Data Privacy

Privacy Policy of SSL Automotive Group GmbH

As of: 3 June 2022

1. Subject matter and scope of application

We take the protection of your personal data very seriously. With this Privacy Policy, we inform you about which personal data we collect and how and for what purposes it is processed.  

On the one hand, this data protection information explains which personal data we collect and process in the context of the use of our 2trde platform for the remarketing of used cars and our other products trade-in calculator and intake app (hereinafter uniformly "2trde platform").

In addition, this data protection information also applies to visits to our website and to various other data processing activities, for example also when you visit our social media pages, when you contact us, when we work with you as a customer or as a supplier, or when you apply to work for us as an employee.

We always treat your personal data in accordance with the statutory data protection regulations and this data protection information.

2. Controller and data protection officer

The controller within the meaning of Art. 4 No. 7 GDPR is SLL Automotive Group GmbH, Erika-Mann-Straße 63, 80636 Munich, Germany, Telefon +49 89 9545 77 44, E-Mail: info@2trde.com (hereinafter "2trde").

Our data protection officer is attorney Christian Schmoll, e-mail: schmoll@lucid-compliance.com. Any data subject may contact our data protection officer directly at any time with any questions or suggestions regarding data protection.

3. Use of the 2trde app/platform

3.1. Creating an account
If you set up an account for the use of the 2trde Platform or have us set up an account for you or register as an invited user, we as the responsible party will collect and process your data to enable you to use the 2trde Platform.

In this context, we process your data in the context of making the 2trde Platform available or to provide the services we offer. Where applicable, this includes the processing of surnames and first names of users of the software, address(es), contact data (e.g. e-mail address, telephone number), contractual data (e.g. subject matter of the contract, term), payment data and data collected in the course of providing our services and/or required for the provision of our services.

Your data will be processed for as long as you use your account. If you close/delete your account, the data processed via your account will be deleted (subject to any retention obligations, see below under "Retention and deletion").

The legal basis for this storage and processing is the fulfillment of the contract or the implementation of pre-contractual measures in accordance with Art. 6 (1) lit. b) GDPR.

3.2. Hosting of the 2trde Platform

Our 2trde Platform is hosted by a service provider on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This may involve the transfer of personal data to a third country outside the EU without an adequate level of data protection. We provide appropriate safeguards for this data transfer in accordance with Art. 46 GDPR. We will be happy to provide you with proof of the appropriate safeguards (Standard Contractual Clauses) upon request.

3.3. Usage analysis
In order to better understand how you use the 2trde Platform and to continuously improve the 2trde Platform and services, we collect and analyze how users use the 2trde Platform. The data collected in this process is used to create aggregated usage reports.

Usage information may be stored as part of software-specific functions such as reports, analysis or value histories. This information includes usernames and timestamps.

3.3.A. Google Analytics

We use the analysis service Google Analytics with IP anonymization for usage analysis. Google Analytics is provided by Google Ireland Limited in Ireland (hereinafter "Google").

Via JavaScript tags, we can collect information about your use of the 2trde Platform. Google Analytics also regularly uses cookies to collect information about a user's interactions with the 2trde Platform.

As part of the use of Google Analytics, your IP address and information about the use of the 2trde Platform, browser type and version, operating system used, the previously visited page and the time of the server request are transmitted to Google servers and processed there.

Within the scope of IP anonymization, the collected IP addresses of users within the European Economic Area are shortened before being transmitted to the USA. Only in exceptional cases, in the event of technical malfunctions in Europe, will the unabbreviated IP address be transmitted to Google in the USA and shortened there. The transmitted IP addresses are not merged with other data from Google.

Google will act for us as a data processor on the basis of a data processing agreement pursuant to Art. 28 GDPR.

As explained, this may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is your express consent pursuant to Art. 6 (1) lit. a) GDPR.

3.3.B. Hotjar

We also use a so-called heatmap tool that allows us to analyze and understand how users use the 2trde Platform (e.g., how much time users spend on which pages, which links they click on, what users do and do not do, etc.). Based on the analysis of user behavior, we can optimize and further develop the 2trde Platform. As part of the use of this heatmap tool, cookies and other technologies are used to collect data about the behavior of users and their devices, in particular the IP address of the device (collected and stored only in anonymized form), the screen size of the device, the type of device (unique device identifiers), browser information, geographical location (country only) and the preferred language in which our website is displayed). This information is stored in a pseudonymized user profile, but this information is not used to identify individual users or to match it with any other data about an individual user.

