Information on DATA PROTECTION

Karl Diederichs GmbH & Co KG (hereinafter referred to as “Dirostahl” or “we”) attaches great importance to the data protection-compliant handling and security of the processing of your personal data. With this data protection information, we would like to inform you about how we handle personal data in general and in particular.

1. responsibilities

1.1 Responsible in terms of data protection

The controller within the meaning of data protection law is the natural or legal person who – alone or jointly with others – determines the purposes and means of the processing of personal data.

The controller in terms of data protection is the:

Karl Diederichs GmbH & Co KG
Luckhauser Street 1 – 5
42899 Remscheid
E-Mail: Info(at)dirostahl.de

1.2 Our data protection officer

We have appointed an external data protection officer for our organization, who can be contacted using the following contact details:

Boris Nicolaj Willm

Resilien[i]T GmbH
Monschauer Street 12
40549 Düsseldorf
Phone: +49 211 695289 92
E-mail: dsb.dirostahl(at)resilienit.de

1.3 Competent supervisory authority

You can contact the supervisory authority responsible for us at:

State Commissioner for Data Protection and Freedom of Information North Rhine-Westphalia
Kavalleriestr. 2-4
40213 Düsseldorf
Phone: +49 211 38424-0
E-mail: poststelle@ldi.nrw.de

2. general information on data protection

2.1 What data do we process from you?

Depending on the specific processing situation and necessity, we collect and process different types of personal data. We provide detailed information on this in this and / or separate data protection information or as part of the data collection to the respective data subjects.

2.2 For what purposes do we process your data and on what legal basis?

We collect and process various personal data depending on the specific processing situation. Processing is always carried out in accordance with the provisions of the General Data Protection Regulation (GDPR), the Federal Data Protection Act (BDSG) or other legal requirements The legal bases relevant to us result from Art. 6 para. 1 as follows:

2.2.1 On the basis of your consent

If you have given us your consent for the specific processing of your personal data, we will process your personal data on this basis. Consent may relate, for example, to the transfer of data to partner companies, the analysis of your data for targeted advertising measures or the sending of newsletters.

Consent is always voluntary. Refusal or withdrawal of consent will not have any negative consequences for you.

2.2.2 For the fulfillment of contractual obligations

We process your personal data to fulfill contractual or quasi-contractual obligations or to establish a contract, for example for existing customer support or to answer questions from a prospective customer.

If you apply to us by post or electronically and provide us with personal data, we process this data exclusively for the purpose of initiating a future employment relationship.

2.2.3 Due to legal obligations

Within the scope of our legal obligations, we process your personal data if this is provided for or required by law. This may include, for example, the disclosure of your data to government authorities in the context of tax or criminal prosecution proceedings, the evaluation of your data to comply with regulatory requirements or the provision of certain information to statutory bodies.

The processing of your data on this basis is always necessary. The legal obligation to which we are subject as an organization cannot be affected by any refusal or restriction on your part. We assure you that your personal data will be processed in accordance with the law and that it will be comprehensively protected.

2.2.4 Due to legitimate interests

We also process your personal data to protect our legitimate interests, unless your interests or fundamental rights and freedoms, which require the protection of your personal data, prevail.

Subject to a balancing decision to be made in individual cases, we regularly assume that our legitimate interests prevail in the following non-exhaustive list of processing situations:

for existing customer support;
to inform you about offers for services and products if we have received your name, e-mail address or postal address from you in connection with the provision of our services and/or the sale of our products;
Optimization of our offers and services;
Maintaining a customer database in our group of companies to improve customer service;
in the context of legal prosecution;
to ensure the security, confidentiality and integrity of our IT systems;

2.3 Who do we share your data with?

2.3.1 Companies, agencies and partners of Dirostahl

In principle, we only pass on your personal data if this is necessary for the establishment, execution or termination of a contract or contract-like relationship. In these cases, data is only passed on to companies affiliated with us or partners and representatives. Partners and agencies are, in particular, independent sales representatives for the distribution of our goods and services in Germany and abroad. For example, when you contact us, we share the information you provide us with the relevant regional Dirostahl company so that they can offer you our products and services in an optimized way, depending on the needs and regionality of your request.

The Dirostahl companies include:

Wilhelm Sönnecken GmbH
Blombacher Bach 12
D-42287 Wuppertal

You can find an overview of our agencies and partners on our website under Contacts.

