DATA PROTECTION
We take the protection of your personal data very seriously when you visit our website. All details relating to your person, such as your name, address, telephone number, email address, account number, etc., as well as any information that can be traced back to you, are referred to as personal data. This also includes your IP address, which is automatically transmitted when you visit a website. This is technically essential. We want you to know whether and when we collect which data, and how we use it. We have put in place technical and organisational measures to ensure that data protection regulations are observed both by us and by any external service providers. In particular, we take into account the European Union’s (EU) General Data Protection Regulation (GDPR), which has been in force since 25 May 2018, and the national TDDDG (formerly TTDSG). As a general rule, personal data is collected on this website only to the extent necessary for the purposes listed below. We provide you with information on what data is collected during your visit to the website and how it is used.
If you wish to exercise your rights (see below), please contact us as the data controller for this website – please refer to the legal notice for our contact details. For general enquiries or concerns regarding data protection, please write to our external Data Protection Officer (DPO), Thomas Schneider of DSB Baden GmbH, at [email protected]. Please include our company name in the subject line to help the external DPO identify your enquiry more easily.
1.2 LEGAL BASIS
Personal data may only be ‘processed’ if there is a valid legal basis for doing so. Such processing must be linked to a specific purpose. We process any personal data that we may collect from you via this website on the basis of the following legal grounds:
1.2.1 Balancing of interests in accordance with Article 6(1)(f) of the GDPR
Where tools are used with the aim of making our website more user-friendly, efficient and secure, this may be done following a balancing of interests, as this does not involve the profiling of user behaviour and the visitor’s IP address is stored in a non-anonymised form only for a short period.
We also process information that you provide to us for the purposes of a potential or existing business relationship (B2B relationship) as part of a balancing of interests.
1.2.2 Contractual relationship pursuant to Article 6(1)(b) of the GDPR
If you, as a private individual, provide us with your personal data (e.g. as part of a job application or a product enquiry), we will process this data for the purposes of entering into a contract or for the purposes of managing our contractual relationship with you.
1.2.3 Legal requirement pursuant to Article 6(1)(c) of the GDPR
Where we are subject to legal requirements which necessitate the use of your personal data to ensure compliance, this is done in accordance with this legal basis.
1.2.4 Consent pursuant to Article 6(1)(a) of the GDPR
In rare cases, we may wish to use the personal data you have provided for a purpose other than that for which it was originally intended. Should this occur and no other legal basis exist, we will require your voluntary consent – which you may withdraw at any time with future effect – and we will ask you for this separately.
1.3 WEBSITE ACCESS AND LOGGING
When you visit our website, your IP address and other information are automatically transmitted. Our provider, acting as a ‘data processor’ in accordance with Article 28 of the GDPR, stores information in a log file (‘server log file’). This includes:
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Browser type and version
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Operating system used
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Referrer URL
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Hostname of the accessing computer
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Time of the server request
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IP address
The storage of this data serves internal system-related purposes, primarily to ensure the availability of our website, in accordance with, amongst other things, Section 12 of the TDDDG (Disruption of telecommunications systems and misuse of telecommunications services).
This information is not disclosed to any other recipients (with the exception of requests from law enforcement authorities based on existing legal grounds).
Due to ‘anonymisation’ – as the IP address is not stored – this traffic data has no relevance to data protection. We are unable to link this data to a specific individual.
This data is not combined with other data sources. Where applicable, this data is analysed for statistical purposes to improve the quality and services of this website, and is subsequently deleted or anonymised.
The legal basis for this processing is Article 6(1)(f) of the GDPR (‘balancing of interests’).
Where we intend to use the transmitted IP address for other purposes, this is explained in more detail below.
1.4 INFORMATION REQUIREMENTS UNDER ARTICLE 13 OF THE GDPR
Under the General Data Protection Regulation, we are obliged to provide appropriate information whenever we collect personal data directly from the data subject. Should we collect personal data from you via our website, we would like to inform you accordingly. Data collection takes place, for example, when we
• Collect your IP address for the technical operation of the website
• Use a tracking tool that utilises your IP address
• Receive the information you enter in a contact form for the purpose of communicating with us.
General procedure: Where you have provided us with personal data, we generally use it only to respond to your enquiries and for technical administration. As an exception, the anonymised IP address may be used for statistical analysis. Should the IP address be used for any other purpose, this will be specified below.