The heatmap tool Hotjar is provided by Hotjar Ltd. in Malta. Details about the data processing by Hotjar can be found here: https://www.hotjar.com/privacy/.

Hotjar acts for us as a data processor on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is your express consent pursuant to Art. 6 (1) lit. a) GDPR.

3.4. Transaction messages
For transactional messages sent by email in connection with your use of the 2trde Platform, we use an external service provider who performs the email dispatch for us and ensures the deliverability of the messages.

This service provider acts for us as a data processor on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

4. Visiting our internet pages

4.1. Logfiles

Each time you visit our website, our system automatically collects data and information from the computer system of the calling computer. The following data is logged:

IP address of the calling computer

Operating system of the calling computer

Browser version of the calling computer

Name of the retrieved file/website

Date and time of retrieval

Transferred amount of data

Referring URL

This data is processed in order to be able to present the website, to ensure the security, availability and integrity of the website (e.g., detection and defense against DoS attacks or access by bots), to improve the quality and presentation of the website, to be able to identify and correct errors and for statistical purposes.

This data is regularly deleted after a few days.

Our website is hosted by a service provider on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This may involve the transfer of personal data to a third country outside the EU without an adequate level of data protection. We provide appropriate safeguards for this data transfer in accordance with Art. 46 GDPR. We will be happy to provide you with proof of the appropriate safeguards (Standard Contractual Clauses) upon request.

The legal basis for this data processing is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the above purposes.

4.2. Content Delivery Network

We use the Content Delivery Network (CDN) Amazon CloudFront to increase the security and delivery speed of the website. A CDN is a network of servers distributed worldwide that is capable of delivering optimized content to users. For this purpose, personal data may be processed in server log files by CloudFront.

CloudFront acts as a data processor for us on the basis of a data processing agreement pursuant to Art. 28 GDPR.

Since a CDN represents a network of servers distributed worldwide, the use of a CDN may result in the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is to increase the security and delivery speed of the website.

5. Contact and CRM

If you contact us, e.g. by e-mail or via a contact form, the information you provide will be processed for the purpose of handling the request.

We need the information requested in a contact form to process your request, to address you correctly and to send you a reply.

The legal basis for this data processing is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the communication with prospects, visitors and customers. If the purpose of the contact is to conclude a contract, the additional legal basis for processing is Art. 6 (1) lit. b) GDPR.

Inquiries and customer relations are regularly stored and processed in our CRM system. The legal basis for this storage and processing is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the marketing of our products and services and the maintenance of our prospect and customer relationships.

For our contact forms we use external service providers as data processors on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This may involve the transfer of personal data to a third country outside the EU without an adequate level of data protection. We provide appropriate safeguards for this data transfer in accordance with Art. 46 GDPR. We will be happy to provide you with proof of the appropriate safeguards (Standard Contractual Clauses) upon request.

6. Newsletter

6.1. Registration

On our website, you can register to receive a newsletter by e-mail. During registration, the data from the input mask, the IP address of the calling computer and the date and time of registration are transmitted to us. For the processing of the data, your consent is obtained during registration and reference is made to this Privacy Policy.

In order to verify that a registration for the sending of a newsletter is made by the actual owner of an e-mail address, we use the so-called "double opt-in" procedure. In this process, after registration of an e-mail address, a confirmation e-mail is sent to the registered e-mail address. Registration for the newsletter is only completed when a confirmation link contained in the confirmation e-mail is activated. The IP address of the calling computer and the date and time of activation of the confirmation link are also transmitted to us.

The registration for the newsletter can be terminated at any time by using the unsubscribe link contained in each newsletter or by contacting us at the above contact details.

The legal basis for the processing of data after registration for the newsletter is your consent pursuant to Art. 6 (1) lit. a) GDPR.

