Data Protection

We are very pleased about your interest in our company. Data protection has a particularly high priority for the management of IBS Technology GmbH. The internet pages of IBS Technology GmbH can generally be used without providing any personal data. However, if a data subject wishes to use special services of our company via our website, the processing of personal data may become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain the consent of the data subject. The processing of personal data, for example the name, address, email address or telephone number of a data subject, is always carried out in accordance with the General Data Protection Regulation and in compliance with the country-specific data protection provisions applicable to IBS Technology GmbH. By means of this privacy policy, our company would like to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of their rights by means of this privacy policy. As the controller, IBS Technology GmbH has implemented numerous technical and organizational measures (TOMs) to ensure the most complete protection possible of the personal data processed via this website. Nevertheless, internet-based data transmissions can in principle have security gaps, so that absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. Definitions

The privacy policy of IBS Technology GmbH is based on the terms used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for the public as well as for our customers and business partners. To ensure this, we would like to explain the terms used in advance. In this privacy policy, we use the following terms, among others:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject means any identified or identifiable natural person whose personal data is processed by the controller.

c) Processing

Processing means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

f) Pseudonymization

Pseudonymization means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

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

i) Recipient

Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

j) Third party

Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k) Consent

Consent means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the controller

The controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions of a data protection nature is: IBS Technology GmbH
Ferdinand-Porsche-Str. 11
60386 Frankfurt am Main
Germany
Email: contact @ ibs-technology.com
Website: www.ibs-technology.com

Data Protection Officer:

Mr. Eser Esen
Email: eesen @ ibs-technology.com
Tel.: +49 (0)69 40897658

3. Cookies and consent management (Cookiebot)

Our website uses cookies and similar technologies. Cookies are small text files that are stored on your device by your internet browser. Technically necessary cookies are set without your consent (Section 25(2) no. 2 TDDDG; Art. 6(1)(f) GDPR). All other cookies, in particular for statistical analysis, are only set with your prior consent (Section 25(1) TDDDG; Art. 6(1)(a) GDPR).

We use the consent management platform Cookiebot of Usercentrics A/S, Havnegade 39, 1058 Copenhagen, Denmark, to obtain and document your consent. When you visit the website, Cookiebot loads a banner in which you can accept or decline categories of cookies. Until you consent, cookies and services that require consent (such as Google Analytics) are blocked. To prove your choice, Cookiebot stores your consent status, a pseudonymous consent ID, the date and time of your decision and the language and version of the banner in a cookie on your device and in its own records. Your IP address is shortened before storage. The legal basis is Art. 6(1)(c) and (f) GDPR (our legal obligation to be able to prove consent and our interest in a lawful website).

You can change or withdraw your consent at any time with effect for the future via "Cookie settings" in the footer of the website. The cookies currently in use, with their purpose and storage period, are listed in the cookie declaration at the end of this privacy policy. You can also prevent cookies altogether in your browser settings and delete cookies that have already been set. This may limit the functionality of the website.

4. Collection of general data and information

The website of IBS Technology GmbH collects a series of general data and information each time the website is accessed by a data subject or an automated system. This general data and information is stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-pages which are accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol address (IP address), (7) the internet service provider of the accessing system and (8) other similar data and information that serve to avert danger in the event of attacks on our information technology systems. When using this general data and information, IBS Technology GmbH does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by IBS Technology GmbH on the one hand statistically and on the other hand with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files is stored separately from all personal data provided by a data subject.

5. Hosting (Vercel)

Our website is hosted by Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. When you visit the website, the hosting provider processes the server log data described in Section 4 (in particular your IP address, the pages accessed and the time of access) in order to deliver the website and to ensure its security and stability. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the secure and efficient provision of our website. The data may be processed in the United States. Where this is the case, the transfer is based on the provider's certification under the EU-U.S. Data Privacy Framework or on standard contractual clauses.

6. Contact options, enquiries and booking a meeting

The website contains forms and links through which you can contact us or request a meeting. The following applies.

Contact and request forms. If you submit a form on the website, we process the data you enter: first name, last name, email address, company and, in the contact form, your message. In addition we store the page from which you submitted the form, the language setting of the website, the time of submission and, for requests for downloadable content, which content you requested. The data is first saved in a database operated for us by Upstash, Inc. (Redis database) and is then transmitted to our customer relationship management (CRM) system, where our sales team processes your request. The forms are protected against misuse (see Section 7). The legal basis is Art. 6(1)(b) GDPR where your request relates to a contract or pre-contractual measures, otherwise Art. 6(1)(f) GDPR (our interest in answering enquiries and in business contacts). We use the data only to answer your request and to keep in touch about it, and we do not pass it on to third parties beyond the service providers named here.

