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Privacy Policy for our Website

The purpose of this privacy policy is to inform you as website user about the collection of personal data on this website. We attach great importance to a transparent presentation of all essential information regarding the protection of your data. However, should there be any ambiguities, questions and thus a need for clarification, please do not hesitate to contact us. 

A.     RESPONSIBLE BODY (controller)

The responsible body (controller) in the sense of the General Data Protection Regulation (Art. 4 (7) GDPR) and other national data protection laws and data protection regulations is:

ConPolicy GmbH
Crellestr. 37
10827 Berlin
Germany
info[at]conpolicy.de
Complete provider identification within Germany: www.conpolicy.de/impressum/

These contact details are therefore relevant for all questions regarding data protection matters of this website as well as for all data protection claims on your part. 

B.     COLLECTION AND STORAGE OF PERSONAL DATA WHEN VISITING OUR WEBSITE

In the following, we inform you about the processes relevant to data protection law that take place when you visit our website.

1. Log files

Each time you visit our website, we automatically collect data and information from the computer system you use to access the website.

The following data is collected:
(1) Information about your browser type and the version used
(2) Information about your operating system
(3) Information about your internet service provider
(4) Date and time of your access
(5) Websites from which your system accesses our website 
(6) Web pages that are accessed by your system via our website
(7) Your IP address

We do not store this data together with other personal data about you. This data is deleted after seven days. The legal basis for the temporary storage of this data is Art. 6 para. 1 lit. f GDPR. The collection of the data as well as the storage of the data in log files are absolutely necessary for the provision and operation of our website. 
 

2. Website analysis

On this website we use the service "Matomo". This is a web analysis service that is used on the servers operated by us.

Matomo enables us to create pseudonymised user profiles and to use cookies. Cookies are small files that are automatically created by your browser and stored on your computer system when you visit our website. Cookies do not cause any damage to your computer system and do not contain viruses, Trojans or other malware. Actions such as entry and exit pages, device types, operating system versions, browsers, etc. are collected pseudonymously.

The following data is stored and transmitted in the cookies:
(1) Browser type/version and operating system used
(2) Date and time of server request
(3) Web page requests (title, URL) and previous web pages (referrer URL)
4) Number of visits to our website 
(5) Region in which you have accessed the Internet
(6) Web pages that are called up from your system via our web page

This does not include your IP address or any other data that would allow us to associate the data with you. Your IP address is pseudonymised immediately after processing and before it is stored. This data is not stored together with other personal data of yours. Raw data being older than 90 days will be deleted automatically.

You can prevent the installation of cookies by setting your browser software accordingly. However, we would like to point out that in this case not all functions of this website can be used to their full extent.

The use of Matomo is necessary for the aforementioned purposes to protect our legitimate interests as well as those of third parties in accordance with Art. 6 (1) p. 1 lit. f GDPR. We use cookies to improve our website, for example, to make it more user-friendly and to adapt it to user interest.

We also offer you the option of a complete opt-out (refusal) from the analysis process on our website. In this case, your page visits are not recorded, but a cookie is set on your system which signals to our system not to save your data. If you delete this opt-out cookie, you will have to set it again the next time you visit our website.

If you wish to opt-out completely, please remove the blue tick in the next section. In this way, your visit to the website will no longer be recorded.

C. APPLICATIONS

If you apply for a job at our company by post or electronically, the following personal data will be stored:

(1) contact details
(2) Your application documents by data transmission or post
(3) Date of birth
(4) Profession/field of study
(5) Work experience
(6) Qualifications/experiences and languages

The application data is collected, sent to our HR department by e-mail and stored on our server. The data is processed exclusively for the purpose of processing the application. The retention period for application documents is approx. 6 months, by then we delete this data.

D. CONTACT

You can contact us electronically by e-mail or via a form on the website. In this case, the data you send to us will be stored by us. 