6.2. Email Newsletter for Existing Customers
The legal basis for the processing of data after registration for the newsletter is your consent in accordance with Art. 6 Para. 1 lit. a) DSGVO.E-mail newsletter as part of an existing customer relationshipIf you register as a user of our app and provide your e-mail address, this may subsequently be used by us to send an e-mail newsletter if you have not objected to such use. In such a case, the email newsletter will only be used to send direct advertising for our own similar goods or services. You can object to the use of your e-mail address at any time, without incurring any costs other than the transmission costs according to the basic rates, by using the unsubscribe link contained in each newsletter or by contacting us at the above-mentioned contact details.The legal basis for sending the newsletter as a result of the sale of goods or services is Art. 6 para. 1 lit. f) DSGVO in conjunction with Section 7 para. 3 UWG.

6.3. Newsletter analysis
A statistical analysis of usage data may be carried out for our newsletters. For this purpose, we may record both the openings of the email and the internal clicks. This information serves the purpose of measuring and optimising the success of our newsletter campaigns by making the content of the newsletters more relevant to our target group.The legal basis for this analysis is Art. 6 para. 1 lit. f) DSGVO. Our legitimate interest is the evaluation and optimisation of communication with customers and interested parties.

6.4. Newsletter service provider
We use an external service provider as a data processor for sending and analyzing our newsletter on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This may involve the transfer of personal data to a third country outside the EU without an adequate level of data protection. We provide appropriate safeguards for this data transfer in accordance with Art. 46 GDPR. We will be happy to provide you with proof of the appropriate safeguards (Standard Contractual Clauses) upon request.

7. RECAPTCHA

We use the reCAPTCHA service of Google Ireland Limited. This service is used to distinguish whether the input into a form is made by a natural person or abusive by machine and automated processing. Within the scope of reCAPTCHA, your IP address and other data required by Google for the reCAPTCHA service are transmitted to Google.

Further information on data processing by Google can be found in Google's privacy policy at https://www.google.com/policies/privacy.

When using reCAPTCHA, personal data may be transferred to a third country outside the EU without an adequate level of data protection. We provide appropriate safeguards for this data transfer in accordance with Art. 46 GDPR. We will be happy to provide you with proof of the appropriate safeguards (Standard Contractual Clauses) upon request.

The legal basis for this data processing when using reCAPTCHA is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the security of our website and protection against spam.

8. Cookies

Our website uses cookies. Cookies are pieces of information that are transferred from our web server or third-party web servers to your browser and stored there for later retrieval. Cookies may be small files or other types of information storage. Information is stored in cookies that is related to the specific end device used. Cookies contain a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again. A cookie also contains information about its origin and the storage period. However, this does not mean that we gain immediate knowledge of your identity.

8.1. Technically Necessary/Essential Cookies

When visiting our website and using the Platform, cookies are set that are absolutely necessary for the operation of the website or the platform. These essential cookies may be, for example, cookies that are required for the display of the website with a content management system, which are used to recognize language settings, or which are used to document whether you have consented to the setting of further (non-essential) cookies or whether you have rejected them.

The technically necessary cookies, including their purpose and storage period or deletion period, are explained to you in our cookie banner, which is displayed when you access the website.

The legal basis for the processing of personal data using essential cookies is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the operation of our website.

8.2. Non-Essential Cookies

We also use non-essential cookies, for example to collect additional information about the interests of visitors to our websites or about their usage behavior, in order to analyze and optimize our website and generally our customer interactions on this basis.

Non-essential cookies, including their purpose and storage period or deletion period, are also explained to you in our cookie banner, which is displayed when you access the website.

Non-essential cookies are only set if you have expressly consented to the setting of non-essential cookies. You can also select different categories of non-essential cookies that you wish to allow in the cookie banner.  

The legal basis for the processing of personal data using such non-essential cookies is your explicit consent pursuant to Art. 6 (1) lit. a) GDPR.

8.3. Consent Management

We use a consent management service that allows us to obtain and document consent from visitors to our website.

The following data is processed in this process: Date and time of access, browser information, device information, geographic location, cookie preferences and URL of the pages visited.

The data will be deleted after one year.

The consent management service is provided to us by a data processor on the basis of a data processing agreement pursuant to Art. 28 GDPR. The processing takes place in the European Union.