2.3.2 Processors and third parties

On our instructions, your personal data may be processed by processors if their involvement is necessary for processing. In these cases, we ensure that your personal data is processed in accordance with the provisions of the GDPR. Processors in this case are, for example, IT service providers, waste disposal companies, etc. In addition, these processors are contractually obliged to either delete or return the data to us in accordance with the legal requirements when their services are terminated.

Your data will only be transferred and passed on to external recipients if this is permitted or required by law, if the transfer is necessary for the processing and fulfillment of the business relationship or service used or if you have given your consent to the transfer of data.

Personal data may be passed on to the following external recipients:

Public bodies and institutions that receive data due to legal regulations (e.g. tax office, courts, customs, etc.);
Tax consultant, auditor or legal advisor;
Payment service provider, for processing a payment transaction (e.g. financial institutions, payment services);
Collection service providers or credit agencies, insofar as this is necessary to exercise our rights;
IT and other service providers;
Printing and logistics companies, telecommunications service providers, delivery services.

2.4 Information on the transfer of data to third countries

In our organization, we use services from providers based in countries outside the European Economic Area where there is no level of data protection comparable to that in the EU. When using these services, your personal data may be transferred to these countries and processed there. We guarantee that this transfer will only take place within the framework of compliance with Art. 44ff of the General Data Protection Regulation (GDPR) in order to ensure an appropriate level of protection for your data.

2.5 Storage period

If no explicit or statutory storage period is specified at the time of collection, your personal data will be deleted as soon as it is no longer required to fulfill the purpose of storage and there are no statutory retention obligations or legal justifications for storage.

If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion will take place after these reasons no longer apply.

3 Your rights as a data subject

In accordance with the provisions of data protection law, we would like to inform you of your rights as a data subject. These rights are essential components of data protection and guarantee you control over your personal data. It is important to us that you are aware of your rights and understand how you can assert them in order to protect your privacy and the integrity of your data. Below you will find a detailed breakdown of your rights and information on how you can exercise them if necessary.

3.1 Information, correction and deletion

You have the right to receive information about your personal data processed by us. This includes information about the source of the data, the recipients and the purpose of processing. Furthermore, you have the right to correct or delete this data if necessary.

3.2 Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. This right is applicable under the following conditions:

Accuracy of the data: If you dispute the accuracy of your personal data and verification is required.
Unlawful processing: If the processing is unlawful, but you refuse to have it erased and instead request that its use be restricted.
The purpose of processing no longer applies but is required for legal claims: If the controller no longer needs the data for the purposes of processing, but you need them to assert, exercise or defend legal claims.
Objection to processing: If you object to the processing pursuant to Art. 21 para. 1 GDPR and it is still being examined whether the legitimate reasons of the controller outweigh your reasons.

During the restriction period, your data, apart from being stored, may only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

3.3 Right to data portability

You have the right to receive your personal data that you have provided to us in a structured, widely used and machine-readable format in accordance with existing legal requirements. This right also allows you to have this data transferred directly from one controller to another, where technically feasible. This applies in cases where the processing is based on consent or a contract and is automated.

3.4 Right to object to the collection of data in special cases

You have the right to object to the processing of your personal data at any time if this is based on Article 6 (1) lit. f is based. This provision permits data processing on the basis of the legitimate interests of the controller or a third party, unless your interests or fundamental rights and freedoms, which require the protection of personal data, prevail.

You have the unrestricted right to object to the processing of your personal data for advertising purposes at any time. This includes direct marketing. As soon as you object, your data will no longer be processed for these purposes. This right is absolute and has the effect of immediately stopping the corresponding data processing.

Individuals have the right not to be subject to decisions based solely on automated processing which produces legal effects concerning them or similarly significantly affects them.

The right to object also extends to profiling insofar as it is associated with direct marketing.

3.5 Revocation of your consent to data processing

You have the right to revoke processing based on your explicit consent at any time for the future. However, this revocation does not affect the legality of the data processing that took place before your revocation.

3.6 Contact option for exercising your rights as a data subject

You can declare the assertion of your rights and, if applicable, your objection informally by post or e-mail, addressed to:

Karl Diederichs GmbH & Co KG
Area: Data protection
Luckhauser Street 1 – 5
42899 Remscheid
E-mail: datenschutz(at)dirostahl.de

3.7 Right to lodge a complaint

If you are of the opinion that the processing of your personal data violates data protection law, you have the right under Art. 77 para. 1 GDPR, you have the right to lodge a complaint with a data protection supervisory authority of your choice. This also includes the supervisory authority responsible for us.

