2. DATA PROTECTION OFFICER
3. GENERAL INFORMATION ON DATA PROCESSING
6. DATA PROCESSING FOR ADVERTISING PURPOSES
7. WEBSITE OPTIMIZATION, REACH MEASUREMENT AND ONLINE MARKETING CONTACT WITH US
8. CONTACT WITH US
9. PASSING ON OF DATA
10. YOUR RIGHTS
11. SOCIAL- MEDIA, THIRD PARTY CONTENT & TOOLS
12. APPLICANT DATA
14. DEFINITIONS OF TERMS
1. RESPONSIBLE PERSON
is responsible for the processing of your personal data on this website:
Etribes Connect GmbH
2. DATA PROTECTION OFFICER
You can reach our data protection officer at:
DPL Consult, Inh. Jörg F. Smid, Drehbahn 9,
Tel.: +49 (0) 176 251 38 918
3. GENERAL INFORMATION ON DATA PROCESSING
a. Scope & purpose of processing personal data
As a matter of principle, we process your personal data as a user of this website only to the extent that this is necessary for the provision of a functional website and our contents and services. Your personal data will only be processed with your consent for the intended purpose, unless data processing is permitted by law even without obtaining prior consent. The purposes of the processing result from the processing activities described in detail below.
b. Legal basis for the processing of personal data
Insofar as we obtain your consent for the processing of personal data, Art. 6 para. 1 a) EU Data Protection Regulation (DSGVO) serves as the legal basis. If the processing of your data is necessary for the performance of a contract to which you are a party, Art. 6 para. 1 b) DSGVO serves as the legal basis. This also applies to processing operations which are necessary to carry out pre-contractual measures. If processing of your personal data is necessary to fulfil a legal obligation to which we are subject, Art. 6 para. 1 c) DSGVO serves as the legal basis. In the event that vital interests of you or another natural person make it necessary to process personal data, Art. 6 para. 1 d) DSGVO serves as the legal basis. If the processing is necessary to safeguard a legitimate interest of our company or of a third party and if your interests, fundamental rights and freedoms do not outweigh the former, Art. 6 para. 1 f) DPA serves as the legal basis for the processing.
c. Data deletion and storage period
Your personal data will be deleted or blocked as soon as the purpose for which it was stored no longer applies. Furthermore, data may be stored if this has been provided for by law or other binding legal regulations. Data will also be blocked or deleted if a storage period prescribed by the aforementioned legal provisions expires, unless it is necessary to continue storing the data in order to conclude or fulfil a contract.
If you use the website for informational purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser sends to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website and to ensure stability and security (legal basis is Art. 6 para. 1 p. 1 f) EU-DSGVO): Date and time of access, name of the pages accessed, referrer URL (URL from which visitors came to our website), the amount of data transferred, loading time, browser type, language & version, name of the visitor’s access provider, operating system and its interface.
In addition to the data mentioned above, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive by the browser you use and allow us, as the entity that set the cookie, to receive certain information. Cookies cannot execute programs or transfer viruses to your computer. They serve to make the Internet offer altogether more user-friendly.
This website uses the following types of cookies, the scope and function of which are explained below:
a) Temporary cookies are automatically deleted when you close the browser. This includes in particular session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the common session. This enables your computer to be recognised when you return to our website. The session cookies are deleted when you log out or close the browser. Insofar as these cookies and/or the information they contain are personal data, the legal basis for data processing is your consent in accordance with Art. 6 Paragraph 1 a DSGVO. You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or all cookies. We would like to point out that you may then not be able to use all functions of this website.
6. DATA PROCESSING FOR ADVERTISING PURPOSES
Advertising with consent We process your data for marketing purposes only on the basis of your express consent to these purposes in accordance with Art. 6 Paragraph 1 Letter a) DSGVO. Proper agreements on order processing have been concluded with service providers that we engage for the purpose of advertising delivery and that process data on our behalf in strict accordance with our instructions.
Reference to the right of objection
You can object to the use of your personal data for the above-mentioned advertising purposes at any time free of charge and with future effect by using the contact details given in section 1.
If you object, your data will be blocked for further advertising data processing. We would like to point out that in exceptional cases, even after receipt of your objection, advertising material may still be sent temporarily. This is technically due to the necessary lead time within the selection process and does not mean that we have not implemented your objection.
