The term “personal data” means information that refers to an identified or identifiable person. This includes all details that allow the deduction of your identity, like for instance your name, telephone number, address or e-mail address.
The term “personal data” does not include statistical data that, for instance, we collect when you visit our website and that cannot be associated with you personally.
1. DATA CONTACT PARTNER AND CONTROLLER
The contact partner and so-called “controller” for the processing of your personal data in the meaning of the EU General Data Protection Regulation (GDPR) when visiting this website is Clarity.
If you have any questions regarding the use of the website and the assertion of your rights against Clarity, please contact: firstname.lastname@example.org.
For any data protection-related concerns please use the above mail address with the addition of “attn. data protection representative”.
2. PROVISION OF THE WEBSITE AND GENERATION OF LOG FILES
We collect data each time our website is used. Your browser automatically transmits this data to enable your visit to our website. In particular, the
- IP address of the requesting device;
- Date and time of the request;
- Address of the last visited and referring website;
- Technical information about the browser and operating system used by the device.
Data processing is necessary to enable your visit to the website and to guarantee permanent functionality and security of our systems. In addition to the purposes described above, the aforementioned data is also stored for temporary periods in internal log files in order to prepare statistical information about the use of our website and to enhance our website to reflect visitor habits (e.g., if there is a rise in the proportion of page views using mobile devices) and to administrate our website in general. The legal grounds for this form of data processing are set out in Art. 6, paragraph 1, sentence 1, point f, of the GDPR.
The information stored in the log files does not allow us to make any direct deductions as to identifiable persons. In particular, we only store IP addresses in a truncated form. The log files are stored for 30 days and then erased.
You have a variety of options to make contact with us (e.g., by email, contact form or telephone). In this circumstance, we process your contact data exclusively for the purpose of communicating with you. Communication with you is not possible without this data. The legal grounds for this form of processing are set out in Art. 6, paragraph 1, sentence 1, point b, of the GDPR.
4. NEWSLETTER AND ADVERTISING MAILS
You have the option to sign up for our newsletter in which we will inform you regularly about digital marketing news and our special offers. We use the double opt-in procedure for signing up for our newsletter; this means we will not send you our newsletter by email until you have confirmed that you wish to receive it by clicking on a link in our activation email. To do this, we store your email address, the time of registration and the IP address used for said registration (“newsletter registration”) until such time as you unsubscribe to our newsletter. The exclusive purpose of this storage is to send you the newsletter and to provide evidence of your registration. The legal grounds for this form of processing are set out in Art. 6, paragraph 1, point a, of the GDPR
In addition, we may send you advertising mails in which we request your feedback on orders, services and other information. The legal grounds for this form of processing are set out in Art. 6, paragraph 1, point f, of the GDPR.
In order to send you our newsletter and advertising mails, we collaborate with service providers to which we transfer your e-mail address and your newsletter registration, among other things, in order to be able to send you the above mentioned newsletter and advertising mails. The legal grounds for this form of processing are set out in Art. 6, paragraph 1, sentence 1, point b, f, of the GDPR.
You are entitled to unsubscribe to our newsletter and advertising mails at any time and without charge, or to object to receiving them. A corresponding unsubscribe link is contained in each newsletter and advertising mail. Alternatively, you may contact us at any time.
In our newsletters and advertising mails, we use industry-standard technologies that enable us to measure your interaction with the newsletter (e.g., opening the email, links that you click on). We use this data to optimise and develop our content and customer communication and to be able to send you individualised offers. Among the technologies used for this purpose are small graphic elements embedded in the messages (so-called pixels). We are able to associate the data and IDs with your personal data. The legal grounds for this are set out in the requirement for legitimate interest according to Art. 6, paragraph 1, sentence 1, point f, of the GDPR. If you do not wish us to analyse your usage habits, you are entitled at any time to unsubscribe to our newsletter and advertising mails without charge.
5. FACEBOOK BUSINESS PAGE
We operate a Facebook business page in joint responsibility on the social network by Facebook Inc., 1601 Willow Road, Menlo Park, California, 94025, USA (“Facebook”), in order to communicate with interested people and followers there, as well as to provide information about our products and services.
