Privacy Policy
Loan Link24 Mortgage GmbH
We, Loan Link24 Mortgage GmbH, take the protection of your personal data very seriously. When you visit our websites and/or use our services, personal data is processed by you. We treat your personal data in accordance with the legal regulations of the relevant data protection laws, in particular the European Data Protection Regulation (GDPR) and this Data Privacy Policy. This Data Privacy Policy covers the use of our digital offers including our social media profiles. Our digital offers may contain links to other offers of third party service providers to which this Data Privacy Policy does not refer.
1. Responsible party
1.1 Data processing under sole responsibility
If you have registered or would like to register as a user on one of our websites and for data processing in the context of our websites and the services we offer, Loan Link24 Mortgage GmbH is responsible for the data processing carried out by us or on our behalf. You can reach us at the following contact details:
Loan Link24 Mortgage GmbH
Kattrepelsbrücke 1
20095 Hamburg
datenschutz@bilthouse.com
If you have any questions regarding data protection at our company, please write to us at the aforementioned postal address, with the addition of "data protection" or at the e-mail address provided, or contact our data protection officer, Mr Malte Rheingans, directly at bilthouse@cogito.consulting| https://cogito.consulting.
1.2 Data processing under joint responsibility
Loan Link24 Mortgage GmbH also processes personal data under joint responsibility within the meaning of Art. 26 GDPR together with Hüttig & Rompf AG, Hanauer Landstraße 126 - 128, 60314 Frankfurt, Bilthouse GmbH, Kattrepelsbrücke 1, 20095 Hamburg, Baufi24 Baufinanzierungs AG, Kattrepelsbrücke 1, 20095 Hamburg, Bilthouse Service GmbH, Kattrepelsbrücke 1, 20095 Hamburg, FinLink GmbH, Köpenicker Str. 125, 10179 Berlin, Creditweb GmbH, Mathias-Brüggen-Str. 154, 50829 Cologne, and Kredit24 GmbH, Kattrepelsbrücke 1, 20095 Hamburg (together the "Parties"). In the context of joint responsibility for data processing, the Parties have concluded a contract pursuant to Art. 26 GDPR. There it is agreed that the Parties jointly process personal data in order to be able to optimally process and distribute customer enquiries within the Bilthouse Group. Baufi24, Hüttig & Rompf and Creditweb each acquire customers for their brand, but customers can be referred within the Bilthouse Group, in particular to ensure better, coordinated customer care and, if necessary, to be able to respond to excess enquiries. Furthermore, it was agreed that each of the parties is responsible for the data processing carried out by them, i.e. independently assumes all rights and obligations arising therefrom, including the processing of data subjects' rights. Nevertheless, data subjects can contact either party at any time with their concerns and claims using the contact details above.
- Purposes and legal bases of data processing
2.1 Data processing to provide our services
We process personal data in order to process contractual relationships and, if necessary, to be able to submit needs-based contractual offers. We collect and process personal data in particular to the extent that this is necessary for the provision of services in the context of the provision of the functionalities of our websites and/or to the extent that this is necessary for the performance of our contractual relationship. This concerns in particular the e-mail address, if applicable the name or the form of address chosen in order to be able to ensure that only registered persons have access to certain functions of our websites, to be able to provide user-specific optimized services and, if applicable, to be able to communicate regarding the use of our services.
In addition, we process data that is relevant in the counselling process. The personal data processed and used by us in this context are personal details/documents such as name, address, e-mail address, telephone number, marital status, occupation, personal financial circumstances and liabilities, income and expenses; details/documents on the object of financing or the use of funds of the loan; details/documents on the use of funds of the loan. details/documents on the financing object or the use of funds of the loan; details/documents on the financing and processing, e.g. balance, interest rate, term, disbursement requirements, application status, processing status as well as details/documents on the follow-up financing, e.g. remaining balance, instalment, interest rate, end of the interest rate commitment(s) as well as the current financing bank.
For all forms, we collect only those personal data that are absolutely necessary for the initiation or processing of the contractual relationship. The collection of data that is not absolutely necessary but in which we are interested in order to optimize the fulfilment of the purpose is only optional. In this case, it can be decided on a voluntary basis whether and which data we should receive.
The basis for data processing is Art. 6 (1) p. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.
2.2 Data processing in the context of construction financing
For the preparation of your offer for a construction loan, we make use of a network of specialised advisors. This network is supervised by the companies from our group of companies to which we transmit the data you provide for the preparation of the offer. Based on the data we provide, an advisor will be selected from the network to prepare your offer. In order for the advisor to prepare your offer and contact you, the data you entered on our website will be transmitted. You can find a description of how your project will be managed on these websites:
https://www.baufi24.de/finanzierungsablauf, https://www.huettig-rompf.de, https://www.creditweb.de, https://www.kredit24.de/, https://www.loanlink24.com/.
The basis for data processing is Art. 6 para. 1 p. 1 lit. b) GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.
