent management for cookies, and thus in a legally compliant design of our website.
Another legal basis for the processing is also Art. 6 para. 1 lit. c GDPR. As controllers, we are subject to the legal obligation to make the use of technically non-essential cookies dependent on the respective user consent.
Where necessary, we have concluded a data processing agreement with the provider, which ensures the protection of the data of our website visitors and prohibits unauthorized disclosure to third parties.
Further information about the operator and the settings options of the cookie consent tool can be found directly in the corresponding user interface on our website.
11) Rights of the data subject
11.1 The applicable data protection law grants you the following rights as a data subject vis-à-vis the controller concerning the processing of your personal data (rights to information and intervention), whereby the respective legal basis for exercising these rights is referenced:
- Right of access pursuant to Art. 15 GDPR;
- Right to rectification pursuant to Art. 16 GDPR;
- Right to erasure pursuant to Art. 17 GDPR;
- Right to restriction of processing pursuant to Art. 18 GDPR;
- Right to notification pursuant to Art. 19 GDPR;
- Right to data portability pursuant to Art. 20 GDPR;
- Right to withdraw consent given pursuant to Art. 7(3) GDPR;
- Right to lodge a complaint pursuant to Art. 77 GDPR.
11.2 RIGHT OF OBJECTTION
IF WE PROCESS YOUR PERSONAL DATA BASED ON OUR PREDOMINANTLY LEGITIMATE INTERESTS WITHIN THE SCOPE OF A BALANCE OF INTERESTS, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION, WITH EFFECT FOR THE FUTURE.
IF YOU EXERCISE YOUR RIGHT OF OBJECTION, WE WILL CEASE PROCESSING THE DATA CONCERNED. HOWEVER, FURTHER PROCESSING REMAINS PERMISSIBLE IF WE CAN PROVE COMPELLING LEGITIMATE REASONS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS, AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE, OR DEFEND LEGAL CLAIMS.
IF YOUR PERSONAL DATA IS PROCESSED BY US FOR 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. YOU CAN EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
IF YOU MAKE USE OF YOUR RIGHT TO OBJECT, WE WILL CEASE THE PROCESSING OF THE AFFECTED DATA FOR DIRECT MARKETING PURPOSES.
12) Duration of Storage of Personal Data
The duration of the storage of personal data is determined based on the respective legal basis, the processing purpose, and – if applicable – additionally based on the respective statutory retention period (e.g., commercial and tax law retention periods).
When processing personal data based on an explicit consent in accordance with Art. 6(1)(a) GDPR, the affected data will be stored as long as you do not revoke your consent.
If there are legal retention periods for data processed within the framework of contractual or contract-like obligations based on Art. 6(1)(b) GDPR, these data will be routinely deleted after the expiration of the retention periods, provided they are no longer required for the fulfillment or initiation of a contract and/or we no longer have a legitimate interest in further storage.
When processing personal data on the basis of Art. 6 Para. 1 lit. f GDPR, this data will be stored as long as you exercise your right to object under Art. 21 Para. 1 GDPR, unless we can prove compelling legitimate grounds for processing that override your interests, rights, and freedoms, or the processing serves the establishment, exercise, or defense of legal claims.
When processing personal data for the purpose of direct marketing on the basis of Art. 6 Para. 1 lit. f GDPR, this data will be stored as long as you exercise your right to object under Art. 21 Para. 2 GDPR.
Unless otherwise indicated by the other information in this declaration about specific processing situations, stored personal data will otherwise be deleted when it is no longer necessary for the purposes for which it was collected or otherwise processed.