The functionality of the website is not guaranteed without the processing. The data processing is necessary for the fulfillment of a legal obligation (Art. 7 (1) GDPR), the legal basis is accordingly Art. 6 (1) lit. c) GDPR.

9.Third party tools

We use third-party functionalities, plug-ins and tools on the website and as part of the Platform, for example, to expand the functional scope of the website and the Platform, to analyze the use of the Website and the Platform, and to optimize the content accordingly. We explain the third-party tools used below.

9.1. Google Tag Manager

On our website we use the tool Google Tag Manager. Google Tag Manager is provided by Google Ireland Limited in Ireland. Through this tool, website tags can be managed via an interface. Google Tag Manager only implements tags, but no cookies are used, and no personal data is collected. Google Tag Manager triggers other tags, which in turn may collect data, but Google Tag Manager does not access this data.

9.2. Web Analytics

We use web analytics services to understand how our website and our Platform are used by their visitors or users and to optimize the website and the Platform in terms of content and technology.

9.2.A. Google Analytics

We use the web analytics service Google Analytics with IP anonymization. Google Analytics is a web analytics service provided by Google Ireland Limited (hereinafter "Google").

JavaScript tags allow us to collect information about your use of the website and the Platform. Google Analytics also regularly uses cookies to collect information about a user's interactions with the website or Platform.

Within the scope of the use of Google Analytics, your IP address and information about the use of the website or Platform, browser type and version, operating system used, the previously visited page and the time of the server request are transferred to Google servers and processed there.

Within the scope of IP anonymization, the collected IP addresses of users within the European Economic Area are shortened before being transmitted to the USA. Only in exceptional cases, in the event of technical malfunctions in Europe, will the unabbreviated IP address be transmitted to Google in the USA and shortened there. The transmitted IP addresses are not merged with other data from Google.

Google will act for us as a processor on the basis of a data processing agreement pursuant to Art. 28 GDPR.

As explained, this may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is your express consent pursuant to Art. 6 (1) lit. a) GDPR.

9.2.B. Hotjar

We use the web analytics service Hotjar provided by Hotjar Ltd. in Malta. Hotjar enables an analysis of the use of the website and the platform by collecting and processing data on the use of the website or platform and on the behavior of users and on the end devices used via cookies and a script (in particular, the IP address of the end device (in anonymized form), screen size, device type (unique device identifiers), information about the browser used, location (country only), preferred language). Hotjar stores this information in a pseudonymized user profile. The information is neither used by Hotjar nor by us to identify individual users nor is it merged with further data about individual users. The collected data can be used to analyze the users' interactions with the website or Platform, for example by creating heat maps.

Details on data processing by Hotjar can be found here: https://www.hotjar.com/privacy/

Hotjar acts for us as a data processor on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is your express consent pursuant to Art. 6 (1) lit. a) GDPR.

9.3. Marketing and Retargeting

9.3.A. Google Ads

We use Google Ads. Google Ads is provided by Google Ireland Limited in Ireland (hereinafter "Google").

We use Google Ads Conversion. Google Ads Conversion allows us to measure and analyze the performance and success of advertisements (Google Ads) and to optimize our advertising campaigns and make them more relevant. This involves monitoring and recording how often advertisements are displayed and how often users click on a particular advertisement and are then redirected to our website. Google Ads Conversion uses cookies.

We only receive aggregated statistics from Google, which do not allow any conclusions to be drawn about the identity of the visitors to our website.

Through the integration of Google Ads Conversion, Google receives the information that you have visited a particular page of our website and/or clicked on an advertisement from us. If you are registered and logged in to a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in to a Google service, your IP address may be transferred to Google.

We also use Google Ads Remarketing. Google Ads Remarketing allows us to recognize visitors to our website on other websites and present them with specific interest-based advertisements. Google Ads Remarketing also uses cookies.

Google acts for us as a processor on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing is your express consent pursuant to Art. 6 (1) lit. a) GDPR.