Your advisor will contact you after receiving the data in order to further support you in your project. In this respect, she/he will act as a real estate loan broker. To find the right mortgage for you, your advisor uses special internet services that allow you to compare mortgages from more than 500 banks. This software is operated by third party service providers to whom your application data is transmitted to the extent necessary. Your advisor will provide you with the mandatory information for these service providers in accordance with Art. 14 GDPR.
The legal basis for the data processing for the preparation of the offer by your advisor is Art. 6 (1) b) GDPR, as the advice is provided in response to your request and serves to prepare the conclusion of a contract for the brokerage of a mortgage.
If you commission the advisor with the further support of your financing project, the legal basis for the corresponding processing of your data is Art. 6 Para. 1 b) GDPR, as it is carried out for the implementation of the corresponding contract.
2.3 Data processing in the context of the "Apply for an instalment loan" function
If you use the "Apply for instalment credit" function, you are using an offer from Kredit24 GmbH, Kattrepelsbrücke 1, 20095 Hamburg, which is integrated into our websites. The data protection provisions of Kredit24, available at https://www.kredit24.de/Datenschutz, the data protection provisions of the Europace marketplace, available at https://meinedatenschutzhinweise.de/SEN18.pdf.
The legal basis for the data processing for the preparation of the offer with regard to financing is Art. 6 (1) b) GDPR, as the data processing is carried out in response to your request and serves to prepare the conclusion of a contract for an instalment loan.
2.4 Data processing during the property search and transfer to partners
If you wish to use our ImmoPartner service, it is necessary for you to provide us with the necessary data on the property you are looking for. We use this data to find suitable property offers for you. For this purpose, the data is transmitted anonymously to our partners (e.g. estate agents, property developers, new building sales organisations, or construction companies) who provide these property offers.
The voluntary provision of personal data enables us to offer you content or services which, due to their nature, can only be offered to users who provide us with their personal data and details of their property search.
With your consent, in addition to the data relating to the property you are searching for, we will also forward to our partners an anonymised copy of your financing certificate, which your personal advisor has prepared for you. This is done to increase your chances of finding a property, as it provides our partners with information on your basic solvency. No personal data is transmitted to our partners in this process. The ImmoPartner service is only offered in the context of a personal consultation with one of our brokered financial advisors. With your consent, we will contact you by e-mail to send you the property offers received from our partners and to further support you in your project.
The legal basis for this use of your data is your consent in accordance with Art.6 Para. 1 S.1 lit. a) GDPR. Your consent can be revoked at any time with effect for the future. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
2.5 Data processing in the context of the customer account
When you create a customer account, we process the data you provide in order to manage the customer account and to enable you to use the services we offer in connection with your customer account.
In addition to the data you provide, depending on the use of our offers in connection with your customer account, further data may be processed. This includes, for example, calculation results for financing, financing questions and offers, property searches and valuations, communication with us and personal preferences.
The basis for data processing is Art. 6 (1) sentence 1 lit. b) GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual measures.
2.6 Data processing for communication purposes
In addition to the contractual data, we process communication data (name, address, telephone number, e-mail address) in order to process enquiries and/or to be able to contact data subjects and/or to send (possibly automated) notifications in the context of our contractual services. Personal data provided to us by email or any other communication channel we open will only be processed for correspondence with the data subject or for the purpose for which the data was provided to us. This may involve the following data: Surname, first name, address, company if applicable, IP address if applicable and date and time of sending if applicable.
The processing of this data is based on Art. 6 (1) lit. b GDPR, insofar as the communication is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of the enquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on consent (Art. 6 para. 1 lit. a GDPR) insofar as this has been obtained in this respect. You can revoke your consent at any time with effect for the future. You can declare the revocation by making the appropriate setting in the consent management tool used, if applicable, or by e-mail. The legality of the data processing operations already carried out remains unaffected by the revocation.
2.7 E-mail newsletter/advertising
If you wish to subscribe to an e-mail newsletter offered by us, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive e-mail notifications. If you do not declare your consent as a logged-in user, but via a publicly accessible form, we will send you an e-mail with a confirmation link to the specified e-mail address after your entry (double-opt-in). If you do not confirm your registration, your information will be blocked and automatically deleted after one month.
The only mandatory information for concluding such a subscription is your e-mail address. The provision of further, separately marked data is voluntary and is used to address you personally. In addition, we store your IP address and the time of registration and confirmation. The purpose of this procedure is to verify your registration and, if necessary, to be able to clarify a possible misuse of your personal data. We do not collect any other data in this context. We use this data exclusively for sending the requested e-mail notifications. Insofar as we use an order processor to send e-mails, we will of course comply with the applicable data protection laws.
The data processing is based on your consent pursuant to Art. 6 para. 1 p. 1 lit. a GDPR. You can revoke your consent to the sending of e-mail notifications at any time and cancel the respective subscription. You can declare the revocation by clicking on the link provided in each email or by sending a message to us using the contact details listed under point 1. The legality of the data processing operations already carried out remains unaffected by the revocation.