Contact form on the Contact page. If you use the form on our Contact page, we process your name, your email address, your company website (optional) and your message, and in addition the language of the page, the time of submission, the page you came from and, where present, the company domain passed in the link. The data is sent by email to our contact mailbox (contact@ibs-technology.com) through the email service SendGrid (Twilio Inc., 375 Beale Street, Suite 300, San Francisco, CA 94105, USA) and is not saved in our database beyond a short-lived request counter per IP address (see Section 7). The form is protected against misuse by a hidden field, a minimum completion time and a limit on requests per hour. The legal basis is Art. 6(1)(b) GDPR where your request relates to pre-contractual measures, otherwise Art. 6(1)(f) GDPR. The data may be processed in the United States, on the basis of the EU-U.S. Data Privacy Framework or standard contractual clauses. We use the data only to answer your message.

Email. If you contact us by email, we process the personal data you send us in order to handle your enquiry.

Booking a meeting. The "Talk through your use case" buttons lead to a booking page provided by Microsoft Bookings (Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland). When you book, Microsoft processes your name, email address, the chosen time and the information you provide, and we receive the booking. Microsoft's own privacy statement applies to the booking page. The legal basis is Art. 6(1)(b) and (f) GDPR. Providing your data is voluntary; without it we cannot answer your request or confirm an appointment.

7. Protection against misuse (Cloudflare Turnstile)

To protect our forms against automated misuse (spam and bots), we use Cloudflare Turnstile of Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. When a form is displayed, a script from Cloudflare is loaded and checks whether the request comes from a human visitor. For this purpose Cloudflare processes technical data such as your IP address and information about your browser and device. We also store your IP address briefly in our database to limit the number of requests per hour. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the security of our website and the protection of our forms against misuse. The data may be processed in the United States, on the basis of the EU-U.S. Data Privacy Framework or standard contractual clauses.

8. Error monitoring (Sentry)

To detect and fix technical errors in the processing of form submissions, we use the error monitoring service Sentry of Functional Software, Inc., 45 Fremont Street, 8th Floor, San Francisco, CA 94105, USA. If an error occurs on our server, Sentry receives a technical error report, which may contain technical request data such as your IP address. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest is the stability and security of our website. The data may be processed in the United States, on the basis of the EU-U.S. Data Privacy Framework or standard contractual clauses.

8a. Tailored pages (links with ?c=)

If you open a link with a company domain in it (for example ?c=example.com) or type a company domain into the "tailor this page" form, we show you a version of the page that reflects what that company's public website says. The domain you enter or that is in your link is the only input.

What happens with the domain. We send the domain to our server, which reads public pages of that company's website and runs a few public search queries about it. For this we use the crawling service Firecrawl (SideGuide Technologies, Inc., USA) and the search service SerpApi (SerpApi, LLC, 1632 S 1st St, Austin, TX 78704, USA). The text of those public pages and the domain are then passed to the language model Gemini of Google (Google LLC, USA; Google acts as our processor under Google's data processing addendum for paid services and does not use the data to improve its products; we make no claim that the processing takes place in the EU) to write the tailored text. The search service stores search data for 31 days according to its own information. The result is stored on our server for 30 days under the normalised domain so that the same page does not have to be created twice. Company domains are not personal data as such; if a domain contains a personal name, the legal basis for these steps is Art. 6(1)(f) GDPR (our legitimate interest in showing you a relevant offer).

Logo. To display the company's logo, your browser requests it from the logo service logo.dev (Logodev, Inc., USA) with the company domain, without sending a referrer.

Cookie and session storage. After a link with ?c= or after you enter a domain, we store that domain in a session cookie named ibs_c and in your browser's session storage so that the tailored version stays in place while you browse the site. Both are deleted when you close the browser. They are used only for the function you requested.

Rate limits. To prevent misuse and to control costs, our server keeps short-lived counters per IP address in a Redis database (Upstash; hosting is described in section 5). The legal basis is Art. 6(1)(f) GDPR.

Statistics. If you have consented to analytics (section 12), the company domain of a ?c= link is part of the page address that Google Analytics 4 records. If you click the booking button on a tailored page, we send an internal notification with the company, the domain and the use cases shown to our team's Teams channel by email (SendGrid).

9. Routine erasure and blocking of personal data

The controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or where provided for by the European legislator or another legislator in laws or regulations to which the controller is subject. If the purpose of storage ceases to apply or a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with the statutory provisions.