4 Data processing on our website

4.1 General information on the legal basis for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a GDPR and Art. 9 para. 2 lit. a GDPR, insofar as special categories of data pursuant to Art. 9 para. 1 GDPR are processed. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or access to information in your end device (e.g. via device fingerprinting), the data processing is also carried out on the basis of § 25 para. 1 TDDDG. Consent can be revoked at any time. If your data is required to fulfill the contract or to carry out pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be based on our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR must take place. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.

4.2 External hosting

We host our website externally. The personal data collected on our website is stored on the hoster’s servers. This may include IP addresses, contact requests, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.

Our hoster will only process your data to the extent necessary to fulfill its performance obligations and follow our instructions with regard to this data.

We use the following hoster:

Mittwald CM Service GmbH & Co KG
Königsberger Strasse 4-6
32339 Espelkamp
Details can be found in Mittwald’s privacy policy: https://www.mittwald.de/datenschutz

The website is maintained by the:

PixelProduction

Agency for conceptual communication GmbH & Co. KG

Vorm Eichholz 2 . 42119 Wuppertal

We have concluded a data processing agreement (DPA) with the service providers for the use of the above-mentioned services. This is a contract required by data protection law, which ensures that the personal data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.

4.3 SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, we use SSL or TLS encryption for our website(s). You can recognize an encrypted connection by the fact that the web address begins with “https://” and a lock symbol is displayed in your browser. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4.4 Objection to advertising e-mails

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

4.5 Cookies

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

Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies can be used to evaluate user behavior or for advertising purposes.

Cookies that are required to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 para. 1 lit. f GDPR. 1 lit. f GDPR, unless another legal basis is specified. The website operator has a legitimate interest in the storage of necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG); the consent can be revoked at any time.

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

You can find out which cookies and services are used on this website in this data protection information.

4.6 Consent with Borlabs Cookie

Our website uses Borlabs Cookie consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document this in accordance with data protection regulations. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg (hereinafter referred to as Borlabs).

When you enter our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the revocation of these consents are stored. This data is not passed on to the provider of Borlabs Cookie.

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

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

4.7 Server log files

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

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

This data is not merged with other data sources.

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

4.8 YouTube with enhanced data protection

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

When you visit one of these websites on which YouTube is integrated, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

We use YouTube in extended data protection mode. According to YouTube, videos that are played in extended data protection mode are not used to personalize browsing on YouTube. Ads that are displayed in extended data protection mode are also not personalized. No cookies are set in extended data protection mode. Instead, however, so-called local storage elements are stored in the user’s browser, which contain personal data similar to cookies and can be used to recognize the user. Details on the extended data protection mode can be found here: https://support.google.com/youtube/answer/171780.

After activating a YouTube video, further data processing operations may be triggered over which we have no influence.

The use of YouTube is in the interest of an appealing presentation of our online offers. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR represent. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

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

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every DPF-certified company undertakes to comply with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active

4.9 Google Fonts

This site uses so-called Google Fonts, which are provided by Google, for the uniform display of fonts. When you call up a page, your browser loads the required fonts into your browser cache in order to display texts and fonts correctly.

For this purpose, the browser you are using must connect to Google’s servers. This gives Google knowledge that this website has been accessed via your IP address. The use of Google Fonts is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the uniform presentation of the typeface on its website. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

If your browser does not support Google Fonts, a standard font will be used by your computer.

Further information about Google Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=de.

4.10 OpenStreetMap

We use the OpenStreetMap (OSM) map service.

We integrate the map material from OpenStreetMap on the server of the OpenStreetMap Foundation, St John’s Innovation Center, Cowley Road, Cambridge, CB4 0WS, United Kingdom. The UK is considered a safe third country under data protection law. This means that the UK has a level of data protection that corresponds to the level of data protection in the European Union. When using the OpenStreetMap maps, a connection is established to the servers of the OpenStreetMap Foundation. Among other things, your IP address and other information about your behavior on this website may be forwarded to the OSMF. OpenStreetMap may store cookies in your browser or use comparable recognition technologies for this purpose.

The use of OpenStreetMap is in the interest of an appealing presentation of our online offers and an easy findability of the places indicated by us on the website. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR represent. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

4.11 Wordfence

We have integrated Wordfence on this website. The provider is Defiant Inc, Defiant, Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter “Wordfence”).