2.8 Data transfer to or processing by third parties
Users of our services may be given the opportunity to transfer data to third parties. This can take place within the framework of the fulfilment of a contract, for example in the case of a consultation request, or on the basis of consent. For this purpose, it may be necessary to actively select whether personal data should be transmitted to the respective third party.
If, for example, you submit an advisory enquiry via one of our websites, we transmit the data you have provided to our relevant cooperation partners who are named in the context of the transmission or in the run-up to the conclusion of the contract. The respective company is solely responsible for this data, the content of the data provided or generated and/or processed by the respective cooperation partner. If you have any questions regarding the handling of your data by or with this company, in particular in the case of enquiries relating to data protection law, please contact the respective company and take note of the data protection information of the respective company.
Third parties may use your data to contact you at a later date and thus for the purposes stated in the context of your order or your consent, e.g. for the purpose of consultation or for (pre-)contractual measures. The third party may then act as its own controller for the further processing of the data thus transmitted. Users must therefore contact the respective third party directly to assert their so-called data subject rights (see below on data subject rights).
Insofar as the processing of the above data is carried out for the purpose of initiating or implementing a contractual relationship, the legal basis is Article 6 (1) sentence 1 lit. b GDPR. Otherwise, data processing is based on consent pursuant to Art. 6 para. 1 p. 1 lit. a GDPR. Consent given can be revoked at any time with effect for the future. An informal communication to us and/or, if applicable, to the respective third party is sufficient for this purpose. The legality of the data processing operations already carried out remains unaffected by the revocation.
2.9 Cookies
We use so-called cookies on some of our websites/apps in order to be able to offer website-specific services.
Cookies are small text files that are stored on the user's terminal device and may contain data about the respective user in order to enable access to various functions, among other things. Cookies are stored on the respective end device used and may be read by us from here. Consequently, you have control over the use of cookies. By changing the settings, you may be able to deactivate or restrict the transmission of cookies and, for example, reject cookies from third parties or cookies in general. However, if you disable cookies for our services, you may not be able to use the functions or services offered or not to the full extent.
We use necessary cookies that are required to enable the provision of the services owed by us or to ensure the functionality of our services. The legal basis for the setting of these cookies is § 25 para. 2 no. 2 TTDSG. Any processing of personal data carried out in this context is then based on Art. 6 para. 1 p. 1 lit. b GDPR, which permits the processing of data for the performance of a contract or pre-contractual measures, or on Art. 6 para. 1 p. 1 lit. f GDPR, which permits the processing of data to safeguard the legitimate interests of the controller, unless the interests or the fundamental rights and freedoms of the data subject override the interest of the controller in the processing of the data. Our interest then lies in ensuring the provision of the functions of our services.
For the use of other, non-essential cookies, we may obtain your consent. The cookies are then set on the basis of your consent pursuant to § 25 (1) TTDSG, and any processing of personal data carried out in this context pursuant to Article 6 (1) sentence 1 lit. a GDPR. You can revoke your consent at any time. The legality of the data processing already carried out on the basis of your consent remains unaffected by the revocation.
2.10 Trustpilot
If you allow us to ask you to rate our financial advice, we will send you an email at a later date. In this email you will find a link to the corresponding page on one of our partners, ausgezeichnet.org or trustpilot.com. You are not obliged to provide a rating and can also revoke your consent at any time.
The legal basis for the processing is Art. 6 para. 1 a) GDPR. We delete the data that we require as proof that you have consented to the sending of the e-mail after the expiry of the limitation period for corresponding obligations to provide proof. In the event of a revocation, we will immediately delete your consent and the related personal data.
2.11 Google Analytics
On some of our web pages, Google Analytics may be used, integrated via the Google Tag Manager, a web analysis service of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (hereinafter referred to as "Google"), provided that you have consented to this data processing. Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States.
When you visit our website, we may assign you a so-called client ID. This client ID is reassigned for each browser you use if the corresponding cookie is not already stored in it. If you have a user account on our website, we will also assign you a user ID and, with your consent, link this to the client ID(s). Unlike the user ID, we cannot therefore specifically assign the client IDs to persons without a user account. The IDs are stored by means of a cookie with the name _ga. This cookie has a lifespan of 2 years. When you visit our website with the browser, this cookie is read by us in order to read out the ID(s) and restart the cookie's lifetime. As soon as you log in to our website, we can assign your previously pseudonymous client IDs to your unique user ID, even if the usage takes place in different browsers.
Using your pseudonymous client ID or - if available - your personal user ID, we then compile personalised statistics on how you use our website with your consent. We use the following data for this purpose:
- technical information on the browser and end device used (e.g. language setting, screen resolution)
- which website/advertising medium you used to access our website
- whether you carry out certain actions on our website, so-called conversions, such as requesting a financing offer or opening a customer account
- Your use of our website (which links are clicked on, how long you stay on a certain page, from which website you leave our offer again)
The analyses created in this way enable us to understand how you use our website and which advertising measures are successful. This allows us to optimise our website (in particular its structure, contents, functions) as well as advertising measures and thus our business success.