7. WEBSITE OPTIMIZATION, REACH MEASUREMENT AND ONLINE MARKETING
For the purpose of tailoring our pages to your needs and continuously optimising them, we use Google Analytics, a web analysis service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Google Analytics uses so-called “cookies”, text files which are stored on your computer and which enable an analysis of your use of the website. In this context, pseudonymised user profiles are created and cookies are used. The information generated by the cookie about your use of this website such as
• Browser type/version,
• the operating system used,
• Referrer URL (the previously visited page),
• Host name of the accessing computer (IP address),
• Time of the server request.
Google Conversion Tag
We use the online advertising program “Google Ads” on our website and, in this context, conversion tracking (analysis of visitor activity). Google Conversion Tracking is an analysis service of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”).
If you are ordinarily resident in the European Economic Area or Switzerland, Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) is the data controller. Google Ireland Limited is therefore the company affiliated with Google which is responsible for processing your data and for ensuring compliance with applicable data protection laws. When you click on an ad placed by Google, a conversion tracking cookie is placed on your computer. These cookies have a limited validity, do not contain any personal information and are therefore not personally identifiable. If you visit certain pages on our site and the cookie hasn’t expired, Google and we can tell that you clicked on the ad and were redirected to that page. Each Google Ads customer receives a different cookie. As a result, there is no way that cookies can be tracked across the websites of ads customers. The information collected using the conversion cookie is used to compile conversion statistics. This tells us the total number of users who have clicked on one of our ads and been redirected to a page with a conversion tracking tag. However, we do not receive information that personally identifies users. Your information may be transferred to the USA. Google has certified itself under the US-EU Privacy Shield Agreement and is committed to complying with the European Data Protection Directives.
Google Tag Manager
Google Ads (formerly: AdWords)
Google Ad Manager (formerly DoubleClick)
8. CONTACT WITH US
Contact by e-mail, mail & phone You have the possibility to get in contact with us in several ways. By e-mail, by telephone or by post. If you contact us, we use the personal data that you voluntarily provide us with in this context solely for the purpose of contacting you and processing your request. The legal basis for this data processing is Art. 6 paragraph 1 b). Your data will be deleted when they are no longer required for the purpose of processing and there is no legal obligation to store them. Contact form There is a contact form on our website which can be used for electronic contact. If a user takes advantage of this option, the data you enter in the input mask will be transmitted to us in encrypted form and stored. The legal basis for the processing of your data is Art. 6 para. 1 a) DSGVO, if you have given your consent. If no individual consent from you is available, we process your data on the basis of Art. 6 para. 1 b) DSGVO. The processing of the personal data from the input mask serves us solely to process the contact.
9. PASSING ON OF DATA
Data will only be passed on to service providers on the basis of a proper agreement on order processing in accordance with Art. 28 DSGVO. With the exception of the processing described above, we do not pass on your data to recipients based outside the European Union or the European Economic Area. The processing mentioned here causes a data transfer to the servers of the providers of tracking or targeting technologies commissioned by us. These servers are located in the USA. The data transfer is carried out on the basis of so-called standard contractual clauses of the EU Commission and according to the principles of the so-called Privacy Shield.
10. YOUR RIGHTS
When processing your personal data, you have the following rights, about which we are pleased to inform you below. For this purpose you can contact us as the responsible person or the data protection officer. You will find the contact details above under 1. and 2.
a. Right of access to information
Upon request, we will confirm whether personal data concerning you will be processed. If this is the case, you have the right to be informed about the following information
• the purpose(s) of the data processing,
• the categories of data processed, and
• where appropriate, the recipients or categories of recipients to whom data are disclosed on the basis of legal obligations or contractual relations; in particular in the case of recipients in third countries
• the planned storage period, or, if this is not possible, the criteria for determining the duration
• the existence of a right of rectification or erasure of personal data concerning him/her, or of a right to limit the processing carried out by us or to object to such processing
• the existence of a right of appeal to the supervisory authority
• in the event that the personal data are not collected from the data subject All available information on the origin of the data
• the existence of automated decision making, including profiling and meaningful information on the logic involved and the scope and intended impact of such processing on the data subject
• in the case of a transfer to a third country or to an international organisation, of the appropriate safeguards in relation to the transfer.
