Privacy Policy
We are very delighted that you have shown interest in our enterprise. Data protection is of a particularly high priority for the management of the ToolsGroup B.V.. The use of the Internet pages of the ToolsGroup B.V. is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
Our transparency document with all data subject rights and information, e.g. according to Art. 13 and 14 GDPR and on compliance with CCPA/CPRA, can be found HERE.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to the ToolsGroup B.V.. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, the ToolsGroup B.V. has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
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Definitions
The data protection declaration of the ToolsGroup B.V. is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
- a) Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
- c) Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
- e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
- f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed 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 attributed to an identified or identifiable natural person.
- g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
- h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
- i) Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
- j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- k) Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
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Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
ToolsGroup B.V.
Teleportbouleveard 110
1043 Ej Amsterdam
Netherlands
Phone: +31 85 2100107
Email: nl-info@toolsgroup.com
Website: https://www.toolsgroup.com/
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Name and Address of the Data Protection Officer
The Data Protection Officer of the controller is:
Prof. Heiko Jonny Maniero
Franz-Joseph-Str. 11
80801 München
Deutschland
Phone: +49 (0) 8131-77987-0
Email: info@dg-datenschutz.de
Website: www.dg-datenschutz.de
Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection.
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Cookies
The Internet pages of the ToolsGroup B.V. use cookies. Cookies are text files that are stored in a computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the dats subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.
Through the use of cookies, the ToolsGroup B.V. can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.
We use the following cookies:
- Cookie name: __cf_bm
Type: HTTP
Provider: g2crowd.com
Expiration: 1 day
Purpose: This cookie is used to distinguish between humans and bots. This is beneficial for the website to generate valid reports about the use of your website.
- Cookie name: __cf_bm
Type: HTTP
Provider: hubspot.com
Expiration: 1 day
Purpose: This cookie is used to distinguish between humans and bots. This is beneficial for the website to generate valid reports about the use of your website.
- Cookie name: __cf_bm
Type: HTTP
Provider: zoominfo.com
Expiration: 1 day
Purpose: This cookie is used to distinguish between humans and bots. This is beneficial for the website to generate valid reports about the use of your website.
- Cookie name: _cfuvid
Type: HTTP
Provider: zoominfo.com
Expiration: Session
Purpose: This cookie is part of Cloudflare’s services – including load balancing, provision of website content and provision of a DNS connection for website drivers website content and providing a DNS connection for website operators.
- Cookie name: _grecaptcha
Type: HTML
Provider: gstatic.com
Expiration: Persistent
Purpose: This cookie is used to distinguish between humans and bots. This is beneficial for the website to generate valid reports about the use of your website.
- Cookie name: _GRECAPTCHA
Type: HTTP
Provider: google.com
Expiration: 180 days
Purpose: This cookie is used to distinguish between humans and bots. This is beneficial for the website to generate valid reports about the use of your website.
- Cookie name: AWSALB
Type: HTTP
Provider: widget.aggregage.com
Expiration: 7 days
Purpose: Registers which server cluster is serving the visitor. This is used in the context of load balancing to optimise the user experience.
- Cookie name: AWSALBCORS
Type: HTTP
Provider: widget.aggregage.com
Expiration: 7 days
Purpose: Registers which server cluster is serving the visitor. This is used in the context of load balancing to optimise the user experience.
- Cookie name: bcookie
Type: HTTP
Provider: linkedin.com
Expiration: 1 year
Purpose: Used by the social networking service LinkedIn for tracking the use of embedded services
- Cookie name: bscookie
Type: HTTP
Provider: linkedin.com
Expiration: 1 year
Purpose: This cookie is used to identify the visitor via an application. This allows the visitor to log in to a website via their LinkedIn application.
- Cookie name: connect.sid
Type: HTTP
Provider: gartner.com
Expiration: 1 day
Purpose: The cookie is required for secure login and detection of spam or abuse of the website.
- Cookie name: CookieConsent
Type: HTTP
Provider: toolsgroup.com
Expiration: 1 year
Purpose: Saves the user’s consent status for cookies on the current domain.
- Cookie name: li_gc
Type: HTTP
Provider: linkedin.com
Expiration: 180 days
Purpose: Used to store consent of guests regarding the use of cookies for non-essential purposes
- Cookie name: rc::a
Type: HTML
Provider: gstatic.com
Expiration: Persistent
Purpose: This cookie is used to distinguish between humans and bots. This is beneficial for
the website to create valid reports about the use of your website.
- Cookie name: rc::b
Type: HTML
Provider: gstatic.com
Expiration: Session
Purpose: This cookie is used to distinguish between humans and bots.
- Cookie name: rc::c
Type: HTML
Provider: gstatic.com
Expiration: Session
Purpose: This cookie is used to distinguish between humans and bots.
- Cookie name: rc::f
Type: HTML
Provider: gstatic.com
Expiration: Persistent
Purpose: This cookie is used to distinguish between humans and bots.
