Tietosuojakäytäntö

Privacy Policy and Cookies Policy

Protecting your personal data (referred to below as 'data') is a matter of great importance and concern to us. Consequently, we would like to explain in greater detail which data are collected when you visit our online services (website, social media pages, blog), referred to below as 'Websites', and how these data are then processed. We would also like to inform you of your rights and the technical and organisational measures we have taken to ensure your data is processed securely.


This Privacy Policy satisfies the disclosure requirements according to Art. 12 ff. of the EU General Data Protection Regulation (“GDPR”) and provides an overview of the processing of your personally identifiable information (“personal data”, “personal information”) on this website.


1. Who is accountable for processing my personal data?

Arvato infoscore GmbH
Rheinstraße 99, 76532 Baden-Baden
Phone  +49 (0) 7221/50 40-0
Email: info@arvato-finance.com

is responsible for the processing of your data on the website.

You can contact the Arvato Financial Solutions data protection officer at the above-mentioned postal address with the addition "To the data protection officer" or by using the email address datenschutz@arvato-infoscore.de.


Important note:

You can request a personal credit information at the infoscore Consumer Data GmbH (an entity within the Arvato Financial Solutions group) via the following link: https://finance.arvato.com/en/verbraucher/selbstauskunft.html. Only the infoscore Consumer Data GmbH will have access to your postal credit information or your online form and hence be controller as enshrined in Art. 4 no. 7 GDPR. There will be no data transfer within the company group. 

Arvato infoscore GmbH (hereinafter "we" or "us") process personal data in accordance with the provisions of the GDPR and the Federal Data Protection Act (hereinafter "BDSG").

 

2. What data is collected?

In connection with your visit to the website and solely for technical, contractual or legal reasons, your data will be collected in order to be able to display the desired content and to enable you to use the offers.

If you browse our websites by your PC, certain information are collected simply for technical reasons of data flows (technical data). These technical data contain details about the content requested by you on the website and your usage behavior as well as information about the browser type and browser version, the operating system, the Internet service provider, the date and time of use of the website, the previously visited websites and newly accessed websites via the website and the IP address of the computer (also called "server log files"). Pseudonymous user profiles are created and evaluated from the access data with the help of web tracking. In principle, it is not possible for us to draw any conclusions about you personally.

The scope, nature of collection and use of your data differs depending on whether you visit our Websites simply to access information or whether you use services on our Websites which require the provision of additional information, for example, if ordering a newsletter, downloading a white paper, ebooks, Business Insights or using a contact form. In general, you can use the website without providing your data, for example to inform yourself about us. However, when using certain services, it is necessary to provide your data like name, address, e-mail address or phone number, for example to contact us or to order a newsletter. Mandatory fields are regularly marked with *.

3. What cookies are used?

Cookies are used on our website. Cookies are small text files that are saved to your computer when visiting a website. The cookies that are saved can be attributed to the web browser used by you. When the website is visited again, the web browser returns the content of the cookies, thus enabling you, the user, to be recognized. Cookies are limited to a certain runtime (e.g. expiration of the browser session). You can also configure and delete cookies according to your preferences via your browser settings. However, premature deletion may result in limited availability of the offers on the website.

The website distinguishes between two types of cookies: functional cookies and optional cookies. Functional cookies are used to provide the website in a technically and functionally flawless manner (e.g. identification and authentication of the user, language settings, display of image recordings). Without the function-related cookies, the offerings of the website are only available to a limited extent. The optional cookies help to optimize the offers on the website by recording user behavior and evaluating it in statistical form.

As a general principle, cookies enable online recognition without reference to a specific per-son. Cookies can be related to individuals if the information generated by the cookies is combined with other data such as access data (e.g. when using web tracking). Such a combination only takes place in pseudonymised form, i.e. your data do not allow any direct conclusions to your person or on the basis of your consent.

  1. Which cookies are used on this website?

Cookies are used on our website. Cookies are small text files that are saved to your computer when visiting a website. The cookies that are saved can be attributed to the web browser you use. When the website is visited again, the web browser returns the content of the cookies, thus enabling the user to be recognised.  Cookies are limited to a given period (e.g. closing of the browser session). You can also configure and delete the cookies according to your preferences via your browser settings. If you delete the cookies prematurely, however, you may not be able to use all the features of our website.