The personal data is stored for 14 months after your last use of our website. The deletion of data whose storage period has been reached takes place automatically once a month.
However, since IP anonymisation is activated on our website in the case of the use of Google Analytics, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google LLC server in the USA and shortened there. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage.
For more information on terms of use and data protection, please visit http://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies/. We would like to point out once again that the code "anonymizeIp" has been added to Google Analytics on this website to ensure anonymised collection of IP addresses (so-called IP masking).
Important in connection with data processing in the USA: In the opinion of the European Court of Justice, the data protection standard in the USA is inadequate and there is a risk that your data will be processed by US authorities, for control and monitoring purposes and possibly without any legal remedy.
The data processing explained above may be based on your consent pursuant to Art. 6 para. 1 p. 1 lit. a GDPR in conjunction with. Art. 49 para. 1 p. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future. You can declare the revocation by making the appropriate setting in the consent management tool used, if applicable. The legality of the data processing operations already carried out remains unaffected by the revocation.
2.12 Matomo
We may use the web analytics service Matomo to analyse the use and optimise our website. When used, Matomo creates an internal hash value for each visitor to the respective website, which is calculated from various factors such as the anonymised IP address, the resolution, the browser, the plug-ins used and the operating system. Unlike other statistical programmes, Matomo does not transmit any data to a third-party server. The IP address transmitted by the browser via Matomo is neither merged with other data collected by us nor passed on to third parties and is only stored anonymously. Within the scope of our web analysis with Matomo, no tracking cookies are set on the computer. If individual pages of our website are called up, the following data are processed: two bytes of the IP address of the calling system (anonymous), browser type and version, operating system used, the website called up, the website from which our website is visited (referrer URL) - if the browser does not prohibit this, the pages and files called up on our website, if applicable. the website visited after ours (when clicking on an external link on our website), the date and time of access, the time spent on the website, the frequency with which the website is accessed, the location (country).
The use of Matomo described above is based on Art. 6 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in analysing user behaviour in order to optimise our website and identify errors.
2.13 GoogleMaps
On some of our websites, we may use the mapping service Google Maps via an API. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
To use the functions of Google Maps, it is necessary to store your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transmission.
More information on the handling of user data can be found in Google's privacy policy: https://www.google.de/intl/de/policies/privacy/.
Important in connection with data processing in the USA: In the opinion of the European Court of Justice, the data protection standard in the USA is inadequate and there is a risk that your data will be processed by US authorities, for control and monitoring purposes and possibly without any legal remedy.
The data processing is then carried out on the basis of your consent pursuant to Art. 6 Para. 1 S. 1 lit. a GDPR in conjunction with. Art. 49 para. 1 p. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future. You can declare the revocation by making the appropriate setting in our Consent Management Tool. The legality of the data processing operations already carried out remains unaffected by the revocation.
2.14 Google Ads
We may use Google Remarketing Tags on some of our web pages. Provided you have consented to this data processing. These are services provided by Google which use cookies that are stored on your computer and enable an analysis of your use of the website. The information collected by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States, as explained in the preceding paragraph. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Third-party providers, including Google, place advertisements on websites on the Internet. Third-party vendors, including Google, use stored cookies to serve ads based on a user's previous visits to this website. Google will not associate your IP address with any other data held by Google. You can object to the collection and storage of data at any time with effect for the future. You can deactivate the use of cookies by Google by visiting the Google advertising deactivation page. However, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent. You can object to the collection and storage of data at any time with effect for the future. Further information on Google's terms and conditions can be found here.
For more information on terms of use and data protection, please visit http://www.google.com/analytics/terms/de.html or https://www.google.de/intl/de/policies.
Important in connection with data processing in the USA: According to the European Court of Justice, the data protection standard in the USA is insufficient and there is a risk that your data will be processed by US authorities, for control and monitoring purposes and possibly without any legal remedy.
The storage of Google cookies and the evaluation for statistical purposes is based on your consent pursuant to Art. 6 para. 1 p. 1 lit. a GDPR in conjunction with. Art. 49 para. 1 p. 1 lit. a GDPR. You can revoke your consent at any time. [If applicable: You can revoke your consent by making the appropriate settings in our Consent Management Tool or by clicking on the "Revoke" button.] You can declare the revocation by clicking on the aforementioned opt-out link, or by sending a message to the contact data mentioned under point 1 (e.g. e-mail, fax, letter). The legality of the data processing operations already carried out remains unaffected by the revocation.
