This translation of our data privacy statement is a courtesy of Pollux Engineering UG.
It should be used purely for your personal reference. The legally binding version is the original document in German.
This data protection declaration explains to you the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profile (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “person responsible”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Data Privacy Officer
Pollux Engineering UG (limited liability)
Niklas Fiedler
Tannenweg 1
29227 Celle
Types of data processed:
– Inventory data (e.g., names, addresses).
– Contact details (e.g., e-mail, telephone numbers).
– Content data (e.g., text input, photographs, videos).
– Usage data (e.g. websites visited, interest in content, access times).
– Meta / communication data (e.g., device information, IP addresses).
Categories of affected persons
Visitors and users of the online offer (in the following we also refer to the data subjects as “users”).
Purpose of processing
– Make available the online offer, its functions and contents.
– Responding to contact requests and communicating with users.
– Security measures.
– Range measurement/marketing
Terms used
“Personal Data” means any information relating to an identified or identifiable natural person (‘the data subject’); Identifiable is a natural person who can be identified directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.B cookie) or one or more specific characteristics that are an expression of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
“Processing” means any operation or series of operations carried out with or without the help of automated procedures in connection with personal data. The term goes far and covers virtually every use of data.
‘pseudonymisation’ means the processing of personal data in such a way that the personal data can no longer be assigned 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 organisational measures to ensure that the personal data are not assigned to an identified or identifiable natural person.
‘profiling’ means any form of automated processing of personal data, which consists in the use of such personal data to assess certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to work performance, economic situation, health, personal preferences, interests, reliability, behaviour, whereabouts or relocation of that natural person.
‘Responsible person’ means the natural or legal person, authority, body or other body which decides, alone or jointly with others, on the purposes and means of the processing of personal data.
‘processor’ means a natural or legal person, authority, body or other body which processes personal data on behalf of the controller.
Relevant legal basis
In accordance with Article 13 GDPR, we shall inform you of the legal bases of our data processing operations. Unless the legal basis is mentioned in the data protection declaration, the legal basis for obtaining consents is Art. 6 sec. 1 lit. a and Art. 7 GDPR, the legal basis for processing to fulfill our services and to carry out contractual measures as well as answering requests is Art. 6(1) lit.b GDPR, the legal basis for processing in order to fulfil our legal obligations is Art.c. , and the legal basis for processing in order to safeguard our legitimate interests is Art. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 sec. 1 lit. d GDPR serves as the legal basis.
Security
In accordance with Article 32 GDPR, we take appropriate technical and organisational measures to ensure a level of protection compassionate to ensure a level of protection complacency compassionate, taking into account the state of the art, the costs of implementation and the nature, the circumstances and purposes of the processing, as well as the different probability and severity of the risk to the rights and freedoms of natural persons.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, disclosure, security of availability and separation. In addition, we have established procedures that ensure the exercise of data subjects’ rights, deletion of data and response to compromise of the data. Furthermore, we take into account the protection of personal data already during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technical design and through data protection-friendly presets (Art. 25 GDPR).
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit them to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e.B. if a transfer of the data to third parties, such as to payment service providers, in accordance with Art. 6 sec. 1 lit.b GDPR is required for the fulfilment of the contract), you have consented to this only on the basis of a legal permission (e.B. , provides for a legal obligation or on the basis of our legitimate interests (e.B. in the use of agents, web hosts, etc.).
If we entrust third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Article 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if we do so in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only be done if it is done in order to fulfil our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual authorisations, we process or have the data processed in a third country only if the special conditions of Art. 44 e.g. GDPR are met. This means that the processing is carried out .B on the basis of special guarantees, such as the officially recognised determination of an EU-compliant level of data protection (e.B. for the US through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of data subjects
You have the right to request confirmation as to whether the data in question is being processed and for information on such data as well as for further information and copy of the data in accordance with Article 15 GDPR.
They have accordingly. Article 16 GDPR the right to request the completion of the data concerning you or the correction of the inaccurate data concerning you.
In accordance with Article 17 GDPR, you have the right to request that the data in question be deleted immediately or, alternatively, to require a restriction on the processing of the data in accordance with Article 18 GDPR.
You have the right to request that the data concerning you, which you have provided to us, be received in accordance with Article 20 GDPR and request its transmission to other controllers.
They also have the right to lodge a complaint with the competent supervisory authority in accordance with Article 77 GDPR.