The website differentiates between three types of cookies: required cookies, function-based cookies and advertising cookies. The required cookies are used to ensure the website functions smoothly from a technical and functional perspective (e.g. identification and authentication of the user, language settings, displaying visual recordings). Without the required cookies, the website services will only be available on a limited basis. The functional cookies help the optimisation of the website services, whereby the user behaviour is logged and analysed in a statistical form. Advertising cookies are used to show your ads that are relevant for you or receive personalized content based on your interests.

 

4.1 Web tracking

Services are built into the website to optimise the user friendliness and measure the reach of the website. Your access data (see section 2) will thus be logged and the user behaviour analysed with the help of analysis cookies (see section 3). Personal identification is not generally necessary for web tracking, which means that when your access data is logged, the saved IP address is either not used or only used in abbreviated form (abbreviation of the last octet) and anonymous user profiles created. This will generally not be combined with other data and you have the right to object at any time. Personal user profiles will only be created in exceptional cases and if you have consented.

Web tracking is usually conducted by involvement of service providers who process user profiles on our instruction and not for their own purposes. This is ensured by way of data processing agreements. If the service provider is based outside the European Union or the European Economic Area (hereinafter referred to as ‘EU’ or ‘EEA’), a third country transfer will take place. This is permitted if you have consented to this, we have established safeguards of an adequate level of data protection or the EU Commission has classed the relevant third country as a safe third country. The third country transfer of the relevant service is indicated below. You can obtain further information about the recipients of your data and the third country transfer in section 6 and section 7.

 

4.1.1 Adobe Launch

This website uses Adobe Launch for purposes of functionality. This service is provided by Adobe Systems Software Ireland Limited, 6 Riverwalk Naas Road Dublin 24, Ireland (Adobe). Adobe Launch manages the web tracking services embedded in this website using ‘tags’ (placeholder for website code). Adobe Launch only implements these tags. Cookies are used and Adobe Launch does not log specific data. The Adobe Tool Manager only releases other tags, which in turn may log data. Adobe Launch cannot however access this data.

 

4.1.2 Adobe Analytics (Omniture)

This website uses Adobe Analytics, a service provided by Adobe Systems Software Ireland Limited, 6 Riverwalk Naas Road Dublin 24, Ireland (Adobe). Adobe Analytics creates an anonymous user profile to optimise the user-friendliness of the website. The anonymity is assured in that prior to transferring your data to Adobe, the IP address is abbreviated by the last octet and your personal identification is not possible. The anonymous user profile is analysed after transfer for the purposes of optimising the user-friendliness. Adobe does not combine this data with other data. Under a data processing agreement, the company ensures that Adobe only processes the data on its instructions.

You can object to the use of Adobe Analytics at any time by changing your browser settings and/or clicking on the following link to download and install the available browser plugins: http://bertelsarvatoprod.d3.sc.omtrdc.net/optout.html.

You can find further information on data processing by Adobe Analytics in Adobe's privacy policy: https://www.adobe.com/de/privacy/policy.html.

4.1.3 Adobe Audience Manager

This website uses Adobe Audience Manager, a service provided by Adobe Systems Software Ireland Limited, 6 Riverwalk Naas Road Dublin 24, Ireland (Adobe). Adobe Audience Manager creates cross-channel anonymous target group profiles to address potential customers. The anonymity is assured in that prior to transferring your data to Adobe, the IP address is abbreviated by the last octet and your personal identification is not possible. The anonymous target group profile is analysed after transfer for the purposes of optimising the content-presentation. Under a data processing agreement, the company ensures that Adobe only processes the data on its instructions.

You can object to the use of Adobe Audience Manager at any time by changing your browser settings and/or clicking on the following link to download and install the available browser plugins: https://www.adobe.com/de/privacy/opt-out.html.

You can find further information on data processing by Adobe Audience Manager in Adobe's privacy policy: https://www.adobe.com/de/privacy/opt-out.html.