2.15 Microsoft Advertising/Bing Ads
On some of our web pages, we use Microsoft Advertising, formerly Bing Ads, a web analytics service provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA ("Microsoft"), for website analysis. Provided you have consented to this data processing. Microsoft will set a cookie on your terminal device if you have accessed our website via a Microsoft advertisement. In this way, Microsoft and we can recognise that someone has clicked on one of our ads and has been redirected to one of our previously defined target websites. In addition, Microsoft may be able to track usage patterns across multiple electronic devices through cross-device tracking and thereby display personalised ads on Microsoft websites and in Microsoft apps. We only learn the total number of users who clicked on a Bing Ads ad and were then redirected to the relevant target website. Microsoft collects, processes and uses information via the set cookie, from which usage profiles are created using pseudonyms. These usage profiles are used to analyse visitor behaviour and are used to display advertisements. According to Microsoft, no personal information about the identity of the user is processed.
When visiting our website, you can prevent the collection of your data by Microsoft as explained above at any time by deactivating the setting of the cookie required for this via your Internet browser under user settings. You can also prevent the collection of the data generated by the cookie and related to your use of the website, as well as the processing of this data by Microsoft, by declaring your revocation under the following link http://choice.microsoft.com/de-DE/opt-out .
Further information on data protection and the cookies used by Microsoft and Bing Ads can be found on the Microsoft website https://privacy.microsoft.com/de-de/privacystatement and at https://about.ads.microsoft.com/de-de/ressourcen/Richtlinien/richtlinien-zur-datensicherheit-und-datnschutzerklaerung.
Important in connection with data processing in the USA: According to the European Court of Justice, the data protection standard in the USA is insufficient and there is a risk that your data will be processed by US authorities, for control and monitoring purposes and possibly without any legal remedy.
The storage of Microsoft cookies and the evaluation for statistical purposes are carried out on the basis of your consent pursuant to Art. 6 Para. 1 S. 1 lit. a GDPR in conjunction with. Art. 49 para. 1 p. 1 lit. a GDPR. You can revoke your consent at any time. You can declare the revocation by making the appropriate setting in our Consent Management Tool. The legality of the data processing operations already carried out remains unaffected by the revocation.
2.16 Data processing in the context of our Facebook company page & Facebook Pixel
We operate a company page (fan page) on the social network facebook.com ("Facebook") of the company Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. We are jointly responsible with Facebook for the operation of the Facebook fan page within the meaning of Art. 26 GDPR. The joint responsibility agreement can be found here: https://www.facebook.com/legal/terms/page_controller_addendum.
For the type and scope of the information you provide to Facebook, the associated purposes of data processing by Facebook, its lawfulness and information on exercising your rights, please refer to the data policy, as well as further information provided by Facebook on the processing of "Insights data". https://de-de.facebook.com/policy.php
Facebook provides us with so-called page insights for our site. Page Insights (https://www.facebook.com/business/a/page/page-insights) is aggregated data that helps us understand how people interact with our site. The generation and provision of these page insights is the responsibility of Facebook, over which we have no control. This also applies to the data processing, which is carried out exclusively for Facebook's purposes. Facebook also assumes all obligations under the GDPR with regard to the processing of Insights data (including Articles 12 and 13 GDPR, Articles 15 to 22 GDPR and Articles 32 to 34 GDPR).
The purpose of our data processing of the data provided by Facebook is the statistical evaluation of the use of our fan page. This enables us to determine, for example, preferred visiting and posting times of our users and to use this data to optimise our posts and our fan page. In addition, we process personal data made publicly available by you on Facebook (e.g. clear names in the user profile) as well as data directly related to activities on our fan page (e.g. contributions, posts, likes, marks), also for the purpose of communicating with you.
We also use Facebook Pixel for conversion measurement. This allows us to track the behaviour of visitors to our online activities when they have been directed to our offers by clicking on a Facebook ad. In this way, we can evaluate the effectiveness of our Facebook ads for statistical and market research purposes and optimise future advertising measures. The data collected in this way is anonymous for us and we cannot draw any conclusions about the identity of the users recorded in this way. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook data usage policy. This enables Facebook to serve advertisements on Facebook pages as well as outside of Facebook. This use of the data cannot be influenced by us as the site operator. You can deactivate the remarketing function "Custom Audiences" in the settings for advertisements at
https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you must be logged in to Facebook.
The basis for data processing is Art. 6 (1) p. 1 lit. b GDPR, which permits the processing of data for the performance of a contract or pre-contractual measures, insofar as the data are processed in accordance with the Facebook Terms of Use, otherwise, insofar as there is a data protection responsibility on our part, Art. 6 (1) p. 1 lit. f GDPR, which permits the processing of data for the protection of the legitimate interests of the controller, insofar as the interests or fundamental rights and freedoms of the data subject are not overridden. Our interest lies in providing content and communicating with Facebook users and improving the reach and effectiveness of our posts.