9.3.B. Tracking Pixel

Our website uses one or more of the following integrated pixels to track website visitors' actions for the purpose of conversion tracking:

Meta/Facebook

Taboola

LinkedIn

Such pixels are code snippets that can be used to track the behavior of website visitors, which allows the personalization and improvement of the adverting content displayed on the website and the measurement of the performance and success of the advertising content displayed on the website.

The data collected via the integrated pixels may be used by the providers of the respective pixels for their own tracking and advertising purposes. For further details please refer to the privacy policies of the providers of the respective pixels.

The data collected does not allow the website provider to draw any conclusions about the identity of the website visitors.

The integration of such tracking pixels may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards at any time upon request.

The legal basis for this data processing is your express consent pursuant to Art. 6 (1) lit. a) GDPR.

9.4. SalesViewer

Use of SalesViewer® technology:

On this website, data for marketing, market research and optimization purposes is collected using SalesViewer® technology from SalesViewer® GmbH on the basis of the legitimate interests of the website operator (Art. 6 Para.1 lit.f GDPR). For this purpose, a javascript-based code is used, which is used to collect company-related data and the corresponding use. The data collected with this technology is encrypted using a non-recalculated one-way function (so-called hashing). The data is immediately pseudonymised and not used to personally identify the visitor to this website. You can object to data collection and storage at any time with effect for the future by clicking this link https://www.salesviewer.com/opt-out to prevent future acquisition by SalesViewer® within this website. An opt-out cookie for this website will be stored on your device. If you delete your cookies in this browser, you must click this link again.

10. Videos

Videos are embedded on our website. This functionality is provided via a plugin from Google Ireland Ltd. in Ireland ("YouTube").

We use the privacy-enhanced mode for embedded YouTube videos, which means that YouTube does not set cookies. Nevertheless, when you visit a website with the YouTube plugin, a connection to YouTube is inevitably established and your IP address is transferred to YouTube in the process. If you start a video by clicking on it, this information is transmitted to YouTube. If you are logged in to YouTube, the transmitted information may be linked to your account with YouTube.

You can find more information on data protection at YouTube in YouTube's Data Protection and Security Center: https://support.google.com/youtube/topic/2803240?hl=de&ref_topic=6151248

When using YouTube, personal data is transferred to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

The legal basis for this data processing in the context of embedding videos is your express consent pursuant to Art. 6 (1) lit. a) GDPR.

11. Social Media

11.1. Social Media Buttons

Social media buttons of various social media networks (e.g. Linkedin, Instagram, Twitter and Facebook) are integrated on our website.

If you click on one of these social media buttons, you will be redirected to our pages on the respective social media network. In this case, the provider of the respective social media network receives the information that your browser has accessed the corresponding page of our website, even if you do not have a profile with the respective social media network or are not logged in there. This information (including your IP address) is transmitted by your browser directly to a server of the respective provider. If you click on a social media button and are either logged in to the respective social media network or then log in to the page of the respective social media network, the transmitted information can be assigned to your account with the social media network.

For information on the purpose and scope of data collection and processing by the providers of the respective social media network, the provider identification, a contact option and your rights and setting options for data protection, please refer to the respective privacy policy of the providers of the social media networks.The legal basis for the integration and use of social media buttons is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the marketing of our offers and our website.

11.2. Social Media Pages

We maintain a publicly accessible profile on various social media networks (e.g. Linkedin, Instagram, Twitter and Facebook).

If you visit our social media pages and are logged in to the respective social media network, the provider of the respective social media network can analyze your usage behavior and assign the information collected to your account with the social media network and enrich it there. Even if you are not logged in or if you do not have an account with the respective social media network, personal data may be collected by the provider of the respective social media network, for example your IP address or data collected via a cookie.

The operators of the social media networks can use this data to create user profiles. Based on your user profile, you can then be shown interest-based advertisements both on the websites of the social media network and on other websites.

If you visit one of our social media pages, we are jointly responsible with the provider of the social media network for the collection and processing of your personal data that takes place there. For information on the collection and processing of your personal data that takes place there, we refer you to the privacy policy of the respective social media network.

You can assert your data subject rights in accordance with Chapter III. of the GDPR (right to information, correction, deletion, restriction of processing, data portability, etc.) both against us and against the provider of the respective social media network. In this context, we would like to point out that we can only influence the processing of personal data and the implementation of data subject rights within the framework of our social media pages within the scope of the possibilities made available to us by the respective provider.

