Privacy Policy

Date: April 2021

1. Introduction

In this Privacy Policy you will learn,

  • how we process your personal data in the context of your use of our websites and Internet services.

2. Controller

This Privacy Policy applies to data processing by us as Controller pursuant to Article 4 (7) of the General Data Protection Regulation (GDPR). Our contact details are:

collaboration Factory AG
Arnulfstraße 34
D-80335 München

Represented by: Dr. Rupert Stuffer (CEO)
Registry Court and -number: Munich, HRB 262367
Kontakt:

E-Mail: info@collaboration-factory.de
Tel: +49 (0)89 809133 230
Fax: +49 (0)89 809133 239

3. Data Protection Officer

Marco Niederhausen
collaboration Factory AG
Arnulfstraße 34
D-80335 München
privacy@collaboration-factory.de

4. Definition of terms

Unless this Privacy Policy contains or implies a different definition, reference is made to the definitions in Art. 4 GDPR with regard to the terms used.

5. Processing of your personal data

5.1. When accessing our websites

When you access our websites, i.e. if you do not transfer information to us in any other way, we or the host provider acting on our behalf only collect the personal data that your browser transfers to our server. If you wish to view our websites, we collect the following data:

  • IP address
  • Date and time of the request
  • Time zone difference from Greenwich Mean Time (GMT)
  • Content of the request (concrete page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • website, from which the request comes
  • Operating system
  • Language and version of the browser software

This data is technically necessary for us to display and provide you with our websites. The legal basis for this processing is Art. 6 para. 1 p. 1 lit. f GDPR. This data is stored for security reasons (e.g. to clarify acts of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is required for evidentiary purposes is exempt from deletion until the final clarification of the respective incident. The hosting service provider we use processes personal data for us on assignment and within the scope of our instructions as a so-called Processor pursuant to Art. 28 GDPR.

5.2. Analytics through Google Analytics

Our websites optionally use Google Analytics so that we can further improve future websites. You can consent to the use of Google Analytics when accessing the websites. You can revoke your consent to the use of Google Analytics at any time. If you give us your consent, we evaluate the use of the websites. However, we do not make an allocation at the individual level. For this purpose, we process the following personal data from you

  • IP adress (anonymized)
  • Date and time of the request
  • Time zone difference from Greenwich Mean Time (GMT)
  • Content of the request (concrete page)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • website, from which the request comes
  • browser
  • Information about your end device
  • Operating system and its interface
  • Language and version of the browser software
  • screen and window resolution
  • Your approximate location
  • Information about the time you spend on the site
  • Information about actions you perform on the websites

As already mentioned, we process this data exclusively with your consent. The legal basis for this is Art. 6 para. 1 p. 1 lit. a GDPR.

In the context of the use of the Google Analytics services, there are also data transfers from Google to affiliated companies and/or subcontracted processors. In this context, the above-mentioned data may be transferred to the USA and stored there. The level of data protection in the USA is judged to be inadequate by the European Commission. The data transfer to the USA therefore takes place on the basis of the standard contractual clauses pursuant to 46 para. 2 lit. c GDPR. The standard contractual clauses are available at https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32010D008.... Alternatively, you can also request these documents from us using the contact details provided in section 2.

5.3. Use of Google Ads Remarketing

In rare cases, we use the remarketing function within the Google Ads service. The remarketing function allows us to present users of our websites with advertisements based on their interests on other websites within the Google advertising network (in Google Search or on YouTube, so-called "Google Ads" or on other websites). You may consent to the use of Google Ads Remarketing when you access the websites. You can revoke your consent to the use of Google Ads Remarketing at any time. If you give us your consent, we evaluate the use of the websites in order to play you interest-based advertising on other websites. However, we do not make an allocation at the individual level. For this purpose, we process the following personal data from you

  • IP address
  • Date and time of the request
  • Time zone difference from Greenwich Mean Time (GMT)
  • Content of the request (concrete terms)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • website, from which the request comes
  • browser
  • Information about your terminal device
  • Operating system and its interface
  • Language and version of the browser software
  • screen and window resolution
  • Your approximate location
  • Information about the time you spend on the site
  • Information about actions you perform on the websites

As already mentioned, we process this data exclusively with your consent. The legal basis for this is Art. 6 para. 1 p. 1 lit. a GDPR.