 

4.1.4 Google Ads

We use the ‘Google AdWords Conversion’ function provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Adwords Conversion enables our website to be included in the Google search results and on the websites of other providers who also participate in the Google advertising network. For this purpose, Google saves a cookie when you visit our website, which automatically enables interest-based advertising within the scope of the Google advertising network by way of an anonymous cookie ID and on the basis of your access data. If you are redirected to our website via a Google ad on another website, Google will also place a cookie on your computer. These Google cookies generally become invalid after 30 days and do not serve to identify you personally. These cookies merely allow Google to recognise your internet browser. If a user visits certain pages of the website within the Google advertising network and the cookie saved by Google has not yet expired, Google and the website provider can recognise that the user has clicked on the ad and was redirected to this website. Every website provider participating in the Google advertising network is assigned a different cookie by Google. Cookies can therefore not be tracked via the website of other website providers who also participate in the Google advertising network. For our part, we do not collect and process personal data as part of Google Adwords Conversion. We only receive statistical analyses from Google. On the basis of these analyses, we can recognise which of our advertisements are particularly effective in the Google advertising network. We do not receive any further information, and we cannot identify our users using this information. You can find further information on the advertising network of Google and Google’s privacy policy at: http://www.google.com/privacy/ads/

 

4.2  Marketing Automation
We use marketing automation on our websites. Our marketing automation tool cookie is used to track lead information about websites visited and links to websites that have been clicked.

This is done primarily in order to provide information that is tailored especially to your interests. You can prevent the use of these cookies (see also 5. Cookies). Please bear in mind, however, that in this case you may not be able to make full use of all functions and sending you information, which requires the provision of personal data (for example, name and e-mail address) via an online form, may no longer be possible.

Our marketing automation tool has EU-US Privacy Shield certification. The EU-U.S. Privacy Shield is a data protection agreement intended to ensure an appropriate level of data protection for data transfers to certified US companies. The EU Commission determined the guaranteed level of data protection according to the EU-U.S. Privacy Shield in its decision dated 12.07.2016 (Ref. no. C(2016) 4176).

The EU Commission's decision can be viewed here: http://eur-lex.europa.eu/legal-content/DE/TXT/?uri=uriserv:OJ.L_.2016.207.01.0001.01.DEU.

The current status of the certification according to the EU-U.S. Privacy Shield can be found here: https://www.privacyshield.gov/participant?id=a2zt0000000Gnm2AAC.

This information will be deleted after a maximum of two (2) years. The cookie is a so-called first-party cookie which is managed by our website.

Marketo RTP

These cookies are set by Marketo as part of its Web Personalization and ContentAI Products. They deliver customized content and features based on user choices, past browsing, and inferred information.

 

Marketo Munchkin (_mkto_trk)

This allows a website to track visitor behavior on the sites on which the cookie is installed and to link a visitor to the recipient of an email marketing campaign, to measure campaign effectiveness. Tracking is performed anonymously until a user identifies himself by submitting a form.F

4.2.1 Purposes and legal bases of data processing

The legal basis for logging and analysing anonymous user profiles is point (f) of Article 6(1) GDPR in conjunction with Section 15(3) of the Telemedia Act (Telemediengesetz, TMG). The legitimate interest of the company lies in optimising the user-friendliness of the website and the reach measurement.

4.2.2 Duration of storage or criteria for determining the duration

The data that is logged and analysed when using web tracking services is usually stored until you object to their use. The storage duration of analysis cookies is no more than 24 months.

 

4.3 External services and content

We incorporate external services or content in our website. If you use such a service or if third party content is displayed to you, communications data between you and the relevant provider may be exchanged for technical reasons.

The provider of the relevant services or content may also process your data for other purposes of its own. To the best of our knowledge and belief, we have configured services or content from providers who are known to process data for their own purposes so that either no communication takes place for purposes other than to display the content or service on our website or communication only takes place if you have actively decided to use the service. The final responsibility for the processing of data for other purposes shall at all times lies with the third-party provider.

 

4.4 Who receives my data?

At our company, your data will only be accessed by those parties who require it to fulfill the purposes set forth in section 4. Service providers we use may also receive access to your data (hereinafter ‘processors’). The processors support us with the provision and user-friendliness of the website, with the sending of newsletters and e-books as well as with the performance of customer surveys. They are bound by our instructions and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.

No data is transferred to other recipients such as advertising partners, providers of social media services or banks (‘third parties’) unless statutory provisions require this or if you have consented.

In connection with the participation in a newsletter, you consent and agree that your data will be transferred to the companies of the Arvato Financial Solutions. Internal data protection guidelines and joint management of data security ensures the confidential handling of your data and compliance with data protection law provisions. Data transfers for purposes other than those covered by consent or to other third parties do not take place.