This concerns:
(1) Your name
(2) The date you contacted us
(3) Your e-mail address
(4) The content of your enquiry
(5) If applicable, further data, if you provide it

If you write us an email or use the form and are interested in our content, the legal basis for data processing is Art. 6 (1) lit. b GDPR. 

This data transmitted to us will only be used to carry out the conversation and will not be passed on to third parties.

We will delete this data when it is no longer needed for the respective purpose. I.e. when the email exchange with you has ended and we have fully processed your request.

You have the option to revoke your consent to the processing of your data at any time. To do so, please use the contact options above. In the event of a revocation, all your personal data stored for the purpose of contacting you will be deleted.

E.    NEWSLETTER

We offer a newsletter service in which we inform recipients about our services and things worth reading in the field of consumer policy (newsletter subscription). To receive this newsletter, you must register for it on our website. The data you enter as part of the registration will be transmitted to us and only used to send the newsletter.

This involves:
(1) The e-mail address you provide
(2) The IP address of the computer system you are using
(3) The date and time of registration

We need your e-mail address in order to send you the newsletter. The other information is required to prevent misuse of our e-mail address and also of the e-mail address you have provided.

Before sending the registration to receive our newsletter, your consent will be obtained and your attention will be drawn this data protection declaration (Art. 6 para. 1 lit. a GDPR).

A termination of the subscription and thus an objection and removal option of the data processing is possible at any time. For this purpose, there is a corresponding unsubscribe link in every e-mail of our newsletter.

In addition, you have the option of unsubscribing via this link or informing us of your wish via the contact options. You will find the contact options at the beginning of this data protection declaration.

F. PROCESSING IN THIRD COUNTRIES IN GENERAL

Unless otherwise stated above, the processing of your personal data in countries outside the European Union (EU) or the European Economic Area (EEA) is carried out exclusively on the basis of the legal requirements pursuant to Article 44 of the GDPR. In the present case, this is exclusively the case either on the basis of an adequacy decision of the European Commission (Art. 45 GDPR) and/or on the basis of appropriate guarantees (Art. 46 GDPR).

G. GENERAL STORAGE PERIOD

In general, personal data are stored exclusively for as long as is necessary to fulfil the purpose of the data collection or to comply with the respective legal retention period. After the purpose has ceased to exist or the period has expired, the data is deleted.

H. DATA SUBJECT RIGHTS

Insofar as we have processed personal data from you, you are a data subject in the sense of the GDPR and you are entitled to the following rights vis-à-vis us:
(1)    Art. 15 GDPR - You may request information about your personal data processed by us. 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.
(2)    Art. 16 GDPR - You can immediately request the correction of incorrect or completion of your personal data stored by us.
(3)    Art. 17 GDPR - You may 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.
(4)    Art. 18 GDPR - You may request the restriction of the processing of your personal data, 
•    insofar as the accuracy of the data is disputed by you,
•    insofar as the processing is unlawful, but you object to its erasure and we no longer need the data, but you require it for the assertion, exercise or defense of legal claims
•    or insofar as you have objected to the processing pursuant to Art. 21 GDPR.
(5) Art. 20 GDPR - You may receive your personal data that you have provided to us in a structured, common and machine-readable format or request that it be transferred to another responsible party.
(6) Art. 7 (3) GDPR - You can revoke your consent once given to us at any time. This has the consequence that we may no longer continue data processing based on this consent in the future.
(7) Art. 77 GDPR - You can complain to a supervisory authority. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our registered office for this purpose.

I. RIGHT OF OBJECTION

Insofar as your personal data are processed on the basis of legitimate interests pursuant to Article 6 (1) sentence 1 lit. f GDPR, you have the right to object to the processing of your personal data pursuant to Article 21 GDPR, insofar as there are grounds for doing so that arise from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right of objection, which is implemented by us without specifying a particular situation.

If you would like to make use of your right of revocation or objection, it is sufficient to send an e-mail to the above-mentioned e-mail address.

Version: June 21, 2022