Wordfence is used to protect our website from unwanted access or malicious cyberattacks. For this purpose, our website establishes a permanent connection to the Wordfence servers so that Wordfence can compare its databases with the accesses made on our website and block them if necessary.

The use of Wordfence is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its website as effectively as possible against cyberattacks. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://www.wordfence.com/help/general-data-protection-regulation/.

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract prescribed by data protection law, which ensures that the personal data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.

4.12 Contact form

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

This data is processed on the basis of Art. 6 para. 1 lit. b GDPR, provided that your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; the consent can be revoked at any time.

We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Mandatory statutory provisions – in particular retention periods – remain unaffected.

4.13 Newsletter

The data entered in the newsletter registration form is processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You can revoke your consent to the storage of the data, the e-mail address and its use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.

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

Data stored by us for other purposes remains unaffected by this.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist if this is necessary to prevent future mailings. The data from the blacklist is only used for this purpose and is not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

4.14 Analysis tool – Matomo

This website uses the open source web analysis service Matomo.

With the help of Matomo, we are able to collect and analyze data about the use of our website by website visitors. This allows us to find out, among other things, when which pages were accessed and from which region. We also record various log files (e.g. IP address, referrer, browser and operating system used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).

The use of this analysis tool is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TDDDG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

IP anonymization

We use IP anonymization for the analysis with Matomo. Your IP address is shortened before the analysis so that it can no longer be clearly assigned to you.

Cookieless analysis

We have configured Matomo so that Matomo does not store any cookies in your browser.

Hosting

We host Matomo exclusively on our own servers, so that all analysis data remains with us and is not passed on

5 Data processing as part of the application process

We offer you the opportunity to apply to us via the following channels:

by e-mail to bewerbungen(at)dirostahl.de
by post
our recruiting page

Below we inform you about the scope, purpose and use of your personal data collected as part of the application process. We assure you that your data will be collected, processed and used in accordance with applicable data protection law and all other statutory provisions and that your data will be treated in strict confidence.

We use the applicant management software from BITE GmbH, a company based in Germany that offers and operates applicant management software(https://www.b-ite.de/impressum.html).

The data transmitted as part of your application will be transferred using TLS encryption and stored in a database. The company that carries out this online application process is solely responsible for this data within the meaning of Art. 24 GDPR. BITE is the operator of the software and our recruiting site and, in this context, a processor pursuant to Art. 28 GDPR. The basis for processing by BITE is an order processing contract between us, the controller, and BITE. In addition, BITE GmbH processes further data, some of which may also be personal data, in order to provide its services, in particular for the operation of the recruiting site. All information on the scope and purpose of data collection and the retention period for the data can be found in the data protection information in the application form. We assure you that your data will be treated in strict confidence.

An incorrect application, e.g. by e-mail, may be processed, but we cannot guarantee that the documents will actually be deleted in full within the deadline.

In order to ensure a data protection-compliant application process, we therefore ask you to always apply via our recruiting page.

5.1 Scope and purpose of data collection

If you send us an application, we process your associated personal data (e.g. contact and communication data, application documents, notes taken during interviews, etc.) insofar as this is necessary for the decision on the establishment of an employment relationship. The legal basis for this is Art. 6 para. 1 lit. b GDPR (general contract initiation) in conjunction with Section 26 BDSG under German law (initiation of an employment relationship) and – if you have given your consent – Art. 6 para. 1 lit. a GDPR. Consent can be revoked at any time for the future. Your personal data will only be passed on within our company to persons who are involved in processing your application.

If the application is successful, the data submitted by you will be processed on the basis of Art. 6 para. 1 lit. b GDPR and Section 26 BDSG for the purpose of implementing the employment relationship in our data processing systems.

5.2 Online application interviews

As part of the application process, we offer interested parties the opportunity to conduct interviews via a video conferencing tool. This enables contactless interaction and overcoming geographical distances. The video or audio material is not recorded or stored at any time. Applicants are free to switch off the camera function in advance or during the interview. The applicant can refuse the video interview without giving reasons. In this case, a mutually acceptable alternative is sought.

If a video conferencing tool is used, the transfer of data to a third country (in particular the USA) cannot be ruled out. The legal basis for processing is consent in accordance with Art. Art. 6 para. 1 lit. a GDPR. Consent can be revoked at any time.