4.4. Personalized Newsletter


4.4.1 Description and scope of data processing

There is the option on our Websites to subscribe to our free newsletter. In order to send this newsletter, we process the e-mail address, company name and country as provided based on the consent you give when registering. We use the 'double opt-in' procedure for newsletter registration. Once you have registered and given your consent, we will send a message to the e-mail address provided in which we ask for confirmation. In order to prevent the misuse of your data and demonstrate your consent, we store the access data recorded on registration as well as the confirmation message and the text used for this purpose. Once you have confirmed, you are registered for the newsletter and your data will be saved in our customer database.

The newsletter can be cancelled at any time with future effect using the unsubscribe link in the e-mail, for example.

                                                            

4.4.2 Personalised newsletter when downloading ebooks/white papers/studies

4.4.2.1 Description of processing

In return for free downloads of white papers/e-books/studies (referred to below as 'Content') covering current topics in our business areas, you consent to receive personalised newsletters.

In the context of this agreement, we will process your e-mail address, company name and country as provided in order to send a newsletter. We use the 'double opt-in' procedure for newsletter registration. Once you have registered, we will send a message to the e-mail address provided in which we ask for confirmation. In order to prevent the misuse of your data and demonstrate this agreement, we store the access data recorded on registration as well as the confirmation message and the text used for this purpose.

Once you have confirmed, you are registered for the newsletter and your data will be saved in our customer database.

The newsletter can be cancelled at any time with future effect using the unsubscribe link in the e-mail, for example.

 

The dispatch of our newsletter and the downloading of Content are aimed at advertising products, solutions and services from our business divisions (Fraud Management, Credit Risk Management, Payment and Financing Service and Debt Collection Services) to our business customers and informing them of events. We can only demonstrate such corporate diversity with the help of other companies in the Arvato Financial Solutions group of companies, which is why we are entitled, with your consent, to pass on our data within our group of companies for promotional purposes. An overview of the companies in the Arvato Financial Solutions group of companies is available here .

 

If you agree to receive our free personalised newsletter, we collect statistical data about the use of our web services in order tooptimise our services accordingly and adapt these (newsletter and other Content) to your requirements. One or more cookies are saved on your PC for this purpose. These are used to collect data for marketing and optimisation purposes and are saved and processed further on the servers of our marketing automation tools. The data collected may be combined with personal data provided by you voluntarily on the website in order to create a profile. You can object to the creation of a profile by disabling the cookie function in your browser. Further information can be found in Section 5.1.8 Marketing automation.

The website provides the option to register for free newsletters. For sending a newsletter, we will process your email address, company name and language based on your consent to use these data given in the course of registration. Further information regarding your name and sex are voluntary if you want to receive a personalized newsletter. For newsletter registration, we’re employing the so-called double opt-in procedure. That means, after registration and your consent, we will send a message to the email address provided by you, in which we ask for confirmation. In order to avoid data abuse and to provide evidence for your consent, we will store the access data collected during registration as well as the registration message and the texts used therefore. After your approval, you will be registered for the newsletter and your data will be stored in our customer database.

The free newsletter serves to approach (potential) business clients in a promotional manner to present information on products, solutions and services of our business units ID and Fraud Management, Credit Risk Management, Payment and Financing Services, Debt Collection Services and on events. This variety of business offerings can only be displayed with the help of further entities within the Arvato Financial Solutions group. Thus, we are entitled with your consent to forward your data for further promotional measures within our group. You can find an overview of the entities within the Arvato Financial Solutions group here.

 

4.4.2 Purpose and legal basis of data processing

The free newsletter serves to approach (potential) business clients in a promotional manner to present information on products, solutions and services of our business units ID and Fraud Management, Credit Risk Management, Payment and Financing Services, Debt Collection Services and on events. Legal basis for processing your data in registration for and participation in the newsletter this is your consent pursuant to Art. 6(1)(a) GDPR.

4.4.3 Duration of storage or criteria applied in defining this period

Your information is stored for the time of subscription. In case of newsletter inactivity or if you revoke your consent, your data and consent will be stored to be able to prove that we have complied with our legal obligations – to collect your data only upon valid consent. Data processing for the use in further promotional activities will not take place any longer. 