Upon request, you will receive a copy of the data collected and processed by you. This is basically free of charge.
b. Right of rectification
You have the right to ask for the immediate rectification of incorrect personal data concerning you. You have the right to request the completion of incomplete personal data, including by means of a supplementary declaration, having regard to the purposes of the processing.
c. Right to cancellation (so-called right to be forgotten)
Upon request, or after fulfilment or termination of the contract with us, your personal data will be deleted immediately if this is not contrary to tax or commercial law storage or documentation obligations or if the safeguarding of the legitimate interests of the person responsible is at risk.
A claim for deletion exists under the following conditions:
• The personal data has been collected or otherwise processed for purposes for which it is no longer necessary.
• You revoke your consent on which the processing was based pursuant to Art. 6 para. 1 a DSGVO or Art. 9 para. 2 a DSGVO and there is no other legal basis for the processing.
• You object to the processing pursuant to Art. 21 Para. 1 DSGVO, and there are no overriding legitimate reasons for the processing, or an objection to the processing has been lodged pursuant to Art. 21 Para. 2 DSGVO.
• the personal data have been processed unlawfully.
• the deletion of the personal data is necessary to comply with a legal obligation under Union law or the law of the Member States to which the controller is subject.
• the personal data has been collected in relation to information society services offered in accordance with Article 8 (1) DSDSVO (consent has been given by a child)
d. Right to restrict processing (blocking)
Under the following conditions, you have the right to request the restriction of processing, i.e. the blocking of your personal data for processing:
• you contest the accuracy of your personal data, for a period of time which allows us to verify the accuracy of the personal data.
• the processing is unlawful, you refuse to delete the personal data and instead demand the restriction of the use of the personal data
• the controller no longer needs the personal data for the purposes of the processing, but you need the personal data in order to assert, exercise or defend legal claims the user has lodged an objection to the processing in accordance with Art. 21 (1) DS-GVO and it is not yet clear whether the legitimate reasons of the controller outweigh those of the user.
e. Right to data transferability (data portability)
Upon request, your data can be made available in a structured, common and machine-readable format for a fee for you and a service provider working subsequently, in order to enable rapid transmission. This applies in any case if the processing is based on a consent pursuant to Art. 6 para. 1 a DSGVO or Art. 9 para. 2 a) DSGVO or on a contract pursuant to Art. 6 para. 1 b DSGVO and the processing is carried out with the aid of automated procedures.
f. Right of objection
You also have the right to object to the processing of your personal data. If the processing is carried out for the purpose of direct advertising (e.g. newsletters), this right exists at all times.
Otherwise, you may also have the right to object at any time to the processing of your personal data for reasons arising from your particular situation. This only applies insofar as the processing is carried out on the basis of Art. 6 para. 1 e) or f) DSGVO (safeguarding of public interests or protection of legitimate interests by the controller). In order to exercise this right of revocation, you can also send us an informal message stating your e-mail address to … in which your intention to revoke is expressed.
g. Right of complaint to the supervisory authority If you are of the opinion that there has been a violation of data protection regulations, you have the right to complain to the responsible supervisory authority. For companies in Hamburg, for example, this is the Hamburg Commissioner for Data Protection and Freedom of Information: https://www.datenschutz-hamburg.de
11. DATA PROTECTION REGULATIONS FOR THE USE AND APPLICATION OF HUBSPOT
Etribes Connect GmbH uses HubSpot for its online marketing activities. This is an integrated software solution with which we cover various aspects of our online marketing. With HubSpot we have concluded an order data processing contract according to the DSGVO.
These include, among others:
- E-mail marketing (newsletter as well as automated mailings, e.g. for the provision of downloads)
- Social Media Publishing & Reporting
- Reporting (e.g. traffic sources, accesses, etc. …)
- Contact management (e.g. user segmentation & CR
- Landing pages and contact forms
Contact us: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, telephone: +353 1 5187500.
HubSpot is certified under the EU – U.S. Privacy Shield Framework and is subject to TRUSTe’s Privacy Seal and the U.S. – Swiss Safe Harbor Framework.
- More information from HubSpot regarding the EU data protection regulations »
- More information about the cookies used by HubSpot can be found here & here »
If you generally do not want Hubspot to collect cookies, you can prevent the storage of cookies at any time by changing your browser settings accordingly.
12. SOCIAL MEDIA, THIRD PARTY CONTENT & TOOLS
We use social plug-ins from the social networks Facebook, Google+ and Twitter on our website on the basis of Article 6 Paragraph 1 Letter f DSGVO to make our company better known. The underlying advertising purpose is to be considered a legitimate interest within the meaning of the DSGVO. The responsibility for data protection compliant operation is to be guaranteed by their respective providers.