- Cookie name: test_cookie
Type: HTTP
Provider: doubleclick.net
Expiration: 1 day
Purpose: Used to check whether the user’s browser supports cookies.
- Cookie name: DRIFT_openTabs
Type: HTML
Provider: driftt.com
Expiration: Persistent
Purpose: Used to make the chat function consistent across tabs when the user has multiple browser tabs open for the same website.
- Cookie name: DRIFT_SESSION_ID
Type: HTML
Provider: driftt.com
Expiration: Session
Purpose: Allows the website to recognise the visitor in order to optimise the chat box functionality.
- Cookie name: DRIFT_SESSION_STARTED
Type: HTML
Provider: driftt.com
Expiration: Session
Purpose: Stores a unique ID string for each chat box session. This allows the website supporter to see previous problems and reconnect with the previous supporter.
- Cookie name: DRIFT_visitCounts
Type: HTML
Provider: driftt.com
Expiration: Persistent
Purpose: Determines the number of visits of the specific visitor. This is used to make the chat box function more relevant.
- Cookie name: driftt_aid
Type: HTTP
Provider: toolsgroup.com
Expiration: 2 Jahre
Purpose: Necessary for the functionality of the chat box feature of the website.
- Cookie name: lidc
Type: HTTP
Provider: linkedin.com
Expiration: 1 day
Purpose: To facilitate data center selection.
- Cookie name: route-gcrowd-fe-prod
Type: HTTP
Provider: gartner.com
Expiration: Session
Purpose: Used to include customer reviews from third party review sites on the website.
- Cookie name: wp-wpml_current_language
Type: HTTP
Provider: toolsgroup.com
Expiration: Session
Purpose: Indicates the country code calculated based on the user’s IP address. Used to determine which language to use for users.
- Cookie name: __hssc
Type: HTTP
Provider: toolsgroup.com
Expiration: 1 day
Purpose: Indicates whether the cookie data in the visitor’s browser needs to be updated.
- Cookie name: __hssrc
Type: HTTP
Provider: toolsgroup.com
Expiration: Session
Purpose: Used to recognise the visitor’s browser when returning to the website.
- Cookie name: __hstc
Type: HTTP
Provider: toolsgroup.com
Expiration: 180 days
Purpose: Sets a unique ID for the session. This allows the website to obtain data about visitor behaviour for statistical purposes.
- Cookie name: _clck
Type: HTTP
Provider: toolsgroup.com
Expiration: 1 year
Purpose: Collects data about the user’s navigation and behaviour on the website – From this, statistical reports and heat maps are created for the website owner.
- Cookie name: _clsk
Type: HTTP
Provider: toolsgroup.com
Expiration: 1 day
Purpose: Registers statistical data about the behaviour of visitors to the website. Used by the website operator for internal analytics.
- Cookie name: _cltk
Type: HTML
Provider: clarity.ms
Expiration: Session
Purpose: Registers statistical data about the behaviour of visitors to the website. Used by the website operator for internal analytics.
- Cookie name: _ga
Type: HTTP
Provider: toolsgroup.com
Expiration: 2 years
Purpose: Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
- Cookie name: _ga_#
Type: HTTP
Provider: toolsgroup.com
Expiration: 2 years
Purpose: Collects data on how often a user has visited a website, as well as data for the first and last visit. Used by Google Analytics.
- Cookie name: _nav_path
Type: HTML
Provider:
Expiration: Session
Purpose: Registers statistical data about the behaviour of visitors to the website. Used by the website operator for internal analytics.
- Cookie name: _tab_id
Type: HTML
Provider:
Expiration: Session
Purpose: Sets a unique ID for the session. This allows the website to obtain data about visitor behaviour for statistical purposes.
- Cookie name: AnalyticsSyncHistory
Type: HTTP
Provider: linkedin.com
Expiration: 30 days
Purpose: Used to store information about the time a sync took place with the lms_analytics cookie
- Cookie name: c.gif
Type: Pixel
Provider: c.clarity.ms
Expiration: Session
Purpose: Collects data about the user’s navigation and behaviour on the website – From this, statistical reports and heat maps are created for the website owner.
- Cookie name: CLID
Type: HTTP
Provider: clarity.ms
Expiration: 1 year
Purpose: Collects data about the user’s navigation and behaviour on the website – From this, statistical reports and heat maps are created for the website owner.
- Cookie name: dtCookie
Type: HTTP
Provider: gartner.com
Expiration: Session
Purpose: Tracks a visit across multiple requests.
- Cookie name: dtLatC
Type: HTTP
Provider: gartner.com
Expiration: Session
Purpose: Measures server latency for performance monitoring.
- Cookie name: dtPC
Type: HTTP
Provider: gartner.com
Expiration: Session
Purpose: Required to identify proper endpoints for beacon transmission; includes session ID for correlation.