In the context of the use of the Google Ads Remarketing services, there are also data transfers from Google to affiliated companies and/or subcontracted processors. In this context, the above-mentioned data may be transferred to the USA and stored there. The level of data protection in the USA is judged to be inadequate by the European Commission. The data transfer to the USA therefore takes place on the basis of the standard contractual clauses pursuant to 46 para. 2 lit. c GDPR. The standard contractual clauses are available at https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32010D0087&from=DE. Alternatively, you can also request these documents from us using the contact details provided in section 2.

In addition to the possibility of revoking consent to this data processing, you can additionally prevent participation in this tracking procedure in various ways:

  • by adjusting your browser software settings accordingly; in particular, suppressing third-party cookies will prevent you from receiving third-party ads;
  • by installing the plug-in provided by Google at the following link: https://www.google.com/settings/ads/plugin;
  • by disabling the interest-based ads of the providers that are part of the "About Ads" self-regulatory campaign at the link http://www.aboutads.info/choices, with this setting being deleted when you delete your cookies;
  • by permanent deactivation in your browsers Firefox, Internet Explorer or Google Chrome at the link http://www.google.com/settings/ads/plugin,
  • by means of the corresponding cookie setting. We would like to point out that in this case you may not be able to use all functions of this offer to their full extent.

5.4. Use of the Google Tag Managers

We use the Google Tag Manager on our websites. The Google Tag Manager is a service of Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Through Google Tag Manager, we can include various codes and services on our websites in an orderly and simplified manner. This allows us to manage website tags via one interface. When a tag is triggered, Google may process information (including personal data) and process it. In particular, the following personal data is processed by Google Tag Manager:

  • Online identifiers (including cookie identifiers)
  • IP adress

We use the Google Tag Manager in our interest to be able to make a simplified and clear integration of various services. In addition, the integration of the Google Tag Manager optimizes the loading times of the various services. The legal basis for this is Art. 6 para. 1 p. 1 lit. f GDPR.

Google processes the data on our behalf as a so-called Processor pursuant to Art. 28 GDPR. In the context of using the services of the Google Tag Manager, there are also data transfers from Google to affiliated companies and/or subcontractors. In this context, the above-mentioned data may be transferred to the USA and stored there. The level of data protection in the USA is judged to be inadequate by the European Commission. The data transfer to the USA therefore takes place on the basis of the standard contractual clauses pursuant to 46 para. 2 lit. c GDPR. The standard contractual clauses are available at https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32010D0087&from=DE. Alternatively, you can also request these documents from us using the contact details provided in section 2.

5.5. Analytics through LinkedIn Insight Tags

Our websites optionally use the LinkedIn Insight Tag, a service of LinkedIn Ireland Ltd, Wilton Plaza, Wilton Place, Dublin 2, Ireland. The LinkedIn Insight Tag stores and processes information about your user behavior on our websites. For this purpose, the LinkedIn Insight Tag uses, among other things, pixel, i.e. small image files that are stored locally in the cache of your web browser on your end device and that enable an analysis of your use of our websites. We process your data to evaluate campaigns and collect information about websites visitors who may have reached us through our campaigns on LinkedIn. You can consent to the use of the LinkedIn Insight Tag when accessing the websites. You can revoke your consent to the use of the LinkedIn Insight Tag at any time. If you give us your consent, we evaluate the use of the websites. For this purpose, we process the following personal data from you:

  • IP address
  • Date and time of the request
  • Time zone difference from Greenwich Mean Time (GMT)
  • Content of the request (concrete terms)
  • Access status/HTTP status code
  • Amount of data transferred in each case
  • website from which the request comes
  • browser
  • Information about your terminal device
  • Operating system and its interface
  • Language and version of the browser software
  • screen and window resolution
  • Your approximate location
  • Information about the time you spend on the site
  • Information about actions you perform on the websites
  • demographic information if you are an active LinkedIn member.