Your personal data will only be disclosed to third parties or otherwise transferred if this is necessary for the purposes of contract fulfilment – in particular, the disclosure of order details to suppliers/service providers – if it is necessary for billing purposes, if we are legally obliged to do so, in the context of data processing by subcontractors, or if you have given your prior consent. You have the right to withdraw any consent you have given at any time with effect for the future.
Stored personal data will be deleted if you withdraw your consent to its storage; if it is no longer necessary for the fulfilment of the purpose for which it was stored – in other words, once the transaction has been completed and there are no statutory retention periods preventing its deletion; or if its storage is unlawful for other legal reasons. Furthermore, your objection to processing may result in the deletion of the stored data. Should the data not be able to be deleted for technical reasons, we will anonymise it so that it can no longer be linked to a specific individual in future.
Our company is responsible for all data collection and processing carried out on this website.
Further detailed information can be found in the sections below.
In its current form, our website does not collect any personal data from you other than the ‘technical’ personal data gathered when you access the website.
1.5 CONTACT FORMS
We do not use contact forms on our website. Please use the email addresses provided to get in touch with us.
1.6 COOKIES
Cookies are small text files that may be stored on your computer for various purposes. Cookies can serve a range of functions. For example, some cookies enable users to navigate the website more easily, whilst others track user behaviour or help to identify users when they revisit a website. Where cookies are not technically necessary (e.g. shopping basket cookies in an online shop are considered technically necessary), they require the user’s consent (see Section 25 of the TDDDG).
Apart from any technically necessary cookies, we do not use any other cookies on our website. However, if you leave this website via a link, subsequent pages operated by other providers may set cookies. We are not responsible for this. Please also note our information regarding the tools used on the website.
1.7 LINKS TO OTHER WEBSITES
Our website contains links to external third-party websites over whose content we have no control. We are therefore unable to accept any liability for this external content. The respective provider or operator of the linked pages is always responsible for their content. The linked pages were checked for any potential legal infringements at the time the links were created. No unlawful content was identifiable at the time the links were created. However, it is not reasonable to expect us to monitor the content of the linked pages on an ongoing basis without specific evidence of a legal infringement. Should we become aware of any legal infringements, we will remove such links immediately. Please note the privacy policy of the third party whose website the link leads to.
Please note that, in some cases, when you click on a link, the third party may analyse how you arrived at their site. They may be able to identify the referring site (our website), your IP address and other data.
If you do not wish to do so, please do not click on the link. Please note the privacy policies of the third parties whose websites the link leads to.
1.8 YOUR RIGHTS – RIGHTS OF DATA SUBJECTS UNDER THE GDPR
Articles 12–23 of the GDPR set out the rights of the data subject, i.e. your rights regarding the processing of your personal data. Essentially, these rights in relation to us are:
• The right to information at the latest at the time of collection, in accordance with Article 13 of the GDPR, which we fulfil through this privacy policy.
• Right of access under Article 15 of the GDPR
• Right to erasure under Article 17 of the GDPR
• Right to restriction of processing under Article 18 of the GDPR
• Right to object under Article 21 of the GDPR
• Where applicable: Right to data portability under Article 20 of the GDPR
We will assist you in exercising your rights in accordance with the GDPR and other relevant legislation. For enquiries regarding the exercise of your rights, please contact the relevant department within our company as specified above. Please understand that, in the interests of protecting the rights of others, we can only provide personal data if you can provide adequate proof of your identity. You also have the right to lodge a complaint with a supervisory authority of your choice. Within Germany, the competent authority is generally the State Data Protection Commissioner of the federal state in which the ‘controller’ has its registered office – in our case, this is the State Data Protection Commissioner of Baden-Württemberg. A list of data protection commissioners and their contact details can be found via the following link:
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html
1.9 ANALYTICS, TRACKING AND OTHER TOOLS
Web analytics programmes are generally not used to identify website visitors, but are primarily employed for statistical purposes to optimise our own website. In this context, it is important, amongst other things, to understand how anonymised visitors navigate our website. The IP address should always be truncated in such a way that it is no longer possible to identify the data subject. The legal basis for this is usually Article 6(1)(f) of the GDPR (‘balancing of interests’) or consent under Article 6(1)(a) of the GDPR. In addition, such programmes frequently use cookies (see above), which require consent.
We do not currently use any web analytics tools.
1.10 SAFETY NOTICE
We endeavour to store your personal data in such a way that it is not accessible to third parties, by utilising all available technical and organisational measures. In the event of communication via unencrypted email, we cannot guarantee complete data security; we therefore recommend that you use an encrypted method or post for confidential information.