In this context, we may receive statistics from Facebook on the use of our business page by Facebook or its users, e.g. data about likes, comments or summarised information and statistics (e.g. about the age or locations of our followers) that help us to learn more about the interaction on our page. To learn more about the type and scope of these statistics, visit the Facebook page statistics information, and the Facebook page insight supplement for information about the respective controller. The legal grounds for this data processing are set out in Art. 6, paragraph 1, sentence 1, point b, of the GDPR, as well as in its Art. 6, paragraph 1, sentence 1, point f, based on our legitimate interest as stated above.
We are unable to influence the data processed by Facebook on its own responsibility and based on the Facebook terms and conditions of use. Please be aware that data about your usage habits on Facebook and on the business page is transferred to the Facebook servers when you visit the page. Facebook uses the aforementioned information to compile detailed statistics and for its own market research and advertising purposes, over which we have no influence. For further information, please refer to the Facebook privacy policies. Facebook is subject to the terms of the EU-US Privacy Shield whenever that personal data is transferred to the United States.
6. COOKIES AND EQUIVALENT TECHNOLOGIES
In their standard settings, most browsers will accept cookies. However, you can adjust the browser settings to reject cookies, or only to accept cookies with your prior consent. You will not be able to use the full functionality of our website if you reject cookies.
6.1. PROPRIETARY COOKIES FOR A CONVENIENT USER EXPERIENCE
Amongst other things, we use persistent cookies to remember that information shown on our website was displayed to you, in order that we may display it to you again when you return to our website. Persistent cookies are automatically deleted after a set period that may differ individually for each cookie.
These services enable you to enjoy a convenient and individual use of our offerings and are based on our legitimate interests. The legal grounds for this form of processing are set out in Art. 6, paragraph 1, sentence 1, point f, of the GDPR.
6.2. COOKIES AND EQUIVALENT TECHNOLOGIES BY THIRD-PARTY PROVIDERS FOR ANALYSIS AND MARKETING PURPOSES
We use a variety of technologies to analyse usage behaviour and evaluate the associated data, in order to improve our website. In particular, the collected data may include the IP address of the device, the date and time of the access, the cookie identifier, the device identifier for mobile devices, as well as technical data about the browser and operating system.
This data is processed for marketing purposes, like for instance to display individualised advertising messages. The legal grounds for this form of processing are set out in Art. 6, paragraph 1, sentence 1, point f, of the GDPR. In the section below, we will describe these technologies and the providers used in this context.
Where you do not wish to receive interest-based advertising banners, you can object to their use by making appropriate settings on http://preferences-mgr.truste.com a website that provides grouped objection options in regard to advertisers. The website by TRUSTe, Inc, 835 Market Street, San Francisco, CA 94103-1905, USA (“TRUSTe”) uses opt-out cookies to allow you to disable all banners at once, or alternatively to adjust the settings for each provider individually. Please take note that you must again place an opt-out cookie after deleting all cookies in your browser, or if you use a different browser or profile.
6.2.1. GOOGLE ANALYTICS, ADS CONVERSION TRACKING AND REMARKETING
Our website uses Google Analytics, a web analysis service by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (“Google“). In addition, our website uses Google Ads and Google Tag Manager conversion tracking, Ads remarketing and Google Signals, which are also services by Google.
The data collected in this context may be transferred by Google to a server in the United States and stored there. Whenever that personal data is transferred to the United States, Google has agreed to the conditions of the EU-US Privacy Shield.
Google will truncate your IP address before analysis of the usage statistics, which means that conclusions cannot be drawn as to your identity. For this purpose, the code “anonymizeIP” has been added to Google Analytics on our website to guarantee collection of anonymised IP addresses.
On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing the website operator with other services relating to website and Internet use.
The Google Ads conversion tracking cookies ordinarily remain enabled on your computer for around 30 days. If you visit our website during this period, both Google and we will be informed that you saw the displayed advertisement.
In case you use a Google account, Google can, depending on the settings stored in your Google account, associate your Internet and browser cache with your Google account and use information from your Google account to personalise advertisements. You must sign out of your Google account before visiting our website if you do not want this association made with your Google account.