Withdrawal
You have the right to revoke consents given in accordance with Art. 7 sec. 3 GDPR with effect for the future
Right to object
You may object at any time to the future processing of the data concerning you in accordance with Article 21 GDPR. The opposition may be made in particular against the processing for direct marketing purposes.
Cookies and right of objection in the case of direct marketing
“Cookies” means small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or.dem device on which the cookie is stored) during or after his visit within an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes their browser. In such a cookie, for example.B the contents of a shopping cart can be stored in an online shop or a login status. Cookies are called “permanent” or “persistent” and remain stored even after the browser is closed. For example.B the login status can be saved if the users visit them after several days. Similarly, such a cookie may store the interests of users who are used for range measurement or marketing purposes. “Third-party cookie” means cookies that are offered by providers other than the person responsible for the online offer (otherwise, if it is only its cookies, it is called “first-party cookies”).
We may use temporary and permanent cookies and clarify this within the scope of our data protection declaration.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional limitations of this online offer.
A general objection to the use of cookies used for online marketing purposes can be explained by a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all functions of this online offer can be used.
Deletion of data
The data processed by us will be deleted or restricted in their processing in accordance with Articles 17 and 18 GDPR. Unless expressly stated in the context of this data protection declaration, the data stored by us will be deleted as soon as they are no longer necessary for their purpose and the deletion is not precluded by legal retention obligations. Unless the data is deleted because it is necessary for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example.B to data that must be retained for commercial or tax reasons.
According to legal requirements in Germany, the retention is carried out in particular for 10 years in accordance with Sections 147 (1) AO, 257 (1) No. 1 and 4, paragraph 4 of the German Commercial Code (Books, Records, Management Reports, Accounting Documents, Commercial Books, relevant documents, etc.) and 6 years in accordance with Sections 257 (1) No. 2 and 3, paragraph 4 of the German Commercial Code (HGB).
According to legal requirements in Austria, the storage is carried out in particular for 7 J in accordance with Section 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with land and for 10 years in the case of documents relating to electronically supplied services, telecommunications, radio and television services provided to non-entrepreneurs in EU Member States for which the Mini-One Stop-Shop (MOSS) is used.
Business-related processing
In addition, we
process contract data (e..B. , subject matter of the contract, term, customer category).
– Payment data (e..B, bank
details, payment history) from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Agency services
We process the data of our customers within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.
We process inventory data (e..B., customer master data, such as names or addresses), contact data (e..B, e-mail, telephone numbers), content data (e.B., text entries, photographs, videos), contract data (e..B., contract subject matter, term), payment data (e..B, bank details, payment history), usage and metadata (e.B. In principle, we do not process special categories of personal data, unless these are components of commissioned processing. Those affected include our customers, interested parties as well as their customers, users, website visitors or employees as well as third parties. The purpose of the processing is to provide contractual services, billing and our customer service. The legal bases of the processing are derived from Article 6 (1) lit.b GDPR (contractual services), Article 6 (1) lit. f GDPR (analysis, statistics, optimisation, security measures). We process data that is necessary for the establishment and performance of the contractual services and point out the necessity of their specification. Disclosure to external parties is only made if it is required as part of an order. When processing the data provided to us in the context of an order, we act in accordance with the instructions of the clients as well as the legal requirements of order processing in accordance with Art. 28 GDPR and do not process the data for any purpose other than the purposes specified in the order.
We delete the data after expiry of legal warranty and comparable obligations. the need to retain the data is reviewed every three years; in the case of the statutory archiving obligations, the deletion shall take place after their expiry (6 J, in accordance with Section 257 (1) of the German Commercial Code ( HGB, 10 J), in accordance with Section 147 (1) AO). In the case of data disclosed to us in the context of an order by the client, we delete the data in accordance with the specifications of the order, basically after the end of the order.
Administration, Financial Accounting, Office Organization, Contact Management
We process data in the context of administrative tasks as well as the organisation of our operations, financial accounting and compliance with legal obligations, such as .B of archiving. In doing so, we process the same data that we process in the context of the provision of our contractual services. The basis for processing is Art. 6 sec. 1 lit.c. GDPR, Art. 6 sec. 1 lit. f. GDPR. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and the provision of our services. The erasure of the data with regard to contractual services and contractual communication corresponds to the information referred to in these processing activities.
We disclose or transmit data to the tax administration, consultants, such as .B, tax advisors or auditors, as well as other fee agencies and payment service providers.
Furthermore, on the basis of our business interests, we store information about suppliers, organizers and other business partners, e.B. for the purpose of contacting them later. We store this majority company-related data permanently.