Please assert your rights to information, correction, deletion, restriction of processing and data portability of your stored Insights data against Facebook, as Facebook has assumed the corresponding obligations:
Meta Platforms Ireland Limited
4 Grand Canal Square
Dublin 2, Ireland
Privacy policy: https://www.facebook.com/about/privacy/
2.17 Data processing in the context of our LinkedIn company page
We have a company page on the social network linkedin.com of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland ("LinkedIn") and are provided with so-called page analytics by LinkedIn. We are jointly responsible with LinkedIn for this operation of the LinkedIn company page within the meaning of Art. 26 GDPR.
The type and scope of the information processed or provided by LinkedIn, the associated purposes of the data processing by LinkedIn, its lawfulness as well as information on the exercise of data subject rights can be found in LinkedIn's data privacy policy at the URL https://www.linkedin.com/legal/privacy-policy and in the joint responsibility agreement, which can be found at the URL https://legal.linkedin.com/pages-joint-controller-addendum. Page analytics involves aggregated data that allows us to understand how people interact with our pages. The generation and provision of these page analytics is the responsibility of LinkedIn, over which we have no control. LinkedIn assumes all obligations under the GDPR with regard to the processing of insights data (including Articles 12 and 13 GDPR, Articles 15 to 22 GDPR and Articles 32 to 34 GDPR).
The purpose of the data processing by us of the data provided by LinkedIn is the statistical evaluation of the use of our company page. This enables us, for example, to determine preferred visiting and posting times and to use this data to optimise our posts and our company page. In addition, we process personal data made publicly available on LinkedIn (e.g. clear names in the user profile) as well as data directly related to activities on our company page (e.g. contributions, posts, likes, marks), also for the purpose of communication.
The basis for the above data processing is nature 6 para. 1 p. 1 lit. a GDPR. Insofar as a corresponding consent has been given to LinkedIn, this consent can be revoked at any time with effect for the future. Insofar as consent has been granted to us in this regard, this consent can be revoked at any time with effect for the future. Otherwise, the basis for our data processing is nature 6 para. 1 p. 1 lit. f GDPR, which permits the processing of data to protect the legitimate interests of the controller, provided that the interests or fundamental rights and freedoms of the data subject are not overridden. Our interest is to provide content and communication with LinkedIn users and to improve the reach and effectiveness of our posts.
The rights of access, rectification, deletion, restriction of processing and data portability of stored insights data can be asserted against LinkedIn, as LinkedIn has assumed the corresponding obligations:
LinkedIn Ireland Unlimited Company
Wilton Place
Dublin 2
Ireland
Privacy policy https://www.linkedin.com/legal/privacy-policy
2.18 Data processing with Hubspot
We use the software HubSpot of the software company of the same name from the USA with the following branch in Ireland: HubSpot, Ground Floor, Two Dockland Central, Guild Street, Dublin 1, Ireland (hereinafter referred to as "Hubspot"). HubSpot is a software solution for the control and implementation of digital inbound marketing and for the management of customer relationships (so-called CRM = Customer Relationship Management). When you give your consent, Hubspot sets a cookie (see above) via your browser. In particular, this enables the identification and processing of your previous and subsequent website visits. Further information on cookies and how they work in general can be found in section 2.8 of this privacy policy. You can find more information in the terms of use and the privacy policy of HubSpot Inc. at http://www.hubspot.com/terms-of-service and at http://www.hubspot.com/privacy-policy. For more information on how HubSpot's specific tracking cookies work, please visit https://knowledge.hubspot.com/de/account/how-does-hubspot-track-visitors.
We may also use HubSpot's services to contact visitors to our website and to determine which of our company's services are of interest to them. We use all the information we collect exclusively to optimise our marketing. With the help of HubSpot, we may send automated e-mail notifications to registered users, such as welcome messages, but also - with the appropriate consent - newsletters about services and/or current promotions of our company. The following data may be processed for this purpose, if and to the extent specified: First name, last name, e-mail address, telephone number. The information is stored on HubSpot servers in the USA, among other places. As a processor of our company, HubSpot is contractually obligated to comply with the standards of the European Commission on data protection in the interest of a secure and data protection-compliant handling of your sensitive data. This is ensured through the use of so-called standard contractual clauses. You can find the exact regulations at https://legal.hubspot.com/dpa.
Important in connection with data processing in the USA: In the opinion of the European Court of Justice, the data protection standard in the USA is insufficient and there is a risk that your data will be processed by US authorities, for control and monitoring purposes and possibly without any legal remedy. However, the EU Commission's standard contractual clauses used in this case, as described above, are now intended to guarantee a European level of data protection.
The processing of personal data is based on your consent pursuant to Art. 6 Para. 1 S. 1 lit. a GDPR in conjunction with Art. 49 Para. 1. Art. 49 para. 1 p. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future. The legality of the data processing already carried out remains unaffected by the revocation. Insofar as the processing of the above data is carried out for the purpose of initiating or implementing a contractual relationship, the legal basis is Art. 6 para. 1 p. 1 lit. b GDPR.
