Use of the mailing service provider “MailChimp”

The newsletter is sent using “MailChimp“, a newsletter distribution platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.

The email addresses of our newsletter recipients, as well as their other data described in this notice, are stored on MailChimp’s servers in the USA. MailChimp uses this information to send and analyze the newsletter on our behalf. Furthermore, MailChimp may, according to its own information, use this data to optimize or improve its own services, e.g. for the technical optimization of the dispatch and presentation of the newsletter or for economic purposes in order to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them itself or pass the data on to third parties.

We trust in the reliability and IT and data security of MailChimp. MailChimp is certified under the US-EU data protection agreement “Privacy Shield” and thus undertakes to comply with EU data protection regulations. Furthermore, we have concluded a “Data Processing Agreement” with MailChimp. This is a contract in which MailChimp undertakes to protect the data of our users, to process it on our behalf in accordance with its data protection regulations and, in particular, not to pass it on to third parties. You can view MailChimp’s privacy policy here.

There are cases in which we direct newsletter recipients to the MailChimp website. For example, our newsletters contain a link that newsletter recipients can use to retrieve the newsletter online (e.g. in the event of display problems in the email program). Newsletter recipients can also correct their data, such as their email address, at a later date. MailChimp’s privacy policy is also only available on their website.

In this context, we would like to point out that cookies are used on MailChimp’s websites and that personal data is therefore processed by MailChimp, its partners and service providers (e.g. Google Analytics). We have no influence on this data collection. Further information can be found in MailChimp’s privacy policy. We would also like to draw your attention to the options for objecting to the collection of data for advertising purposes on the websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/ (for the European area).

You can unsubscribe from our newsletter at any time, i.e. revoke your consent. Your consent to the sending of the newsletter via MailChimp and the statistical analyses will expire at the same time. Unfortunately, it is not possible to cancel the sending of the newsletter via MailChimp or the statistical analysis separately. You will find a link to unsubscribe from the newsletter at the end of each newsletter.

6. newsletter tracking

The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the MailChimp server when the newsletter is opened. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval, is initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times.

The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of MailChimp to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The website of the Deutsches Institut für Compliance e.V. contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purposes of processing or contacting the data subject. This personal data is not passed on to third parties.

8 Routine deletion and blocking of personal data

The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose no longer applies or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data will be routinely blocked or deleted in accordance with the statutory provisions.

9 Rights of the data subject

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

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

• the purposes of processing
• the categories of personal data that are processed
• the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations
• where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
• the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing
• the existence of a right to lodge a complaint with a supervisory authority
• if the personal data is not collected from the data subject: All available information about the origin of the data
• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has a right to information as to whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards in connection with the transfer.

If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the controller.

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to demand the immediate correction of incorrect personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, including by means of a supplementary declaration, taking into account the purposes of the processing.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary

• The personal data was collected or otherwise processed for purposes for which it is no longer necessary.
• The data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
• The data subject objects to the processing pursuant to Art. 21 (1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21 (2) GDPR.
• The personal data was processed unlawfully.
• The deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.
• The personal data was collected in relation to information society services offered in accordance with Art. 8 para. 1 GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the Deutsches Institut für Compliance e.V., he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of Deutsches Institut für Compliance e.V. or another employee shall promptly ensure that the erasure request is complied with immediately.

If the personal data have been made public by the Deutsches Institut für Compliance e.V. and if our company is obliged to erase the personal data as controller pursuant to Article 17(1) of the GDPR, the Deutsches Institut für Compliance e.V. shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data. shall take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other data controllers who process the published personal data that the data subject has requested the deletion of all links to this personal data or of copies or replications of this personal data from these other data controllers, insofar as the processing is not necessary. The Data Protection Officer of Deutsches Institut für Compliance e.V. or another employee will arrange the necessary measures in individual cases.

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
• The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
• The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Deutsches Institut für Compliance e.V., he or she may at any time contact our Data Protection Officer or another employee of the controller. The Data Protection Officer of the Deutsches Institut für Compliance e.V. or another employee will arrange the restriction of the processing.