The legal basis for our use of social media pages is Art. 6 (1) lit. f) GDPR. Our overriding legitimate interest is the presence and marketing of our products and services on the Internet.

12. Job Applications

We collect and process personal data of applicants for the purpose of processing the application process. If an applicant submits his or her application documents to us electronically, they are processed electronically.

If we conclude an employment contract with an applicant, the data transmitted will be processed in order to carry out the employment relationship in compliance with the statutory provisions. If no employment contract is concluded with the applicant, the application documents will be deleted immediately after completion of the application procedure, provided that deletion does not conflict with any overriding legitimate interest, such as the defence of claims or a preservation of evidence function according to the General Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz - AGG).

The legal basis for this storage and processing is the performance of the contract or the implementation of pre-contractual measures pursuant to Art. 6 (1) lit. b) GDPR, in Germany § 26 BDSG.

13. Video conferences and webinars

If you participate in or register for a videoconference, webinar or online meeting etc. (hereinafter "video conferences") organized by us, we process your personal data in the course of your participation.

When you participate in a video conference, various categories of data are processed. The scope of the data also depends on the data you provide before or during participation in a video conference.

If you participate in a video conference organized by us, you usually have to provide at least a name when registering. However, you can also use a pseudonym. Your IP address will also be processed to enable your participation and login information and device/hardware information will be stored. Your email address and profile picture will also be processed, if provided. If you dial in by phone, your phone number and IP address, if any, will be processed.

To enable participation in the video conference, data from your terminal's microphone and any terminal video camera and, if you share your screen, information from this "screenshare" is processed. You can switch off or mute the camera or microphone yourself at any time. You always decide yourself whether and which parts of your screen are shared.

Audio and video recordings of the video conference can be made. In this case, MP4 files of all video, audio and presentation recordings are processed. There will always be an indication of the recording if one is made and, if necessary, the explicit consent of the participants to the recording will always be obtained.

You may have the opportunity to use the chat, question or survey functions in a video conference. In this respect, the text entries you make are processed in order to display them in the video conference and, if necessary, to record them.

Insofar as personal data of our employees is processed, § 26 BDSG (German Federal Data Protection Act) is the legal basis for data processing, insofar as German law is applicable to the processing of employee data.

If German law is not applicable to the processing of employee data or if, in connection with participation in video conferences, the processing of personal data is not necessary for the establishment, implementation or termination of the employment relationship, but is nevertheless an elementary component of participation in a video conference, our overriding legitimate interest pursuant to Art. 6 (1) lit. f) GDPR is the legal basis for the data processing. In these cases, our overriding legitimate interest is in the effective implementation of video conferences.

Furthermore, the legal basis for data processing when conducting video conferences is Art. 6 (1) lit. b) GDPR, insofar as the meetings are conducted in the context of contractual relationships or with a view to initiating a contractual relationship (for example, in the case of video conferences with our clients in the context of the implementation of a project or participation in a webinar).

Furthermore, the legal basis for data processing in the context of your participation in a video conference organized by us is our legitimate interest pursuant to Art. 6 (1) lit. f) GDPR. Our legitimate interest in these cases is the effective implementation of video conferences.

We use one or more service providers as data processors for the organization and implementation of video conferences on the basis of a data processing agreement pursuant to Art. 28 GDPR.

This may involve the transfer of personal data to a third country without an adequate level of data protection. In this case, we ensure that appropriate safeguards are provided for the transfer in accordance with Art. 46 GDPR. We will provide you with proof of the appropriate safeguards (Standard Contractual Clauses) at any time upon request.

14. Mergers and acquisitions (M&A)

f we are involved in a restructuring, acquisition, asset sale, merger, financing, transfer of services to another provider, due diligence, insolvency or receivership, your personal data may be transferred to third parties to the extent legally permitted in connection with and as part of the relevant legal process, subject to the basic principles of data protection law.

15. Age restriction

This website is not intended or designed for use by children under the age of 16. We do not knowingly collect personally identifiable information from or about anyone under the age of 16.