2.19 Log files
Each time our websites are accessed, usage data is transmitted by the respective internet browser and stored in log files, the so-called server log files. The data records stored in this process contain the following data: Browser type and browser version, operating system used, referrer URL, time of server request, shortened IP address.
This data cannot be assigned to specific persons. This data is not merged with other data sources. We reserve the right to check this data retrospectively if we become aware of specific indications of unlawful use.
The basis for data processing is Art. 6 (1) sentence 1 lit. f GDPR, which permits the processing of data to safeguard the legitimate interests of the controller, provided that the interests or fundamental rights and freedoms of the data subject are not overridden.
2.20 Data processing for the protection of legitimate interests
We also process your data if it is necessary to safeguard legitimate interests of us or of third parties. This may be the case in particular to ensure IT security and IT operations, especially in the case of support requests, to be able to reconstruct and prove facts in the event of legal disputes or, among other things, to statistically evaluate usage.
The basis for the data processing is Art. 6 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in the aforementioned data processing.
2.21 Data processing for advertising purposes
In the case of the use of your data for advertising purposes for services or products of us and/or, if applicable, our cooperation partners, we may obtain your consent or we may advertise to you because we already have a contractual relationship with you and you receive this information from us as a so-called existing customer.
If you, as an existing customer, do not wish to receive any further information about our services, a message to us is sufficient to stop this type of information. Apart from that, the data processing is based on your consent (Art. 6 para. 1 p. 1 lit. a GDPR). You can revoke your consent at any time with effect for the future. The legality of the data processing operations already carried out remains unaffected by the revocation.
2.22 Data processing for market and opinion research
We may also use your data for market and opinion research. Of course, we will only use them anonymously for statistical purposes and only for our company. Your answers in surveys will not be passed on to third parties or published.
The basis for data processing is Art. 6 (1) p. 1 lit. f GDPR, which permits the processing of data to protect the legitimate interests of the controller, provided that the interests or fundamental rights and freedoms of the data subject are not overridden.
2.23 Other data processing based on your consent
We may also ask for your consent to process personal data about you. Any consent given and the relevant data processing will be on a voluntary basis and you will not suffer any disadvantage if you do not give your consent.
The data processing is then carried out on the basis of your consent in accordance with Art. 6 Para. 1 Sentence 1 lit. a GDPR. You can revoke your consent at any time with effect for the future. An informal communication to us is sufficient for this purpose. The legality of the data processing operations already carried out remains unaffected by the revocation.
2.24 Data processing for the fulfilment of legal obligations
In addition, we process your data to fulfil legal obligations (e.g. regulatory requirements, commercial and tax law retention and verification obligations).
The basis for data processing is Art. 6 para. 1 p. 1 lit. c GDPR, which permits processing for the fulfilment of a legal obligation.
2.25 Data processing for applications
You can send us applications for jobs in our company via our websites and our contact details stored there. Insofar as personal data is transmitted to us by you in this way or in any other way when you apply, we process your data for the purpose of examining, processing and responding to your application and, if necessary, for preparing the employment relationship.
The basis for the data processing is either Art. 88 para. 1 GDPR, Section 26 para. 1 BDSG (new) which permits the processing of data for the decision on the establishment, for the establishment as well as for the implementation of employment relationships or - if you have given your consent - Art. 6 para. 1 sentence 1 lit. a GDPR. You can revoke your consent at any time with effect for the future. For this purpose, an informal communication by e-mail to us is sufficient. The legality of the data processing operations already carried out remains unaffected by the revocation.
2.26 Data transfer to third countries
For various services that are used on our website with your consent or by means of which data is processed (e.g. for advertising purposes), you will find a warning in this data protection notice that data may be transferred to third countries.
What does this warning mean?
In the event of a data transfer to a third country, your personal data will leave the local scope of the GDPR. In individual cases, a level of data protection may apply in the third country that does not meet the requirements of the GDPR. For some states, e.g. Switzerland, there is a so-called adequacy decision. In the opinion of the EU Commission, the level of data protection in these states meets the requirements of the GDPR. They are therefore considered safe for data protection purposes. For other countries, in particular the USA, there is no such decision, as in these countries there is no level of protection for your personal data that corresponds to that of the GDPR. In the case of a data transfer to a third country, it is therefore possible that your personal data will be transferred to a country for which there is no level of data protection that is compatible with the GDPR.
What does this mean for your personal data?
In the context of a division of labour economy, many companies use service providers to process personal data. In other cases, large companies, such as Google, Amazon, Facebook or Apple, have numerous different companies in different countries that do not each carry out data processing on their own. Rather, they use group-wide IT services, so that, for example, a company in Ireland uses services of the parent company in the USA. For this purpose, either personal data is transferred to the USA or the parent company in the USA has access to the data in the EU.
By concluding so-called standard contractual clauses, the GDPR allows to agree that the contractual partner, e.g. the parent company in the USA, must comply with the requirements of the GDPR for the corresponding data processing, even if these would otherwise not apply to the contractual partner. This is intended to contractually create a level of data protection that corresponds to that of the GDPR so that data subjects are not placed in a worse position than if their personal data were processed in the EU.