10. Rights of the Data Subject

a) Right to Confirmation

Every data subject has the right, granted by the European legislator of directives and regulations, to obtain from the controller confirmation as to whether or not personal data concerning them are being processed. If a data subject wishes to exercise this right to confirmation, they may contact an employee of the controller at any time.

b) Right of Access

Every data subject affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to obtain from the controller at any time, free of charge, information about the personal data stored about them and a copy of this information. Furthermore, the European legislator of directives and regulations has granted the data subject access to the following information:

  • the purposes of the processing

  • the categories of personal data being processed

  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations

  • where possible, the envisaged period for which the personal data will be stored, or, if this is not possible, the criteria used to determine that period

  • the existence of the right to request from the controller rectification or erasure of personal data concerning the data subject, or restriction of processing, or to object to such processing

  • the existence of the right to lodge a complaint with a supervisory authority

  • where the personal data are not collected from the data subject: any available information as to their source

  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and — at least in those cases — meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has the right to obtain information as to whether personal data have been transferred to a third country or to an international organisation. Where this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to exercise this right of access, they may contact an employee of the controller at any time.

c) Right to Rectification

Every data subject affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to obtain without undue delay the rectification of inaccurate personal data concerning them. Furthermore, the data subject has the right, taking into account the purposes of the processing, to have incomplete personal data completed — including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, they may contact an employee of the controller at any time.

d) Right to Erasure (Right to Be Forgotten)

Every data subject affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to obtain from the controller the erasure of personal data concerning them without undue delay, where one of the following grounds applies and insofar as the processing is not necessary:

  • The personal data have been collected or otherwise processed for purposes for which they are no longer necessary.

  • The data subject withdraws consent on which the processing is based according to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal ground for the processing.

  • The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.

  • The personal data have been unlawfully processed.

  • The personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

  • The personal data have been collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.

If one of the above grounds applies and a data subject wishes to request the erasure of personal data stored by IBS Technology GmbH, they may contact an employee of the controller at any time. The employee of IBS Technology GmbH will arrange for the erasure request to be complied with without undue delay. Where the personal data have been made public by IBS Technology GmbH and our company, as controller, is obliged pursuant to Art. 17(1) GDPR to erase the personal data, IBS Technology GmbH, taking account of available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform other controllers which are processing the published personal data that the data subject has requested from those other controllers the erasure of any links to, or copy or replication of, those personal data, insofar as the processing is not necessary. The employee of IBS Technology GmbH will arrange the necessary steps in each individual case.

e) Right to Restriction of Processing

Every data subject affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.

  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.

  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.

  • The data subject has objected to processing pursuant to Art. 21(1) GDPR and it has not yet been verified whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by IBS Technology GmbH, they may contact an employee of the controller at any time. The employee of IBS Technology GmbH will arrange the restriction of processing.

f) Right to Data Portability

Every data subject affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to receive the personal data concerning them, which the data subject has provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR or on a contract pursuant to Art. 6(1)(b) GDPR and the processing is carried out by automated means, unless the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising their right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and where this does not adversely affect the rights and freedoms of others. To assert the right to data portability, the data subject may contact an employee of IBS Technology GmbH at any time.

g) Right to Object

Every data subject affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to object, on grounds relating to their particular situation, at any time, to processing of personal data concerning them which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on those provisions. In the event of an objection, IBS Technology GmbH will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing serves the establishment, exercise or defence of legal claims. Where IBS Technology GmbH processes personal data for direct marketing purposes, the data subject has the right to object at any time to processing of the personal data for such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to IBS Technology GmbH to the processing for direct marketing purposes, IBS Technology GmbH will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them which is carried out by IBS Technology GmbH for scientific or historical research purposes or for statistical purposes pursuant to Art. 89(1) GDPR, unless such processing is necessary for the performance of a task carried out for reasons of public interest. To exercise the right to object, the data subject may contact any employee of IBS Technology GmbH or another employee directly. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.

h) Automated Individual Decision-Making, Including Profiling

Every data subject affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is based on the data subject's explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) is based on the data subject's explicit consent, IBS Technology GmbH will implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, which include at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision. If the data subject wishes to assert rights relating to automated decision-making, they may contact an employee of the controller at any time.

i) Right to Withdraw Consent Under Data Protection Law

Every data subject affected by the processing of personal data has the right, granted by the European legislator of directives and regulations, to withdraw consent to the processing of personal data at any time. If the data subject wishes to exercise their right to withdraw consent, they may contact an employee of the controller at any time.

11. Data Protection for Applications and in the Application Process

The controller collects and processes the personal data of applicants for the purpose of handling the application process. The processing may also take place by electronic means. This is the case in particular where an applicant submits corresponding application documents to the controller by electronic means, for example by email or via a web form on the website. If the controller concludes an employment contract with an applicant, the data submitted will be stored for the purpose of handling the employment relationship in compliance with statutory provisions. If no employment contract is concluded with the applicant by the controller, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller oppose deletion. Other legitimate interests in this sense include, for example, a duty to provide evidence in proceedings under the General Equal Treatment Act (AGG).

12. Use of Google Analytics 4 (with consent)

With your consent, we use Google Analytics 4, a web analytics service of Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland ("Google"). Google Analytics is only loaded after you have consented to statistics cookies in the cookie banner; until then no data is sent to Google.