Any person affected by the processing of personal data has the right, granted by the European legislator, to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format. He or she also has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR or on a contract pursuant to point (b) of Article 6(1) of the GDPR and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising their right to data portability pursuant to Art. 20 (1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by the Deutsches Institut für Compliance e.V. or another employee.

Any person affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

The Deutsches Institut für Compliance e.V. shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If the Deutsches Institut für Compliance e.V. processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This also applies to profiling insofar as it is associated with such direct advertising. If the data subject objects to the Deutsches Institut für Compliance e.V. to the processing for direct marketing purposes, the Deutsches Institut für Compliance e.V. will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Deutsches Institut für Compliance e.V. for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may directly contact the Data Protection Officer of the Deutsches Institut für Compliance e.V. or another employee. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the controller, or (2) is authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the Deutsches Institut für Compliance e.V. shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact our Data Protection Officer or another employee of the controller.

Any person affected by the processing of personal data has the right granted by the European legislator of directives and regulations to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise their right to withdraw consent, they can contact our data protection officer or another employee of the data controller at any time

In accordance with Article 77 GDPR, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal data relating to you infringes the GDPR or the BDSG.

Berlin Commissioner for Data Protection and Freedom of Information
Friedrichstr. 219
Visitor entrance: Puttkamerstr. 16 – 18 (5th floor)
10969 Berlin
Phone: 030 13889-0
Fax: 030 2155050
E-mail: mailbox@datenschutz-berlin.de

10. data protection for applications and in the application process

The controller collects and processes the personal data of applicants for the purpose of handling the application process. Processing may also be carried out electronically. This is particularly the case if an applicant submits corresponding application documents to the controller by electronic means, for example by email or via a web form on the website. If the controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If the controller does not conclude an employment contract with the applicant, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller stand in the way of deletion. Other legitimate interest in this sense is, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).

11. data protection provisions about the application and use of LinkedIn

The controller has integrated components of LinkedIn Corporation on this website. LinkedIn is an Internet-based social network that allows users to connect with existing business contacts and make new business contacts. Over 400 million registered people use LinkedIn in more than 200 countries. This makes LinkedIn currently the largest platform for business contacts and one of the most visited websites in the world.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA. LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible for data protection matters outside the USA.

Each time you visit our website, which is equipped with a LinkedIn component (LinkedIn plug-in), this component causes the browser used by the data subject to download a corresponding representation of the LinkedIn component. Further information about the LinkedIn plug-ins may be accessed under https://developer.linkedin.com/plugins. As part of this technical process, LinkedIn receives information about which specific subpage of our website is visited by the data subject.

If the data subject is logged in to LinkedIn at the same time, LinkedIn recognizes which specific subpage of our website the data subject is visiting each time the data subject accesses our website and for the entire duration of their stay on our website. This information is collected by the LinkedIn component and assigned by LinkedIn to the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores this personal data.

LinkedIn always receives information via the LinkedIn component that the data subject has visited our website if the data subject is logged in to LinkedIn at the same time as accessing our website; this takes place regardless of whether the data subject clicks on the LinkedIn component or not. If the data subject does not want this information to be transmitted to LinkedIn, they can prevent the transmission by logging out of their LinkedIn account before accessing our website.

LinkedIn offers the option to unsubscribe from email messages, SMS messages and targeted ads and to manage ad settings at https://www.linkedin.com/psettings/guest-controls. LinkedIn also uses partners such as Quantcast, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua and Lotame, which may set cookies. Such cookies can be rejected at https://www.linkedin.com/legal/cookie-policy. The applicable data protection provisions of LinkedIn may be retrieved under https://www.linkedin.com/legal/privacy-policy LinkedIn’s cookie policy is available at https://www.linkedin.com/legal/cookie-policy.