As already mentioned, we process this data exclusively with your consent. The legal basis for this is Art. 6 para. 1 p. 1 lit. a GDPR.

In the context of the use of LinkedIn Analytics services, there are also data transfers from the LinkedIn Insight Tag to affiliated companies and/or subcontracted processors. In this context, the above-mentioned data may be transferred to the USA and stored there. The level of data protection in the USA is assessed by the European Commission as not adequate. The data transfer to the USA therefore takes place on the basis of the standard contractual clauses pursuant to 46 para. 2 lit. c GDPR. The standard contractual clauses are available at https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32010D0087&from=DE. Alternatively, you can also request these documents from us using the contact details provided in section 2.

5.6. Handling Support Request using Zendesk

We use Zendesk to handle incoming support requests. Zendesk is a service provided by Zendesk Inc, 989 Market Street #300, San Francisco, CA 94102, USA. Zendesk is used to integrate contact forms and forward your requests to us. In particular, the following personal data is processed by Zendesk when you submit a support request to us:

  • E-mail adress
  • Name
  • Your adress
  • Informationen about your request

We use Zendesk in our interest to integrate a convenient and simple solution for handling support requests and to be able to guarantee you fast and uncomplicated processing of your requests in this way. The legal basis for this is Art. 6 para. 1 p. 1 lit. f GDPR. The use of Zendesk is optional. If you do not agree to us processing your data using Zendesk, we offer you alternative contact options for submitting support requests by phone or mail.

Zendesk processes the data on our behalf as a so-called Processor pursuant to Art. 28 GDPR. In the course of using Zendesk's services, data is also transferred by Zendesk to affiliated companies and/or sub-processors. In this context, the above-mentioned data may be transferred to the USA and stored there. The level of data protection in the USA is assessed by the European Commission as not adequate. The data transfer to the USA therefore takes place on the basis of the standard contractual clauses pursuant to 46 para. 2 lit. c GDPR. The standard contractual clauses are available at https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32010D008.... Alternatively, you can also request these documents from us using the contact details provided in section 2.

5.7. In the context of contacting us by e-mail

We process e-mails that you transfer to us and we transfer to you using the services of our e-mail provider. In the context of e-mail communication, our e-mail provider processes your personal data (i.e. your e-mail address and the information you provide in the e-mail) on our assignment to enable us to communicate with you by e-mail or, if you are our customer, to process the contract. The processing of your personal data occurs on the basis of Art. 6 para. 1 p.1 lit. f or Art. 6 para. 1 p. 1 lit. b GDPR. We delete the data if it is no longer necessary and there are no legal obligations to the contrary. We review the necessity every six months.

5.8. Within the framework of the subscription to our newsletter

With your consent, you can subscribe to our newsletter, with which we inform you about our current interesting offers. In addition, our newsletters contain information about our products, promotions and our company.

For the registration to our newsletter we use the so-called double opt-in procedure. This means that after your registration, we will send you an e-mail to the e-mail address you provided, in which we ask you to confirm that you wish to receive the newsletter shipping. In addition, we store your IP addresses and the times of registration and confirmation. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.

Mandatory information for sending the newsletter are your e-mail address and name. After your confirmation, we store your e-mail address for the purpose of sending the newsletter and your name for the purpose of personal address in the mailings. The legal basis is Art. 6 para. 1 p. 1 lit. a GDPR. We store your e-mail address for this purpose until you revoke your consent.

For mailing our newsletter, we use the services of service providers who act on our behalf and within the scope of our instructions as so-called Processors in accordance with Art. 28 GDPR personal data. This also includes service providers based in the USA. The level of data protection in the USA has been assessed as inadequate by the European Commission. The data transfer to the USA therefore takes place on the basis of the standard contractual clauses pursuant to 46 para. 2c GDPR. The standard contractual clauses are available at https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32010D0087&from=DE. Alternatively, you can request these documents from us using the contact details provided in section 2.