4.4.4 Options for lodging an objection and having your data removed:

You can revoke your consent at any time by writing to Arvato infoscore GmbH via E-Mail newsletter-abbestellung@arvato-finance.com or via mail to „Rheinstraße 99, 76532 Baden-Baden“.

 

4.5. Newsletter following download of e-books, whitepapers, and studies

4.5.1 Description and scope of data processing

Apart from registering for our newsletter, the website offers the download of free e-books/whitepaper on current topics from our business segment. Only the provision of your professional e-mail address is required for the download. If, on the other hand, you wish to be contacted in a company-related and/or personal manner, you can also provide information about yourself and/or your company. After entering your data and giving your consent, you will be able to download the information. Your data will be stored in our customer database.

The free download of e-books also serves to approach (potential) business clients in a promotional manner to present information on products, solutions and services of our business units ID and Fraud Management, Credit Risk Management, Payments and Financing Services, Debt Collection Services and on events. This variety of business offerings can only be displayed with the help of further entities within the Arvato Financial Solutions group. Thus, we are entitled with your agreement to forward your data for further promotional measures within our group. You can find an overview of the entities within the Arvato Financial Solutions group here.


4.5.2 Purpose and legal basis of data processing


The free download of e-books on current topics from our field of business serves to present our company’s activities, to facilitate interested parties with scientific study results and to approach (potential) business clients in a promotional manner to present information on products, solutions and services of our business units ID and Fraud Management, Credit Risk Management, Payment and Financing Services, Debt Collection Services and on events. Legal basis for processing your data in registration for and participation in the newsletter this is your consent pursuant to Art. 6(1)(a) GDPR.

Your information is stored during your participation in the newsletter. In case of newsletter inactivity or if you revoke your consent, your data and consent will be stored to be able to prove that we have complied with our legal obligations - to let you consent to data processing. Data processing for the use in further promotional activities will not take place any longer.


4.5.3 Options for lodging an objection and having your data removed

You can revoke your consent at any time by writing to Arvato infoscore GmbH via E-Mail newsletter-abbestellung@arvato-finance.com or via mail to „Rheinstraße 99, 76532 Baden-Baden“.

4.6. Business customer survey

4.6.1 Description of the processing

If you have a business relationship with us, we shall occasionally use your data to conduct a customer survey to gauge your satisfaction with our services and to show potential for improvement. Participation in the survey is voluntary and shall only occur for customers who gave us their consent when the business relationship was established. The survey is conducted via service providers who are bound to our instructions as processors. We have assessed them pursuant to data protection law prior to commencing the survey.

4.6.2 Purposes and legal bases of data processing

The purpose of the survey is to improve our products, services and as such establish and maintain good customer relations. The basis for this survey under data protection law is found in point (f) of Article 6(1) GDPR. Our legitimate interest lies in that we wish to offer our customers a regular and efficient channel to make criticism so that we can adapt our services accordingly.

4.6.3 Duration of storage or criteria for determining the duration

The data used are stored in our CRM system for the duration of our contractual relationship. After the termination of our contractual relationship, the data shall only be used for a final customer satisfaction survey and then blocked for this purpose.

4.6.4 Right of objection and removal

You have the right to withdraw your consent to the use of your data for the purposes of the business customer survey at any time. You will find a note to that end in every e-mail inviting you to participate. You also have the right to object to the processing. You also have the right to request the erasure of your data pursuant to Article 17 GDPR. Furthermore, you have to right to rectification and of access to the data we store.

In order to exercise your rights as a data subject, please send a message to the contact address mentioned in section 1.

 

4.7. Application for employment

4.7.1 Description and scope of data processing

Job advertisements are published on the website. Via the job advertisement you will be forwarded to our applicant portal, which collects and processes your data for recruitment purposes. Therefore, the actual data processing for online application processes will not take place on this website. Further information about data processing for recruitment purposes can be obtained in the applicant portal. Responsible for the job opening is the company that has published the job opening and is looking for new employees. Thus, this company is usually the entity that will receive your data sent in with your application. There will be no transfer of data to further entities unless legally required or based on your consent.

Basic information on responsible individuals, the scope of data processing and the respective legal basis as well as possible receivers and storage periods can be found in the respective job offer. Further details on data processing for the respective online application process will be provided at your registration and applicant profile creation.