- Cookie name: hubspotutk
Type: HTTP
Provider: toolsgroup.com
Expiration: 180 days
Purpose: Sets a unique ID for the session. This allows the website to obtain data about visitor behaviour for statistical purposes.
- Cookie name: ln_or
Type: HTTP
Provider: toolsgroup.com
Expiration: 1 day
Purpose: Registers statistical data about the behaviour of visitors to the website. Used by the website operator for internal analytics.
- Cookie name: rxvisitid
Type: HTML
Provider: gartner.com
Expiration: Session
Purpose: Is used to monitor site performance, analyze website usage and track user behavior
- Cookie name: rxVisitor
Type: HTTP
Provider: gartner.com
Expiration: Session
Purpose: This cookie is used to accurately track visitors for website traffic.
- Cookie name: rxVisitor
Type: HTML
Provider: gartner.com
Expiration: Session
Purpose: This cookie is used to accurately track visitors for website traffic.
- Cookie name: rxvt
Type: HTTP
Provider: gartner.com
Expiration: Session
Purpose: Sets a timestamp of when the visitor entered the website. This is used for analytical purposes on the website.
- Cookie name: rxvt
Type: HTML
Provider: gartner.com
Expiration: Session
Purpose: This cookie is used to determine when the visitor last visited another sub-page on the website – the cookie will also create a timestamp when the session begins.
- Cookie name: ziwsSession
Type: HTML
Provider:
Expiration: Session
Purpose: Collects statistics about the user’s visits to the website, such as the number of visits, average time spent on the website and which pages were read.
- Cookie name: __ptq.gif
Type: Pixel
Provider: hubspot.com
Expiration: Session
Purpose: Sends data to the marketing platform Hubspot about the visitor’s device and behaviour. Tracks the visitor across devices and marketing channels.
- Cookie name: _gcl_au
Type: HTTP
Provider: toolsgroup.com
Expiration: 3 months
Purpose: Used by Google AdSense to experiment with advertising effectiveness on websites that use their services.
services.
- Cookie name: _gd_session
Type: HTTP
Provider: toolsgroup.com
Expiration: 1 day
Purpose: Collects data about the user’s visits to the website, such as the number of visits, average time spent on the website and which pages were loaded, with the aim of displaying targeted ads.
- Cookie name: _gd_visitor
Type: HTTP
Provider: toolsgroup.com
Expiration: 2 years
Purpose: Collects data about the user’s visits to the website, such as the number of visits, average time spent on the website and which pages were loaded, with the aim of displaying targeted ads.
- Cookie name: _session_id
Type: HTTP
Provider: tracking.g2crowd.com
Expiration: 14 days
Purpose: This is used to gain insights into the impact of the company’s G2 product profile on customer buying behaviour by tracking visitors who navigate between the G2 product profile and the website.
- Cookie name: _tab_ids
Type: HTML
Provider:
Expiration: Persistent
Purpose: Contains data on user navigation, interaction and dwell time on the website and its subpages. This data is used to optimise the relevance of ads and for statistical purposes.
- Cookie name: 6suuid
Type: HTTP
Provider: 6sc.co
Expiration: 400 days
Purpose: Used by the website to register user behaviour and navigation on the website – The cookie registers every interaction with active campaigns on the website. This is used to optimise advertising and efficient retargeting.
- Cookie name: ANONCHK
Type: HTTP
Provider: c.clarity.ms
Expiration: 1 day
Purpose: Registers data about visitors from multiple visits and on multiple websites. This information is used to measure the advertising impact on websites.
- Cookie name: drift_aid
Type: HTTP
Provider: toolsgroup.com
Expiration: 2 years
Purpose: Sets an ID for the specific user. This allows the website to contact the user with relevant offers via their chat functionality with relevant offers.
- Cookie name: drift_campaign_refresh
Type: HTTP
Provider: toolsgroup.com
Expiration: 1 day
Purpose: Sets an ID for the specific user. This allows the website to contact the user with relevant offers via their chat functionality with relevant offers.
- Cookie name: DRIFT_NOTIFICATION_PLAYED
Type: HTML
Provider: driftt.com
Expiration: Session
Purpose: Pending
- Cookie name: DRIFT_SESSION_CAMPAIGNS
Type: HTML
Provider: driftt.com
Expiration: Persistent
Purpose: Used to determine when and where certain pop-ups should be displayed on the website for the user and to remember if the user has closed them so that they are not displayed more than once.
- Cookie name: dtSa
Type: HTML
Provider: gartner.com
Expiration: Session
Purpose: Collects data about the user’s navigation and behaviour on the website – This is used to create statistical reports and heat maps for the website owner.
- Cookie name: IDE
Type: HTTP
Provider: doubleclick.net
Expiration: 1 year
Purpose: Used by Google DoubleClick to record and report the user’s actions on the website after viewing or clicking on one of the provider’s ads, for the purpose of measuring the effectiveness of an advertisement and displaying targeted advertising to the user.