5.9. In the context of contact by telephone

If you contact us by phone, we need your personal data (e.g. name, contact details, etc.) to process your inquiry or request. This data processing is necessary to enable us to communicate with you or, if you are our customer, to process the contract. The processing of your personal data is based on Art. 6 para. 1 p.1 lit. f or Art. 6 para. 1 p. 1 lit. b GDPR. We delete the data if it is no longer necessary and there are no legal obligations to the contrary. We review the necessity every six months.

5.10. Within the scope of contacting us via contact form

If you contact us via contact form, we need your personal data (e.g. name, contact details, etc.) to process your inquiry or request. This data processing is necessary to enable us to communicate with you or, if you are our customer, to process the contract. The processing of your personal data is based on Art. 6 para. 1 p.1 lit. f or Art. 6 para. 1 p. 1 lit. b GDPR. We delete the data if it is no longer necessary and there are no legal obligations to the contrary. We review the necessity every six months.

6. Deletion of Data

The data processed by us will be deleted in accordance with Art. 17 GDPR or its processing will be restricted in accordance with Art. 18 GDPR.

Unless otherwise regulated in this Privacy Policy, the data processed by us will be deleted as soon as it is no longer necessary for its intended purpose and the deletion does not conflict with any statutory retention obligations. We review the necessity every six months.

In accordance with legal requirements in Germany, the retention or storage of, in particular, books, records, inventories, annual financial statements, management reports, the opening balance sheet as well as the work instructions and other organizational documents required for their comprehension, the received and sent commercial or business letters, the accounting vouchers as well as other documents, insofar as they are of significance for taxation, is carried out for ten years in accordance with Section 147 (1) of the German Fiscal Code (Abgabenordnung – AO). This also applies to any personal data of data subjects contained in the aforementioned documents.

7. Rights of Data Subjects

You have the right:

  • request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information about its details;
  • in accordance with Art. 16 GDPR, to immediately request the correction of incorrect or completion of your personal data stored by us;
  • in accordance with Art. 17 GDPR, to request the erasure of your personal data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise or defense of legal claims;
  • in accordance with Art. 18 GDPR, to request the restriction of the processing of your personal data, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you object to its erasure and we no longer require the data, but you need it for the assertion, exercise or defense of legal claims or you have objected to the processing in accordance with Art. 21 GDPR;
  • in accordance with Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another Controller;
  • complain to a supervisory authority in accordance with Art. 77 GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters for this purpose.

 

8. Revocation of given consents

If we process your personal data on the basis of your consent pursuant to Art. 6 para 1 lit. a GDPR, you have the right to revoke any consent granted to us pursuant to Art. 7 (3) GDPR with effect for the future.

If you wish to exercise your right of withdrawal, you can do so by sending an e-mail to privacy@collaboration-factory.de. Alternatively, you can also use the contact details mentioned above under point 2.

9. Objection in case of processing based on legitimate interest

If we process your personal data on the basis of our legitimate interests pursuant to Art. 6 para 1 p. 1 lit. f GDPR, you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR, provided that there are grounds for doing so that arise from your particular situation or the objection is directed against direct marketing. In the latter case, you have a general right to object, which is implemented by us without specifying a particular situation.

If you would like to exercise your right to object, you can notify us by e-mail at privacy@collaboration-factory.de. Alternatively, you can also use the contact details mentioned above under point 2.

10. Security measures

We take organizational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of data protection laws are complied with and thus to protect the data processed by us against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons. The security measures include in particular the encrypted transmission of data between your browser and our server.

11. Changes to this Privacy Policy

We reserve the right to change our Privacy Policy if this should be necessary due to new technologies or changes in our data processing procedures or in order to adapt it to changes in the legal situation applicable to us. However, this only applies to this Privacy Policy. If we process your personal data on the basis of your consent or if parts of the Privacy Policy contain provisions of the contractual relationship with you, any changes will only be made with your consent.

The current version of our Privacy Policy can be found at www.collaboration-factory.de/en/privacy .

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