If you have enabled personalised advertising in your Google account, Google will be able to prepare data models and reports on website habits, which show, for instance, on which device you first clicked on an advertisement and on which device any eventual purchase took place. These data models and reports are based on random samples and are pseudonymised to ensure anonymity, which means that we are unable to draw any conclusions as to the identities of the individual Google users.
As described earlier, you can adjust your browser settings to reject cookies, or you can prevent the collection of the data generated by the cookies in regards to your use of the website (including your IP address) and its processing by Google, by downloading and installing the browser add-on provided by Google. As an alternative to the browser add-on, or if you are using a mobile device to access our website, you can use this opt-out link. Doing so will prevent the collection of data by Google Analytics on this website, effective for the future (the opt-out will only work for the current browser, and only for this domain). You must click on the link once more if you delete cookies in your browser.
6.2.2. FACEBOOK PIXEL
In addition, our website uses remarketing tabs for marketing purposes (also known as “Facebook Pixel”) by Facebook Inc., 1601 Willow Road, Menlo Park, California 94025, USA (“Facebook”). This tag establishes a connection between your browser and a Facebook server when you visit our website. Facebook therefore receives information that you have accessed our website with your IP address.
Whenever that personal data is transferred to the United States, Facebook has agreed to the conditions of the EU-US Privacy Shield Facebook uses this information to send a statistical and anonymous data about the general use of our website, as well as on the efficiency of our Facebook advertising (“Facebook Ads”).
If you are a member of Facebook and have made the appropriate privacy settings on your Facebook account, Facebook will also be able to associate the information stored with us about your visit with your personal account, which it can use for the targeted display of Facebook Ads.
You can access and change the Privacy Settings for your Facebook profile at any time. If you are not a member of Facebook, you may prevent Facebook from processing your data by clicking on the disable button for “Facebook” on the aforementioned TRUSTe website. Moreover, you can prevent data processing by clicking on the following button. Doing so will prevent the collection of data by Facebook on this website, effective for the future (the opt-out will only work for the current browser, and only for this domain)
7. APPLICATION PROCESS
When you apply for a vacant position with us, we use your applicant data exclusively to manage the application procedure. The legal grounds for your data processing are set forth in Art. 6, paragraph 1, point b, of the GDPR.
We store your personal data when we receive your application. When we accept your application, we store your applicant data for three years at maximum after the end of the working relationship. When we reject your application, we store your applicant data for six months after rejection of your application at maximum, except if you grant your consent for a longer period of storage by us.
We cooperate with recruitment service providers in the management of our application procedures. The legal grounds for this form of processing are set out in Art. 6, paragraph 1, sentence 1, point b, f, of the GDPR.
8. INCLUSION OF SERVICES AND CONTENT FROM THIRD PARTIES
It is possible that content by third parties, for instance videos by YouTube, cartographic material by Google Maps, RSS feeds or graphics from other websites are embedded in our website. This is only possible if the providers of these contents (“third-party providers”) are aware of your IP address, as without it they would not be able to send content to your browser. The IP address is therefore necessary for the presentation of this content. The legal grounds for this form of processing are set out in Art. 6, paragraph 1, point b, f, of the GDPR.
We make efforts to include only content from providers that use the IP address exclusively to deliver content. Notwithstanding, we have no influence insofar as to the third-party provider uses the IP addresses for statistical or other purposes.
8.1. INTEGRATION OF YOUTUBE VIDEOS
We have integrated YouTube videos in our website that are stored on YouTube and are directly playable from our website. YouTube is a multimedia service by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (“Google“). Whenever that personal data is transferred to the United Sates, Google and its subsidiary YouTube have agreed to the terms of the EU-US Privacy Shield. The legal grounds are as set out in Art. 6, paragraph 1, sentence 1, point f, of the GDPR, and are defined by our legitimate interest in the integration of video and image content.
When you visit our website, YouTube receives the information that you have accessed the corresponding sub-page of our website. This occurs regardless of whether or not you are logged onto a Google or YouTube account. YouTube and Google use data for the purposes of advertising, market research and needs-based design of their websites. If you access YouTube on our website while logged into your YouTube or Google profile, YouTube and Google will be able to associate this event with your personal profile. If you do not want this association to take place, it is necessary that you log out of your YouTube and Google account before visiting our website.