- Cookie name: li_sugr
Type: HTTP
Provider: linkedin.com
Expiration: 3 months
Purpose: Used to make a probabilistic match of a user’s identity outside the Designated Countries
- Cookie name: MR
Type: HTTP
Provider: bing.com
Expiration: 7 days
Purpose: Used to track visitors on multiple websites to present relevant advertising based on the visitor’s preferences based on the preferences of the visitor.
- Cookie name: MR
Type: HTTP
Provider: c.clarity.ms
Expiration: 7 days
Purpose: Used to track visitors on multiple websites to present relevant advertising based on the visitor’s preferences based on the preferences of the visitor.
- Cookie name: MUID
Type: HTTP
Provider: bing.com
Expiration: 1 year
Purpose: Widely used by Microsoft as a unique user ID. The cookie enables user tracking by synchronising the ID in many Microsoft domains.
- Cookie name: MUID
Type: HTTP
Provider: clarity.ms
Expiration: 1 year
Purpose: Widely used by Microsoft as a unique user ID. The cookie enables user tracking by synchronising the ID in many Microsoft domains.
- Cookie name: pagead/1p-user-list/#
Type: Pixel
Provider: google.com
Expiration: Session
Purpose: Used to track whether the visitor has shown interest in certain products or events on multiple websites and how the visitor navigates between websites – This is used to measure advertising spend and facilitates payment of referral fees between websites.
This is used to measure advertising efforts and facilitates the payment of referral fees between websites.
- Cookie name: pagead/landing
Type: Pixel
Provider: doubleclick.net
Expiration: Session
Purpose: Collects data on visitor behaviour across multiple websites to present more relevant advertising. This also allows the website to limit the number of times the same ad is shown.
- Cookie name: SM
Type: HTTP
Provider: c.clarity.ms
Expiration: Session
Purpose: Registers a unique ID that identifies the user’s device during revisits to websites that use the same display network.
sites that use the same display network. The ID is used to enable targeted advertising.
- Cookie name: SRM_B
Type: HTTP
Provider: bing.com
Expiration: 1 year
Purpose: Used to track the user’s interaction with the website’s search bar function. This data can be used to offer relevant products or services to the user.
- Cookie name: UserMatchHistory
Type: HTTP
Provider: linkedin.com
Expiration: 30 days
Purpose: Used for id sync process. It stores the last sync time to avoid repeating the syncing process in a frequent manner.
- Cookie name: _bugherd_session5
Type: HTTP
Provider: bugherd.com
Expiration: 6 months
Purpose: To remember your login so that the sidebar will show on your site for all the invited users.
- Cookie name: _zitok
Type: HTTP
Provider: toolsgroup.com
Expiration: 2 years
Purpose: First-party cookie set to identify unique visitors.
- Cookie name: unifiedScriptVerified
Type: HTML
Provider:
Expiration: Session
Purpose: Pending.
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Collection of general data and information
The website of the ToolsGroup B.V. collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, the ToolsGroup B.V. does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the ToolsGroup B.V. analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
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Subscription to our newsletters
On the website of the ToolsGroup B.V., users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
The ToolsGroup B.V. informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.
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Newsletter-Tracking
The newsletter of the ToolsGroup B.V. contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the ToolsGroup B.V. may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analyzed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. The ToolsGroup B.V. automatically regards a withdrawal from the receipt of the newsletter as a revocation.
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Contact possibility via the website
The website of the ToolsGroup B.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 e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
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Subscription to comments in the blog on the website
The comments made in the blog of the ToolsGroup B.V. may be subscribed to by third parties. In particular, there is the possibility that a commenter subscribes to the comments following his comments on a particular blog post.
If a data subject decides to subscribe to the option, the controller will send an automatic confirmation e-mail to check the double opt-in procedure as to whether the owner of the specified e-mail address decided in favor of this option. The option to subscribe to comments may be terminated at any time.
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Routine erasure and blocking of personal data
The data 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 is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
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Rights of the data subject
- a) Right of confirmation
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 any employee of the controller.
- b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- 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 organisations;
- 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 the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
- c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
- d) Right to erasure (Right to be forgotten)
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 are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to 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 Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the ToolsGroup B.V., he or she may, at any time, contact any employee of the controller. An employee of ToolsGroup B.V. shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, 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, as far as processing is not required. An employees of the ToolsGroup B.V. will arrange the necessary measures in individual cases.
- e) Right of restriction of processing
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 instead 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 defence of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the 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 ToolsGroup B.V., he or she may at any time contact any employee of the controller. The employee of the ToolsGroup B.V. will arrange the restriction of the processing.
- f) Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as 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, as long as 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 his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so 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 any employee of the ToolsGroup B.V.
- g) Right to object
Each data subject shall have 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 ToolsGroup B.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 defence of legal claims.
