Data Protection and Privacy Policy

Preamble 

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 EU General Data Protection Regulation (“GDPR”), and in accordance with the country-specific data protection regulations applicable to Cargocoon. By means of this data protection declaration, our enterprise would like to inform the general public and our customers of the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed, using this data protection declaration, of the rights to which they are entitled as website users and customers. 

Cargocoon has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website and the mobile applications (also referred to as apps) offered by us. 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 or by mail. 

1. Definitions 

This Data Protection and Privacy Policy of Cargocoon is based on the terms used by the European legislator for the adoption of the GDPR. Our data protection declaration should be legible and understandable for the general public, as well as our customers and other 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: 

1. 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. 

1. b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by us. 

1. 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. 

1. d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future. 

1. 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. 

1. 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. 

1. 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. 

1. h) Processor

A processor is a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller. 

1. 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. 

1. 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. 

1. 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. 

2. Name and address of the controller 

Controller for the purposes of the GDPR, other data protection laws applicable in Member states of the European Union and other provisions related to data protection is: 

Cargocoon Netherlands BV 

Groothandelsgebouw  

Stationsplein 45 Unit A4.004 

3013 AK Rotterdam 

Netherlands 

Phone: +31 6 29 5777 29 

Email: info@cargocoon.com 

Website: www.cargocoon.com 

3. Name and Address of the Data Protection Officer 

Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection. 

Kristel van der Horst 

Stationsplein 45 A4.004 

3013 AK Rotterdam 

The Netherlands 

E-Mail: dataprotection@cargocoon.com 

4. Collection of general data and information 

The websites of Cargocoon and the mobile and tablet applications offered by us collect a series of general data and information when a data subject or automated system calls them up. 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, Cargocoon 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, Cargocoon 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. 

5. Registration for the Cargocoon Portal 

You have the possibility to register on our website for the Cargocoon Portal with the indication of personal data. Which personal data are transmitted to us is determined by the input mask used for the registration. For data minimization purposes, we have marked the personal data which is necessary for the registration with a (*). The personal data entered by the data subject are collected and stored exclusively for our internal use, and for own purposes. 

Offered services are 

Track & Trace European Road Freight 

Track & Trace Air- & Sea Freight 

Order Entry European Road Freight 

Freight Calculator European Road Freight 

Cargocoon may request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to Cargocoon. 

By registering on our website, the IP address—assigned by the Internet service provider (ISP) and used by the data subject—date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary for our protection s. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution. 

Your registration, with the voluntary indication of personal data, is intended to enable us to offer you contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from our data stock, insofar as there is no other legal basis for the further processing of the data (e.g. relating to interim order placements based on the provided data). 

We shall, at any time, provide you with information upon request as to what personal data are stored about you. In addition, we shall correct or erase personal data at your request or indication, insofar as there are no statutory storage obligations. The above-mentioned Data Protection Officer, as well as the entirety of our employees are available to you in this respect as contact persons. 

6. Subscription to our newsletters 

On our website, users are given the opportunity to subscribe to our enterprise’s newsletter. The subscription to the newsletter only requires the provision of your email address. 

Cargocoon informs its customers and other 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 our legal protection. 

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 our website, or to communicate this to us in a different way. 

7. Newsletter-Tracking 

The newsletter of Cargocoon 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, Cargocoon may potentially see if and when an e-mail was opened, and which links in the e-mail were called up, i.e. information on the number of website accesses resulting from the notice in the newsletter. 

Such data collected in the tracking pixels contained in the newsletters are statistically aggregated and not personally identifiable. Cargocoon exclusively stores and analyzes information on how often newsletters are opened and how often links in the newsletter are clicked, but no information on the email address of the specific recipient. This shall optimize the shipping of the newsletter, and adapt the content of future newsletters even better to the interests of the data subject. 

8. Contact possibility via the website 

Our website 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 us 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 Cargocoon are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties. 

9. Comments function in the blogs on the website 

Cargocoon provides some information to users also through blogs, on our website. A blog is a web-based, publicly-accessible portal, through which one or more people called bloggers or web-bloggers may post articles or write down thoughts in so-called blogposts. These blogposts may also be commented by third parties. 

If a data subject leaves a comment on one of our blogs, the comments made by the data subject are also stored and published, as well as information on the date of the commentary and on the user’s (pseudonym) chosen by the data subject. In addition, the IP address assigned by the Internet service provider (ISP) to the data subject is also logged. This storage of the IP address takes place for security reasons, and in case the data subject violates the rights of third parties, or posts illegal content through a given comment. The storage of these personal data is, therefore, in our own interest r, so that we can exculpate in the event of an infringement. This collected personal data will not be passed to third parties, unless such a transfer is required by law or serves the aim of our defense. 

10. Routine erasure and blocking of personal data 

Cargocoon 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 Cargocoon 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. 

11. Rights of the data subject 

You have the following rights with respect to your personal data: 

Right of access 

Right to rectification 

Right to erasure 

Right of restriction of processing 

Right to object 

Right to data portability 

If you wish to exercise one of the aforementioned rights, you may at any time directly contact our Data Protection Officer. 

You are also entitled to lodge a complaint with a supervisory authority to complain about the processing of your personal data by us. 

12. Data protection for applications and the application procedures 

We manage applications primarily via our application portal, which allows you at any time to access and correct the data processed by us. In this portal, you have the option to legitimate yourself on the basis of third party plugins/connectors, which are listed with the logos of these providers and identified by the associated tooltip (also: “quick info” or “mouse-over-text”). 