16. Recipients of data

Within our company, those internal departments or organisational units receive your data which they need to fulfil their tasks, to fulfil contracts with you if necessary, for data processing with your consent or to safeguard our overriding legitimate interests.

Data will only be passed on to third parties within the framework of legal requirements. We will only pass on your data to third parties if, for example, this is necessary for contractual purposes on the basis of Art. 6 (1) lit. b) GDPR or to safeguard our overriding legitimate interest pursuant to Art. 6 (1) lit. f) GDPR in the effective conduct of our business operations.

Insofar as we use service providers within the framework of the provision of the website and/or Platform or other services, we take appropriate legal precautions as well as appropriate technical and organisational measures to ensure the protection of your personal data.

17. Your rights

You have the rights explained below with regard to the personal data processed by us concerning you:

17.1. Right of Access

You can request information in accordance with Art. 15 GDPR about your personal data that we process.

17.2. Right to Rectification

If the information concerning you is not (or no longer) accurate, you may request a correction in accordance with Art. 16 GDPR. If your data is incomplete, you may request that it be completed.

17.3. Right to Erasure

You may request the erasure of your personal data in accordance with Art. 17 GDPR.

17.4. Right to Restriction of Processing

In accordance with Art. 18 GDPR you have the right to request restriction of processing of your personal data.

17.5. Right to Object to Processing.

You have the right to object at any time on grounds relating to your particular situation to the processing of your personal data which is carried out on the basis of Art. 6 (1) lit. e) or lit. f) GDPR in accordance with Art. 21 (1) GDPR. In this case, we will not further process your data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or if the processing serves to assert and exercise or defend against legal claims (Art. 21 (1) GDPR).

In addition, according to Art. 21 (2) DSGVO, you have the right to object at any time to the processing of personal data concerning you for the purposes of direct marketing; this also applies to any profiling, insofar as it is related to such direct marketing.

17.6. Right to Withdraw Consent

Insofar as you have given your consent for processing, you have a right to withdraw your consent pursuant to Art. 7 (3) GDPR.

17.7. Right to Data Portability

You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format ("data portability") as well as the right to have this data transferred to another controller if the conditions of Art. 20 (1) lit. (a) and (b) GDPR are met.

17.8. Exercise of Rights

You can exercise your rights by notifying the above contact details for the data controller or the data protection officer.

17.9. Right to complain to the Data Protection Authorities

If you believe that our processing of your personal data violates data protection law, you also have the right to complain to a data protection supervisory authority of your choice pursuant to Article 77 of the GDPR.

The data protection supervisory authority responsible for us is the Berlin Commissioner for Data Protection and Information Security, Friedrichtstr. 219, 10969 Berlin.

18. Compulsory data and profiling

The provision of personal data is neither required by law nor by contract, and you are not obliged to provide personal data, although the provision of personal information is required for the conclusion of a contract to the extent that certain details are required in order to conclude (and perform) a contract.

We do not perform automated decision making, including profiling.

19. Information security and deletion

We take appropriate technical and organizational measures in accordance with the state of the art to ensure a level of protection for the personal data we process that is appropriate to the risk of the respective processing and to protect the data we process against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons.

Our website uses SSL encryption for security reasons and to protect the transmission of confidential content, such as orders, inquiries or payment data that you send to us.

Our employees receive regular training on data protection and information security and are committed to confidentiality and data protection.

A restrictive rights and roles concept on a "need to know" basis ensures that employees only have access to the personal data they absolutely need to perform their duties.

We adhere to the principles of data avoidance and data economy and only store your personal data for as long as is necessary to achieve the respective purpose of the data processing purposes or as stipulated by the storage periods provided by law. If the purpose of storage no longer applies or if a storage period provided for by law expires, the personal data will be routinely anonymized or deleted in accordance with the statutory provisions.

20. Amendment of this privacy policy

We reserve the right to amend this Privacy Policy from time to time so that it always complies with current legal requirements or in order to implement changes to our services in the Privacy Policy, e.g. when introducing new services. Your renewed visit will then be subject to the amended Privacy Policy.

Contact us!

Call our experts to find the right solution for you.

Thank you! Your submission has been received!

Oops! Something went wrong while submitting the form.