4.7.2 Purpose and legal basis of data processing

By handing in your online application for a specific job opening, your data will be processed for recruitment purposes. In the phase on contract initiation for employment, your potential employer is interested in securing that you have the competencies and individual qualification to fill in the vacancy. The legal basis is Art. 6 sec. 1 lit. a GDPR.

4.7.3 Duration of storage or criteria applied in defining this period

Data processing takes place as long as is required to justify an employment. After the online application and the decision for employment have been finalised, your data will be deleted after the end of the legal storage period (currently regularly six months).

4.7.4 Options for lodging an objection and having your data removed

Processing your data is necessary for the justification of employment, therefore pre-contractually. Hence there is no option for objections.


4.8 Webtracking

The website includes services that optimize user-friendliness and measure the reach of the website. Your access data (see paragraph 2) is recorded and the usage behaviour is evaluated with the help of cookies (see paragraph 3). Personal identification is generally not required for web tracking, so that when your access data is recorded, the stored IP address is either not used or only used in abridged form (shortened by the last octet) and pseudonymous user profiles are created. This data will not be merged with other data and you have the possibility of revocation at any time. Personal user profiles are only created in exceptional cases and if you have given your consent.

The web tracking services are regularly provided by service providers who process the pseudonymous user profiles only according to instructions and not for their own purposes. This is ensured by means of contracts for order processing. If the service providers are established outside the European Union or the European Economic Area (hereinafter referred to as "EU or EEA"), a so-called third country transfer takes place. This is permissible if you have given your consent, if we have created guarantees for a level of data protection that meets European standards or if the EU Commission has classified the respective third country as a safe third country. The third country transfer of the respective service is identified below. Further information on the recipients of your data can be found in paragraph 6 and paragraph 7.


4.8.1 Adobe Tag Manager

This website uses Adobe Tag Manager. Adobe Tag Manager is a service provided by Adobe Systems Software Irland Limited, 6 Riverwalk Naas Road Dublin 24, Ireland (Adobe). Adobe Tag Manageronly  manages „tags“ (placeholder for website code). Adobe Tag Manager does not use cookies, does not collect data and data collected by the tags cannot be accessed by the Adobe Tool Manager.

4.8.2 Google Analytics

This website uses Google Analytics. Google Analytics is a service provided by Google Inc. Google Analytics causes a usage profile to be created in order to optimize the user-friendliness of our website. A pseudonym is assigned to this profile. In so doing, your access data is collected as described in section 2 and your usage behaviour analyzed using analytics cookies as described in section 3. Personal identification is not necessary for web tracking: when collecting your access data your IP address is shortened before being transmitted to Google Inc., meaning no information can be attributed to you. These usage profiles to which pseudonyms are assigned are analyzed for the purpose of optimizing user-friendliness. This data is not merged with other data by Google Inc. We ensure that Google Inc. only uses this data as instructed by us under a contract data processing contract we have concluded with Google Inc

With the use of Google Analytics, a third-country transfer is occurring. However, Google is ensuring through a certification in accordance with the EU-US Privacy Shield that the European level of data privacy is warranted at the site of the recipient. Further information on third-country transfer can be found at paragraph 7.

You can always dissent the use of Adobe Audience Manager by changing your browser settings and / or using the following link to download and install available browser plugins http://bertelsarvatoprod.d3.sc.omtrdc.net/optout.html.

For more information on data processing related to Google Analytics, refer to the Google’s privacy policy: 
https://policies.google.com/privacy?hl=en
.

4.8.3 Adobe Analytics (Omniture)

This website uses Adobe Analytics. Adobe Analytics is a service provided by Adobe Systems Software Ireland Limited, 6 Riverwalk Naas Road Dublin 24, Ireland (Adobe). Adobe Analytics causes a usage profile to be created in order to optimize the user-friendliness of our website. A pseudonym is assigned to this profile. In so doing, your access data is collected as de-scribed in section 2 and your usage behaviour analyzed using analytics cookies as described in section 3. Personal identification is not necessary for web tracking: when collecting your access data your IP address is shortened before being transmitted to Adobe meaning no in-formation can be attributed to you. These usage profiles to which pseudonyms are assigned are analyzed for the purpose of optimizing user-friendliness. This data is not merged with other data by Adobe. We ensure that Adobe only uses this data as instructed by us under a con-tract data processing contract we have concluded with Adobe.