5.3 U-form test as part of the trainee application process

As part of the application process for trainees, we carry out a u-form test to assess the suitability of applicants. The legal basis is Art. 6 para. 1 lit. b GDPR (implementation of pre-contractual measures) and Art. 6 para. 1 lit. f GDPR (legitimate interest). The provider of the test is u-form Testsysteme GmbH & Co. KG, Klauberger Straße 1, 42651 Solingen, Germany(https://www.testsysteme.de/impressum).

We process the following personal data:

Name
Contact details
Test results of the u-form test

The data will be stored for the duration of the application process and in accordance with statutory retention obligations.

5.4 Data retention period

If we are unable to make you a job offer, you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR) for up to 6 months from the end of the application process (rejection or withdrawal of the application). The data is then deleted and the physical application documents are destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the use of the data will be necessary after the 6-month period has expired (e.g. due to an impending or pending legal dispute), the data will only be deleted when the purpose for further storage no longer applies.

Data may also be stored for longer if you have given your consent (Art. 6 para. 1 lit. a GDPR) or if statutory retention obligations prevent deletion.

5.5 Inclusion in the applicant pool

If we do not make you a job offer, you may have the opportunity to join our applicant pool. If you are accepted, all documents and details from your application will be transferred to the applicant pool so that you can be contacted in the event of suitable vacancies.

Inclusion in the applicant pool is based exclusively on your express consent (Art. 6 para. 1 lit. a GDPR). The submission of consent is voluntary and is not related to the current application process. The data subject can withdraw their consent at any time. In this case, the data will be deleted from the applicant pool immediately, provided there are no legal grounds for retention.

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

6 Data processing when using our whistleblower system

We offer you the opportunity to use our externally operated internal reporting office via the whistleblower system on our website. We would like to inform you about the possible processing of personal data.

The provider and operator of the whistleblowing system is audatis Services GmbH, a company based in Germany(https://www.audatis-manager.de/impressum/).

The internal reporting office is managed by the service provider Resilien[i]T GmbH. This department receives the information and coordinates further processing after a pre-qualification (e.g. communication with the whistleblower, checking information, carrying out any necessary clarification of the facts, documentation).

6.1 Processors and data controllers

We have concluded an order processing contract (AVV) with the above-mentioned system provider. This regulates and ensures that personal data is only processed in accordance with our instructions and in compliance with the GDPR.

Depending on the type of measures required by the notification, service providers not bound by instructions may be entrusted with the specific implementation of the corresponding clarification. These service providers may include auditors, law firms or tax consultants. In these cases, the service providers act primarily as their own data controllers within the meaning of Art. 4 No. 7 GDPR.

6.2 Scope and purpose of data collection

The purpose of the whistleblower system is to securely and confidentially receive and process reports of (suspected) violations of the law or serious internal rules against our organization, e.g. in the course of professional activities.

The processing of personal data within the framework of the system used is based on the legal basis of the legitimate interest in the detection and prevention of misconduct and the associated prevention of damage and liability risks in accordance with Art. 6 para. 1 lit. f GDPR. Art. 6 para. 1 lit. f GDPR in conjunction with. §§ Sections 30, 130 OWiG. Furthermore, the Whistleblower Directive (EU) 2019/1937 and the national HinSchG, which came into force on July 2, 2023, require implementation in companies on the legal basis of Art. 6 para. 1 lit. c GDPR.

6.3 Use of the whistleblower portal

6.3.1 Type of personal data collected

The whistleblower system is used on a voluntary basis. If you submit a report via the whistleblower system, we collect the following personal data and information:

Your name, if you disclose your identity, possibly also your private address, private telephone number, private e-mail address).

whether you are employed by [Organisation] or what your relationship is with our company
if applicable, names of persons and other personal data of the persons you name in your notification.
In individual cases, special categories of personal data within the meaning of Art. 9 para. 1 GDPR, e.g. if the information provided by a whistleblower already contains corresponding data. This category of data is only processed for the purposes specified in Art. 9 para. 2 GDPR, or § 26 para. 3 BDSG and treated with special confidentiality.

6.3.2 Possible recipients of the data

We ensure that personal data is only accessible to a limited number of authorized persons who need this data to perform their tasks, including employees of the Reporting Office and persons who support them in the performance of their tasks. This also includes the named service providers who are subject to separate data protection obligations. In certain cases, there may be an obligation under data protection law to inform the accused person about the allegations made against them. This is required by law if it is objectively established that the provision of information to the accused can no longer affect the concrete clarification of information at all. As far as legally possible, your identity as the whistleblower will not be disclosed and it will also be ensured that no conclusions can be drawn about your identity as the whistleblower.