As described above, you can adjust your browser settings in such a way that it rejects cookies, or you can prevent the registration of data generated by the cookies about your use of this website, as well as the processing of this data by Google, by disabling the button “Personalised ads on the web” in the Google settings for advertising. In this case, Google will only show you non-personalised advertising.
For further information, refer to the Google privacy policies, which also apply to YouTube.
9. RECIPIENTS OF PERSONAL DATA
The data we collect will only be transferred when this is necessary for the performance of a contract, to ensure the technical functionality of the website, or where other legal grounds apply to the transfer of data (e.g., when we are required by law to disclose data (disclosure of information to criminal investigation agencies and courts; disclosure of information to public sector agencies that receive data based on statutory provisions, e.g. social insurance agencies, tax offices and suchlike), or when we are required, for the exercise of our claims, to commission the services of third parties who are professionally bound to duties of confidentiality).
Some of the data processing can be executed by service providers. In particular, they may include data centres that host our website and databases, IT service providers that maintain our system, logistics and transport service providers or marketing and customer service providers, as well as consulting companies. When we transfer data to service providers, they shall be entitled to use the data exclusively for the performance of their tasks. We carefully selected and commission the third parties. They are contractually bound to adhere to our instructions, obliged to maintain confidentiality, have the appropriate technical and organisational measures in place to protect the rights of the individuals concerned, and are checked by us on a regular basis.
10. DURATION OF STORAGE
As a general rule, we only store your personal data for as long as it is necessary for the satisfaction of our contractual or lawful obligations for which we collected the data, after which time we will erase the data without undue delay, except when we require the data until the end of the statutory period of limitations for the purposes of evidence in civil law claims or based on statutory retention periods.
For example, we are required for evidential purposes to store contractual data for a period of three years from the end of the year in which the contractual relationship with you is terminated, as any claims will only lapse after this period at the earliest based on the regular limitation periods.
11. YOUR RIGHTS
You have the right at any time to information about your personal data that is processed by us. In this context, we will explain to you the purpose of data processing and provide an overview of the personal data stored about you.
When the data we have stored is incorrect or no longer up-to-date, you have the right to obtain rectification of this data.
You are also entitled to demand the erasure of your data. When the erasure is not possible in exceptional cases due to another legal provision, the data will be blocked to ensure that it is only available for its lawful purpose.
In addition, you have the right to restrict the processing of your data, for instance if you doubt the accuracy of the data.
You have the right to data portability, which means that we will, upon your request to do so, send you a copy of the personal data provided by you.
When data processing is based on the legal grounds set out in Art.6, paragraph 1, point f, of the GDPR, you may also object where reasons apply that relate to your particular circumstances or where you are objecting to processing for reasons of direct marketing. In the latter case, your right to object shall always be valid and it will be implemented by us, even if you do not provide reasons. Moreover, you have the right at any time to withdraw consent previously granted to us. In this case, we will no longer process the data based on your consent, effective for the future. Withdrawal of consent does not affect the lawfulness of processing conducted until such time as consent is withdrawn.
You may use the contact data provided above to correspond with us and exercise your rights, as described, at any time.
You are also entitled to file a formal complaint with the National Commission for Data Protection (Comissão Nacional de Proteção de Dados – CNPD).
12. DATA SECURITY
We maintain up-to-date technical measures to guarantee data security, in particular the protection of your personal data against risks associated with data transfer or unauthorised access by third parties. These technical measures are adapted to remain up-to-date. For the protection of the personal data input by you on this website, we use the Secure Sockets Layer (SSL) standard, which encrypts the information you enter.
Our website uses Google reCAPTCHA, a service by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. reCAPTCHA prevents automated software (so-called bots) from executing improper activities on the website, i.e. it checks whether entries are actually made by a human.
In addition, Google imports the cookies by other services like Gmail, Search and Analytics. You must sign out from Google if you do not want these associations with your Google account to be made.
This data is transferred to Google in an encrypted form. Google’s evaluation decides on how the Captcha is shown on the page. Whenever personal data is transferred to the United States, Google has agreed to the terms of the EU-US Privacy Shield.
For more information, refer to the Google privacy policies.