You can always dissent the use of Adobe Audience Manager by changing your browser settings and / or using the following link to download and install available browser plugins: http://bertelsarvatoprod.d3.sc.omtrdc.net/optout.html . 

For more information on data processing related to Adobe Analytics, refer to the Adobe privacy policy:
https://www.adobe.com/de/privacy/policy.html.

4.8.4 Adobe Audience Manager

This website uses Adobe Audience Manager. Adobe Audience Manager is a service provided by Adobe Systems Software Irland Limited, 6 Riverwalk Naas Road Dublin 24, Ireland (Adobe). Through Adobe Audience Manager, cross-channel, pseudonymous target profiles are created to address interested parties. A pseudonym is assigned to this profile. In so doing, your access data is collected as de-scribed in section 2 and your usage behaviour analyzed using analytics cookies as described in section 3. Personal identification is not necessary for web tracking: when collecting your access data your IP address is shortened before being transmitted to Adobe meaning no in-formation can be attributed to you. These usage profiles to which pseudonyms are assigned are analyzed for the purpose of optimizing user-friendliness. This data is not merged with other data by Adobe. We ensure that Adobe only uses this data as instructed by us under a con-tract data processing contract we have concluded with Adobe.

You can always dissent the use of Adobe Audience Manager by changing your browser settings and / or using the following link to download and install available browser plugins: http://bertelsarvatoprod.d3.sc.omtrdc.net/optout.html . 

For more information on data processing related to Adobe Analytics, refer to the Adobe privacy policy:

https://www.adobe.com/de/privacy/policy.html 

 

4.8.5 Google Ads

We use the "Google AdWords Conversion" function of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). We use Google Adwords Conversion to promote the site in Google search results and on the sites of other providers that also participate in the Google advertising network. When you visit our website, Google sets a cookie that automatically uses a pseudonymous cookie ID to enable interest-based advertising within the Google advertising network based on your access data. If you access our website via a Google ad on another website, Google will also set a cookie. These Google cookies usually expire after 30 days and are not intended to personally identify you. These cookies only allow Google to recognize your Internet browser. If a user visits certain pages of the website within the Google advertising network and the cookie stored by Google has not yet expired, Google and the website provider can recognize that the user has clicked on the ad and has been redirected to this website. Google assigns a different cookie to each website provider that participates in the Google advertising network. Therefore, cookies cannot be traced through the website of other website providers that also participate in the Google advertising network. We do not collect and process any personal data within the framework of Google AdWords Conversion. We only receive statistical evaluations from Google. These reports help us to determine which of our ads are most effective on the Google advertising network. We do not receive any further data, in particular we cannot identify our users on the basis of this information. For more information about Google’s advertising network and Google’s privacy policy, please visit: http://www.google.com/privacy/ads/.

 

4.8.6 Purpose and legal basis of data processing


The legal basis for collecting and analyzing pseudonym user profiles follows from Art. 6(1)(f) GDPR. We have a legitimate interest in optimizing the user-friendliness of our website and performing marketing reach measurements.

 

4.8.7 Hotjar

Our website uses Hotjar, an essentially tracking code based web- analysis-tool from Hotjar Ltd (Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta). Using Hotjar, interactions of randomly selected, individual visitors to our website are recorded anonymously. This results in a log of mouse movements and clicks, for example, with the aim of identifying potential improvements to our website-offering. In addition, information on the operating system, browser, incoming and outgoing links, geographical origin, as well as the resolution and type of terminal device accessing our website are evaluated for statistical purposes using Hotjar. The information collected is not personal, is stored by Hotjar Ltd. for max. six months and is not passed on to other third parties. Additional information on functions and data use via Hotjar can be found at: https://www.hotjar.com/privacy. If you do not wish a website analysis using Hotjar to be carried out, you can deactivate it on all websites that use Hotjar by setting a DoNotTrack header in your browser (Opt-out). For this purpose, follow the link: https://www.hotjar.com/opt-out.

Hotjar is fully committed to compliance with the GDPR. Read more: https://www.hotjar.com/legal/compliance/gdpr-commitment

 

4.8.8 Duration of storage or criteria applied in defining this period

As a general rule, the data that is collected and analyzed in association with Google and Ado-be Analytics remains stored until you raise an objection to it being used in this manner. Analytics cookies are stored for a maximum of 24 months.