12. data protection provisions about the application and use of Twitter

The data controller has integrated Twitter components on this website. Twitter is a multilingual, publicly accessible microblogging service on which users can publish and disseminate so-called tweets, i.e. short messages limited to 140 characters. These short messages can be accessed by anyone, including people who are not registered with Twitter. However, the tweets are also displayed to the so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Twitter also makes it possible to address a broad audience via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

Each time one of the individual pages of this website is accessed, which is operated by the controller and on which a Twitter component (Twitter button) has been integrated, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Twitter component to download a representation of the corresponding Twitter component from Twitter. Further information about the Twitter buttons is available at https://about.twitter.com/de/resources/buttons. During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is to enable our users to redistribute the contents of this website, to make this website known in the digital world and to increase our visitor numbers.

If the data subject is logged in at the same time on Twitter, Twitter recognizes with each call-up to our website by the data subject and for the entire duration of his or her stay on our Internet site, which specific sub-page of our Internet page was visited by the data subject. This information is collected by the Twitter component and assigned by Twitter to the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, the data and information transmitted with it is assigned to the personal Twitter user account of the data subject and stored and processed by Twitter.

Twitter always receives information via the Twitter component that the data subject has visited our website if the data subject is logged in to Twitter at the same time as accessing our website; this takes place regardless of whether the data subject clicks on the Twitter component or not. If the data subject does not want this information to be transmitted to Twitter, they can prevent the transmission by logging out of their Twitter account before accessing our website.

The applicable data protection provisions of Twitter may be retrieved under https://twitter.com/privacy?lang=de.

13. data protection provisions about the application and use of Xing

The data controller has integrated Xing components on this website. Xing is an Internet-based social network that enables users to connect with existing business contacts and to make new business contacts. Individual users can create a personal profile for themselves on Xing. Companies can, for example, create company profiles or publish job offers on Xing.

The operating company of Xing is XING AG, Dammtorstraße 30, 20354 Hamburg, Germany.

Each time one of the individual pages of this website is accessed, which is operated by the controller and on which a Xing component (Xing plug-in) has been integrated, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Xing component to download a representation of the corresponding Xing component from Xing. Further information about the Xing plug-ins may be accessed under https://dev.xing.com/plugins. As part of this technical process, Xing receives information about which specific subpage of our website is visited by the data subject.

If the data subject is logged in at the same time on Xing, Xing recognizes with each call-up to our website by the data subject and for the entire duration of their stay on our Internet site, which specific sub-page of our Internet page was visited by the data subject. This information is collected by the Xing component and assigned by Xing to the respective Xing account of the data subject. If the data subject clicks on one of the Xing buttons integrated on our website, for example the “Share” button, Xing assigns this information to the personal Xing user account of the data subject and stores this personal data.

Xing always receives information via the Xing component that the person concerned has visited our website if the person concerned is logged in to Xing at the same time as accessing our website; this takes place regardless of whether the person concerned clicks on the Xing component or not. If such a transmission of this information to Xing is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their Xing account before a call-up to our website is made.

The data protection provisions published by Xing, which can be accessed at https://www.xing.com/privacy, provide information about the collection, processing and use of personal data by Xing. Xing has also published data protection information for the XING share button at https://www.xing.com/app/share?op=data_protection.

14. legal basis of the processing

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

15. legitimate interests in the processing pursued by the controller or a third party

Where the processing of personal data is based on Article 6 I lit. f GDPR, our legitimate interest is the performance of our business activities for the benefit of the well-being of all our employees.

16. duration for which the personal data is stored

The criterion for the duration of the storage of personal data is the respective statutory retention period. After this period has expired, the corresponding data is routinely deleted, provided that it is no longer required for contract fulfillment or contract initiation.

17. legal or contractual provisions for the provision of personal data; necessity for the conclusion of the contract; obligation of the data subject to provide the personal data; possible consequences of non-provision

We would like to inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual regulations (e.g. information on the contractual partner). Sometimes it may be necessary for a contract to be concluded for a data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data if our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before the data subject provides personal data, the data subject must contact our data protection officer. Our data protection officer will inform the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences would be if the personal data were not provided.

18. existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

This Privacy Policy has been generated by the Privacy Policy Generator of the German Association for Data Protection that was developed in cooperation with RC GmbH, which sells used IT and the Privacy Lawyers from WILDE BEUGER SOLMECKE, Cologne.