If the ToolsGroup B.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 applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the ToolsGroup B.V. to the processing for direct marketing purposes, the ToolsGroup B.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 ToolsGroup B.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 contact any employee of the ToolsGroup B.V.. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
- h) Automated individual decision-making, including profiling
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, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised 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 not 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 ToolsGroup B.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 any employee of the ToolsGroup B.V.
- i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the ToolsGroup B.V.
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Data protection for applications and the application procedures
The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Other legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).
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Data protection provisions about the application and use of Google Analytics
Google Analytics is a tool from Google LLC that provides website and app operators with detailed statistics on traffic and user behavior. It enables the collection and analysis of data on website visits, user interactions and conversion rates, which helps operators to understand and optimize their online presence. Google Analytics uses cookies to collect information about user behavior, including page views, time spent on the site and the paths users take on the site.
When using Google Analytics, Personal Data such as IP addresses, browser information and interaction data are processed. This data helps website operators to measure the performance of their website, improve the user experience and develop targeted marketing strategies.
The operating company of the service and therefore the recipient of the Personal Data is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Purposes of the processing for which the personal data are intended and the legal basis for the processing: The purpose of the processing is the analysis and optimization of websites and apps and advertising. The processing is based on Art. 6 (1) (f) GDPR, whereby the legitimate interest lies in improving the website, increasing user-friendliness and the effectiveness of online marketing.
The company operating the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of standard contractual clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The operating company of the service may be a certified member of one or more of the data privacy frameworks. You can find more information at https://www.dataprivacyframework.gov/list. You can request a copy of the suitable or appropriate safeguards from us.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company operating the service or statutory or contractual retention periods. The provision of Personal Data is generally not required by law or contract, nor is it necessary for the conclusion of a contract. As a rule, you are not obliged to provide us or the operating company of the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.
Further information and the applicable data protection provisions of Google Analytics can be found at https://policies.google.com/privacy.
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Data protection provisions about the application and use of LinkedIn
LinkedIn is a social network for professional contacts and career development. The platform allows users to create a professional profile, network with colleagues, business partners and potential employers, share professional experiences and skills, and keep up to date with industry news. LinkedIn also provides tools for companies and recruiters to source talent, post job ads and build a brand presence.
When using LinkedIn, Personal Data such as names, email addresses, professional titles and experience, educational background, skills, interests, and platform usage data are processed. This information is necessary to provide and use the service, to create networking opportunities, to present personalized content and job offers and to ensure the security of user data.
The operating company of the service and thus the recipient of the Personal Data is LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA.
Purposes of the processing for which the personal data are intended and the legal basis for the processing: The purpose of the processing is the use and optimization of network and career services. The processing is based on the consent of the user (Art. 6 (1) (a) GDPR), the performance of a contract (Art. 6 (1) (b) GDPR) to which the Data Subject is party and on legitimate interests (Art. 6 (1) (f) GDPR), such as marketing and recruitment.
The company operating the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of standard contractual clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The operating company of the service may be a certified member of one or more of the data privacy frameworks. You can find more information at https://www.dataprivacyframework.gov/list. You can request a copy of the suitable or appropriate safeguards from us.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company operating the service or statutory or contractual retention periods. The provision of Personal Data is generally not required by law or contract, nor is it necessary for the conclusion of a contract. As a rule, you are not obliged to provide us or the operating company of the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.
Further information and the applicable data protection provisions of LinkedIn Corporation can be found at https://www.linkedin.com.
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Data protection provisions about the application and use of YouTube
YouTube is a video sharing and viewing platform used by individuals, artists, businesses, and media companies to publish a variety of content such as music videos, vlogs, educational material and much more. YouTube offers users the ability to upload, share, comment and interact with a broad community.
When using YouTube, Personal Data such as IP addresses, user interactions (e.g., videos viewed, comments), location data (if enabled for services) and information from linked Google accounts are processed. This information is required to provide personalized content and advertising, enable user interactions, keep the platform secure and improve the user experience.
The operating company of the service and therefore the recipient of the Personal Data is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Purposes of the processing for which the personal data are intended and the legal basis for the processing: The purpose of the data processing lies in the use of the video sharing services. The processing is based on the performance of a contract pursuant to Art. 6 (1) (b) GDPR, to which the Data Subject is a party, and on legitimate interests pursuant to Art. 6 (1) (f) GDPR, such as the use of an efficient video platform, the improvement of the user experience, the use of personalized advertising and the use of embedded videos on our website.
The company operating the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of standard contractual clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The operating company of the service may be a certified member of one or more of the data privacy frameworks. You can find more information at https://www.dataprivacyframework.gov/list. You can request a copy of the suitable or appropriate safeguards from us.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company operating the service or statutory or contractual retention periods. The provision of Personal Data is generally not required by law or contract, nor is it necessary for the conclusion of a contract. As a rule, you are not obliged to provide us or the operating company of the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.