4.9 External services and content on our website

We integrate external services and content on our website. If you use one of these services or you are shown the content of third parties, communication data is exchanged between you and the provider of that service or content for technical purposes.

That provider may use your data for their own purpose. To the best of our knowledge and belief, we have configured the services or content of third-party providers who are known to use data for their own purposes so that communication for purposes other than rendering their content or services on our website is prevented or communication does not come about unless you actively decide to use the service. However, since we have no control over the data collected by third parties and its processing by them we are unable to make any binding statements pertaining to the purpose and scope of the processing of your data.

For further information on the purpose and scope of the collection and processing of your data, please refer to the privacy policy of the responsible provider (under data protection law) of the services or content integrated by us:

YouTube: https://support.google.com/youtube/answer/7671399

Google Maps: https://maps.google.com/help/terms_maps.html

5. Who comes into possession of my personal data?

Within our company those who need access to your information for the purposes described in section 4 will be given access to it. Service providers contracted by us may also be given access to your information (“contract data processors”, e.g. data centers, mailing services for newsletters, web tracking). These contract data processors support us in providing our website, improving its user experience, by sending out newsletters and e-books as well as by carrying out customer surveys. They are bound by our directives and must provide for data security and the confidential treatment of your information under the contract data processing agreements we have concluded with them.

Sharing of information with other recipients such as advertising partners, providers of so-cial media services or credit institutions (“third parties”) only takes place if legal regulations require this or you have given your consent. When registering for a newsletter or ordering an e-book, you have given your consent that your dara will be transferred to the entities within the Arvato Financial Solutions group. Through internal data protection guidelines and a joint data protection management, the confidential management of your data and adherence to privacy rights is secured. A sharing of information for purposes than determined in the letter of consent as well as to further parties does not take place. 


6. Is my personal data processed outside of the EU or EEA (‘transfer to a third country)?

If the service providers and/or third parties mentioned under point 5 are located outside the EU or the EEA, this may result in your data being transferred to a country where an appropriate level of data protection cannot be guaranteed for the EU or the EEA. However, such a level of data protection can be ensured with an appropriate guarantee. Suitable guarantees include standard contractual clauses provided by the EU Commission. You can request a copy of these warranties on request under the contact details mentioned in section 1. Any guarantees may exceptionally be waived if you give your consent or the transfer to a third country is necessary for the fulfilment of our contractual relationship. The EU Commission has also recognised certain third countries as safe third countries, so that here too the company can refrain from providing suitable guarantees.

Through the use of Google Analytics, a third country transfer takes place. Generally, data is stored within the EU by Google. Only in special cases such as technical maintenance, Google can access the data temporarily from the US. However, with certification according to the EU-US Privacy Shield, Google ensures that the European data protection level is guaranteed for the transfer to third countries.

Also in case of promotional activities, a third country transfer takes place. On entity of the Arvato Financial Solutions group is located outside of the EU, namely in Switzerland. The EU commission has accepted Switzerland as a secure third country, therefore ensuring an adequate level of data protection for the EU.
 

7. What data privacy rights do I have?

You have the right to request access to your personal data that is currently stored by us. If this data is incorrect or not up to date, you have the right to request rectification. You also have the right to have your personal data erased and/or its processing restricted as provided for in Art. 17 and Art. 18 GDPR. You also have the right to request a copy of the personal data provided by you in a structured, commonly-used, machine-readable format (right to data port-ability).

If you have given your consent to the processing of your personal information for specific purposes, you can revoke that consent at any time for the future.

Pursuant to Art. 21 GDPR, you also have the right for reasons relating to your specific situation to object to the processing of your data.

You also have the right to object to the processing of your personal information for direct marketing purposes. The same applies to automated processes involving the use of individual cookies, unless they are required for providing the functionality of our website.

You also have the right to lodge a complaint with the competent data protection authority. The authority responsible for us is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Baden-Württemberg

Königstraße 10 a
70173 Stuttgart
0711 6155410
poststelle@lfdi.bwl.de


You also have the right to contact the data protection authority at your place of residence and request support in pursuing your matter.


 8. To what extent does automated decision-making take place?

We do not use any fully automated decision-making processes for any of the purposes set out in section 4.

 

9. Is profiling done?

No profiling takes place for any of the purposes set out in section 4.



Date of this Privacy Policy: 30 July 2018
Latest update: 6 November 2018

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