Please note that the use of a registration path via a third party provider requires an existing user account with the respective provider. These services and the associated data processing are exclusively offered, operated and developed by these providers at their own responsibility. If you voluntarily and independently use one of these services to facilitate the registration process in our application portal, the privacy policies of the respective third party provider must be observed. Please note, in particular, that the respective third party provider might become aware that you are interested in working for our company and might potentially disclose this information outside the European Union. We offer this type of registration exclusively at your own convenience. Cargocoon does not collect any data from the respective third party provider. The utilisation or non-utilisation of this function has no effect on the success of your application. 

We process your personal data to establish an employment relationship, if and as far as this is necessary for the decision on the establishment of an employment relationship with us. The legal basis for this is Section 26 para 2 in conjunction with para 8 sentence 2 German Federal Data Protection Act (“BDSG”). 

Your personal data will be treated confidentially and processed exclusively for the purpose of managing the application process, i.e. for recruitment, preparation of employment contracts and support of internal job placements. 

For the management of the application process it is indispensable that employees of HR, the relevant department and, if applicable, the competent bodies such as works councils (Betriebsrat) or the Representative Body for Severely Disabled Employees (Schwerbehindertenvertretung) have access to your personal data. 

In addition to the processing relating to your application for a specific position or a specific hiring date, your personal data will also be processed to contact you for other positions matching your profile, if and as far as you give your consent thereto. In this case, the processing includes access to your personal data by employees of the HR department as well as employees with the authority to make personnel decisions from other parts of the company or other Cargocoon group companies, insofar as this is necessary for the decision on the occupation of a position. 

The general retention and deletion periods apply. We store your personal data only if and as far as this is necessary for a decision on your application. Beyond that, we only process your personal data, if a statutory permission for such further storage applies. Such statutory permission may result, in particular, from tax law and accounting obligations or from the defense against potential claims, in particular under the General Equal Treatment Act (AGG). 

If you have not consented to the further processing of your personal data for other positions that may match your profile, we will delete your data no later than six months after completion of the application process. If you have consented to the further processing of your data for other positions or if you have submitted an unsolicited application without restrictions in time, we will store your personal data for a maximum period of three years as of the end of the calendar year in which you have given Cargocoon your consent or in which you have submitted your unsolicited application. In the event of a successful application, we will include your application documents into your personnel file. 

15. Application and use of various social media 

Cargocoon maintains various company profiles in different social networks and on similar platforms. This includes e.g. Facebook, Instagram, Twitter, Google+, LinkedIn and XING. 

These profiles shall promote the company and shall enable interested parties and customers to contact us. We constantly integrate links to these profiles or platforms into our website. With the exception of videos from the platform “YouTube” as well as the “Analytics” and “AdWords” services offered by Google as described in the following, we do not integrate any content from these service providers directly into our websites. 

In other words, no external content of such services is automatically loaded in case of access of our websites and no information on such access by our website visitors is disclosed to these service providers, unless you click on a specific link. 

If you click on the link, you leave Cargocoon’s websites. The services and the related processing of your personal data on the respective landing page are offered, operated and developed exclusively by the respective service provider at his own responsibility. Accordingly, the privacy policies of the respective service provider must be observed, which are beyond Cargocoon’s control. 

16. Data protection provisions about the application and use of Google Analytics 

On its websites, Cargocoon has integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising. 

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States. 

For the web analytics through Google Analytics, we use the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area. 

The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us. 

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by Cargocoon and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements. 

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties. 

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs. 

In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons. 

If and as far as mobile applications use Google Analytics, the function may be activated and deactivated directly in the data protection settings. 

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the following Link https://www.google.com/analytics/. 

17. Data protection provisions about the application and use of Google-AdWords 

On this website, the controller has integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords. 

The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES. 

The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google. Third-party advertising is not inserted on our website. 

If a data subject reaches our website via a Google ad and contacts Cargocoon via a form provided on our website, a conversion cookie is filed on the information technology system of the data subject through Google. The definition of cookies is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain forms were called up on our website. Through the conversion cookie, both Google and the controller can understand whether a person who reached an AdWords ad on our website contacted the company. 

The data and information collected through the use of the conversion cookie is used by Google to create visit statistics for our website. These visit statistics are used in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads in the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject. 

The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties. 

The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by means of a corresponding setting of the Internet browser used and thus permanently deny the setting of cookies. Such a setting of the Internet browser used would also prevent Google from placing a conversion cookie on the information technology system of the data subject. In addition, a cookie set by Google AdWords may be deleted at any time via the Internet browser or other software programs. 

The data subject has a possibility of objecting to the interest based advertisement of Google. Therefore, the data subject must access from each of the browsers in use the link www.google.de/settings/ads and set the desired settings. 

Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ 

18. Data protection provisions about the application and use of YouTube 

On this website, we have integrated components of YouTube. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and videos made by users via the Internet portal. 

The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES. 

With each call-up to one of the individual pages of our Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component. Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject. 

If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject. 

YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made. 

YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google. 

19. 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 Cargocoon (Recital 47 Sentence 2 GDPR). 

20. The legitimate interests pursued by Cargocoon 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. 

21. 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. 

22. Statutory or contractual requirement to provide personal 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 our Data Protection Officer. Our Data Protection Officer 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. 

23. Existence of automated decision-making 

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

This Privacy Policy is based on a declaration of the Privacy Policy Generator of the External Data Protection Officers that was developed in cooperation with the Media Law Lawyers from WBS-LAW. 

Date: 15 January 2024