Google Analytics collects data about the use of our website, for example the pages viewed, how long they are viewed, the website from which you came (referrer), approximate location, and device and browser information, and it sets cookies to recognise your browser. We use the results to understand how visitors use our website and to improve it, and to measure how often our contact and booking buttons are used. Google Analytics 4 does not log or store IP addresses. Data may nevertheless be transferred to Google LLC in the United States, on the basis of the EU-U.S. Data Privacy Framework or standard contractual clauses.

The legal basis is your consent (Art. 6(1)(a) GDPR and Section 25(1) TDDDG). You can withdraw your consent at any time with effect for the future via "Cookie settings" in the footer. You can also prevent the collection of the data generated by Google Analytics by installing the browser add-on available at https://tools.google.com/dlpage/gaoptout. Further information can be found at https://policies.google.com/privacy.

13. Privacy Policy on the Use and Application of Google Fonts

To display the content on our website in a uniform way, the script code "Google Fonts" collects data (IP address, time of visit, device and browser information), transmits it to Google and Google then processes it. We have no influence on this subsequent data processing.

14. Privacy Notice for Online Meetings, Conference Calls and Webinars via "TEAMs" and Supporting Tools, e.g. "Miro"

Below we would like to inform you about the processing of personal data in connection with the use of "TEAMs".

Purpose of processing

We use the "TEAMs" tool to conduct conference calls, online meetings, video conferences and/or webinars (hereinafter: "online meetings"). "TEAMs" is a service of Microsoft, which is based in the USA.

Controller

The controller responsible for data processing that is directly connected with the conduct of "online meetings" is IBS Technology GmbH.

Scope of processing

IBS Technology GmbH uses "Microsoft Teams" to conduct "online meetings". If "online meetings" are to be recorded, this will be communicated transparently in advance and, where necessary, consent will be requested.

Chat content is logged when Microsoft Teams is used. If it is necessary for the purposes of recording the results of an online meeting, IBS Technology GmbH will log the chat content. As a rule, however, this will not be the case.

Recipients / disclosure of data

Personal data processed in connection with participation in "online meetings" is generally not disclosed to third parties unless it is specifically intended for disclosure. Please note that, as with in-person meetings, content from "online meetings" may well serve to communicate information to third parties and is therefore intended for disclosure.

Other recipients: The provider of "Microsoft Teams" necessarily obtains knowledge of the above-mentioned data to the extent provided for in the data processing agreement with "Microsoft Teams".

15. Legal Basis of the Processing

Art. 6 I lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations necessary for the supply of goods or the provision of any other service or consideration, the processing is based on Art. 6 I lit. b GDPR. The same applies to processing operations that are necessary for carrying out pre-contractual measures, for example in cases of inquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfillment of tax obligations, the processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may become necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our premises and his name, age, health insurance data or other vital information had to be passed on to a doctor, a hospital or other third parties. The processing would then be based on Art. 6 I lit. d GDPR. Finally, processing operations could be based on Art. 6 I lit. f GDPR. This legal basis is used for processing operations that are not covered by any of the aforementioned legal bases, if the processing is necessary to protect a legitimate interest of our company or of a third party, provided that the interests, fundamental rights and freedoms of the data subject do not override them. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European legislator. In this regard, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (Recital 47 sentence 2 GDPR).

16. Legitimate Interests in the Processing Pursued by the Controller or a Third Party

If the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the conduct of our business for the benefit of the well-being of all our employees and our shareholders.

17. Period for Which the Personal Data Will Be Stored

The criterion for the period of storage of personal data is the respective statutory retention period. After the expiry of that period, the corresponding data is routinely deleted, provided that it is no longer necessary for the performance or initiation of a contract.

18. Statutory or Contractual Requirements for the Provision of Personal Data; Necessity for the Conclusion of a Contract; Obligation of the Data Subject to Provide the Personal Data; Possible Consequences of Failure to Provide Such Data

We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information about the contractual partner). Occasionally, it may be necessary for the conclusion of a contract that a data subject provides us with personal data, which subsequently must be processed by us. For example, the data subject is obliged to provide us with personal data when our company enters into a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact one of our employees. Our employee will clarify to the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and what the consequences of failure to provide the personal data would be.

19. Existence of Automated Decision-Making

As a responsible company, we refrain from automatic decision-making or profiling. This privacy policy was created by the privacy policy generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which conducts data protection audits, in cooperation with the media law firm WILDE BEUGER SOLMECKE.

20. Technical and Organizational Measures (TOM)

Technical and organizational measures (TOM) for data security (pursuant to Art. 32 GDPR). As of: 22.05.2024 Download PDF

References & Sources

Source: mustervorlage

Image sources: iStockPhoto, unsplash, picjumbo, Freepik.