Business analysis and market research
In order to be able to operate our business economically, to be able to recognize market trends, wishes of the contractual partners and users, we analyze the data available to us on business transactions, contracts, enquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata based on Art. 6 sec. 1 lit. f. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we can take into account the profiles of registered users with information, e.B. about the services used. The analyses serve us to increase user-friendliness, optimize our offer and business efficiency. The analyses are for us alone and are not disclosed externally, unless they are anonymous analyses with summarized values.
If these analyses or profiles are personal, they will be deleted or anonymized upon termination of the users, otherwise after two years from the conclusion of the contract. In addition, the macroeconomic analyses and general trends are, where possible, compiled anonymously.
Akismet Anti-Spam Check
Our online offer uses the “Akismet” service offered by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. The use is based on our legitimate interests within the meaning of Art. 6 sec. 1 lit. f) GDPR. This service distinguishes comments from real people from spam comments. For this purpose, all comment information is sent to a server in the USA, where it is analyzed and stored for comparison purposes for four days. If a comment has been classified as spam, the data will be stored beyond this time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information about the browser used as well as the computer system and the time of the entry.
Further information on the collection and use of the data by Akismet can be found in the data protection notices of Automattic: https://automattic.com/privacy/.
Users can use pseudonyms or refrain from entering their name or email address. You can completely prevent the transfer of data by not using our comment system. That would be a pity, but unfortunately we do not see alternatives that work just as effectively.
Contact
When contacting us (e.B. via contact form, e-mail, telephone or via social media) the user’s details for processing the contact request and its processing in accordance with Art. 6 sec. 1 lit.b) GDPR will be processed. Users’ information can be stored in a customer relationship management system (“CRM system”) or similar request organization.
We will delete the requests if they are no longer required. We review the necessity every two years; In addition, the statutory archiving obligations apply.
Hosting and e-mailing
The hosting services we use are intended to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e-mail, security and technical maintenance services that we use for the purpose of operating this online offer.
In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 sec. 1 lit. f GDPR i.V.m. Art. 28 GDPR (contract processing contract).
Collection of access data and log files
We, or our hosting provider, collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 sec. 1 lit. f. GDPR. The access data includes the name of the retrieved website, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Logfile information is stored for security reasons (e..B. to investigate abuse or fraud) for a maximum period of 7 days and then deleted. Data, the further retention of which is necessary for the purpose of proof, is excluded from deletion until the relevant incident is finally clarified.
Google Analytics
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 sec. 1 lit. f. GDPR) we use Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and the internet usage. Pseudonymous user profiles of the users can be created from the processed data.
We only use Google Analytics with IP anonymization enabled. This means that the IP address of the users is truncated by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.
The IP address transmitted by the user’s browser will not be merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
For more information about Google’s use of data, settings and objections, see Google’s privacy policy (https://policies.google.com/technologies/ads) and the settings for google’sdisplay of advertisements (https://adssettings.google.com/authenticated ).
The personal data of the users will be deleted or anonymized after 14 months.
Jetpack (WordPress Stats)
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 sec. 1 lit. f. GDPR), we use the plugin Jetpack (here the subfunction “WordPress Stats”), which includes a tool for statistical evaluation of visitor access and from Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack uses so-called “cookies”, text files that are stored on your computer and which enable an analysis of your use of the website.
The information generated by the cookie about your use of this online offer is stored on a server in the USA. User profiles of the users can be created from the processed data, whereby these are only used for analysis purposes and not for advertising purposes. For more information, see Automattic’s privacy policy: https://automattic.com/privacy/ and notes on jetpack cookies: https://jetpack.com/support/cookies/.
Integration of third-party services and content
Within our online offer, we use third-party content or service offerings based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 sec. 1 lit. f. GDPR) content or service offerings from third parties in order to integrate their content and services, such as .B videos or fonts (hereinafter uniformly referred to as “Content”).
This always presupposes that the third parties to this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We make every effort to use only those content whose respective providers use the IP address only for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, among other things, technical information about the browser and operating system, referring websites, visiting time and other information on the use of our online offer, as well as being linked to such information from other sources.
Google ReCaptcha
We include the bot detection feature, e..B. when entering online forms (“ReCaptcha”) from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Google Maps
We include the maps of the Google Maps service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include in particular IP addresses and location data of the users, which are not collected without their consent (usually carried out within the framework of the settings of their mobile devices). The data can be processed in the United States. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.