Further information and the applicable YouTube Privacy Policy can be found at https://policies.google.com.
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Data protection provisions about the application and use of X (formerly Twitter)
X (formerly known as Twitter) is a global platform for public self-expression and real-time conversation. Users can create and share short messages, called tweets, which can include text, images, videos, and links. The platform allows users to follow breaking news, interact with others and participate in global discussions.
When using X, various types of Personal Data are processed, including usernames, e-mail addresses, telephone numbers and location data. This information can be used for account creation, personalization of content, provision of advertising, security purposes and for analytical evaluations.
The operating company of the platform and therefore the recipient of the Personal Data is X Corp, Suite 900, 1355 Market Street, San Francisco, California, 94103, USA.
The processing of Personal Data takes place, among other things, on the basis of the user’s consent (Art. 6 (1) (a) GDPR), for the performance of a contract (Art. 6 (1) (b) GDPR) to which the Data Subject is a party, or on the basis of legitimate interests (Art. 6 (1) (f) GDPR), such as the use of the platform and the improvement of communication with the public.
The company operating the service is based in a third country, namely the USA. Transfers to third countries may be based on the conclusion of standard contractual clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The operating company of the service may have concluded one of the EU standard contractual clauses with us. You can request a copy of the suitable or appropriate safeguards from us.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company operating the service or statutory or contractual retention periods. The provision of Personal Data is generally not required by law or contract, nor is it necessary for the conclusion of a contract. As a rule, you are not obliged to provide us or the operating company of the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.
Further information and the applicable data protection provisions of X can be found at https://twitter.com/.
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Data protection provisions about the application and use of Cloudflare
Cloudflare offers a wide range of services to improve the security, performance and reliability of websites and web applications. Core features include DDoS protection, web application firewall, content delivery network services, secure DNS services and more. By using Cloudflare, we can protect our online presence from cyberattacks, improve the loading speed of our website and ensure the overall availability of our services.
When using Cloudflare services, data such as IP addresses, system configurations and network traffic information is processed. This information is necessary to ward off threats, optimize data traffic and provide insights into website usage.
The operating company of the service and therefore the recipient of the Personal Data is Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA.
Purposes of the processing for which the personal data are intended and the legal basis for the processing: The purpose of the processing is the use of services to secure and optimize websites and web applications. The processing is based on Art. 6 (1) (f) GDPR, whereby the legitimate interest lies in ensuring the security, performance, and reliability of our online presence.
The operating company of the service is based in a third country, namely in the USA. Transfers to third countries may be based on the conclusion of standard contractual clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. Cloudflare, Inc. may have concluded one of the EU standard contractual clauses with us. You can request a copy of the suitable or appropriate safeguards from us.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company operating the service or statutory or contractual retention periods. The provision of Personal Data is generally not required by law or contract, nor is it necessary for the conclusion of a contract. As a rule, you are not obliged to provide us or the operating company of the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.
Further information and the applicable data protection provisions of Cloudflare, Inc. can be found at https://www.cloudflare.com.
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Data protection provisions about the application and use of Google Tag Manager
Google Tag Manager is a tag management system from Google LLC that allows website and app operators to easily implement and manage tags for web analytics and marketing optimization tools without having to change the source code of their websites or apps. Tags are small snippets of code that are used to analyze website data, understand user behavior, and monitor the effectiveness of online marketing campaigns. Google Tag Manager supports the integration of a variety of tags, including Google Analytics, Google Ads and many third-party tags.
The service allows users to manage and trigger tags that can collect data. This data is processed and stored by the respective tags and not by the Google Tag Manager.
The operating company of the service and therefore the recipient of the Personal Data is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Purposes of the processing for which the personal data are intended and the legal basis for the processing: The purpose of using Google Tag Manager is to simplify tag implementation and tag management. The processing is based on Art. 6 (1) (f) GDPR, whereby the legitimate interest lies in optimizing and increasing the efficiency of tag management and the associated web analysis and marketing activities.
The operating company of the service is based in a third country, namely in the USA. Transfers to third countries may be based on the conclusion of standard contractual clauses or other suitable or appropriate safeguards referred to in Art. 46 (2) GDPR. The operating company of the service may be a certified member of one or more of the data privacy frameworks. You can find more information at https://www.dataprivacyframework.gov/list. You can request a copy of the suitable or appropriate safeguards from us.
The criteria for determining the duration for which the Personal Data is processed are the contractual relationship between us and the company operating the service or statutory or contractual retention periods. The provision of Personal Data is generally not required by law or contract, nor is it necessary for the conclusion of a contract. As a rule, you are not obliged to provide us or the operating company of the service with Personal Data. However, if you do not provide it, you may not be able to use our services or those of the company operating the service.
Further information and the applicable data protection provisions of Google Tag Manager can be found at https://policies.google.com/privacy.
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Legal basis for the processing
Art. 6(1) lit. a GDPR serves 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, the processing is based on Article 6(1) lit. b GDPR.