However, contracts only bind the parties to them and not third parties, such as government bodies. Therefore, in one country, e.g. the US, state authorities may have the right to access personal data of EU citizens, even if this violates their rights. These accesses can be very broad and can cover all of your data that is processed there. They can take place without a judge or similar having to order them. They can be secret, so that you do not know about these accesses. And they may be such that you have no way of defending yourself against access and any use of your data, especially in a court of law. Furthermore, the data subject rights to which you are entitled under the GDPR (e.g. information, deletion) may also not exist or may not be enforced. The data processed in this way may also be combined with other data relating to you from other sources, e.g. in order to create a profile about you.
This possible use of your data could, but does not have to, be associated with disadvantages for you. Since government agencies in third countries in particular are not subject to EU law or German law, it is not possible to specify exactly what disadvantages these might be. Disadvantages can therefore be of any nature, e.g. economic or political. For example, it could be that you are denied entry into a country, but it could also be that these data are used against you in foreign criminal proceedings. The disadvantages can therefore be very serious in individual cases.
How high are my risks?
We cannot give a general answer as to how high the risks described are in individual cases. We can only point out that the decisive question is which service, and therefore which company, has access to your data in connection with your use of our website. Furthermore, it is decisive which personal data is affected by this. On our website, it is - in our opinion - only about the possible processing of personal data in third countries in connection with advertising services such as Google, Microsoft or Facebook. This will be data on which website you visited and when, how long you stayed on this website, from where the access took place, which end device or which software (browser, app) was used for this purpose, which interactions you carried out on the website, if this is transmitted to the operator of the service (e.g. the purchase of a product after clicking on an advertisement). Please read the information provided with the respective services) and, if applicable, further data processed by the respective operator. For this, we refer you to the respective data protection information of the services. The links to these can be found in these data protection notices in the explanation of the respective service.
You must weigh up for yourself whether granting consent and a possible transfer to a third country could create a situation for you that you do not wish to live with. In this case, please do not give your consent to the use of these services.
You will not suffer any disadvantages if you do not give your consent
If you do not wish to give your consent to the use of certain or all services or the storage of cookies, this will not have any disadvantages for you on our website. All our offers are available to our customers under the same conditions, regardless of whether they give their consent or not. Of course, you can revoke your consent at any time with effect for the future.
3. Recipients of personal data
- Your personal data will only be passed on or otherwise transferred to third parties if this is necessary for the purpose of contract processing or billing or if you have given your prior consent or if there is a legal basis for the transfer.
Insofar as we use the services of third parties for the implementation and handling of processing procedures, the provisions of the GDPR are complied with. Service providers that support us in the provision of our services to you include hosting providers, e-mail service providers, payment providers.
4. Duration of data storage
In principle, we delete your data as soon as it is no longer required for the above-mentioned purposes, unless temporary storage is still necessary. For example, we store your data on the basis of legal obligations to provide proof and to retain data, which result, among other things, from the German Commercial Code (Handelsgesetzbuch) and the German Fiscal Code (Abgabenordnung). The storage periods are then up to ten full years. In addition, we retain your data for the period in which claims can be asserted against our company (statutory limitation period of three or up to thirty years). Insofar as we process the data for the performance of a contract, we store it at least as long as the respective contract exists and thereafter until no claims resulting from it can be asserted against us any longer. Even after this period has expired, we may now continue to process the data stored until then on the basis of the performance of the contract on the basis of a legitimate interest by way of a change of purpose. We store the data collected on the basis of a legitimate interest until the legitimate interest no longer exists, the weighing reaches a different result or an effective objection to the respective data processing has been lodged and we have no other entitlement to continue this respective data processing.
5. Data security
Your personal data is transmitted securely by us using encryption. We use the SSL (Secure Socket Layer) coding system for this purpose. You can recognise an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line. Furthermore, we secure our websites and other systems by technical and organisational measures against loss, destruction, access, modification or distribution of your data by unauthorised persons.
6. Data subject rights
Within the framework of the applicable legal provisions, you have the right at any time to free information about your personal data stored by us, its origin and recipient and the purpose of the data processing and, if applicable, the right to correction, blocking or deletion of this data. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time using the contact details given in section 1. You may also have the right to restrict the processing of your data and the right to receive the data you have provided in a structured, common and machine-readable format.
If you have given us consent to process personal data for specific purposes, you may withdraw your consent at any time with future effect. If we process your data to protect legitimate interests, you may object to this processing on grounds relating to your particular situation. Unless we can demonstrate compelling legitimate grounds for further processing that override your interests, rights and freedoms, or if we process the relevant data from you for the purpose of direct marketing, we will then no longer process your data (Art. 21 GDPR).
In addition, you have the option of contacting a data protection supervisory authority (right of complaint).