For the purpose and scope of data collection and the further processing and use of data by the respective provider, as well as your rights in this regard and setting options for protecting your privacy, please refer to the provider’s respective data protection information, which we link to below.
By logging out of social network pages and deleting cookies, you can avoid that social networks assign the information collected about you to your user account on the respective social network during your visit to our site. If you do not want social networks to associate the information collected through our site directly with your profile, you must log out of the relevant social networks before visiting our site. You can also completely prevent the loading of the plugins with add-ons for your browser, e.g. with the ScriptBlocker “NoScript”, which can be found at: http://noscript.net.
Integration of third party services and content
Within the framework of our website, we use offers from third parties on the basis of consent in accordance with Art. 6 Para. 1 f) DSGVO or, if consent is not available in individual cases and is not legally required, on the basis of our legitimate interests (i.e. interest in evaluating the use of our website and improving the operation of our website within the meaning of Art. 6 Para. 1 f) DSGVO) in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This may require the respective third party providers to be aware of your IP address, as without the IP address they would not be able to send the Content to your browser. The IP address is therefore necessary for the delivery and display of this content. The third party providers may also use so-called “pixel tags” (non-visible graphic files, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” enable the user behaviour on this website to be analysed. The pseudonymous information may be stored in cookies on your device and may contain, for example, technical information about visiting times, browser and operating system, previously visited website and other information about the use of our website. There is no link to similar information from other sources. If you do not want pixel tags to record your usage behavior, you can object to the data collection at any time.
We may include videos from the “YouTube” platform of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can find their data protection information at: https://www.google.com/policies/privacy/ You can set an opt-out under this link: https://adssettings.google.com/authenticated.
We may include maps of the Google Maps service of the provider 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, however, are not collected without their consent (usually in the context of the settings of their mobile devices). The data may be processed in the USA. Its data protection information can be found at: https://www.google.com/policies/privacy/ You can set an opt-out under this link: https://adssettings.google.com/authenticated.
LinkedIn Insight tag
We also use the LinkedIn Insight tag.
The LinkedIn Insight tag is used to provide detailed campaign reporting and information about visitors to our website. As a LinkedIn marketing solutions customer, we use the LinkedIn Insight tag to track conversions, retarget our website visitors, and gather additional information about the LinkedIn members who view our ads.
Within the framework of our website, we use the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc., on the basis of consent in accordance with Art. 6 Para. 1 f) DSGVO or, if consent is not available in individual cases and is not legally required, on the basis of our legitimate interests (i.e. interest in the evaluation of the use of our website and improvement of the operation of our website in the sense of Art. 6 Para. 1 f) DSGVO), 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active). The Facebook pixel enables Facebook to identify visitors to our website as a target group for the display of advertisements (so-called “Facebook Ads”). Accordingly, we use the Facebook Pixel to display the Facebook Ads placed by us only to those Facebook users who have also shown an interest in our offers or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we want to help ensure that our Facebook ads correspond to the presumed interest of the users and that ads do not appear disturbing or inappropriate, but rather appear interesting and useful to the user. The Facebook Pixel is also intended to help us track the effectiveness of Facebook Ads for statistical and market research purposes by showing us whether users have been redirected to our website after clicking on a Facebook Ad (so-called “conversion”). Facebook processes the data in accordance with Facebook’s Data Use Policy. This policy contains further information on the display of Facebook advertisements: https://www.facebook.com/policy.php. Specific information about the Facebook pixel and its functionality can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616.
13. APPLICANT DATA
We process the personal data of applicants for the purpose of processing the application procedure. The processing can also take place electronically. This is particularly the case if an applicant submits appropriate application documents to us electronically, for example by e-mail. If a contract of employment is concluded with an applicant, the transmitted data is stored for the purpose of processing the employment relationship in accordance with the statutory provisions. If no contract of employment is concluded, the application documents are automatically deleted six months after notification of the rejection decision, provided that no other legitimate interests of the person responsible conflict with deletion.
The responsible person reserves the right to adapt security and data protection measures, as far as this becomes necessary due to technical or legal developments. In these cases, the responsible person will also adapt these data protection notes accordingly. Therefore, please note the current version of our data protection information.
© This data protection notice was created with the support of the SMARTDPO Data Protection Generator. Owner of the copyright is JENTZSCH IT Rechtsanwaltsgesellschaft mbH, Hamburg.