The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.
Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
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The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
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Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
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Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her.
The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject 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 the consequences of non-provision of the personal data.
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General Terms and Conditions for Data Protection
Our Terms and Conditions for Data Protection , which include, among other things, all five versions of the EU Standard Contractual Clauses, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, a Data Processing Agreement governed by UK law, a CCPA-CPRA Contractor Agreement and a Data Protection and Confidentiality Agreement for suppliers, will automatically form part of all agreements entered into with us. By entering into any other agreement with us, you automatically agree to the respective terms. In detail:
- EU Standard Contractual Clauses 2021/915 between Controller and Processor:
If you are an EU/EEA-based vendor of ours that processes personal data on our behalf, by conducting business for or with us, you automatically consent to the applicability of our published Standard Contractual Clauses 2021/915. If we are your processor, the Standard Contractual Clauses 2021/915 published by us will also automatically apply between you and us.
- EU Standard Contractual Clauses 2021/914 MODULE ONE: Transfer Controller to Controller:
To the extent that you are a vendor of ours located in a third country and receive personal data (protected by the GDPR, Member State law or European Economic Area law) from us as a Controller and act as a Controller, by conducting business for or with us, you automatically consent to the applicability of the published Standard Contractual Clauses 2021/914 Module One. The same applies if you act as a Controller and transfer personal data to us as a Controller.
- EU Standard Contractual Clauses 2021/914 MODULE TWO: Transfer Controller to Processor:
To the extent that you are a vendor of ours located in a third country and receive personal data (protected by the GDPR, Member State law or European Economic Area law) from us as a Controller and act as a Processor, by conducting business for or with us, you automatically consent to the applicability of the published Standard Contractual Clauses 2021/914 Module Two. The same applies if you act as a Controller and transfer personal data to us as a Processor.
- EU Standard Contractual Clauses 2021/914 MODULE THREE: Transfer Processor to Processor:
To the extent that you are a vendor of ours and we are acting as a Processor (e.g., for a subsidiary or a third party), you are located in a third country and receive international data transfers of personal data (protected by the GDPR, Member State law or European Economic Area law), and you are therefore a (Sub)Processor, by conducting business for or with us, you automatically consent to the applicability of the published Standard Contractual Clauses 2021/914 Module Three. The same applies if you act as a Processor and transfer personal data to us as a (Sub)Processor.
- EU Standard Contractual Clauses 2021/914 MODULE FOUR: Transfer Processor to Controller:
To the extent that you are a vendor of ours and we are acting as a Processor (e.g., for a subsidiary or a third party), you are located in a third country and receive international data transfers of personal data (protected by the GDPR, Member State law or European Economic Area law), and you are a Controller, by conducting business for or with us, you automatically consent to the applicability of the published Standard Contractual Clauses 2021/914 Module Four. The same applies if you act as a Processor and transfer personal data to us as a Controller.
- Confidentiality and Data Protection Agreement for Vendors:
If you are a vendor of ours that is not a processor, or if you receive other and non-personal data from us, by conducting business for or with us, you automatically consent to the applicability of the published Confidentiality and Data Protection Agreement for Vendors.
- Confidentiality and Data Protection Agreement for Customers:
If you are a customer of ours and data is exchanged between us, we may separately agree to the published Confidentiality and Data Protection Agreement for Customers by a concurring statement. This Confidentiality Agreement shall only become effective upon a separately declaration of intent by the parties.
- International Data Transfer Agreement (United Kingdom):
To the extent that you are a party to an agreement with us, and personal data transferred by us to you belongs to individuals who are from the United Kingdom or we are based in the United Kingdom, and you yourself are based outside the United Kingdom and receive personal data (protected by the UK GDPR or UK law) from us, by conducting or transacting business for or with us, you automatically consent to the applicability of the published “International Data Transfer Agreement”.
- International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses for International Data Transfers (United Kingdom):
To the extent that you are a party to an agreement with us, and personal data we transfer to you belongs to individuals who are based in the UK or where we are based in the UK and you yourself are based outside the UK and receive personal data (which is protected by the UK GDPR or UK law) from us, by carrying out or transacting business for or with us, you automatically consent to the applicability of the published ” International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses for International Data Transfers”.
- Data Processing Agreement for the United Kingdom:
To the extent that you are a party to an agreement with us, and both we and you have our registered office in the United Kingdom, and you process personal data (which is protected by the UK GDPR or UK law) on our behalf, you automatically agree to the applicability of the published “Data Processing Agreement for the United Kingdom” by executing or conducting business for or with us. The same applies if you act as a Controller and transfer personal data to us as a Processor.
- CCPA-CPRA CONTRACTOR AGREEMENT for California:
To the extent that you are a contractor of ours, and we or you have a place of business in California, or employ or engage employees, service providers, processors, or other persons from California, and if the Contractor processes consumer data protected by CCPA-CPRA or California law as part of the relationship, you automatically enter into the CCPA-CPRA CONTRACTOR AGREEMENT published by us with us by each execution or handling of business, either as a Business or as a Contractor.