As a matter of principle, our whistleblower system does not provide for the transfer of data to bodies in countries outside the European Union (so-called third countries). Should such a transfer nevertheless be necessary in individual cases (e.g. due to a reference from a country outside the EU), a transfer will only take place if there is a legal basis and a suitable guarantee (e.g. adequacy decision, standard contractual clauses, express consent).

If there is a corresponding legal obligation or data protection requirement for the disclosure of information, other possible categories of recipients may be considered:

Law enforcement authorities,
Cartel authorities,
other administrative authorities,
Courts, lawyers, auditors

Every person who receives access to the data is or will be obliged to maintain confidentiality.

Confidentiality cannot be guaranteed if false information is knowingly posted with the aim of discrediting a person (denunciation).

6.3.3 Data security

Personal data and information entered into the whistleblower system is encrypted and stored securely with password protection. The whistleblowing system is operated in an ISO27001-certified data center. The data can only be viewed by an authorized group of people who are obliged to maintain confidentiality; other third parties have no access to the data. The security of the process is guaranteed by comprehensive technical and organizational measures.

6.3.4 Retention period of personal data

All incoming reports must be documented in accordance with § 11 HinSchG in compliance with the confidentiality obligations. The documentation will be deleted 3 years after completion of the procedure. Personal data is stored for as long as is necessary for clarification and final assessment or for as long as the company has a legitimate interest or is required by law.

7 Data processing in other cases

7.1 Request by e-mail or telephone

If you contact us by e-mail or telephone, we will store and process your request, including all personal data (name, request), for the purpose of processing your request. We do not pass on this data without your consent.

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

7.2 Data processing in the context of audio and video conferences

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

The conference tools collect all data that you provide/enter to use the tools (e-mail address and/or your telephone number). The conference tools also process the duration of the conference, the start and end (time) of participation in the conference, the number of participants and other “context information” in connection with the communication process (metadata).

Furthermore, the provider of the tool processes all technical data required for the processing of online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

If content is exchanged, uploaded or provided in any other way within the tool, this is also stored on the tool provider’s servers. Such content includes, in particular, cloud recordings, chat/instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared while using the service.

Please note that we do not have full control over the data processing operations of the tools used. Our options depend largely on the company policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection information of the respective tools used, which we have listed below this text.

7.2.1 Purpose and legal basis

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 lit. b GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). If consent has been requested, the tools in question are used on the basis of this consent; consent can be revoked at any time with effect for the future.

7.2.2 Storage period

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

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

7.2.3 Conference tool used – Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Details on data processing can be found in the Microsoft Teams data protection information: https://privacy.microsoft.com/de-de/privacystatement.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every DPF-certified company undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000KzNaAAK&status=Active.

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that the personal data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.

7.3 Video surveillance at our locations

To protect the property of our organization, employees, customers and suppliers as well as to prevent and investigate theft and vandalism, check for material damage, regular functional checks, video surveillance is carried out at our location(s). The storage period is 72 hours. Recordings required for the purpose of preserving evidence are stored for as long as is necessary for legal prosecution.

The records can be viewed by the service provider (processor) during maintenance of the system.

In the context of criminal prosecution, the data may be forwarded to authorities and or lawyers commissioned by us.

The legal basis for video surveillance is Art. 6 para. 1 lit. f) GDPR, whereby our interests arise from the aforementioned purposes. Insofar as special categories of personal data are processed, this is done on the basis of Art. 9 para. 2 lit. f) in conjunction with. Art. 6 para. 1 lit. f) GDPR, our interest lies in improving the protection of the property of the company, customers, suppliers and its employees against burglary, theft, vandalism, to safeguard domiciliary rights and to assert claims against third parties.

7.4 Dispatch of product information

If we provide you with information as part of pre-contractual measures or an existing business relationship, we only process the data that is necessary. These are:

Personal details (first name and surname);
Name of the company;
Contact details (telephone number, e-mail address)

7.5 Sending newsletters to existing customers

If you order goods or services from us and enter your e-mail address, this e-mail address may subsequently be used by us to send you newsletters, provided we inform you of this in advance. In such a case, only direct advertising for our own similar goods or services will be sent via the newsletter. You can unsubscribe from this newsletter at any time. For this purpose, you will find a corresponding link in every newsletter. In this case, the legal basis for sending the newsletter is Art. 6 para. 1 lit. f GDPR in conjunction with § 7 para. 3 UWG.