A list of our sub-processors must be requested separately from us.
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Transfers to the United States via EU-U.S. Data Privacy Framework
The European Commission adopted the EU-U.S. Data Privacy Framework on July 10, 2023.
The EU-U.S. Data Privacy Framework is an adequacy decision that allows transfers of personal data from the European Economic Area (EEA), which includes the 27 EU member states and Norway, Iceland, and Liechtenstein, to any U.S. company that has undergone a specified self-certification process. U.S. companies certified through the EU-U.S. Data Privacy Framework are listed on the following website:https://www.dataprivacyframework.gov/s/participant-search
Until the EU-U.S. Data Privacy Framework is invalidated by the Court of Justice of the European Union (CJEU) or the European Commission, or superseded by a new adequacy decision, the Controller will transfer Personal Data from the EEA to all companies certified through the EU-U.S. Data Privacy Framework and identified in this Privacy Policy or in the List of Processors and Data Recipients based on the EU-U.S. Data Privacy Framework. These transfers are permitted under Article 45 GDPR.
The Controller points out that in the case of transfers based on the EU-U.S. Data Privacy Framework, neither an analysis of the legal situation in the recipient country (so-called Transfer Impact Assessment) nor supplementary measures, such as encryption to protect transferred personal data from access by U.S. authorities, are required or implemented.
The EU-U.S. Data Privacy Framework obligates certified companies from the U.S. to comply with defined data protection principles, which are based on the requirements of GDPR, and to fulfill data subject rights (e.g., right of access and deletion).
Data Subjekts from the EEA who believe that the requirements of the EU-U.S. Data Privacy Framework are not being observed by a certified U.S. company may complain to the European Data Protection Authority responsible for them. This Data Protection Authority will forward the complaint to the European Data Protection Board, which subsequently transmits it to the U.S. authority responsible for handling the complaint.
EEA Data Subjects also have legal remedies before independent arbitration bodies in the United States.
If the Controller is based in the U.S. and certified under the EU-U.S. Data Privacy Framework, the Controller acts as a data importer and complies with the requirements of the EU-U.S. Data Privacy Framework.
If you have any questions about the EU-U.S. Data Privacy Framework, you may contact the Data Protection Officer of the Controller at any time.
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E-mail advertising to customers or prospective customers
We may send you advertising using electronic mail in corresponding application of Section 7 (3) of the German Unfair Competition Act (UWG) if the advertising is in connection with the sale of products or services from us, if we received the electronic mail address from you, and use this address for direct advertising for our own similar goods or services, and you have not objected to the use. You were clearly informed when the address was collected and will be clearly informed each time it is used that you can object to the use at any time without incurring any costs other than the transmission costs according to the basic rates.
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Webinars and Online-Meetings
We organize webinars and invite customers, prospective customers, service providers and suppliers, including their and our employees, to online meetings. We use different third-party providers (operators of online meeting applications, application providers). Which third-party provider we use for a specific webinar or online meeting is recognizable from the participation link. You can find the privacy policy and, if applicable, additional legally required information on the website of the respective third-party provider.
By registering, accepting, and/or participating in a webinar or online meeting, you explicitly consent to your personal data being processed for the purposes of registering, planning, organizing and conducting the webinar or online meeting, which includes transfers to third-party providers (which may be located in a third country), and to audio, film or photo recordings being transmitted and/or published, and/or published to other participants as part of the webinar or online meeting.
By a single action, you give multiple consents. By registering, accepting, in and/or participating, you also voluntarily give your explicit consent pursuant to 49 (1) (1) (a) GDPR for data transfers to third countries for the purposes of registration, planning, organization and implementation of the webinar or online meeting, in particular for such transfers to third countries for which an adequacy decision of the EU/EEA is absent or does exist, and to companies or other entities that are not subject to an existing adequacy decision on the basis of self-certification or other accession criteria, and that involve significant risks and no appropriate safeguards for the protection of your personal data (e.g., because of Section 702 FISA, Executive Order EO12333 and the CloudAct in the USA).
We hereby inform you in advance regarding your voluntary and explicit consent that in third countries there may not be an adequate level of data protection and that your data subject rights may not be enforceable, and that published personal data may not be deleted, may not be altered or may not be made anonymous at all, only conditionally and/or with a delay. You give your consent voluntarily. You are not obligated to give consent and may choose to stay away from or not participate in the webinar or online meeting, which we will consider a refusal of our request to give consent.
You have the right to withdraw your data protection consent in whole or in part at any time with effect for the future, in particular by deactivating, switching off or not activating your sound, film or photo transmissions during the webinar or online meeting. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. By your action, you also confirm that you have read and acknowledged this Privacy Policy and the transparency document linked in it.
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Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.