After you unsubscribe from the newsletter distribution list, we may store your e-mail address in a blacklist to prevent future mailings to you. The data from the blacklist is only used for this purpose and is not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

7.6 Postal advertising

We use your address in compliance with all legal provisions for sending postal advertising (postal advertising).

The legal basis for this is our legitimate interest in direct advertising in accordance with Art. 6 para. 1 lit. f in conjunction with Recital 47 GDPR. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; consent can be revoked at any time. More specific regulations may be communicated to you as part of the data collection process and take precedence over these regulations.

Your address will remain with us until the purpose for data processing no longer applies. If you assert a justified request for deletion or revoke your consent to postal advertising, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion will take place after these reasons no longer apply.

7.7 Christmas and New Year greetings

We may send Christmas/New Year greetings to customers and business partners at the end of the year. Your name and address will be collected and processed in order to send you these.

The processing of the data is based on a business purpose in accordance with Art. 6 para. 1 lit. f GDPR. The controller has a legitimate interest in thanking and promoting the customer and business relationship.

Your data will not be passed on to third parties.

If you do not wish to receive greeting cards from us, you can object to receiving them. You can address your objection to us without giving reasons, as described in the section Data subject rights. Your data will then no longer be used for this purpose.

8 Our social media presence

8.1 Data processing by social networks

We maintain publicly accessible profiles in social networks. The individual social networks we use are listed below.

Social networks can generally analyze your user behavior comprehensively when you visit their website or a website with integrated social media content (e.g. like buttons or advertising banners). Visiting our social media presences triggers numerous data protection-relevant processing operations. In detail:

If you are logged into your social media account and visit our social media presence, the operator of the social media portal can assign this visit to your user account. However, your personal data may also be collected if you are not logged in or do not have an account with the respective social media portal. In this case, this data collection takes place, for example, via cookies that are stored on your end device or by recording your IP address.
With the help of the data collected in this way, the operators of the social media portals can create user profiles in which your preferences and interests are stored. In this way, interest-based advertising can be displayed to you inside and outside the respective social media presence. If you have an account with the respective social network, the interest-based advertising can be displayed on all devices on which you are logged in or were logged in.
Please also note that we cannot track all processing operations on the social media portals. Depending on the provider, further processing operations may therefore be carried out by the operators of the social media portals. For details, please refer to the terms of use and data protection provisions of the respective social media portals.

8.2 Legal basis

Our social media presence is designed to ensure the most comprehensive online presence possible. This is a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. The analysis processes initiated by the social networks may be based on different legal bases, which must be specified by the operators of the social networks (e.g. consent within the meaning of Art. 6 para. 1 lit. a GDPR).

8.3 Responsible party and assertion of rights

If you visit one of our social media sites (e.g. Facebook), we are jointly responsible with the operator of the social media platform for the data processing operations triggered during this visit. You can exercise your rights (information, rectification, erasure, restriction of processing, data portability and complaint) both vis-à-vis the data controller and the data processor. us as well as towards the operator of the respective social media portal (e.g. Facebook).

Please note that, despite the joint responsibility with the social media portal operators, we do not have full influence on the data processing procedures of the social media portals. Our options depend largely on the company policy of the respective provider.

8.4 Storage period

The data collected directly by us via the social media presence will be deleted from our systems as soon as you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Stored cookies remain on your end device until you delete them. Mandatory statutory provisions – in particular retention periods – remain unaffected.

We have no influence on the storage period of your data, which is stored by the operators of the social networks for their own purposes. For details, please contact the operators of the social networks directly (e.g. in their data protection information, see below).

8.5 Social networks in detail

8.5.1 Instagram

We have a profile on Instagram. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

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

Details on how they handle your personal data can be found in Instagram’s privacy policy: https://privacycenter.instagram.com/policy/

8.5.2 LinkedIn

We have a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.

If you wish to deactivate LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs

Details on how they handle your personal data can be found in LinkedIn’s data protection information: https://www.linkedin.com/legal/privacy-policy

8.5.3 YouTube

We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Details on how they handle your personal data can be found in YouTube’s data protection information: https://policies.google.com/privacy?hl=de